ML19347C674
| ML19347C674 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/02/1981 |
| From: | Paton W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8101050073 | |
| Download: ML19347C674 (12) | |
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l UNITED STATES OF R4 ERICA MM
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NUCLEAR REGULATORY COMMISSION 3
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD j
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CONSUMERS POWER COMPANY
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Docket Nos. 50-329-0M & OL j
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50-330-0M & OL
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(Midland Plant, Units 1 and 2)
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I, NRC STAFF INTERR0GATORIES TO CONSUMERS POWER COMPANY ii Pursuant to 10 C.F.R. 5 2.740(b), the NRC Staff serves the following interrogatories on Consumers Power Company.
In several interrogatories we have included requests for documents. The requests are made in the event you will respond absent a formal Motion to Produce these Documents.
INSTRUCTIONS AND DEFINITIONS 1.
Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Consumers Power Company.
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As used herein, " documents" includes, but is not li nited' to, subsurface i
investigation and foundation reports, geotechnical engineering calcula-tions, geotechnical evaluations and special study reports, construction plans and specifications, papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of e
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e conversations or of phone calls, interoffice, intra-agency or interagency memoranda or writter, concunications of any nature, recordings of i
conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchca.ds and computer printout sheets, computer
- data, telecopier transmissions, directives, proposals,. and all drafts, revisions, and differing versions (whether formal or informal) of any.
of the foregoing, and also all copies of any of the foregoing which differ in any way (including handwritten notations or other written or 1
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printed matter of any nature) from the original.
j Interrogatory 1 Your response to Question 17 in " Responses to !<RC Requests Regarding Plant Fill" regarding piping founded in the plant area fill, states:
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"When two pipelines were parallel and in the same proximity, only one.
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was profiled."
(a) Define "same proximity" as used in the above quotation.
(b)
In view of the random nature and varying properties of_ the fill, what assurance exists that the settlement of the profiled pipelines-is similar to pipelines not orofiled?
(c) What assurance exists that future settlement of the profiled pipelines will be similar to pipelines not profiled?
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Interrogatory 2 Your response to Question 17 in " Responses to NRC Requests Regarding Plant Fill" includes a Figure 17-1 showing the locations of some, but not all, of the piping listed in Table 17-1 of that response.
Do you have sketches like that of Figure 17-1 identifying the location of the remaining piping f
listed in Table 17-l? If yes, please provide copies.
Interrogatory 3 The legend for Figure 17-1 of your response to Question 17 in '" Response to NRC Requests Regarding Plant Fill" makes reference to a Note #1 and a Note #2. Neither note is shown. State the contents of these two notes, if they exist.
Interrogatory 4 1
j Figure 17-2 of your response to Question 17 in " Responses to NRC Requests Regarding Plant Fill" regarding piping founded in the plant area fill shows l
some differences between profiles of a given pipe taken on different dates.
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Specifically, the profiles for pipeline 20" - lHCD-169 between stations 3+00 and 4+30 show a decrease in slope changes (i.e., a smoothing out) and relocation of certain peaks when the March / April 1979 profile is compared to the July 1979 profile. How do you explain the difference of these two profiles?
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Interrogatory 5 Figure 19-1 of your response to Question 19 in " Responses to NRC Requests Regarding Plant Fill" regarding piping founded in the plant area fill shows some differences between profiles of a given pipe taken on different dates.
1 Specifically, the profile for pipeline 10" - 0HBC-27 taken September 1979 1
is at a higher elevation than the profile of that same line taken in January 1979.
How do you reconcile these differences?
Interrogatory 6 Figure 19-1 of your response to Question 19 in " Responses to NRC Rer.dests Regarding Plant Fill" regarding piping founded in the plant area fill shows i
some differences between profiles of a given pipe as taken on different i
dates. Specifically, the profile for pipeline 8" - lHBC-81 measured in September 1979 is at a deeper elevation than the profile of this pipeline taken in January 1979 and the change in slope for.the September 1979 profile is not as great as for the January 1979 profile. How do you reconcile i
this bahavior?
Interrogatory 7 i
Have any underground pipelines other than those for which the profiled results are reported in your-responses to Questions 17 and 19 of " Responses a
to NRC Requests Regarding Plant Fill", and which are not provided in response to Interrogatory 2 herein, been measured for profile? As to any affirmative
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reply, please describe the results and any sketches of profile results.
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j Interrogatory 8 State the principal architectural and engineering criteria provided pursuant to 10 C.F.R. s 50.35 to which each of the following structures I
and components were designed (or were to have been designed) with respect i
to soil properties, foundation support and performance during severe natural
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(1) Diesel Generator Buildinc (2) Auxiliary Building (3) Service Water Intake Structure and integral retaining walls (4) Feedwater Isolation Valve Pits (5) Underground seismic Category I piping and conducts i
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(6) Undergound piping other than seismic Category I piping, located j
beneath or near seismic Category I structures and components (7) Borated water storage tanks and ring support (8) Underground diesel fuel oil storage tanks and fuel oil lines (9) Cooling pond dikes Interrogatory 9 Identify all principal archithctural and engineering criteria identified in your answer to Interrogatory 8 which will-not be met unless the remedial actions proposed or completed for the soils placed and compacted at the Midland site'are implemented.
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Interrogatory 10 i
flidland PSAP, Section 2.8.4.1, as last amended on May 28, 1969, states the following design criterion for fill and backfill:
"All fill and backfill materials are adequately compacted to insure stability of the fill and to provide adequate support for structures founded on this fill without excessive settlements."
(a) With respect to this criterion, define " excessive settlements".
(b) With respect to this criterion, define " adequately compacted".
(c) Was this design criterion met for the fills and backfills as originally placed and compacted (i.e., prior to the surcharge program) beneath or adjacent to the Diesel Generator Building?
(d) Has this design criterion been met for the fills and backfills which were subjected to the Diesel Generator Building surcharge program?
(e) Was this design criterion met for the fills and backfills as originally placed and compacted beneath or adjacent to the Auxiliary Building?
(f) Will this design criterion be met once the proposed remedial action for the Auxiliary Building has been completed?
(g) If the answer to Interrogatory.10(f) is no, what design criterion will be met?
(h) Was the design criterion quoted above met for the fills and backfills
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as originally placed and compacted beneath or adjacent to the Service Water Intake Structures?
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'(i) Will the design criterion quoted above be met once the proposed remedial action for the Service Water Intake Structure has been completed?
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If the answer to Interrogatory 10(i) is no, what design criterion will be met?
(k) Did the original fill and backfills placed inside and beneath the ring supports of the Borated Water Storage Tanks meet the qucted design criterion?
(1) Do the existing fills and backfil'Is-placed inside and beneath the ring supports of the Borated Water Storage Tanks meet the quoted design criterion?
(rt) If the answer to Interrogatory 10(1) is no, what. design criterion -
is' met?.
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i (n) Was the quoted design criterion met for the fills and backfills placed and compacted in the vicinity of the Diesel Fuel Oil Storage Tanks?
I (o) Was all of the fill for the Diesel Fuel Oil Storage Tanks placed origini311y to the requirements of Zone 2 materials?
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If the answer to 10(o) is no, what arers were not placed to Zone 2 requirements; on what basis was this material accepted?
(q) Was the design criterion quoted above met for the fills and backfills as originally placed and compacted beneath and adjacent f
to the Feedwater Isolation Valve Pits?
I (r) Will the design criterion quoted above be met once the proposed r
remedial action for the Feedwater Isolation Valve Pits has been completed?
(s)
If the answer to Interrogatory 10(r) is no, what design criterion will be met?
(t) Has the design criterion quoted above been met for the cooling pond dikes? If yes, state how this was determined.
If no, what design criterion was met?
Interrogatory 11 For all structures and components listed in Interrogatory 8, list all design bases (as design basis is defined in 10 C.F.R. 6 50.2(u)) of significance to safety which depend upon adequate foundation support or 5
soil related properties and which would not be met unless remedial actions are implemented.
r Interrogatory 12 When, if ever, was your intent to include lean concrete as a Zone 2:
material first conveyed to the' NRC?. To whom and by what means of j
communication was this intent conveyed to NRC?
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- i Interrogatory 13 Have you performed, or do you know of the existence of, any studies
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of the consequences of failure of the Midland cooling pond dike? If yes, provide copies of or a reference to these studies.
If no, what is the justification for not performing such studies?
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- I Interrogatory 14 j;
Have you performed, or do you know of the existence of, any studies of the probability of failure of the Midland cooling pond dike? If yes, provide copies of or references to these studies.
If no, what is the justification for not performing such studies?
Interrogatory 15 In your responses to NRC requests 24b and 51 concerning permanent dewatering, you used a specific yield coefficient of 14 percent for determining the volume of ground water to be removed from storage within the plant dikes.
In determining average permeability, you used a value of 30 percent for h
effective porosity. Under water table conditions such as exist at Midland, " specific yield" means the same as " effective porosity". Provide justification for using two different percentages.
I Interrogatory 16 In your response to request 24 concerning permanent dewatering, you used an error function equation to define water level rise. This equation is as follows:
h=H 1 - erf 4Kht "e
b p.
I In applying this equation you used 0.1 foot for h,1.6 feet for H and 3
3 20 feet for 5.
In request 49, we asked for additional information on why 20 feet had been used for 5 when h is defined as the average depth of water. Your response to request 49 was that the values of h and H are much smaller because they_
represent the changes in head above the original potentiometric surface i(
while the value of n is the thickness of natural sands through which the e
seepage from the cooling pond is assumed to flow.
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The equation that you used to model groundwater flow, from Bear 1972, assumes a horizontal impervious bottom as a datum from which the terms h, H and h are measured.
It is not clear why you are using one datum, i.e., the original potentiometric surface (approximately 622 feet) to 4
measure h and H and another lower datum (approximately elevation 607) to riieasure Ii.
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studies done using a single datum from which to measure h, H and 5? If k
- yes, (a) identify these studies, (b) do these studies justify your use of two different datums, and (c) if the answer to (b) is affirmative, please state the justification li provided in these studies.
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f Provide your justification for using two different datums and show that
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your resultant groundwater rebound time is at least as conservative as j
the rebound time would be if computed using a single datum as in Bear,1972.
Respectfully submitted, i
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William D. Paton Counsel for NRC Staff l
Dated at Bethesda, Maryland j
this 2nd day of January,1981 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE AT0"IC SAFETY A'j3 LICENSIN3 BOAC3 In the Matter of
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E CONSUMERS POWER COMPANY
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Docket Nos. 50-329-0M & OL i
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50-330-0*< & OL (Midland Pla.t, Units 1 ar.d 2)
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CERTIFICATE OF SERV!CE i
i I hereby certify that copies of "NRC STAFF INTERR05; TORIES TO CONSU".ERS
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POWER COMPANY" in the above-captioned proceeding have been:. served on the following by deposit in the United States mail, first class, or as indicated by an asterisk, throuch deposit in the Nuclear Reculatory Comission's internal mail system, this 2nd day of January,1981:
- Charles Bechhoefer, Esq.
Ms. Mary Sinclair Atomic Safety and Licensing Board 5711 Sumerset Street a
U. S. Nuclear Regulatory Comission Midland, Michigan 48640 Washington, D.C.
20555
- Mr. Gustave A. Linenberger Michael I. Miller, Esq.
i Atomic Safety and Licensing Board Ronald G. Zamarin, Esq.
V. S. Nuclear Regulatory Comission Alan S. Farnell, Esc.
Washington, D.C.
20555 Isham, Lincoln & Beale
.t One First National Plaza A
Dr. Frederick P. Cowan 42nd Floor l l 6152 N. Verde Trail Chicago, Illinois 60603 Apt. B-125 Fl l
Boca Raton, Florida 33433
- Atomic Safety and Licensing 4
Board Panel I
Frank J. Kelley U. S. Nuclear Regulatory Comission Attorney General of the State Washington, D.C.
20555
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of Michigan j
Steward H. Freeman
- Atomic Safety and Licensing 4
Assistant Attorney General Appeal Board Panel D
Grecory T. Taylor U. S. Nuclear Regulatory Comission Assistant Attorney General Washington, D.C.
20555 Environmental Protection Division 720 Law Building
- Docketing and Service Section Lansing, Michigan 48913 Office of the Secretary U. S. Nuclear Regulatory Comission Myron M. Cherry, Esq.
Washington, D.C.
20555 1 IBM Plaza E
Chicago, Illinois 60611 l
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James E. Brunner, Esq.
Consumers Power Co pany 212 West Michigan Avenue Jackson, Michigan 49201 Ms. Barbara Stamiris j
5795 N. River Freeland, Michigan 48623 Mr. Steve Gadler i
2120 Carter Avenue p
St. Paul, Minnesota 5510S 8
Wendell H. Marshall, Vice President Mid est Environ ental Protection Associates RFD 10 Midland, Michigan 48640 o*
Ms. Sharon K. Warren h
635 Hillcrest I
Midland, Michigan 4S640 h
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Killiam D. Paton
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Counsel for NRC Staff e
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