ML19347D885

Response to Intervenor B Stamiris 810114 Interrogatories. Provides Info Re IE Insp Repts 50-329/78-12 & 50-330/78-12, Audits Re Soil Settlement & Administration Bldg.A Boos & N Swanberg Affidavits Encl.Related Correspondence

ML19347D885
Person / Time
Site:	Midland
Issue date:	03/30/1981
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Stamiris B AFFILIATION NOT ASSIGNED
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8104140392
Download: ML19347D885 (8)

Text

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\, f ,% / EFORE THE ATOMIC SAFETY AND LICENSING BOARD 6;c " g

.vl l N O CC In the Matter of Docket Nos. 50-329-0M CONSUMERS POWER COMPANY 0]32-0

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(Midland Plant, Units 1 and 2

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'JA ') A/ &o CONSUMERS POWER COMPANYS' RESPONSE TO INTERVENOR REQUESTS 1/14/81 Discovery Request 1 NRC Inspection Report 50-329/330 78-12 notes "Other Activities to be Planned (1) Possible core borings in cooling pond dike area to verify integrity of

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dikes." Provide documents as a basis for this statement and relating to the decision on this matter as it was first considered.

Response

Since this statement was made by the NRC in an inspection report, it is impossible for Applicant to determine which, if any, documents were relied upon in =aking it.

However, with respect to the cooling pond dike, some consideration was given to borings in early meetings (See Tab 12, Volu=e 4, 50.54f Responses), during ,

which it was decided that the dikes would not present a problem and that borings need not be taken. Since that time, the NRC Staff has submitted a request that borings be taken in the dike, which Applicant has acceded to.

Applicant is now in the process of taking borings in the dike.

Discovery Request 2 Were any audits conducted covering soil settlement matters (including QA QC aspects) l which have not been presented to the NRC? If so, provide these findings.

Response

The documents requested are produced at the Midland Service Center.

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Discovery Request 3 How much time is allotted in the most recent completion schedule for remediation of soil settlement matters and for responses to NRC testing and boring requests?

Response

The time allotted for the various soil settlement remedial. measures is shown on the document "SOU.S SETTLEMENT - STUDY" provided as an attachment to these responses. That document includes a study of the schedule pertaining to the response to the NRC's botIng request. It should be noted that the provided schedule is preliminary in nature and is subject to change or revision at any time.

Discovery Request 4 When was the Administration Building begun? What was the means of recording

, settlement for the Administration Building and when was that means established?

Response

The civil and structural construction of admiaistration building was started during June 1977.

• The means of recording settlement is and was to periodically survey the settle-ment markers that are installed on the building from a known benchmark. The survey data thus obtained is transcribed onto a drawing. The settlement, if any, of each marker, is then deduced from the survey data for each period and plotted on a time scale graph to observe its trend. Settlement monitoring for Adminis- -

tration Building began on September 16, 1978. (The grade beam failure was dis-covered prior to the settlement monitoring program.)

Discoverv Request 5 l l

Provide the Bechtel reports as to the cause of the Administration Building  !

settlement and whether it was an isolated problem, or any other reports recommending procedural changes stemming from this event.

Response .

! Produced at Midland Service Center.

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Discovery Request 6 Describe the Established Foundation Data Survey Program for the diesel generator building. When was it established, and by whom?

Response

The foundation data survey program was and is implemented by installing surveying markers on the walls, floors or pedestzi's, and by conducting periodic.

surveys using standard s"urveying techniques. These survey results are re-viewed, and the settlement for each marker is calculated for each surveying period. The settlement values thus obtained 'are tabulated on design drawings, which are issued periodically, and then reviewed by the design and the geotechnical engineering groups.

After review, the settlement of each marker is plotted on a time scale graph to observe its trend. Settlement values are then compared against predicted settlements. These settlement data are reported in the final safety analysis report or in updates of other licensing reports.

The first settlement reading from the program was taken during July of 1978, based on markers installed in May of,the same year. This monitoring program was established by Bechtel Associates Professional Corporation by means of issuing a specification and drawings during 1977.

Discoverv Recuest 7 Were any settlements noted formally er informally prior to July 1978 to the diesel generator building?

If so provide these observations.

Response

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No.

Discoverv Request 8 When was Dr. Peck or any other soil settlement consultant first told of the settlement of the Administration Building? Provide any documents recording dis-cussion of the Administration Building with soil settlement consultants.

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Response

Applicant objects to t)is question, on the ground that it is irrelevant and im-material. Subject to that objection, Applicant answers as follows:

Drs. Peck and Hendron were not directly involved with the Administration Building settlement matter. Dr. Hendron recalls that he was made aware of the previous problem with the Administration Building in one of the earliest meetings he attended regarding the diesel generator building matter. Upon inquiry, -

Dr. Peck did not recall having heard of the Administration. Building problem.

There are no documents recording the above discussions, to the best of Applicant's knowledge.

Discovery Request 9 l When was the NRC first informed of the settlement of the Administration Building?

Relate the circumstances of this initial disclosure.

Response

The NRC was first informed of the settlement.of the Administration Building during the site investigation by Mr. Gallagher, (Region III, I.E.) which took place October 24 - 27, 1978.

Discovery Request 10 Amendment 3 to the FSAR eliminated the original site dewatering plan. Provide documents relevant to this decision.

Response

Applicant objects to this request on the ground that it calls for information which is irrelevant to these proceedings.

Discovery Request 11 At the July 29, 1980 Caseload Forecast Panel Meeting in Midland, mention was made of C.P.Co. loans to Bechtei and other subcontractorsin the interest of staying on schedule. Describe the extent of these loans and the circumstances surround- '

ing them.

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Response

The only loans mentioned at the July 29, 1980 case load panel meeting concerned the loaning of Consumers engineering or technical personnel to Bechtel.

Discovery Request 12 Were there any established requirements regarding groundwater elevations and their effects on plant foundations and structures in 1978? If so, provide these documents.

Response

In 1978, the normal high water table was assumed to be at El. 627', and during the probable maximum flood the water surface elevation at the site, including the effect of wave runup, would be El. 635.5' . Plant foundations and structures have been

' designed for the effects of water at these elevations as discussed in the Midland FSAR section 3.8.6.

Discovery Request 13 h t work has been done since April 1980 on the diesel generator building and what percent complete is the building?

Response

Installation of mechanical and electrical equipment has been and is continuing as an ongoing activity. Since April, 1980 minor concrete placements such as curbs, equipment pads, and grade slabs have been completed. As of December 31, -

1980, the total facility was_74 percent complete, and the concrete work was 99 percent complete.

Discoverv Request 14 What procedure or system is followed to record or correct poor employee per-formance by Bechtel or C.P.Co? Have any employees with jobs relating to soil settlement matters been fired or received some type of warning related to job I

performance? If so provide these records. ,

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Response

Employees of both Bechtel and Consumerr are given periodic performance appraisals.

The answer to the question posed in the second sentence is "no". ,

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l Discovery Request 15 .

On page 26 of NRC Inspection Report 50-329/330 78-20, mention is made of the QC inspector who was primarily responsible for the plant fill work who is no longer employed by Bechtel. Provide the name of this individual, his position, and the date of his employment, and forwarding address.

Response

The name of the QC inspector referenced is Daryle Osborn. His position was Quality Control Engineer / Assistant Lead Civil Quality Control Engineer. He was employed at the site from September 6, 1975, through July 21, 1978. His last 6 known forwarding address is 13025 S.W. 107th Terrace, Miami, Florida, 33186.

Discoverv Request 16 Provide the names and addresses of any other QA or QC personnel with jobs re-lating to soil settlement from 1975-1980 who are no longer employed by Bechtel or C.P.Co.

Response

Applicant objects to this question on the grounds that it is irrelevant, in-material, and burdensome.

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l UNITED STATES OF AMERICA RELATED CO NUCLEAR REGULATORY COMMISSION .WENCE BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) DOCKET NOS. 50-329-0M CONSUMERS POWER COMPANY ) 50-330-0M

) 50-329-OL (Midland, Units 1 and 2) ) 50-329-OL

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County of Washtenaw) D

)ss d State of Michigan ) 000 A il2 6 1981 *

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ffR T5 g a d . 7=64 O t;;,;i.n.:, t Mme AFFIDAVIT OF ALAN BOOS Emd 6 a

! Alan Boos, being duly sworn, deposes and says that he is the e

Assistant Project Manager, Midland Project, Be,chtel Power Corporation; that he is primarily responsible for providing an answer to Barbara Stamiris' Interrogatory Nos. 7 and 14 to Consumers Power Company; and that to the best of his knowledge and belief the above information and the answer to

.the above interrogatory is true and correct.

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' Alan Boos ,

Subscribed and sworn to before me this do day of h 4 3981.

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Notary Public, Washtenaw County, Michigan MyCommissionExpires:[ b,/#fg T9[yNd7,~5cH Irr.1 C3.,7.IM .

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. l UNITED STATES OF AMERICA ED CO NUCLEAP. REGUTATORY COMMISSION B BEFORE THE ATOMIC ~ SAFETY AND LICENSING BOARD In the Matter of ) DOCKET NOS. 50-329-0M CONSUMERS POWER COMPANY ) 50-330-0M

) ,Q 50-329-OL (Midland, Units 1 and 2) ) 50-329-OL DOCFETED

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County of Washtenaw) APR 61981 *

)ss g ( ::: cf t : Ler.bry State of Michigan ) NO.x!. ; : S.vi:e Et e e a AFFIDAVIT OF NEAL SWANBERG Neal Swanberg, being duly sworn, deposes and says that he is the

Assistant Project Engineer, Midland Project, Bechtel Associates Professional Corporation; that he is primarily responsible'for providing an answer to -

Barbara Stamiris' Interrogatories 3, 4, 6, 8, 12, 13, and 15 to consumers Power Company; and that to the best of his knowledge and belief the above information and the answers to the above interrogatories are true and correct.

Neal Swanberg Subscribed and sworn to before me this SC day of >/'u s i 1981.

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4 1 d Aw Notary Public, Washtenaw County, Michigan My Commission Expires: NA h ,20/ef/A

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