ML19352B285

Responds to 810519 Second Request for Production of Documents.Uncirculated Notes Will Not Be Produced Because Notes Are Not in NRC Possession

ML19352B285
Person / Time
Site:	Bailly
Issue date:	06/25/1981
From:	Hodgdon A NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Vollen R BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES
Shared Package
ML19352B286	List: ML19352B285 ML19352B287 ML19352B289
References
NUDOCS 8107010429
Download: ML19352B285 (2)

Text

[on m c g* 'c UNITED STATES i

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7 NUCLEAR REGULATORY COMMISSION pany;1 9

WASHINGTON, 0. C. 70555 g ;jj.

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t-June 25, 1981 s c>

g Robert J. Vollen, Esq.

M R G 1931% h c/o BPI meu..%,,,

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109 North Dearborn Street j

Chicago, Illinois 60602 g

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In the Matter of NORTHERN INDIANA PUBLIC SERVICE COMPANY (Bailly Generating Station, Nuclear-1)

Docket No. 50-367 (Construction Permit Extension)

Dear Mr. Vollen:

This is in response to your Second Request for production of documents of May 19, 1981, in which you ask Staff to produce for copying at your offices in Chicago on June 23, eleven categories of documents not available in the NRC's public document room pursuant to 10 C.F.R. 5 2.790.

I have identified a number of documents responding to your Second Request and a number of others which update Staff's response to your First Request and am enclosing copies of them. We are not producing uncirculated notes, because such notes are not in the Commission's possession.

The requests numbered 4 through 9 relate to Staff's responses to your First Set of Interrogatories. We will, of course, provide any documents relied on by Staff in responding to any of your Interrogatories that the Board directs us to answer at the time that we provide answers.

Sincerely, k.

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p..

Ann P. Hodgdon Counsel for NRC Staff

Enclosure:

As Stated cc w/ enclosure: William H. Eichhorn, Esq.

Secretary i

l cc w/o enclosure:

Herbert Grossean, Esq., Chairman Kathleen H. Shea, Esq.

Robert L. Holton Edward W. Osann, Jr., Esq.

i J. Venn Leeds Robert L. Graham, Esq.

George & Anna Grabowski Atomic Safety and Licensing Board John Van Vranken, Esq.

Atomic Safety and Licensing Appeal Board Clifford Mero 8107040t{$

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LIST OF DOCUMENTS 1.

Note from G. Lea", NRC to Lyman Heller, NRC, on Bailly 5/21/81 Pile Driving Monitor.

2.

Meeting Notice with attachments on Coordination of NRC 3/18/81 Staff licensing efforts on Bailly Nuclear Station, from G. Lear.

3.

Note from H. D. Lynch to Distribution List on Pile QA/QC 3/05/81 manual. Attached is a NIPSCO letter from E. M. Shore to H. Denton, NRC, indicating a revision of a pile placement procedures manual will be submitted prior to any installation.

4.

Transmittal slip from 0. Thompson, NRC, to L. Heller, 1/28/18 G. Lear, J. Knight, NRC, noting the attached memo H. Denton, NRC, to V. Stello, concerning Bailly - Monitoring of Pile installation.

5.

Memo from W. J. Dircks, NRC, to Commissioner Gilinsky 1/14/81 on Questions Regarding Bailly.

6.

Disposition from Geotechnical Engineering assistance to the 2/11/80 NRC, Trip Report, meeting, at Bailly Generating Station on 11/26/79.

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i4 UC L E M : T C. ? s, e i Ji n C O.'.T.* l S'. :

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!.' M 2 1 19 g; NOTE T0:

Lyman Heller, Leader, Geotechnical Engineering Section, HGEB

1. Thompson, Geotechnical Engineering Section, HGEB James Henderson, OIE FR0ii:

George Lear, Chief, Hydrologic & Geotechnical Engineering Branch, DE

SUBJECT:

BAILLY PILE DRIVIllG N0tlITOR Today I was advised by Jim Knight and Jim Henderson that:

OflRR and CIE (E. Case and V. Stello) agreed that OIE will administer a a.

contract for the Bailly pile driving monitor. OIE, Region III, will provide this function and will arrange for distribution to ONRR of information obtained by the pile driving monitor.

(OrlRRwill presumably provide technical review appropriate to its assigned safety evaluation function, as described in the letter from Eisenhut to Shorb dated March 5,1981).

Gene Gallagher and Jim Henderson of Hqs. OIE wiil establish the OIE procedures related to this contract.

.b.

The OIE contract for the pile driving monitor will incorporate the provisions of the " Scope of Work" previously prepared by ONRR (Dr. Owen Thompson) for guidance of the contractor.

The contractor may be either the Corps of Engineers or a private consultant if the Corps is not available.

RFPA's had been prepared by HGEB for either eventuality and were sent for processing to PPAS, ONRR (H. Thompson and B. Grenier).

OIE will obtain (or will be provided) these RFPA's from PPAS.

c.

OIE will discuss with PPAS, ONRR the method (s) to be used for funding a contract and providing OIE contract management.

Division of Contracts will provide appropriate information as needed.

The staff is to be aware that:

a.

This new contract with the Corps will have new travel funding provisions whereby NRC provides the travel money and related Corps requests / vouchers processing.

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b.

A contract with the Corps may not be operative beyond FY 81 if, as it has been directed by DE, ONRR, ONRR retrieves four (4) personnel spaces

" loaned" to the Corps for FY 81 for the technichl support of ONRR casework, i.e.:

Midland and Bailly. Since some uncertainty exists as to the continued availability of the Corps after this fiscal year for work on Bailly and Midland, HGEB, ONRR had prepared the previously mentioned contract for services of a consultant to monitor the pile driving at Bailly.

W George r, Chief Hydrologic and Geotechnical Engineering Branch Division of Engineering cc:

J. Knight R. Tedesco H. Thompson C. Poslusny B. Grenier

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.a Docket tio. 50-367 MEETIllG !!0TICE

SUBJECT:

C00RDINATI0tl 0F STAFF LICEllSING EFFORTS BAILLY llVCLEAR STATI0ii, GARY, IllDIAtlA Date:

Thursday, March 19, 1981 Time:

2:30 pm Place:

P-214 (G. Lear's Office)

Attendees:

W. Olmstead, OELD

5. Goldberg, OELD R. Tedesco, DL B. J. Voungblood, DL M. D. Lynch, DL P. M. McKee, IE HQ J. Knight, DE G. Lear, DE, HGEB L. Heller, DE, HGEB R. Gonzales, DE, HGEB

0. Thompson, DE, HGEB Agenda:

As attached SQ zW George Lear, Chief Hydrologic and Geotechnical Engineering Branch Division of Engineering cc:

Attendees I

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i Meeting Agonda Coordination of Staff Licensing Efforts Bailly Nuclear Station Thursday, March 19, 1981, 2:3C pm; P-214 1.

Introduction and Purpose of Meeting G. Lear 5 min.

2.

Summary of Legal issues; Listing S. Goldberg 10 min.

of items requiring discussica 3.

Background on Safety Issues i.e. Shorter

0. Thompson 5 min.

Pile Proposal by NIPSC0; Listing of items requiring discussion (See n"' <k-r 1) 4.

Background on Environmental Issues, i.e.,

R. Gonzales 5 min.

Additional construction dewatering effects due to extended construction periods and preparation of EIA.

Listing of items requiring discussion.

5.

Discussion of items from 2, 3, and 4, above G. Lear 25 min.

(Chair) 6.

Summaries IE P. McKee 2 min.

DE G. Lear 2 min.

DL D. Lynch

2. min.

OELD S. Goldberg

2. min.

7.

Closure G. Lear 2 min.

Total I hour t

agg

I IJtdgrour en Safety Issues a)

The staff has accepted the Shorter Pile Proposal by letter (Eisenhut, DL, to Shorb, NIPSCO, dated March 5, 1981) that includet the staff SER related to the Pile Foundation Design and Installation for Bailly.

b) The SER permits the licensee to drive piles; NIPSCO could start early Summer 1981 with a low-level effort (1 shift per week) or wait till Spring 1982 until CP extension is approved (see Environmental Issues, below) and start an intensive (2 or 3 shift per week) installation program.

c) The SER, section 2.14 states:

.....the on-site NRC inspection effort will be greater than that normally expended at this stage of cor.struction...."

..... Region III.... will provide the enhanced inspection program....."

" Additionally,....(NRR) will institute an on-site monitoring program as part of its continuing review effort....".

d) The requirements of item (c) atave were discussed between H. Thornburg (IE), R. Tedesco (DL), J. Knight (DE), et al.on October 9, 1980; a memo documenting the agreements reached has not yet been issued; J. Knight currently has a draft of this memo.

e) An RFPA requesting the Corps of Engineers (C0E) to provide on-site monitoring of pile installation was signed by R. Vollmer on October 30, 1980; action has not beentaken by Division of Contracts.

Agreement could not be reached between NRC and COE regarding payment of travel costs and there may be other reasons why this RFPA has not been issued.

f) Because of a subsequent decision to phase-out COE contracts another RFPA was initiated (signed by G. Lear January 27,1981) requesting proposals from independent engineering firms to provide on-site monitoring of pile installation.

Division of Engineering (NRR) management has not acted on this RFPA.

g) The NRC must resolve how to provide the inspection and conitoring of pile installation when pile driving ' starts, as required by the SER and the Commission Order dated December 12, 1979.

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Docket No. 50-367 MEMORANDUM FOR: Victor Stello, Director Office of Inspection and Enforcement FROM:

Harold R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

INSPECTION AND MONITORING OF PILES AT BAILLY (TAC-4764)

The staff evaluation of the applicant's pr, posed pile driving program for the

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Bailly plant was submitted from Division of Engineering to Division of Licensing in a memorandum from J. Knight to R. Tedesco dated September 25, 1980. The staff has detennined that augmented i~nspection and field monitoring of the pile installation is necessary to assure adequate safety and is a prerequisite to meeting the intent of the December 12, 1979 Order cf the Commission.

Inspection and enforcement will be provided by IE in accordance with normal practice. The field monitoring will be an extension of the NRR review process and will be provided by NRR and its consultants.

Agreements reached during a discussion on October 9, 1980 between H. Thornburg (IE) and R. Tedesco, J. P. Knight, B. J. Youngblood, D. Lynch and O. Thempson (NRR), are summarized in the attached description of the duties of the on-site NRR representative and the anticipated interfaces between the on-site NRR representative who will perform the field monitoring, the NRR staff and its consultants, the IE inspector, IE, and the applicant.

'If you or your staff require further discussion regarding inspection or monitoring of the Bailly pile installation, the project manager, D. Lynch, can be contacted at 492-8413 to arrange a meeting.

Harold R. Denton, Director Office of Nuclear Reactor Regulation

Attachment:

As stated f

cc: See page 2 l

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':ello.

t cc: w/ attachment H. Denton H. Thornburg D. Eisenhut R. Vollmer R. Shev. maker R. Tedesco J. Knight B. Youngblood F. Schauer R. Jackson W. Haass G. Leir D. Lynch L. Heller J. Ma S. Goldberg P. Crane

' O. Thompson E. Gallagher P. Barrett l

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Subject:

Inspection and Monitoring of Piles at Bailly (i/.C-4764)

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Prepared By:

Dr. 0.een 0. Thompson, Geotechnical Engineering, Hydrologic and Geotechnical Engineering Branch, Division of Engineering, NRR Justification for On-site NRR Representative The !!RP, staff and its consultants require field monitoring of the installation of piles at the Bailly site to assure adequate safety of the foundation of this plant.. The field nonitoring will be an extension of the NRR review effort and is required because pile installation is a critical part of plant construction and errors made cannot be rectified after the plant is complete.

Furthermore, the staff requires a significant quantity of verification (load tests, heave measurements, etc) of the pile foundation design to be accomplished on a daily basis during construction.

The on-site NRR representative is also needed tn assure that the verification activities are reviewed and evaluated by the staff in a timely manner.

Finally, the staff believes that an on-site NRR representative

'is a prerequisite to meeting the intent of the December 12, 1979 Order of the

.Comission and the intent of the statf's comitment in the SER that installation of piles will be closely followed during construction.

Duties of On-site !!RR Representative The on-site NRR representative will observe the driving of piles and related activities; he will review and evaluate field records and report his findings to the NRR staff or its consultants, as directed by' the NRR staff.

In particular, the on-s'ite NRR representative will monitor:

1.

Daily records of pile driving and redriving.

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i 2.

The opplicant's evaluatict of ne sL ::f _:::r.v densification of eta, area 1

describ' d by the applicant as a "precoi.struction area."

e 3.

The applicant's evaluations of piezometer and groundwater data.

4.

The technical background and experience of the applicant's structural and geotechnical engineers who will process fiCR's.

5.

The qualifications and experience of the applicant's pile inspectors.

6.

The applicant's redriving of piles which show heave equal to or greater than 0.5 inches, and, if necessary,the applicant's evaluation of piles with final heave greater than 0.5 inches.

7.

The applicant's submittals for periodic settlement reading's at significant stages of the plant construction.

8.

The applicant's selection of piles to be load tested.

9.

Changes to the applicant's QA/QC manual as related to pile driving.

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10. The pile foundation installation for compatability with project plans, specifications, and accepted engineering practices.

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The applicant is con.c.itted to obtair, t.c;ific cpprcvai fr:

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activities.

The on-site NRR representative will monitor these activities and report to NRR. As directed by NRR, the on-site NRR representative shall simultaneously inform the applicant and the IE inspector of NRR apprcval.

The on-site NRR representative shall maintain a daily log of monitoring activities.

Interfaces Between the On-site NRR Representative, the NRR Staff and its Consultants, the IE Inspector, IE, and the Applicant The NRR staff will direct the activities of the on-site NRR representative, with assistance from consultants, as required.

The on-site NRR representative will report to NRR or to a consultant as directed by NRR. The NRR contact is 0. Thompson, lechnical Monitor (301-492-8186).

The on-site NRR representative will respond, as described above, to the applicant's requests for approval of the specific activities for which NRR review and approval are required. The IE inspector will simultaneously be informed.

The on-site NRR representative will not perform any ereforcement activity except in the case of immediate risk to life.

Any activities requiring enforcement action will be referred to the IE inspector and to NRR.

The on-site NRR representative will not be required to perform inspection activities, except at necessary to assist the NRR review effort.

Nothing in the representatives duties shall take away the responsibilities of the IE inspector in the performance of the normal IE function.

The e

- lah representative shi.ii s..r' ir. coor_

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E inspector so that each knows what tha other is doing.

Ultir. ate inspection and enforcer.ent responsibility remains with the IE inspector.

The on-site NRR representative shall request from the applicant information necessary to the IUR review effort.

Lack of edequate or tir.ely submittals i

L from the applicant shall be referred to flRR and IE for appropriate action.

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Summary of. Environmental Issues - Bailly 1)

Intervenors have contended that an EIS must be prepared in connection with ~

the CP extension proceeding.

2). The-staff in a letter-to the Hearing Board dated October 30, 1980 (concurred by Denton) committed to prepare an EIA on the CP extension' before detennining if an impact statement should be prepared.

3) EIA will address envir nmental impacts due to the longer construction period that has been requested, including post-CP extension dewatering effects.

4)

If EIA shows significant environmental impacts due to CP extension, the staff will prepare an EIS.

5) Contract proposal to conduct review in preparation of an EIS was issued to L..G. Hulman in March 16, 1981.

If acceptable, Mr. Hulman is expected to begin his review on March 23, 1981.

6) Hulman contract to be monitored by HES.

Following acceptance of contract by Hulman, HES will ask for an estimate of when Mr. Hulman will provide -

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his' written report for use in preparing an EIS.

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SUW ARY OF CONSTRUCTION DEWATERING AT THE BAILLY PLANT PREPAP,ED BY R. G0::ZALES, HYDROLOGIC ENGINEERING SECTION E efore a Hearing Board on On August 9,1973, NRC Staff provided testimony b

f intervenor contentions dealing with dewatering effects and ash pond water use.

The staff testified that the well point construction dewatering system was expected to cause a temporary change in the relative direction of water movement and groundwater flow rates within a radius of 1 mile of such activitiesi The greatest changes were expected to be encountere) within a radius of about half a mile from the dewatering activities.

The staff testified that without' mitigation, construction deaatering would likely increase seepage from the ash ponds and reduce water levels in several of the interdunal ponds such that ponds closest to the dewatering activities could be drained.

To mitigate these effects, the staff suggested that water levels in the interdunal ponds be maintained as close to natural levels as possible. The staff suggested three methods by which mitigation could be accomplished.

(a) Piping a portion of the water from the de.atering activities to the interdunal ponds affected by such activities.

(A technique such as this was also suggested by the applicant's consultant during the hearings).

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- See Hulman, TR 7045-7091, August 9, 1978 Hearing, Valparaiso, Ind.

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(b)1.'ater from Lake Michigan could be routed or piped to the interdunal ponds.

(c)l4 portion of the existing potable water supply could be diverted.t'o the interdunal ponds.

It was recognized during the hearings that selection of any one or a combination of the above sources for maintaining water levels in the interdunal ponds would also require a careful initial detennination of the chemical quality of the cater supply sources.

If there should be problems with the natural water chemistry, the staff testified that there could be artificial recharge of the groundwater table using well points along the applicants property -- to prevent the interdunal pond water levels from being diminished due to construction dewatering.

On October 17, 1973 the applicant, Northern Indiana Public Service Company (1;!PSCO) proposed a program for monitoring water levels in the interdunal ponds.

The ASLB on April 5, 1974 found that the applicants proposed monitoring i

program, as approved by the staff on November 9,1973, was adequate to detect any effects on the interdunal ponds caused by the dewatering activities.

This decision was affirmed by the ASLAP on August 29, 1974 and became the Commission's final action.

On September 13, 1974, the Commission's final action was appealed by the joint intervenors to the U.S. Court of Appeals for the Seventh Circuit.

In addition, on September 18, 1974 the intervenors filed a motion for a stay on dewatering activities during construction pending judicial review of their appeal. As a l

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result of this appeal, the Court halted construction of the Bailly plant on Odtober 16, 1974.

On April 1,1975, the Court of Appeals #nvalidated the CP and pennanently enjoined the construction of the Dailly facility.

The Supreme

~ Court subsequently reversed this decision and reaffirmed the Coramission action euthorizing construction of the Bailly Plant.

Throughout the Bailly proceedings, the National Park Service (NPS) of the Department of the. Interior has become increasingly interested because of its role as caretaker of the Indiana Dunes National Lakeshore (IDNL).

The NPS's objective regarding the character of the Lakeshore is to restore the Lakeshore to its original nature to the extent feasible.

As a result the NPS is concerned not only with declines in groundwater levels due to coastruc+. ion dewatering but also'with groundwater. increases due to water that is seeping from onsite ash ponds. The ponds are used to impound ash and water from the Bailly coal fired units.

In September 1974, the NPS asked the U.S. Geological Survey (USGS) to investigate the possible effects on the hydrologic system in the IDNL of planned dewatering at Bailly.

In July 1976 the USGS published the results of its investigation in report 76-82 by J. Marie.2/ This report described the results of a digital-computer model simulation of the hydrologic system in the area. The results

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were that the planned dewatering would lower the groundwater level by about four i

feet under the westernmost interdunal pond in the IDNL.

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Shortly af ter receiving its construction permit, NIPSCO on September 6,1974 proposed to the staff the use of a slurry wall, in lieu of a well point dewatering system, to alleviate the potential effects of construction

' dewatering.

The staff evaluated the proposal and issued a favorable finding on October 3 1974.

That day, the Commission ordered an additional hearing 1,efore a Licensing Board to review the environmental effects of the use of a slurry wall.

Subsequently, the Licensing Board authorized installation of the slurry wall.

Its decision was affirmed by the Appeal Board on December 17, 1975. The slurry wall was installed in February 1977.

Because of concern over the continued impacts of the ash ponds, the NPS stated its intent to take NIPSCO to court to force sealing of the ash ponds. As a result, NIPSCO agreed to seal the ponds voluntarily.

NIPSCO was then faced with conflicting requirements from NRC and NPS.

NRC required mitigation efforts to maintain uater levels while NPS required sealing of the ash ponds which would result in a decline of groundwater levels.

Sealing of the ash ponds was initiated in March 1980.

l In preparation for construction, NIPSCO began a water level monitoring program

-in March 1972. This program has been continuously expanded and toJay the prcgram is a combined effort between NIPSCO, NPS and USGS.

Hydrologic data-have been accumulated since 1972.

Since 1976, when the USGS published 2IUSGS Report 76-82, "Model Analysis of Effects on Water Levels at Indiana Dunes National Lakeshore Caused by Construction Dewatering," July 1976.

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4 report 76-82, several changes have occurred at'the Bailly site which.have affected the validity of the results of the USGS study:

the slurry wall-has been installed and the ash ponds are' being scaled.

In addition, the hydrologic.

monitoring program has been expanded to provide considerably much more data on the geologic setting, the hydrologic characteristics of the aquifers and E

the interrelations between the interdunal ponds, the ash ponds, and the aquifer system.

As a result of these changes, the USGS undertook another study in i,

197G wh4 k into account the slurry wall around the Bailly excavation and

-the seepage fiom the ash ponds. The study also considered the existance of two aquifers separated by a confining, relatively impermeably,aq'uitard which appeared to be discontinuous in the southeast corner of the Bailly excavation.

The results of this study were published in January 1979 in report 78-138 by Meyer and Tucci.3_/ This report described a digital computer model which was developed to simulate a multilayered soil-profile and the groundwater system.

f Results of this simulation were that.within the ID'll there would be a groundwater I, '

level decline. of 3-feet or less in the upper unconfined aquifer and 5 feet or less in the lower confined aquifer due to construction dewatering of the Bailly site.

The dewatering plan haC initially involved pumping only from the upper aquifer but on August 27, 1979, in a report titled " Supplementary Infonnation, Hydrologic Evaluation of Construction Dewatering-Bailly Generating Station, j

??uclear 1," flIPSCO proposed a modification to the dewatering plan.

This modification was needed because one portion of the installed system -- free 3IUSGS Report 78-138, " Effects of Seepage from Fly-Ash Settling Ponds and Construction Dewatering on Groundwater levels in the Cowles Unit, Indiana l

Dunes flational Lakeshore, Indiana," January 1979/

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flowing drains installed to relieve pressure in the lower aquifer -- had not been as effective as had been expected.

fl!PSCO proposed a system of deep wellpoints for pumping to relieve pressure in the lower confined aquifer and, thereby, preventing uplift (sand boils) in the Bailly excavation as it was deepened. Also, to mair+ain groundwater levels within the IDril during construction,flIPSCO proposed a trickling ilter recharge system to inject water into the upper aquifer betticen the Bailly excavation and the IDfil.

As a result of this modf fied dewatering plan, the USGS conducted a reassessment of the effects of the construction dewatering plan.

Its findings i

were published in rgnrt 80-1105 by Gillies and Lapham.N Dewatering at Bailly had been expected to be completed before the ash ponds were sealed, but because of delays at the Bailly plant, this did not occur. Thus the USGS report assumed that decline of grcendwater lavels due to ash-pend sealing could occur simultaneously viith Cailly construction dewatering.

Conclusions reached by the USGS were that f;IPSCO's revised denatering plan would n0t produce water level declines significantly different from those reported in the USGS's January 1979 report.

Hor:ever, in considering a discontinuity beneath Cowles Bog (the confining aquitard normally present between the upper and lower aquifers, appeared to be 1

OUSGS Report 80-1105, " Reassessment of the Effects of Construction Dewatering on Groundwater Levels in the Cooler Unit, Indiana Dunes flational Lakeshore, Indiana," September 1980.

(

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thin or absent in the area of Cowles Bog, a marsh area located in the IDHL about 8,000 feet east of the Bailly excavation) the USGS's computer simulation showed a lowering 'in the upper aquifer in Cowles Bog:

the trickling l

filter mitigation plan operating at the maximum design rate of 400 ' gallons per minute could maintain water levels in the upper aquifer at the Bailly-IDML property line, but the mitigation plan still wreld not canpletely eliminate groundwater declines at Cowles Bog.

There seems to be a lack of complete confidence in the USGS model because the USGS's September 1980 report also concluded, that, since the computer model had J

not been verified, it could be used only in a general way to estinate minimum i

and maximum estinates of the impact of construction dewatering.

In addition, the applicant has submitted documents' to NRC which refute the USGS's assessment t

i of the groundwater regime.

The' applicant contends E/ that the USGS Report 78-138 (11 eyer & Tucci) was deficient in several aspects of soil parameter cha racteriza tion.

The deficiencies include:

- A large body of data were not used in the study, The permeability of various subsurface strata used in the r.odel was incorrectly stated or used.

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Aq titards influencing the analyses were ircorrectly assumed to be continuous, l

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1 E/" Soil Paramet.ers Used in USGS Report 78-138, 'D' Appolonia Consulting Engineers for Northern Indiana Public Service Com.pany, May 1980.

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Aquifers and aquitards were, in some cases, incorrectly described (and used in the USGS model) with regard to location, elevation, thickness, and continuity.

The groundwater elevations assumed in the USGS model are differcnt from those existina.

In a detailed assessment of the USGS model report and predicticns / the 5

applicant further criticizes the USGS assessment of the effects of the construction deuatoring of the lower aquifer by pressure relief deep well points on the IDNL.

MIPSCO concludes that the USGS prediction of drawdown is "o ong and unreliable" because:

- actual field aata was ignored and misused, assu:rgtions incarporated into the model are wrong and do not represent actual field data, and

- the model was misapplied in obtaining the draudoun estimates.

NIPSCO also assessed the potential drawdown due to construction dewatering of the lo. er aquifer by deep wellpoints.

The radius of influence of the drawdown is estimated, based en actual field data and permeabilities, to 5/" Assessment of the Influence of Dewatering at Bailly N-1, "D'Appolonia Consulting Engineers for Northern Indiana Public Service Company, November 1980.

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be less than 950 feet.

Further, a similar assessment using the erroneous (asserted by flIPSCO) USGS permeabilities indicates the radius of drawdown effect would be limited to about 1450 feet. Since the environmentally sensitive Cowles Bog is located more than 8001 feet from the area of construction dewatering,filPSCO concludes that the dewatering pressure relief system cannot effect the Bog.

The divergent technical opinions (i.e., tilPSCO vs. USGS) is further complicated by the lining of the N!PSCO ash ponds ordered by the lips.

While the lining is not yet co.nplete, groundwater levels bordering the ash ponds (and the IDill) have de-lined up to 10 feet. The decline is expected to progress into the IDril affecting, in time, the ponds therein, including Cowles Bog.

The I;RC staff has maintained a close watch on the groundwater levels neas,! red in the t11PSCO and OMS monitoring wells.

In over 3 years of collected data several trends are obvious. There is a significant area of drawdown near the southeast corner of the construction excavation.1/ There is also a general cyclical, seasonal, variation of groundwater elevation of 1-3 feet with some measurements indicating even larger differences.

1/ e are unaware of any disagreement between tilPSCO, tiRC, tips, or the USGS about l

W this area. The slurry wall is only partially effective in reducing inseepage due to a discontinuity in the aquitard into which the slurry wall extends.

The discontinuity effects at least the SE corner.

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The staff initially concluded that effects of construction dewatering in the upper unconfined aquifer could be identified and mitigated by the applicant. We continue to hold that view.

Ilowever, the Department of Interior I contends that the pressure relief 0

wellpoints which were not included in the staff's initial assessment will cause a significant decline in the groundwater level at Cowles Bog (supported by the USGS) and that the decline will produce unacceptable impacts in the Bog (supported by the fiPS).

The applicar.t refutes the facts with regard to groundwater decline and thus denies the occ':rrence of adverse impacts attributable to dewatering.

Resolution of this issue will be a part of the EIA.

8) Letter dated October 3, 1980 from Interior Secretary, Cecil Andrus to John F. Ahearne l

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