ML20005B412

Reply to B Stamiris Answers to Util Interrogatories Re Contention 2 on Soil Settlement Issues.Certificate of Svc & Affidavit Encl

ML20005B412
Person / Time
Site:	Midland
Issue date:	06/30/1981
From:	Peck R BECHTEL CIVIL & MINERALS, INC. (SUBS. OF BECHTEL, BECHTEL GROUP, INC.
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8107080195
Download: ML20005B412 (8)

Text

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STAMIRIS ANSWERS TO CONSUMERS POWER INTERROGATORIES ON CONTENTION 2 2A. Turther examples of the effect of financial and time pressures on soil settlement issues:* Table A 2A. Example

1. 11/7/78 Bechtel action item: " proceed with preparations for preload as rapidly as possible" 2B. Effect on soil settlement issues

1. Root causes not adeq. investigated, organizational deficiencies not eliminated prior to proceeding with remediation Dr. Peck's Response It is noted that the quoted statement deals with " preparations for preload," not the actual institution of the preload. Moreover, since it was obvious that the fill was settling progressively under its own weight and was known to contain clay which would cause a progressive settlement, no i

further information was needed regarding " root causes" to conclude that surcharging would be appropriate. The surcharge f

could be acting and producing its beneficial affects while organizational deficiencies, if any, were being remedied.

i 2A. Example

2. 11/7/78 decision to fill pond "immediately, because the amount of river water available for filling is restricted" t

• Contention 2 reads: " Consumers Power Company's financial and time schedule pressures have directly and adversely affected resolution of soil settlement issues, which constitutes a compromise of applicable health and safety regulations as demonstrated by:"

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2B. Effect on soil settlement issues

2. Affected piezometric measurements during preload Dr. Peck's Response In order to avoid the complexities in measurement that would be introduced by pore-air pressures if the plant fill were to contain large amounts of air, Dr. Hendron and I concurred in the desirability of allowing the pond level to rise so that the tips of the piezometers and their surrounding capsules of sand would be below groundwater level. The effect of the presence of air would thus be minimized.

If groundwater level beneath the Diesel Generator Building could have been held at a constant high level throughout the surcharge process, constant base conditions for interpretation of excess pore pressures would have existed. However, it was not possible to raise the pond quickly to a maximum elevation and maintain it at that maximum level, and there was no evidence that, even if this were done, the groundwater levels beneath the Diesel Generator Building would necessarily reach a stable elevation. It was my opinion that the best course of action, taking into account these considerations, was to allow the pond level to rise as rapidly as possible and to proceed with the surcharging.

Furthermore, filling the pond had a beneficial effect on the piezometric measurements, in that submergence of the piezometer tips permitted the use of reliable standpipe-type piezometers without introducing excessive time lags.

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Finally, addition, since at this early stage of investigation the hypothesis was still being entertained that the clays might be dry of optimum, it was considered desirable to submerge as much of the clay as possible. The implications of these decisions in the light of the observed behavior are considered subsequently in my testimony concerning the Diesel Generator Building preload.

2A. Example

3. 11/7/78 "5 month period is available in the schedule for preloading"

3. Effect on soil settlement issues The surcharge was removed at the end of thi7 5 months despite lack of NRC satisfaction that secondary consolidation was assured Dr. Peck's Response I approved removal of the surcharge on August 15, 1979 because both settlement and piezometric data conclusively demonstrated completion of primary consolidation. The timing of this approval was unrelated to any predetermined duration.

The NRC had no logical technical basis for believing secondary consolidation had not been achieved.

2A. Example

11. Depth and breadth of surcharge limited by practical consideration of DGB, Turbine B. structures

11. Effect on soil settlement issues Afforded less than otpimum conditions for surcharge Dr. Peck's Response Quite properly, when surcharging was being considered, a review of available space was made to determine whether there was sufficient .ea to place a surcharge fill needed to achieve the necessary stress levels in the subsoil.

• Adequate area and vertical space were available to obtain needed surcharge stresses, except adjacent to the Turbine Building. There a retaining system was constructed to permit placement of enough surcharge to achieve the needed stress levels. Thus conditions were fully sufficient for successful surcharge.

• r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

)

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

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

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

)

STATE OF ILLINOIS)

) SS.

COUNTY OF COOK )

AFFIDAVIT OF RALPH B. PECK I am Ralph B. Peck. I am presently consultant to Bechtel with regard to certain geotechnical aspects of the Midland Project site. Based upon knowledge, information and belief the attached testimony is true and correct.

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l Ah Ralph S. Peck SUBSCRIBED AND SWORN TO BEFORE ME THIS 30TH DAY OF JpNE, 1981.

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My Commission Expires: / Mr.* .!

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This is a portion of the testimony of Ralph B. Peck.

I reside at 1101 Warm Sands Drive SE, Albuquerque, New Mexico.

I graduated from Rensselear Polytechnic Institute in 1934 with the degree of Civil Engineer and in 1937 received the degree of Doctor of Civil Engineering with a major in Structures. From April 1938 to January 1939 I attended the Graduate School of Engineering, Harvard University, where I attended the courses in Soil Mechanics and Foundation Engineering and served as a laboratory assistant to Professor Arthur Casagrande.

I am a registered Structural Engineer in the State of Illinois and was a member of the Illinois Structural Engineering Examining Board from 1959 to 1969. I am re-gistered as a Professional Engineer in Illinois and Hawaii, and as a Civil Engineer in California'. My detailed experience record will be attached to my testimony concerning the diesel generator building preload.

I am a consultant to Bechtel with regard to certain geotechnical aspects of the Midland Project site. I have been associated with the Midland plant from September 28, 1978 to date.

The purpose of this testimony is to address certain These contentions and m N contentions of Barbara Stamiris. t response follow. ,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

)

In the Matter of )

)

CONSUMERS POWER COMPANY ) Docket Nos. 50-329-OM

) 50-330-OM (Midland Plant, Units 1 and 2) ) 50-329-OL

) 50-330-OL

)

CERTIFICATE OF SERVICE I, Alan S. Farnell, hereby certify that a copy of the testimony of Ralph B. Peck dealing with certain Stamiris contentions was served upon all persons shown in the attached service list by deposit in the United States mail, first class, this 30th day of June, 1981.

CL 4. M Y Alan S. Farnell I

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v SERVICE LIST Frank J. Kelley, Esq. Steve Galdler, Esq.

Attorney General of the 2120 carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq.

Assistant Attorney General Atomic Safety & Licensing Appeal Pnl.

Environmental Protection Div. U.S. Nuclear Regulatory Commission 720 Law Building Washington, D.C. 20555 Lansing, Michigan 48913 Mr. C. R. Stephens Myron M. Cherry, Esq. Chief, Docketing & Service Section One IBM Plaza Office of the Secretary Suite 4501 U.S. Nuclear Regulatory Commission Chicago, Illinois 60611 Washington, D.C. 20555 Mr. Wendell H. Marshall Ms. Mary Sinclair RFD 10 5711 Summerset Street Midland, Michigan 48640 Midland, Michigan 48640 Charles Bechhoefer, Esq. William D. Paton, Esq.

Atomic Safety & Licensing Bd. Pnl. Counsel for the NRC Staff U.S. Nuclear Regulatory Com. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Frederick P. Cowan Atomic Safety & Licensing Bd. Panel 6152 N. Verde Trail U.S. Nuclear Regulatory Commission Apt. B-125 Washington, D.C. 20555 Boca Raton, Florida 33433 Barbara Stamiris Admin. Judge Ralph S. Decker 5795 North River Road Route No. 4, box 190D Route 3 Cambridge, Maryland 21613 Freeland, Michigan 48623 Carroll E. Mahaney Babcock & Wilcox P. O. Box 1260 Lynchburg, Virginia 24505 James E. Brunner, Esq.

Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201

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