ML20003C350
| ML20003C350 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/25/1981 |
| From: | Hood D Office of Nuclear Reactor Regulation |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102270793 | |
| Download: ML20003C350 (49) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION N D 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-329-0M 50-330-0M CONSUttERS POWER C0ftPANY 50-329-OL (flidland Plant, Units 1 and 2) ) 50-330-OL NRC STAFF'S ANSWERS TO INTERROGATORIES FILED BY CONSUMERS POWER COMPANY Interroaatory 1 Define " acceptance criteria," as that tem is used at page 3 of the Order. Answer Acceptance criteria are the standards on which a judgement or decision is based. As used in the December 6,1979 Order on Modification, the standards to be used by the licensee to make its judgment or decision that proposed remedial measures are acceptable was sought by the NRC for its review. This infonnation was required to be submitted by the licensee in order for the NRC to determine whether there was reasonable assurance that the facility, as modified by the proposed remedial measures, can be con-structed and operated without undue risk to the health and safety of the public. G 820227o793
The NRC practice in perfoming radiological safety reviews is such that the tem " acceptance criteria" has a wide meaning and it is this broader meaning that applies as the tem is used within the Order. The NRC practice is to use a document entitled " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG-75/087, for the radiological safety revitw of applications for licenses of nuclear power plants such as the Midlano Plant. Each section of the Standard Review Plan (SRP) is organi-zed into four subsections, and one of these subsections is entitled " Accept-ance Criteria". This subsection contains a statement of the purpose of the review and the technical basis for detemining the acceptability of the design or the programs within the scope of the area of review of the SRP section. The technical bases consists of specific criteria such as NRC Regulatory Guides, General Design Criteria Codes and Standards, Branch Technical Positions, and other criteria. This subsection is further dis-cussed in the first section of the Standard Review Plan, which is entitled " Introduction". To illustrate the tem " acceptance criteria," refer to SRP Section 2.5.411, page 2.5.4-3 and Section 2.5.5II, page 2.5.5-1. SRP Section 2.5.4 is entitled " Stability of Subsurface Materials and Foundations," and SRP Section 2.5.5 is entitled " Stability of Slopes." From these examples it is seen that " acceptance criteria" for the pertinent geotechnical review areas would include, for each specific and important engineering feature, a thorough evaluation of the particular engineering aspect based on analyses of basic data that support all conclusions. These analyses and basic support data are required to allow the Staff to conduct independent analys2s and reach
independent conclusions on whether reasonable assurance of plant safety exists. Interrogatory 2 State which "of the Staff's requests were directed [as of or before r December 6, 1979] to the determination and justification of acceptance criteria to be applied to various remedial measures taken" (Order at page 3) and which portion of each request was so directed. Answer Attached Table 2-1 lists Staff's requests that were directed to the determination and justification of acceptance criteria to be applied to various remedial measures taken and proposed by Consumers. As of Decem-ber 6,1979, the only remedial action that had been taken was the placement of the sand surcharge inside and around the Diesel Generator Building, which had reached the maximum height of 20 feet above final plant grade on April 7, 197d/andwhichhadbeenremovedbyAugust 31,1979.E The requests in Table 2-1 relevant to the remedial action for the Diesel Generator were Requests number 4, 5, 8,12,13,14,18,19, 20, 21(c), 25, 26, 27, 28, 30, and 35. 1/ S. Howell letter of April 30 1979 to J. Keppler, forwarding MCAR 24 Interim Report 5. 2/ S. Howell letter of November 2,1979 to J. Keppler, forwarding MCAR 24 Interim Report 8.
l 4 In addition to the requests listed in Table 2-1, the Staff had pre-viously submitted other requests to Consumers directed _to the determina-tion and justification of acceptance criteria to be applied to various remedial measures taken and proposed by Consumers. These requests are identified in Appendix A hereto. Seismic issues to be resolved are dis-j cussed in the answer to Interrogatory 11. TABLE 2-1 Staff's 50.54(f) Signatory /Date of Applicable Portion Request No. Request letter of Request 4 H. Denton, 3/21/79 Al1 5 All 6 All 8 First and third sentences 9 All 10 All 11 All 12 All 13 All 14 All 15 All 16 All 17 Third and fourth sentences 18 All 19 Second and third sentences .~
5-Staff's 50.54(f) Signatory /Date of Applicable PortiodI Request No. Request letter _ of Request 20 All 21 Subparagraph (c) 24 L.S. Rubent.tein, 11/19/79 All 25 All 26 All 27 All 28 All 29 All 30 All 31 All 34 All 35 All NOTES: 1/ Portion of Staff's request directed to the detemination and justi-fication of acceptance criteria to be applied to various remedial ~ measures taken or proposed. APPENDIX A NRC REQUESTS PRIOR TO DECEMBER 6, 1979 OTHER THAN 50.54(f) REQUESTS Signatory / 'ApplicablePortiod/ Staff Request Date of Request Letter of Request 130.21 S. Va rga, 12/11/78 All 362.12 First sentence 362.13 All but last sentence
1 i Signatory / Applicable Portion Staff Request Date of Request Letter of Request 40.106 S. Varga,1/18/79 All 130.23 All, with respect to Category I structures other than Containment. 130.24 All, with respect to Category I structures other than Containment. 362.14 All 362.15 All 362.16 All 362.17 All NOTES: 1/ Portion of Staff's request directed to the determination and justifi-cation of acceptance criteria to be applied to various remedial neasures taken and proposed. Interrogatory 3 State and explain the reasons why "such [ acceptance criteria], coupled with the details of the remedial action, are necessary for the Staff to evaluate the technical adequacy and proper inolementation of the proposed action." (Orderatpage3.) Answer Technical adequacy and proper implementation are two of the principal ingredients necessary to the Staff conclusion regarding reasonable assurance as to whether the facility as proposed to be modified can be constructed and
_7_ 1 operated without undue risk to the health and safety of the public. The licensee's criteria, as defined in response to Interrogatory 1, and the specific details of the remedial action constitute the basis of review from which such conclusions by the Staff are derived. Interrogatory 4 State and explain the basis for tne statement, L page 3 of the Order, that "the information provided by the licensee fails to provide such criteria." (Acceptance criteria ) (Orderatpage3.) Answer The reply to Interrogatory 6(d) identifies which of the licensee's responses the Staff found to be inadequate as of December 6, 19 M, and the response to Interrogatory 6(f) explains why. The responses were inadequate, in part, because they did not provide the acceptance criteria, as cefined in the response to Interrogatory 1, which the Staff requires for its radiological safety review. Consider, for example, 50.54(f) Request 4 which on March 21, 1979 in part asked (1) what criteria the licensee would use to judge the acceptability of fill, structures, and utilities upon conclusion of the preload program, (2) what extent of residual settlement would be pemitted, and (3) the basis for the limit. The licensee's most recent reply prior to December 6,1979 (Revision 3 to Amendment 72 dated September 13,1979) stated that the cri.teria and the extent to which residual settlements would s
be pemitted would be provided by December 1979.E Therefore, the licensee's reply did not include acceptance criteria and the Staff considered the response to be inadequate and the mat'er remains unresolved. For further examples, refer to the response to Interrogatory 6(f). Interrogatory 5 State with particularity each item of infomation the Staff requested up and until December 6, 1979 with regard to acceptance criteria. Answer The items of information the Staff requested up and until December 6, 1979 with regard to acceptance criteria are given in the reply to Interroga-tory 2. Interrogatory 6 With regard to each item of infomation identified in response to Interrogatory 5, state: (a) the identity of the request; (b) whether Con-sumers responded to that request; (c) the identity of the communication that the Staff considered Consumers response to the request; (d) whether the Staff considered the response adequate; (e) the identity of the communica-tion by which the Staff communicated its position as to the adequacy or inadequacy of the response; (f) the basis for the Staff's position regarding y The licensee's response was ultimately submitted February 28, 1980 by Amendment 74; or about 10 months after the full surcharge for the -Diesel Generator Building had been placed and 6 months after the sur-charge had been completely removed.
9-adequacy or inadequacy of Consumers respense; and (g) the Staff personnel responsible for detemining whether Consumers' response was adequate or inadequate. Answer With regard to each item of infomation identitifed in response to Interrogatory 5 (which in turn refers to the answer to Interrogatory 2), Table 6-1 responds to parts (a), (b), (c), (d), (e) and (g) of Interroga-tory 6. Answers to parts (e) and (f) of Interrogatry 6 follow. For those requests shown in Table 6-1 to be issued before December 6,1979, but for which replies were initially made after December 6,1979, refer to the answer to Interrogatory 8. Similar infonnation for requests identified in Appendix A is provided by Appendix B. Regarding part (e) of Interrogatory 6, the means by which the Staff communicated its position as to the inadequacy of the licensee's response was primarily by the issuance of additional questions on the same subject. These followup requests are listed in Table 6-1. For example, 50.54(f) Request 35 pecifically indicated the response to pr'evious Request 5 was unacceptable. It is not Staff practice to indicate acceptable responses to licensees, except by seperate request on a case-by-case basis. Such indi-cation of acceptance is typically left for issuance of the Staff's safety evaluation report for those responses which are of significance to that report.
. The basis for the Staff position of inadequacy shown by part (f) of Interrogatory 6 is that the licensee's response failed to meet the Staff's acceptance criteria as defined in response to Interrogatory 1. Specific reasons for failing are given below, and typically include not being fully responsive to the Staff's requests or insufficient submittal of basic data to support the conclusions or positions submitted by the licensee. Consumer's responses to 50.54(f) Requests 4, 5, 6,12 and 21(c) were inadequate because of missing information or data or the responses raised additional questions. The portions of these requests which were inadequate are identified by +.he followup requests listed under Column 6(e) of Table 6-1. The response to 50.54(f) Request 13 is inadequate because Consumers has not completed its analysis of the Category I structures affected by the settlement factoring in the effects of settlement (ie., cracks, modeling changes, and material properties changes). Consumers acknowledges the continuing nature of their studies in their answer to Request 13. The response to 50.54(f) Request 14 is inadequate because Consumers has not completed its analysis of the Category I structures affected by cne settlement, factoring in the effects of the settlement (ie. cracks, modeling changes, material properties changes). Consume;s has provided some infor-mation on the cracks present in most Qtegory I structures, but has not detemined the related load and the related changes to analytical models and material properties. In addition Consumers has not detemined if the cracks will continue to propagate. The response to 50.54(f) Request 15 is inadequate because Consumers has not acknowledged the fact that differential settlement as used in the load
. combinations is not a self-limiting effect. In addition we have not accepted tha proposed fixes. The response to 50.54(f) Request 16, 21though responsive, is of a nature that additional work by Consumers is required for an acceptable reply. 50.54(f) Request 17 asked how code-allowable conditions of underground Category I piping will be assured throughout plant life. The reply contained no commitment to use the 3.0Sc limit of part NC-3652.3 of Section III of the ASME Code, Division 1. However, the response, in Table 17-2, did indicate that the Code calculations were used. The response provided a comparison of the ASME Code limit to the calculated pipe stresses resulting from settlement. From the response, it was not clear whether this response to the Code was for illustrative purposes only, or whether it was intended to hpresent Consumer's criteria. The reply provided no acceptance criteria fcr inclu-sion of future settlement of buried piping over the life of the plant. Also, no criteria was provided for cases where the allowable stresses were exceeded. 50.54(f) Request 18 asked for an identification and description of evaluations of seismic Category I piping to assure that it could withstand increased differential settlement between buildings, within the same build-ing, or within the piping systems itself without exceeding code-allowable stress criteria. Request 18 also asked for the licensee's plans to assure compliance with code allowable stress criteria throughout the life of the plant. The response for seismic Category I piping between structures makes
, 4 a general referer:ce to applicable codes, but provides no indication as to which codes or as to what specific acceptance criteria the piping is to meet. Therefore, more spectric criteria as to the stress limits to be used are required. 50.54(f) Request 20 asked for acceptance criteria required to define acceptable loads or components and supports produced by pipe deformations due to settlement. The reply defined no acceptance criteria, but only stated that the loads on components were within the allowables. The reply provides no acceptance criteria as to when flanged joints will be disassem-bled and the methods for determining nozzle loads. Acceptance criteria for the allowable differential settlement for the 2-inch and smaller diesel generator fuel oil lines was not addressed. As noted in Appendix B, the response to Staff Request 40.106 was con-sidered to be inadequate. The response was in conflict with the response to Request 20. Specifically, the response to Request 20 indicated that a stress analysis for the diesel generator fuel oil lines was unnecessary because of the inherent flexibility of small piping (1 1/2" to 2" diameter); whereas the response to Request 40.106 indicates an extensive program for monitoring and analysis of this same piping would be perfomed. Consumers position needs to be clarifief For reasons indicated by followup Requests 25 and 26, the response to Request 130.21 as noted in Appendix B was inadequate. Consumers did not complete the answer to this question to our satisfaction. Consumer's The evalua-response refered to other 10 CFR 50.54 requests and responses. tions of _ Category I structures have not been perfomed to our satisfaction, w The applicant has not justified in full the proposed fixes and has not provided a detailed evaluation of its analysis and design. The response to Request 130.23 as noted in Appendix B was inadequate because the current criteria requires the use of ACI 349 as supplemented by Regulatory Guide 1.142. In addition the effects of the settlement (i.e., cracks, change in modeling, change in material properties) need to be fac-tored in the analysis and design of these Category I structures. Further-more, the answer addressed only the internal structures to the containment building and the auxiliary building but deferred any consideration for other Category I structures. The response to Request 130.24 as noted in Appendix B was inadequate because Consumers did not complete its evaluation of all Category I struc-tures for the effect of the use of Regulatory Guides 1.60 and 1.61 in place of its proposed seismic responsa spectra and related damping values. % effect of settlement should be factored into Consumer's reevaluation. Certain Consumer's responses were indicated to be inadequate. Consumer's responses to kequests 362.13, 362.14 and 362.16 were inadequate because the Staff concern raised in these FSAR questions were not to be fully resolved until Consumers completed additional field and laboratory work. Ul timately these issues have been pursued by the Staff in subsequent 50.54(f) requests as identified in Appendix B. The portions of the response to Request 362.17 which deal with predicted settlement are similar to the above in that field work had to be completed before the issue could be resolved. The portion of che response pertaining to induced vertical stresses versus depth was unrespons.ve in providing needed specific data and results.
TABLE 6-1 Identity Of Whether
Response
Staff's Follow-up Responsible 50.54 (f) Consumer Identification Consideration Requests Staff Request Responded as of 12/6/79 of Response Personnel as of Adequacy 12/6/79 as of 12/6/79 6 (a) -6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 4 Yes Rev. 3, 9/13/79, Inadequate 27, 40 L. Heller & Responses to NRC D. Gillen Requests Regarding Plant Fill 5 Yes Rev. O, 4/24/79, Inadequate 35, 37 L. Heller & Responses to NRC D. Gillen Requests Regarding Plant Fill 6 Yes Rev. 3, 9/13/79, Inadequate 31, 33, 43 L. Heller & Responses to NRC D. Gillen Requests Regarding Plant Fill 8 Yes Rev. O, 4/24/79 Adequate H. Balujir.: Responses to NRC L. Helle Requests Regarding D. Gillan Plant Fill 9 Yes Rev. O, 4/24/79,
Response
Refer to L. Heller & Responses to NRC referred to Request ]2 D. Gillen Requests Regarding Question 12 Plant Fill 10 Yes Rev. O, 4/24/79
Response
Refer to L. Heller & Responses to NRC referred to Request 12 D. Gillen Requests Regarding Question 12 Plant Fill 11 Yes Rev. O, 4/24/79 Adequate L. Heller & Responses to NRC D. Gillen Requests Regarding Plant Fill 9 0
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TABLE 6-1 Identity of Wh.sther
Response
Staff's Follow-up Responsible 50.54.(f) Consumer Identification Consideration Requests Staff . Request Responded as of 12/6/79 of Response Personnel as of Adequacy as of 4 12/6/79 12/6/79 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 12 Yes Rev. 3, 9/13/79, Inadequate 38,39,41,42,43 L. Heller & Responses to NRC 44,45,46,47,48 D. Gillen Requests Regarding Plant Fill 13 Yes Rev. 1, 5/31/79 Inadequate 25,48 R. Lipinski Responses to NRC F. Rinaldi Requests Regarding F-Schauer Plant Fill a 14 Yes Rev. 3, 9/13/79 Inadequate 25, 28, 29 R. Lipinski 7 Responses to NRC F. Rinaldi Requests Regarding F. Schauer Plant Fill 15 Yes Rev. 3, 9/13/79 Inadequate 25, 26 R. Lipinski Responses to NRC F. Rinaldi Requests Regarding F. Schauer Plant Fill i 16 Yes Rev. O, 4/24/79 Responsive 34 L. Heller & Responses to NRC but additional D. Gillen Requests Regarding work by Consumers Plant Fill required to' resolve 17 Yes Rev. 2, 7/9/79, Inadequate 45 1/ R. Stephens Responses to NRC A. Cappucci Requests Rega. ding Plant Fill 4 4 18 Yes Rev. O, 4/24/79, Inadequate .l/ R. Stephens Responses to NRC A. Cappucci Requests Regarding Plant Fill r ,_~-
. TABLE 6-l~ Identity of Whether
Response
Staff's Follow-up Responsible 50.54 (f) Consumer Identification Consideration Requests Staff Request Responded as of 12/6/79 of Response Personnel as of Adequacy as of 12/6/79 12/6/79 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 19- .Yes Rev. O, 4/24/79, Not determined -1/ R. Stephens Responses to NRC (and presently A. Cappucci Requests Regarding under review) Plant Fill 20~ Yes Rev. 2, 7/9/79, Inadequate -1/ R. Stephens Responses to NRC (and presently A. Cappucci Requests Regarding under review) Plant Fill 4 21(c) Yes Rev. O, 4/24/79, Responsive but 35,37,40 L. Heller 7 Responses to NRC Inadequate J. Kane Requests Regarding D. Gillen Plant Fill 24 through 31 No (after 12/6/79) 34,35 No (after 12/6/79) Notes: ,1f See Enclosure 3 to " Summary of January 16, 1980 Meeting on Supplemental Requests Regarding Plant Fill," dated February 4, 1980. 9
APPENDIX B _ldentity'of Whether Communication Staff's Follow-up Responsible . Request Consumer Identification Consideration Request Staff Responded as of 12/6/79 of Response Personnel as of Adequacy 12/6/79 as of 12/6/79 6 (a) 6'(b) 6 (c) 6 (d) 6 (e) 6 (g) l 362.12 Yes FSAR Rev. 24, 9/79, Adequate L. Heller Responses to NRC D. Gillen Questions ' 362.13 Yes FSAR Rev. 20, 4/79, Inadequate 4.5,7,9,12,13,14 L. Heller Responses to NRC D. Gillen Questions 362.14 Postponed FSAR Rev. 24, 9/79, Inadequate. 9,10,12,15 L. Heller A Responses to NRC
Response
D. Gillen 7 Questions postponed to 7 future date. 362.15 Yes FSAR Rev.24, 9/79, Adequate L. Heller Responses to NRC D. Gillen Questions 362.16 Yes FSAR Responsive but 4,12 L. Heller Responses to NRC submittal of D. Gillen Questions needed revised f settlement t analysis postponed to future 362.17 Yes FSAR Rev. 24, 9/79, Inadequate 4,8,14 L. Heller D. Gillen f 130.21 Yes FSAR Rev. 24, 9/79, Inadequate 25,26 R. Lipinski l Responses to NRC F. Rinaldi Questions F. Schauer t e-w- - ~ -,,- w w
t APPENDIX B. Identity of Whether Communication Staff's Follow-up Responsible Request Consumer Identification Consideration Request Staff f Responded as of 12/6/79 of Respon:e Personnel as of Adequacy 12/6/79 as of 12/6/79 i 6 (a) 6 (b) 6 (c )' 6 (d) 6 (e) 6 (g) ( ( (?) 130.23-Yes FSAR Pev. 24, 9/79, Inadequate 25,26 R. Lipinski ? Responses to NRC F. Rinaldi Questions F. Schauer (?) 13').24 Yes FSAR Rev. 24, 9/79 Inadequate 25,26 R. Lipinski ? Responses to NRC F. Rinaldi l Questions F. S c h a u e.- 40.106 Yes FSAR Rev. 24, 9/79 Inadequate 20 H. Balujian Responses to NRC (clarification R. Stephens y. Questions required) A. Cappucci I i e 1-t i
I i _ 19 - Interrogatory 7 State with particularity each item of infomation the Staff requested af ter December 6,1979 with regard to acceptance criteria. Answer w This answer is provided by Table 7-1 attached.
20 - d S TABLE 7-1 Signatory /Date 3 of Request Apolicable Portion Staff's Request No. Communication of Reouest 36, 37, 38 A. Schwencer, All June 30, 1980 39 through 48 A. Schwencer, All August 4, 1980 49 through 53 R. Tedesco, All August 27, 1980 to Darl S. Hood, Items 1-8 " Summary of January 16, February 4, 1980 1980 Meeting on Supplemental Requests Regarding Plant Fill", 2/4/80 NRC Staff Interroga-W. D. Paton Interrogatories tories to Consumers November 26, 1980 1-9 Power Company, November 26, 1980 NRC Staff Interroga-W. D. Paton Interrogatories tories to Consumers January 2,1981 1,10,11,15 and 16 Power Company, January 2, 1981 e i 9 9 e r-+ e v r- - -+ y , ~,. -, v ~ t
. Interroaatory 8 With regard to each item of in?onnation identified in response to Interrogatory 7. state: (a) the identity of the request; (b) whether Con-sumers responded to that request; (c) the ioentity of the communication that the Staff considered Consumers response to the request; (d) whether the Staff considered the response adequate; (e) the identity of the communica-tion by which the Staff communicated its position as to the adequacy or inadequacy of the response; (f) the basis for the Staff's position regarding adequacy or inadequacy of Consumers response; and (g) the Staff personnel responsible for detemining whether Consumers' response was adequate or inadequate. Answer This answer is provided in Table 8-1. Additionally, Table 8-1 includes items of information the Staff requested before December 6, 1979 with regard to acceptance criteria, but for which the initial reply by Consumers had not been submitted as of December 6, 1979. Regarding part (f) of Interrogatory 8, it is not Staff practice to indicate acceptable responses to licensees, except by separate request considered by the Stoff on a case-by-case basis. Such indication of accept- .ince is the function of the Staff's safety evaluation report for those responses which are of significance to that report. The means most fra-quently used by the Staff to communicate its position regarding inadequate responses during the course of the safety review is by issuance of addi-tienal questions on tne same suWect. Such followup requests are listed in Table 8-1.
Parts (d) and (g) of 50.54(f) Request 24 involved review by both geo-technical and hydrologic engineering disciplir.es. The parts of Response 24 indicated to be inadequate were the subject of followup requests or an NRC interrogatory to Consumers identified in column 8(e) of Table 8-1. Inese followup matters provide the basis for the conclusion regarding inadequacy by the Staff. The response to 50.54(f) Request 25 is responsive to our request but is not complete. Consumers does not address the effects of the cracks on the loed combinations, the rationale to the proposed fixes for Category I struc-tures, the modeling to be used in the analyses, the justification for material properties used in the analyses and design and a comparison of the results with suitable acceptance criteria. The response to 50.54(f) Response 26 is inadequate because Consumers has not considered the effects of settlement in its analysis of the Category I structures. Consumers states that the effects of differential settlement on Category I structures utilizing corrective measures are negligible while they propose further investigations for the Diesel Generator Building. We feel that the effects of differential settlement (i.e., cracks, modeling changes, material properties changes) needs to be considered for all Cate-gory I structures founded fully or partially on the fill material. The response to 50.54(f) Response 28 is inadequate because Consumers does not address the concerns identified in our followup requests 25,28 and
- 29. Consumers provides additional infonnation on crack mapping but does not address analytical considerations.
The response to 50.54(f) Response 29 is inadequate because the effects of the cracks have not been satisfactorily included in the analysis. How-ever, Consumers attempted to identify the cracks in these inaccessible areas. The Staff feels that the effect of the structural cracks in the Category I structures should be considered in the re-analysis of these structures. The response to 50.54(f) Response 30 will be adequate if Consumers classifies the duct banks as Category I structures with no requirement for mintaining a pressure boundary for the cables within those ducts. The response to Request 31 was considered to be inadequate for the reasons identified by followup Request 43. With regard to the response to 50.54(f) Request 34, the buckling stresses due to earth loads, vehicular and railroad traffic, are based on unifom soil properties. From the pipe profiles, it is apparent that this is not the case. The responses to 50.54(f) Requests 35 and 37 are inadequate for the reasons stated in A. Schwencer's letter of June 30, 1980 and in " Summary of Appeals Meeting of August 29, 1980 Regarding Additional Explorations and Testing of Midland Plant Fill," February 10, 1981. Items 1 through 8 on an enclosure to a summa ~ of a 1/16/81 meeting are responded to by Consumers answers to Requests 17 and 34. In regard to the response to Request 17, the criteria does not consider the buckling or crippling stresses due to high bending stresses in the large diameter thin wall piping. Also, there was not sufficient infomation as to the total piping involved, the proximity of the non-profiled to the profiled piping,
- the percentage of piping profiled or soil characteristics in the area of concern. Due to the changes in slope of some of the profiled piping, it would appear that soil characteristics vary. Again with regard to 50.54(f) Request 17, the rate of change of slope or the radius of curvature determines the bending stress more than the overall deflection. This request was made on that basis. If a satisfactory allowable stress and strain criteria is presented with an acceptable stress analysis, the criteria for the change in piping curvature would not be requi red. The response to Request 34 was previously discussed. t e i
TABLE 8-1 Identity of Whether
Response
Sta f f's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 24(a) Yes Rev. 6, 4/80 Inadequate 47,48,49 R. Gonzales Rev. 6, 4/80 52 R. Lipinski Reponses to NRC l Requests Regarding Plant Fill 24(b) Yes Responses to NRC Inadequate 42,47,48 R. Gonzales i Requests Regarding 49,50,51, Corps of Engr. Plant Fill 52,53, NRC Interrog-tories 16 to Consumers dated 1/2/81 Rev. 6, 4/80 24(c) Yes Responses to NRC Inadequate 47,49 R. Gonzales Requests Regarding Plant Fill Rev. 6, 4/80 24(d) Yes Responses to NRC Adequate R. Gonzales Requests Regarding Plant Fill w
.~ Table 8-1 Identity of Whether
Response
Staff's follow-up Responsible Request Consumers Identiff ation Consideration Requests Staff Responded Reviewed by of Response or Canmuni-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 24(d) Yes Rev. 5, 2/80 Adequate Corps of Engr.; Responses to NRC J. Kane Requests Regarding Plant Fill i 24(e) Yes Rev. 6, 4/80, Adequate R. Gonzales Responses to NRC d> Requests Regarding 4 "f Plant Fili 24(f) Yes Rev. 6, 4/80, Adequate R. Gonzales Responses to NRC Requests Regarding Plant Fill 24(g) Yes Rev. 6, 4/80, Adequate 36,42,47 R. Gonzales Responses to NRC Requests Regarding Plant Fill 24(g) Yes Rev. 5, 2/80, Inadequate 36,47 Corps of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill 24(h) Yes Rev. 6, 4/80, Adequate R. Gonzales Responses to NRC Requests Regarding Plant Fill i s
Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) ~ 24(i) Yes Rev. 6, 4/80, Adequate R. Gonzales Responses to NRC Requests Regarding Plant Fill 25 Yes Rev. 10, 11/80, Inadequate NRC Interr-F. Rinaldi g Responses to NRC ogatories Requests Regarding 1-9 to a Plant Fill Consumers, 11/26/80 26 Yes Rev. 5, 2/80, Inadequate NRC Interr-F. Rinaldi Responses to NRC ogatories Requests Regarding 1-9 to Plant Fill Consumers, 11/26/80 27 Yes Rev. 5, 2/80, Adequate Corps of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill 28 Yes Rev. 5, 2/80, Inadequate NRC Interr-F. Rinaldi Responses to NRC ogatories Requests Regarding 1-9 to Plant Fill Consumers, 11/26/80
Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) '29 Yes Rev. 5, 2/80, Inadequate NRC Interr-F. Rinaldi Responses to NRC ogatories Requests Regarding 1-9 to Plant Fill Consumers, 11/26/80 e5 30 Yes Rev. 8, 8/80, Adequate F. Rinaldi 7 Responses to NRC Requests Regarding Plant Fill 31 Yes Rev. 5, 2/80, Inadequate 43 Corps. of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill 34 Yes Rev. 5, 2/80, Inadequate A. Cappucci Responses to NRC Requests Regarding Plant Fill 35 Yes Rev. 9, 9/80, Inadequate 37,40 Corps of Engr; Responses to NRC J. Kane Requests Regarding Plant Fill l...
Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 36 Yes Rev. 9, 9/80 Adequate Corps of Engr; Responses to NRC J. Kane Request Regarding Plant Fill 37 Yes Sept. 14, 1980 Inadequate Tedesco letter Corps of Engr; ds. Report - Discussion to Cook J. Kane
- ?
of Applicant's 11/10/80 Position '38 Yes Rev. 9, 9/80 Adequate Corps of Engr; Responses to NRC J. Kane Request Regarding Plant fill 39 Yes Rev. 10, 11/80 Under review To be Corps. of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill 40 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill
Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 41 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC detennined J. Kane Request Regarding Plant Fill 42 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane R Request Regarding Plant Fill 43 Yes Rev. 10, 11/80 Under review To be Corps of Engr; -Responses to NRC determined J. Kane Request Regarding Plant Fill 44 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Iane Request Regarding Plant Fill 45 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC detennined J. Kane Request Regarding Plant Fill 46 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill
-Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 47 Yes Rev. 10, 11/80 Under review To be Corps of Engr; Responses to NRC determined J. Kane Request Regarding Plant Fill 48 Yes Rev. 10, 11/80 Under review To be Corps. of Engr; Responses to NRC determined J. Kane d Request Regarding 7 Plant Fill 49a .Yes Rev. 10, 11/80 Under review Interroga-R. Gonzales Responses to NRC tory 16 to Requests Regarding Consumers Plant Fill dated 1/2/81 49b Yes Rev. 10, 1 U80 Under review Interroga-R. Gonzales Responses to NRC tory 16 to Requests Regarding Consumers Plant Fill dated 1/2/81 49c Yes Rev. 10, 11/80 Under review To be R. Gonales Responses to NRC determined Requests Regarding Plant Fill 50 Yes Rev. 10, 11/80 Adequate R. Gonzales Responses to NRC Requests Regarding Plant Fill
Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) 51 Yes Rev. 10, 11/80 Under review Interroga-R. Gonzales Responses to NRC tory 15 to Requests Regarding Consumers Plant Fill dated 1/2/81 '52 Yes Rev. 10, 11/80 Under review To be R. Gonzales ?! Responses to NRC determined Requests Regarding Plant Fill 53 Yes Rev. 10, 11/80 Under review To be R. Gonzales s Responses to NRC determined Requests Regarding Plant fill Items 1-3 of Yes 17, revision 5; Inadequate Conference A. Cappucci to Callo{I Summary of 9/8/80-1/16/80 34, revision 5 Inadequate Conference A. Cappucci Call o
- meeting, 9/8/80-[j 2/4/80 If W. P. Chen Exhibit 7, Oral Deposition of January 21, 1981.
4 Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration itequests Staff Responded Reviewed by of Response or Communi-Personnel after.12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) Item 4 of No 17, revision 5 Inadequate Conference A. Cappucci Call o 9/8/80-{f to Summary of 1/16/80
- Meeting, 2/4/80 Items 5-8 Yes 17, revision 5 Inadequate Conference A. Cappucci of Enclosure Callo{/
3 to Summary 9/8/80-of 1/16/80
- meeting, 34, revision 5 Inadequate Conference A. Cappucci 2/4/80 Callo{f 9/8/80-NRC Inter-Not yet None Not received None F. Rinaldi rogatories to Consumers 1-9, November 26, 1980 i
NRC Interr-ogatories to Consumers 1/2/81:
Table 8-1 Identity of Whether
Response
Staff's Follow-up Responsible Request Consumers Identification Consideration Requests Staff Responded Reviewed by of Response or Communi-Personnel after 12/6/79 Staff Adequacy cations as of 2/24/81 8(a) 8(b) 8(c) 8(d) 8(e) 8(g) Interr. 1 Not Yet None Not received None A. Cappucci Interr. 10,11 Not Yet None Not received None J. Kane D. Hood Interr. 15,16 Not yet None Not received None R. Gonzales 1 Interrogatory 9 Excluding the infomation provided in response to interrogatory 5, state with particularity each item of information the Staff felt was nec-essary, as of December 6,1979, for Consumers to provide in order for the Staff to have concluded that "the safety issues associated with remedial action taken or planned to be taken by the licensee to correct the soil deficiencies will be resolved." (Order at page 3). Answer As of December 6,1979 the Staff had detemined that, because the Licensee had failed to supply certain acceptance criteria, it could not conclude that the safety issues associated with remedial action taken or planned to be taken to correct the soil deficiencies would be resolved. The Staff had not detemined, as of December 6,1979 "each item of infomation the Staff felt was necessary, as of December 6,1979 for Consumers to provide in order for the Staff to have concluded that the safety issues associated with remedial action taken or planned to be taken by the licensee to correct the soil deficiencies will be resolved' Order at page 3." See also discussion of need for seismological information in answer ti Interrogatory 11. The infomation the Staff felt was necessary, as of December 6,1979 was essentially that identified in answer to Interrogatories 2 and 5, in-cluding Appendix A, relative to acceptance criteria. It shoted be noted, however, that prior to December 6,1979, the full extent of the plant fill settlement problem was unknown and was under review. For example, 50.54(f) Request 12 from H. Denton letter of March 21, 1979 asked for documentation of the condition of the soils under all safety related structures and utili-ties founded on plant fill or natural lacustrine deposits. This same request asked for discussions of measures to be taken if foundation materials are found to be deficient. Consumer's response to Request 12 (initially on April 24, 1979 and subsequently by Revision 1 on May 31,1979, Revision 2 on July 9, 1979, and Revision 3 on September 13,1979) provided information which the Staff found not to be fully responsive and, therefore, unacceptable. The basis for the Staff's conclusion on acceptability is illustrated by the issuance of followup requests wFich seek to have Consumers provide its design and criteria in sufficient detail to enable the Staff to conclude whether there is reasonable assurance of plant safety considering those modifications. An example of this problem is illustrated by the issuance of Requests 41 and 42 by the Staff's letter of August 4,1980 in which the Staff's geotechnical consultant, the U.S. Amy Corps of Engineers, continue to seek basic infomation and data not previously provided in Consumers responses regarding the fixes proposed for the Service Water Intake Struc-ture and the Auxiliary Building which the Staff needs to reach a conclusion on the acceptability of plant repairs. Certain items of information, in addition to tnat provided in response to interrogatories 2 and 5 were probably-felt to be needed by the Staff 4_/ The initial staff reviewer in the Mechanical Engineering Branch (MEB), Mr. R. Stephens, is no longer employed with the NRC. The items identi-fled reflect the opinion or recollection of the subsequent and present MEB Staff reviewed, Mr. A. Cappucci, from earlier personal discussions and notes. It is not known how or whether any of these possible needs may have been conveyed to Consumers. prior to December 6,1979 with respect to underground piping and associated components. The items are that: (a) All the seismic Category I piping be profiled. (b) Remedial action be specified for the case in which stresses due to settlement should approach or exceed Code allowable values. (c) Details as to the calculational methods and assumptions for deter-mining stresses due to settlement and other combined loads be provided for review. (d) Results of the stress analysis of nozzle loads be submitted. (e) A suitable monitoring program be established to monitor future settlement for the life of the plant. (f) Future settlements be included in the planned stress analyses. Interrogatory 10 For each item of infomation set forth in response to interrogatory 9, state (a) whether the Staff had requested Consumers to provide such informa-tion; (b) the identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response to the request; (d) whether Consumers' response was deemed adequate by the Staff; (e) the identity of the communication by which the Staff's evaluation of Consumers' response was communicated to Consumers; (f) the basis for the Staff's position regarding adequacy or inadequacy of Consumers' response; and (g) the Staff personnel responsible for detemining whether Consumers' response was adequate or inadequate. j Answer See answer to Interrogatory 9. Because the infomation the Staff felt was necessary as of December 6,1979 was essentially that identified in answer to Interrogatories 2 and 5, the answer to interrogatory 10 is essen-tially provided by the answers to Interrogatory 6, including Appendix B, and by that part of Interrogatory 8 relevant to indicated Requests 24 through 35. With respect to certain items of infomation (a) through (f) identified in the answer to Interrogatory 9 with respect to underground piping and associated components, the answer to Interrogatory 10 is provided by Table 10-1. The answer to Interrogatory 10(f) follows. (a) The criteria for selection of the piping to be profiled appears to be based on the soils in the same proximity as being homogeneous. There appears to be insufficient evidence that this is the case. (b) The response to 50.S4(f) Request 17 stated that the stresses due to settlement would be well below the code allowable values as indicated in Table 17-2 of that response. Therefore, it was indi-cated that remedial action was not planned by Consumers. This is not adequate because (1) not all seismic Category 1 piping was profiled, (2) future settlements had not been predicted, and (3) the results of the surcharge program had not been established. (e) The response to 50.54(f) Request 18 in July 1979 indicated no plans for a monitoring program if the settlements remain within the predicted range. It was not clear as to the time frame and methods for verifying the predicted ranges. (f) The response to 50.54(f) Request 17 provided no infomation on settlements over plant lifetime. The response to 50.54(f) Request i 18 was adequate. The response to 50.54(f) Request 19 provided no information as to the predicted deformations. Interrogatory 11 Excluding the infomation provided in response to interrogatory 7, state with particularity each iten of information the Staff feels, as of the date of answering this interrogatory, is necessary for Consumers to provide in order for the Staff to conclude that "the safety issues associated with remedial action t* ken or planned to be taken by the licensee to correct the soil deficiencies will be re 31ved." (Order at page 3.) Answer The Staff has not completed its review of infomation submitted by Licensee relative to the propsed remedial actions. It is therefore impossi-ble to delineate "with particularity each item of infomation the Staff feels, as of the date of answering this interrogatory, is necessary for Consumers to provide in order for the Staff to conclude that 'the safety issues associated with remedial action taken or planned be taken by the licensee to correct the soil deficiencies will be resolved.' (Orderat page 3.)" t
TABLE 10-1 Item from - Whether Staff Identity of
Response
Staff's Con-How Position Responsible i Interr. Requested Request Identification sideration of ' Conveyed to Staff 9 Information 10(b) 10(c)
Response
Consumers Personnel 10(a) Adequacy 10(e) (10(g) 10(d) 9(a) Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17, quest 17, Rev. A. Cappucci Denton 3/21/79 '>. 7/79, Res-ponses to NRC Requests Re-garding Plant Fill 9(b) Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17 quest 17, Rev. A. ,g Denton 3/21/79 2, 7/79, Respon-ses to NRC Re-quests Regard-ing Plant Fill 9(b) Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17 quest 17, Rev. A. Cappucci Denton 3/21/79 2, 7/79, Respon-ses to NRC Re-quests Regard-ing Plant Fill 9(c) No Hone None Not applicable Not applic-R. Stephens A. Cappucci 9(d) No None None Not applicable Not applic-R. Stephens able A. Cappticci
TABLE 10-1 Item from Whether Staff Identity of
Response
Staff's Con-How Position Responsible Interr. Requested Request Identification sideration of Conveyed to Staff 9 Information 10(b) 10(c)
Response
Consumers Personnel 10(e) (10(g) 10(a) 6 Adequacy) 10(d 9(e) Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 18 quest 18, Rev. A. Cappucci 2, 7/79, Responses to NRC Requests Regarding Plant Fill i 9(f' Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Requests 17, quests 17, 18 A. Cappucci ). 18 and 19 and 19, Rev. 2, T 7/79, Responses to NRC Requests Re-garding Plant Fill i I 4
. To illustrate this inability, consider two recent occurrences: (1) On January 21, 1981, Consumers submitted a potentially reportable 50.55(e) report advising of an error in the 1977 computer model usea for the seismic analyses of the Control Tower and the main portion of the Auxiliary Building. Pending further analysis by Consumers, it is not possible for the NRC to assess the ability of the Control Tower to assume the additional load result-ing from the bridged support scheme proposed for the Electrical Penetration Area; (2) Consumers has also indicated that additional cracking of the concrete ring base of the Borated W3tr.r Storage Tank has occurred during the full scale load test. The Staff is presently awaiting Consumers' assessment of this occurrence. It should also be noted that resolution of the matter of establishing appropriate seismolt? cal input, as discussed in the Staff's i le eter of October-14,1980 and in a December 22,1980 " Summary of December 5, 1980 Meeting on Seismic Input Parameters," is deemed to be relevant to the staff conclusion that the safety issues associated with remedial action taken or planned will be resolved. l The infomation needed by the staff for its review of the remedial actions is essentially that identified in response to interrogatories 2, 6, 7 and 8, plus Appendices A and B, with respect to acceptance criteria for those response items indicated to be inadequate. In Table 6-1 and Aoppendix A, the indication of response adequacy by the staff is with respect to December 6, 1979. However, the present staff. position may be ascertained from the indicated disposition of the associated follow-up questions. The occurrences and seismic matter discussed in Interrogatory 11 also needs to be satisfactorily resolved. L
. With regard to underground piping, and excluding the infomation needed from interrogatory 7, the following infomation is needed: (a) A final stress analysis of the seismic Category I piping. (b) An explanation for some of the relatively rapid changes in sone of the piping profiles and the magnitude of the loads which cause these changes. (c) The actual and predicted clearances at end of plant life of seisnic Category I piping at building penetrations. (d) The loads and stresses on the piping at their temination points (anchors, equipment,largerpipe,etc.). (e) From the Jant:3ry 20 1981 meeting, provide method and basis for nomalizing the profile data prior to perfoming the stress analysis and use of 3-inch future settlement data. If a non-linear analysis is to be performed, provide the analysis methodology with a summary of the resul ts. Include a presentation of the rargin to the Code allowable value for settlement only and the same for the margin to failure considering all primary and secondary stresses. Interrogatory 12 For each item of infomation set forth in response to interrogatory 11 -state: (a) whether the Staff had requested Consumers to provide such infor-mation; (b) the identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response; (d) whether Consumers' response was deemed adequate by the Sttff; (e) the identity of the communication by which the Staff's evaluation of Consumers'
i TABLE 12-1 TABLE L2-1 Interr. 11 Whether Staff Request
Response
Adequacy How Disp. Responsible item Requested Identi fi-Identi ty Disposition Communi-Staff Consumers cation 12(c) 12(d) cated to Personnel 12(a) 12(b) Consumers (12(f) (12(e) lla Yes-Tedesco Cook letter Inadequate Conference A. Cappucci letter-11/14/80 with call 1/14/81 J. Brammer 10/20/80 encl. 11 b,c & d -Yes Meeting of No response No response No response A. Cappucci 1/20/81 J. Brammer 11e 'In progress Not Abplice* le None Not appl. Not app. A. Cappucci a J. Brammer 1 4 e
. response was communicated to Consumers; (f) the basis for the Staff's posi-tion regarding adequacy or inadequacy of Consumers' response; and (g) the Staff personnel responsible for detennining whether Consumers' response was adequate or inadequate. Answer See answer to Interrogatory 11. With respect to the infonnation needed with respect to underground piping, see Table 12-1. With respect to the adequacy of item lla on Table 12-1, the Bechtel stress analysis appeared to be unconservative and did not give a true repre-santation of the actual stress in piping. There were questions as to which profiles were used and the justification f 3r the boundary conditions assumed. An ETEC stress analysis demonstrated much higher stresses than those in the Bechtel report. At the 1/20/81 meeting Bechtel stated that subsequent analyses had shown higher stresses for some lines. Interrogatories 13 through 16. See separate objections filed by the Staff. Interrogatory 17 Explain and provide the basis for the statement at page 2 of the Order that "This statement is material in that this portfor. 'f the FSAR would have been found unacceptable without further Staff analysis and qui.stions if the Staff had known that Category I structures had been placed in fact on random fill. rather than controlled compacted cohesive fill as stated in the FSAR." Answer Infomation submitted as part of an application for licenses in accord-ance with 10 CFR 50.30 is " material" i' that infomation would or could have an influence upon a safety conclusion of the NRR Staff. A material statement which is false is of concern if it could have resulted in an improper finding or a less probing analysis by the NRR Staff. As described on page 2 and Appendix B of the Order, hac the NRR Staff relied upon the statement in FSAR Section 2.5.4.5.3 which states that "all fill and backfill were placed according to Table 2.5-9", it would or could have erroneously concluded that the fills and backfill placed for the support of structures and the Diesel Generator Building consisted of " clay" (Table 2.5-9 under " Soil Types") or " Controlled compacted cohesive fill" (Table 2.5-14 under " Supporting Soils") which had been compacted, as a minimum, to 95% of LTM D 1557-66 T modified to get 20,000 foot-pounds of compactive energy per cubic foot of soil (see Table 2.5-9 under " Compaction Criteria"). The reality of the situation is that the fills and backfills beneath the structures and the Diesel Generator Building are not " clay" or a " controlled compacted cohesive fill", but consist of a heterogeneous mixture of sand, clay, silt and lean concrete, and the minimum compaction criteria implied as having been achieved by the quoted statement from FSAR Section 2.5.4.5.3 was not achieved. Therefore, a t conclusion by the Staff that the fills and backfills were of a different type or had been enmpacted to known minimum standards would have been erro-neous and woul6 or could contribute to or preclude a more probing analysis or further questioning. Based upon the FSAR infomation, the Staff would or could have concluded that the structure was adequately supported, that it l
4 _ 47 would not experience detrimental settlement, that its foundations would remain stable under both static and earthquake loading, and that the fill properties would be at least equal to design values provided in the PSAR. The Staff's conclusion would have been relevant to the NRC findings pursuant to 10 CFR 50.57 (3) for issuance of operating licenses and would have con-tributed to a finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public. Darl Hood, being duly sworn, states that to the best of his knowledge and belief the above information and the answers to the above interroga-tories are true and correct. Darl Hood Subscribed and sworn to before me this 25 day of February,1981. ft I& (L)?.At / No pry Public My. Commission Expires: r: . T. cc a t 7, g..... - - -
- c.,.. g o te,y C n:.: ;. ::-(;:: h.y 1,1932 l
l l l
f UNITED STATES OF AMERICA ~ NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING E0ARD In the Matter of ) ) 09::SUMERS POWER CO:1?A"Y ) Dec'<et Nos. 50-329-0M & OL ) 50-330-0M & OL (Midland Plant, Units 1 and 2) ) CERTIFICATE OF SERVICE I hereby certify that copies ;f NRC STAFF'S ANSWERS TO INTERR0GATORIES FILED BY CONSUMERS 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, through deposit in the Nuclear Regulatory Commission's internal mail system, this 25th day of February,1981.
- Charles Bechhoefer, Esq.-
Ms. Mary Sinclair Atomic Safety and Licensing Board 5711 Summerset Street U. S. Nuclear Regulatory Commission Midland, Michigan 48640 Washington, D.C. 20555 =Mr. Gustave A. Linenberger Michael I. Mill'r, Esq. Atomic Safety and Licensing Board Ronald G. Zamaria, Esq. U. S. Nuclear Regulatory Commission Alan S. Farnell, Esq. Washington, D.C. 20555 Isham, Lincoln & Beale One First National Plaza Dr.. Frederick P. Cowan 42nd Floor 6152 N.. Verde Trail Chicago, Illinois 60603 Apt. B-125 Boca Raton, Florida 33433
- Atomic Safety and Licensing Board Panel Frank J. Kelley U. S. Nuclear Regulatory Commission Attorney General of the State Washington, D.C.
20555 of Michigan Steward H.. Freeman
- Atomic Safety'and Licensing Assistant Attorney General Appeal Board Panel-Gregory T. Taylor U. S. Nuclear Regulatory Commission 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 Commission
~ i'yron M. Cherry, Esq. Washington, D.C. 20555 1 IBM Plaza Chicago, Illinois ~60611
James E. Brunner, Esq. Jeann Linsley Consumers Power Company Bay City Times 212 West Michigan Avenue 311 Fifth Street Jackson, Michigan 49201 Bay City, Michigan 48706 I4. Barbara Stamiris 5/95 N. River Freeland, Michigan 48623 Mr. Steve Gadler 2120 Carter Avenue S t._ Paul, Minnesota 55108 Mendell H. Marshall, Vice President Midwest Environmental Protection Associates RFD 10 MiJland, l'ichigan 4S640 h c.es R. Kates 203 S. Washington Avenue Saginaw, Michigan 48605 '( ) Wi11ioni D. Paton Counsel for NRC Staff}}