ML19339D058

Interrogatories Re Quality of Fill Soil,Composition of Random Fill,Adequacy of Permanent Dewatering Procedures & Effect of Preloading Procedures on Diesel Generating Bldg Structure

ML19339D058
Person / Time
Site:	Midland
Issue date:	02/09/1981
From:	Farnell A CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:	Warren S AFFILIATION NOT ASSIGNED
Shared Package
ML19339D056	List: ML19339D055 ML19339D058 ML19339D062
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102170174
Download: ML19339D058 (6)

Text

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UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION -

Before the Atomic Safety and Licensing Board 4

)

In the Matter of ) Docket Nos. 50-329-OL

) 50-330-OL CONSUMERS POWER COMPANY ) 50-329-OM

) 50-330-OM (Midland Plant, Units 1 and 2) )

)

CONSUMERS POWER COMPANY'S INTERROGATORIES TO INTERVENOR SHARON K. WARREN Consumers Power Company hereby submits to inter-venor Sharon Warren the following interrogatories to be answered separately, under oath.

Interrogatoriec regarding Contention 1:

lA. Set forth with particularity the basis for your contention that "[t]he composition of the fill soil used to prepare the site of the Midland Plant - Units 1 and 2 is not of sufficient quality to assure that pre-loading techniques have permanently corrected soil settlement problems."

1B. Set forth with particularity the basis for your contention that "[t]he components of random fill can include loose rock, broken concrete, sand, silt, ashes, etc.

all of which cannot he compactqd tirough pre-loading procedures. "

8102170 [7Ji

.. . . Bl un 1 - ,

IC. Set forth with particular.ty each of the com-ponents of the random fill at the Midland site, i.e., does it include " loose rock, broken concrete, sand, silt, ashes, etc."

1D. For each of the components identified in your response to interrogatory Ic set forth with parti:ularity the basis for your assertion that it is a component of the random fill at the Midland site.

Interrogatories regarding Contention 2:

2A. Set forth with particularity the basis for your contention that "[b]ecause of the known seepage of water from the cooling pond into the fill soils in the power block area, permanent dewatering procedures being proposed by Consumers Power Company are inadequate."

2B. Set forth with particularity the basis for your contention that in the event of increased water seepage permanent dewatering procedures being proposed by Consumers Fower Company are inadequate.

2C. Set forth with particularity the basis for your contention that in the event of flooding permanent dewatering procedures being proposed by Consumers Power are inadequate.

2D. Set forth with particularity the basis for your contention that in the event of failure of pumping system dewatering-procedures being proposed by Consumers Power are inadequate.

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2E. Set forth with particularity the basis for your contention that in the event of power outages dewatering procedures being proposed by Consumers Power are inadequate.

2F. Set forth with particularity the basis for your contention that "[u]nder these conditions, Consumers cannot provide reasonable assurance that stated maximum levels can be maintained."

2G. Set forth with particularity the basis for your contention that "these highly permeable soils which underlie, in part, the diesel generator building and other 4

class I structures may be adversely affected by increased water levels producing liquefaction of these soils."

2H. Will the diesel generator building and other Class I structures "be adversely affected by increased water levels producing liquefaction of these soils." If the answer is yes, set forth with particularity the basis for that assertion and set forth with particularity which Class 4

I structures will be adversely affected and for each set forth with particularity in what way they will be affected.

i 2I. Set forth'with particularity the basis for j your contention that the borated water tanks will be affected by the scenario set forth in your contention 2B and set forth with particularity in what way they will be affected.

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i 1 h 2J. Set forth with particularity the basis for your contention that the diesel fuel oil tanks will be j affected by the scenario set forth in your Contention 2B and set forth with particularity in what way they will be affected.

i Interrogatories concerning Contention 3:

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3A. Set forth with particularity the basis for your contention that "[p] re-loading procedures undertaken by Consumers Power have induced stresses on the diesel generating (sic] building structure."

3B. Set forth with particularity the basis for your contention that "[p] re-loading procedures undertaken by

, Consumers Power...have reduced the ability of this structure to perform its essential functions under that stress."

3C. Set forth with particularity each of the

" essential functions" of the diesel generator building.

l 3D. Quantify with particularity the reduction in l ability of the diesel generator building to perform its essential functions.

I 3E. Set forth with particularity the basis for I

your contention that " remedial actions that have been taken have produced uneven settlement" and, quantify with particularity the uneven settlement produced by the remedial actions.

3F. Set forth with particularity the basis for

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your contention that remedial actions that have taken have caused inordinate stress on the diesel generator building and define " inordinate stress" regarding the diesel generator building and quantify with particularity the inordinate stress.

3G. Set forth with particularity the basis for your contention that remedial actions that have been taken have caused inordinate stress on the circulating water lines and define " inordinate stress" regarding the circulating water lines and quantify with particularity the inordinate stress.

3H. Set forth with particularity the basis for your contention that remedial actions that have been taken have caused inordinate stress on the fuel oil lines and define " inordinate stress" regarding the fuel oil lines and quantify with particularity the inordinate stress.

3I. Set forth with particularity the basis for your contention that remedial actions that have been taken have caused inordinate stress on electrical conduit. Set forth with particularity each electrical conduit so affected, define " inordinate stress" regarding electrical conduit and quantify the inordinate stress.

Background Interrogatories

1. Set forth your educational background, in-cluding:

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._ . .- .__ . _ . - . _ . __ _ _ = _ - . . - . . . _ - - - _ . _

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i

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i; l a. College attended

b. Degree granted

c. Courses taken in geotechnical science, structural engineering, mechanical engineering, electrical engineering, quality assurance, a

2. Set forth the approximate number of hours you 4

have spent working on the Midland Soils settlement issues.

3. Set forth with particularity each document,

{ pleading, deposition, book or other written material you have examined, either briefly or in detail, regarding the Midland soils settlement issues.

4. Set forth the date, persons involved in the ,

communication and the substance of each or oral or written i

communication (including any documents that you have either  !

sent or received) you have had with: (a) any employee of the Nuclear Regulatory Commission or any of its Consultants ,

regarding the Midland Soils settlement issues; and (b) any newspaper, magazine, radio station, television station or other media organization.

Sincerely, h.

Alan S. Farnell Attorney for Consumers Power Company ISIIAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 ,

(312) 558-7500 i

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