ML20010D120

Response to Porter County Chapter Intervenors' Third Set of Interrogatories.Related Correspondence

ML20010D120
Person / Time
Site:	Bailly
Issue date:	08/18/1981
From:	Bohn R NORTHERN INDIANA PUBLIC SERVICE CO.
To:	PORTER COUNTY CHAPTER INTERVENORS
References
NUDOCS 8108240029
Download: ML20010D120 (57)

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UNITED STATES OF CUlmh5PONDENrm AMERICA D(s j NUCLEAR REGULATORY COMMISSION s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD AUG 201981 >

Oina CIth3S W l#l C 9 D;;k;tBI& sed;0 Y

In the Matter of ) ~'

) Docket No. 50-367 Y O /

NORTHERN INDIANA PUBLIC ) gs SERVICE COMPANY ) (Construction Permit \ h "'.

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(Bailly Generating Station, ) g \

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Nuclear-1) ) August 18, 1981 7 B> gf ,1goS; ,

Q d' 3 NORTHERN INDIANA PUBLIC SERVICE COMPANY'S RESPONS l,O'x Ol,f PORTER COUNTY CHAPTER INTERVENORS' THIRD SET OF INTERROG TORIES # ' '

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For answer to Porter County Chapter Intervenors' (PCCI)

'Ihird Set of Interrogatories, Northern Indiana Public Service Company (NIPSCO) states as follows:

1. Please state the present elevation of the lowest point of the Bailly excavation, expressing such elevation in terms of both true elevation and station elevation.

ANSWER: The present elevation of the lowest point of the Bailly excavation is approximately plus 8 feet station datum.

NIPSCO does not understand the term "true elevation".

2. Has there ever been any dewatering (including any diversion

of groundwater by drains or pumps of any kind) at the fossil fuel generating plants at the Bailly Generating Station site?

If your answer is yes, please state:

(a) The date (t ) such dewatering commenced; 03 b

(b) The date(s) such dewatering terminated; (c) The volume of water removed; /

, (d) The present rate of dewatering; and

, 8108240029 810818

'DR ADOCK 05000367 G PDR

(e) The purpose of the dewatering.

ANSWER: Yes, dewatering has occurred at the fossil fuel generating stations at the Bailly site. For the purposes of this response, NIPSCO interprets " fossil fuel generating station" to mean the main building housing the boiler and turbines for Units 7 & 8.

(a) NIPSCO does not know the precise date that construction dewatering for Unit 7 commenced however it was sometime in 1960. Unit 8 construction dewatering began in October 1965. Dewatering for construction of the Unit 7 miscellaneous sump began in January 1977. The gravity drains installed around the foundations of Units 7 & 8 became oper-ational when the backfilling operations reached an elevation such that groundwater levels rose above the drains which was approximately one year after commencement of construction devatering.

t (b) NIPSCO does not know the date that construction dewatering for either Units 7 or 8 was terminated.

l Dewatering for the Unit 7 miscellaneous sump was completed in August 1977. The gravity drains are still in service.

(c) NIPSCO does not know what volume of water was removed during the construction of Units 7 & 8 or during the operation of the gravity drain.

The dewatering system for the Unit 7 miscellaneous sump removed 80,776,800 gallons.

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-2A-(d) The present rate of dewatering for the Unit 7, Unit 8 and Unit 7 miscellaneous sump construction is zero. NIPSCO does not know the present rate of dewatering of the gravity drains.

(e) The Unit 7, Unit 8 and Unit 7 miscellaneous sump construction dewatering systems were installed and operated to maintain a dry excavation in which construction could proceed. The gravity drains were installed to prevent seepage of groundwater into Units 7 & 8.

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3. (a) Please state all assumptions concerning the status of NIPSCO's fly ash ponds which you contend were included in each of the following:

(i) " Soil Parameters Used in USGS Report 78-138,"

D'Appolonia Consulting Engineers, May 1980; (ii) " Assessment of the Influence of Dewatering at Bailly N-1," D'Appolonia Consulting Engineers, November 1980; (iii) " Effects of Seepage from Fly-Ash Settling Ponds and Constrt!ction Dewatering on Ground-Water Levels in the Cowles Unit, Indiana Dunes National Lakeshore," Indiana, USGS78-138, January 1979.

(iv) " Reassessment of the Effects of Construction Dewatering on Ground-Water Levels in the Cowles Unit, Indiana Dunes National Lakeshore, Indiana," USGS 80-1105, September 1980; and (v) The decision of the Atomic Safety and Licensing Board authorizing issuance of the construction permit for Bailly N-1.

(b) Please provide the bases for each of the responses to Interrogatories 3(a) (i) through 3 (a) (v) .

ANSWER: NIPSCO makes no contentions regarding accumptions contained in the identified reports. However, the assumptions regarding the fly ash ponds which were utilized in preparation of the identified reports are as follows:

(a) (i) In preparation of the May, 1980 D'Appolonia report, groundwatcr drawdown estimates were based on *he assumption of the Bailly N-1 1

1 dewatering and depressurization programs as the only source of drawdown.

(ii) As the title of the November, 1980 D'Appolonia report .mplies, the sole source of drawdown considered in this report was ' he Bailly N-1 dewatering and depressurization programs.

It was assumed that lining of the settling bacins would be completed and thus that the basins would have no further effects on the groundwater regime.

(iii) Tne studies discussed in this report assume ,

that either the settling basins are not sealed or the basins have been sealed and the ground-water mound is declining.

(iv) The studies discussed in this report assume that the ash ponds are sealed and that the groundwater mound is declining.

(v) The Atomic Safety and Licensing Board in its Initial Dccision for the Construction i Permit Hearing relied on calculations which 1

ignored the effects of the ash ponds on ground-water levels. However, the Board did note that ash pond seepage was likely to offset the effects of construction dewatering to i some extent.

(b) The basis of NIPSCO's assumptions concerning the

status of NIPSCO's fly ash ponds are contained i

in the following documents:

For 3 (a) (i) and (ii)

Agreement between the Department of Interior and Northern Indiana Public Service Company signed I by NIPSCO on February 24, 1978.

For 3 (a) (iii)

Report 78-138 " Effects of Seepage from Fly-Ash Settling Ponds and Construction Dewatering on Ground-Water Levels in the Cowles Unit, Indiana l

Dunes National Lakeshore, Indiana," dated January 1979 and prepared by the USGS (Pages 58 to 85).

For 3 (a) (iv)

Report 80-1105 " Reassessment of the Effects of Construction Dewatering on Ground-Water Levels in the Cowles Unit, Indiana Dunes National Lakeshore, Indiana" prepared by the USGS (pages 17 to 48).

For 3 (a) (v)

Initial Decision before the Atomic Safety and Licensing Board in the matter of North ( n Indiana Public Service Company (Bailly Generating Station Nuclear 1) (Page 75).

4. Please describe in detail each injection point for NIPSCO's proposed dewatering mitigation system.

ANSWER: A description of NIPSCO's proposed dewatering mitigation system for the unconfined aquifer is contained on Pages 12-14 of Sargent & Lundy Report "Hydrogeologic Evaluation of Construction Dewatering, Bailly Generating Station, Nuclear-1", March 30, 1978 and in a July 20, 1978 letter from Mr. R. J. Bohn of NIPSCO to Mr. Ronald L. Ballard of the NRC responding to NRC questions regarding the above report. Both of these documents have been provided to PCCI in response to its second document request.

The mitigation system for the confined aquifer has not yet been designed and, therefore, a description of the injection points is not available.

5. Please state the proposed flow rate or rates for the replacement water of NIPSCO's proposed dewatering mitigation plan.

ANSWER: Flow rates for the dewatering mitigation system will vary as required to prevent significant drawdown of ground-water levels beyond the NIPSCO/ National Park Service property line. These specific rates will be determined during system i

operation depending on need and cannot be specified now.

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6. In " Northern Indiana Public Service Company's Response to th6 People of the State of Illinois' First Set of Interrogatories to NIPSCO" filed July 8, 1981, in response to Interrogatory 8 (a),

you stated that "[olther localized dewatering will be required for short periods of time in small areas, e.g., for installation of the pump house." For each instance of such " localized dewatering" please:

(a) Identify each location at which such dewatering will take place; (b) For each such location, state the depth of such j dewatering, expressing the depth in both station elevation and true elevation; (c) State what amount of water will be removed for such instance of dewatering; (d) State the purpose of such dewatering; (e) State the length and rate of such dewatering; (f) For ea ._cance of dewatering, state the effect at each of the points, numbered "1" through "10" with circles around the numbers, on the map attached hereto and marked " Attachment I."

" Attachment I" is " Figure 2 - Plan Borings and Piezo.neters -

Bailly Generating Station Nuclear 1" from " Assessment of the Influence of Dewatering at Bailly N-1" (D'Appolonia, November 1980), filed November 20, 1980.

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l ANSWER:

(a) Localized dewatering will be required for construction of the Essential Service Water Pumphouse, the essential service water pipeline, the circulating water pipeline, the drain line to existing Unit 7& 8 circulating water discharge, the Circulating Water Pumphouse, the tendon tunnel, the Reactor

, Building, the Radwaste Bu'lding Eleva:or pit and seven sumps located within the main building.

(b) NIPSCO does not understand the meaning of the 1

term "true elevetion". However, the elevation of the bottom of the excavation for each item listed in (a) above is provided in terms of the

" station elevation". The depth of dewatering will be approximately 2 feet 5elow the elevations listed.

(i) Essential Service Water Pumphouse: -29' l

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(ii) Essential service water pipeline

Varies from -30" to +29' (iii) Circulating water pipeline: Varies from

-5' to +21' (iv) Drain line to Unit 7 & 8 circulating water discharge: varies from +1' to +10' (v) Circulating Water Pumphouse: varies from

+13' to +20' (vi) Tendon tunnel: -19'

(vii) Reactor Building: -6' (viii) Radwaste Building elevator pit: -6' (ix) Turbine Building Fire Sump: -5' (x) Off-Gas Building Sumps: -6' (xi) Reactor Building H.P.C.S. Pump Casir.g: -10' (xii) Tendon Tunnel Sump: -22' (xiii) Service Building Petipheral Sump: -10' (xiv) Radwaste Building Sumps: -7' (xv) Radwaste Building Sumps: -8' (c) The amount of water which will be removed for each of the above instances of dewatering is not known at this time.

(d) In all cases dewatering is intended to provide a dry excavation in which construction may proceed.

(e) In all cases dewatering will be seguired until work on that p9rticclar item has reached the point where the excavation has been backfilled to ap-proximately 2 feet above the groundwater level.

The rate of dewatering is unknown at this time.

(f) For purposes of answering this Interrogatory, -

IiPSCO assumes that each point shown on " Attachment I" to PCCI's Third Set ;f Interrogatories is as shown below:

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PCCI Point Number Location 1 NIPSCO Well Number 16 2 (N 1,508,500 E 490,000)

NIPSCO/IDNL Property Lin* within Pond 1 3 USGS Well D 1A 4 '

(N 1,508,600 E 491,300)

Northwest end of Pond 2 5 (N 1,508,500 E 493,100)

West end of Pond 7 6 (N 1,508,100 E 4'i,100)

NIPSCO/IDNL Property Line at the north end of P'PSCO's dike 7 USGS hell GM-38 8 (N 1,509,500 E 497,800)

North central edge of Cowles Bog 9 (N 1,508,500 E 499,100)

Mineral Springs Road 10 (N 1,507,800 E 494,200)

In all instances cited above, the lacalized dewatering activity will have no effect on any of the points numbered 1 through 10 on " Attachment I" to these Interrogatories.

7. In " Northern Indiana Public Service Company's Response to the People of the State of Illinois' First Set of Interrogatories

to NIPSCO" filed July 8, 1981, in response to Interrogatory 8 (a) you state "[g]eneral consttuction dewatering is now being conducted and will be required for the period of time necessary to bring the facility foundationc to grade level. This is estimated to

{ be between 18 and ~ 0 mor.ths af ter construction resumes." Please i

state the bases for your estimation that it will take 18 to 30 months to bring the facility foundations to grade level.

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ANSWER: C. F. Braun's Cetailed Master Schedule, Revised 2/22/80, indicates that the foundation mats for the Reactor Building, Radwaste Building and Off-Gas Building will be completed approxi-mately 17 months after resumption of construction. Shortly after completion of these basemats it is expected that the depressuriza-tic, system for the confined aquifer could be rhut off, thus resulting in the 18-month estimate of the earliest time that a por tion of the dewatering system would be shutdown. The above schedule also indicates that backfill to grade v'11 be completed 28 months after resumption of construction, at which time it is expected that the ba!snce of the dewatering system could be shut off. Allowing a two month contingency for potential delays in the NRC's review of the piling installation prior to allowing concrete to be poured resulted in the 30 month estimate of the latest time by which dewatering should be completed.

8. Please provide all calculations upon which your responses to Interrogatories 13 (a) (1) through 13 (a) (4) of People of the State of Illinoin' First Set of Interrogatories to NIPSCO are based.

j ANSWER. For the unconfined 3quifer, NIPSCO's response was based on the proposed dewatering mitigation program preventing any significant off-site effects of dewatering the unconfined aquifer. Thus, no calculations were required. For the confined aquifer, NIPSCO relied on the calculations described in D'Appolonia I

Report " Assessment of the Influence of Dewatering at Bailly N-1,"

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i November, 1980 at pages 34-35, which has been provided in response .

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{ to PCCI's second request fer production of documents. .

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i j 9. Please describe in detail each item of expense presently

! being incurred by NIPSCO with reference to the Bailly project, giving a description of each item of expense, and the amount incurred for each item of expense during each month for the past six months.

ANSWER: Objected to.

i j 10. Please identify each person presently on NIPSCO's nuclear staff, and state a description of that person's professional qualifications.

ANSWER: Objected to.

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11. Please describe in detail all changes, refinements or revisions, s.ince the date of issuance of the Bailly construction i

permit, to the plans or specifications for any of the following l components of the proposed Bailly plant:

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l (a) Containment vessel i

(b) Turbine room building (c) Radwaste building (d) Service building (e) Cooling tower (f) Piping between any of the above buildings or structures ANSWER: Objected to.

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12. In " Northern Indiana Public Service Company's Response to Porter County Chapter Intervenors' First Set of Interrogatorier, "

1 filed April 8, 1981, in response to Interro'atory 8, you attached i

a table described as " Table I - NIPSCO LOAD A.'D CAPABILITY DATE."[ sic]

In that table, you described " Purchase Power - MW" for the years 1980 through 1994. For each such year, please state:

(a) Whether the amounts shown in Table I u.e the

maximum amount of power that can be purchased under the terms of the purchase power agreements; (b) Whether you are obligated to purchase that amount, or whether your purchase is optional; (c) If a purchase is obligatory, the number of megawatts which you are obligated to piirchase.

ANSWER:

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(a) Yes, except for the 100 MW value shown for the year 1988 which has not yet been secured by contract.

(b) NIPSCO is obligated to purchase power from three sources in the amcants shown below:

I&M Contract Expires Year December 31, 1987 PSI WVPA l

1980 400 MW 1981 400 "

1982 400 "

l 1983 400 "

l 1984 400 "

i 1982 400 " " Note 1" 1986 400 "

, 1987 400 " 113 MW " Note 2" 113 MW " Note 3" l 1988 226 "

1989 226 "

1990 226 "

1991 226 "

l 1992 226 "

1993 226 "

1994 226 "

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" Note 1" -Upon 48 months notification NIPSCO has the option to reduce the amount of power received to not less than 200 MW. No such notice has been given. The I&M contract expires on December 31, 1987.

" Note 2" 10% of Marble Hill Unit 1 from date of commercial operation (Late 1986) through September 30, 1987.

" Note 3" -10% of Marble Hill Unit 1 from date of commercial operation (Late 1986) and 10% of Marble Hill Unit 2 from date of commercial operation (Late 1987).

(c) See response in 12(b).

13. In footnote (1) of " Table I" referred to in Interrogatory 12, you refer to a "156 MW derating of generating capacity in 1979." Please state the reason for such derating and identify the unit (s) derated.

ANSWER: Adjustments to the Northern Indiana Public Service Company generation capability were made to more accurately reflect the capability actually available to serve the system load under operating conditions. The Units which have been deratad are:

Michigan City Units 2 and 3, Mitchell Units 4, 5, 6 nnd 11 and Bailly Units 7 and 8.

14. PlrSse explain the reason for each action or situation described in footnote (7) of " Table I" referred to in Interrogatory 12.

ANSWER:

l (a) Includes 113 MW from WVPA of MH 2:

Marble Hill Unit #2 is scheduled for commercial operation in late 1987. By contractual arrangement

with WVPA, NIPSCO will be receiving as purchase and imported power 113 MW of the WVPA portion of Marble Hill #2.

(b) Termination of PSI power from MH1 on 9/30/87:

Marble Hill Unit #1 is scheduled for comn.ercial operation in late 1986. Py contractual arrangement with 73I, NIPSCO will be purchasing 113 MW of the PSI portion of Marble Hill #1 from its commercial date of operation until 9/30/87.

(c) End of Firm purchase:

Effective January 1, 1978, NIPSCO is purchasing 400 MW of Firm power from I&M. This contract s

expires recember 31, 1987.

(d) 100 MW purchase power during 1988:

4 This 100 MW in 1988 is required to maintain our minimum reserve margin but has not been secured by contract.

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15. Does NIPSCO have any plans, stand-by, tentative or

, otherwise; to reduce future peak electrical demand? If your answer is yes, please describe such plans in detail.

l ANSWER: Yes, NIPSCO does have plans which should aid in the reduction of peaks. The rate design of 2 rate schedules l (832 and 833) applicable to the larger customer contain provisions i

which provide an economic incentive for them to reduce their demands on the NIPSCO system. This economic incentive has been in effect for a number of years and has proven very successful in reducing the demand at times of system peak.

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1 In addition, NIPSCO has, as part of its electric service tariff, an interruptible rate schedule which allows the Company to request i a reduction of customer demand upon 10 minutes notification.

Thi: schedule provides for 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of reduction to be available at the Company's request in a 12-month period.

NCPSCO also has a rate schedule which makes provisions for customere i

to install peak shaving generation equipment to allow them to

'I limit their demands on the NIPSCO system.

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j 16. Does NIPSCO have any plans, stand-by, tentative or otherwise, to reduce long-term electrical demand on its system?

If your answer is yes, please describe such plans in detail.

ANSWER: No. 6 t

17. Does NIPSCO have any plans, stand-by, tentative or otherwise, to reduce the rate of growth on its system? If your

, answer is yes, please describe such plans in detail.

) ANSWER: No.

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, 18. (a) Using all of the following assumptions, please i

state what you contend would be the water table level or surface water level at each of the points l numbered "1" through "10" with circles around

! the numbers on " Attachment I" to these interrogatoriet:

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uewatering for 30 months at a rate sufficient to reach the lowest point necessary for con-struction of the Bailly plant;

-- With the effects of the slurry wall as presently installed;

-- In the absence of any mitigation program; and With no seepage from NIPSCO's ash ponds and no dewatering for the sealing of NIPSCO's ash ponds.

(b) Please state all other assumptions used in calculating your responses to subsection (a), including but not limited to the rate of dewatering assumed, and whether your assumptions include a hydraulic connection between " Unit 1" and " Unit 3" .

(c) Please give all calculations used in formulating your answers.

(d) Please state the bases for youi answers.

For the purpose of answering these Interrogatories, NIPSCO may assume that " Unit 1" and " Unit 3" refer to those units so described in "SGS reports78-138 and 80-1105.

ANSWER:

(a) NIPSCO rrsumes that the points numbered "1" through "10" on " Attachment I" to these Interrogatories are as defined in the response to Interrogatory 6(f) above. Since none of these points is located within.the limits of an interdunal pond, no surface water levels have been calculated.

NIPSCO has not attempted to identify the water table levels of any of these ten points. However, drawdowns (decreases from the seasonal groundwater levels) have been estimated for the unconfined aquifer dewatering system and for the confined aquifer depressurization system. NIPSCO has determined that the total drawdown resulting from the unconfined aquifer dewatering system and the confined aquifer depressurization system will be less than the drawdown which was approved by the Atomic Safety and Licensing Board at the time of the Construction Permit hearing. Thus no calculations have been performed to identify specific drawdowns at points 1 through 10.

(b) Not applicable.

(c) Not applicable.

(d) The presence of a slurry wall and pumping at a lower rate than that discussed in the construction permit hearing will result in less drawdown than that approved by the Licensing Board following the Construction Permit hearings.

19. (a) Using all of the following assumptions, please state what you contend would be the water table or surface water level at each of the points numbered "1" through "10" with circles around the numbers,

on "Attaahment 1" to these interrogatories

Dewatering for 30 months at a rate sufficient to reach the lowest point necessary for con-struction of the Bailly plant; With the effects of the slurry wall as presently installed; With NIPSCO's proposed mitigation program; and With no seepage from NIPSCO's ash ponds and no dewatering for the sealing of NIPSCO's ash ponds.

(b) Please state all other assumptions uo a in calculating your responses to subsection (a), including but not limited to the rate of dewatering assumed, and whether your assumptions include a hydraulic connection between " Unit 1" and " Unit 3."

l (c) Please give all calculations used in formulating your answers.

(d) Please state the bases for your answers.

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ANSWER:

(a) The mitigation program will be designed to maintain the groundwater levels at the NIPSCO/ Indiana Dunes National Lakeshore property line within one foot of seasonal levels. The groundwater levels at both points 1 and 2 which are located on NIPSCO property will be controllable with the mitigation system. There will be no change in groundwater levels at points 3 through 10, inclusive.

(b) The mitigation program design has not been completed.

However, the recharge systems will be properly sized and located to allow mitigation of any drawdown at the property line.

(c) No calculations were required to prepare the answers to Interrogatories 19(a) and (b) above.

(d) The bases for the answer is provided in Interrogatory 19(b) above.

20. (a) Using all of the following assumptions, please state what you contend would be the water table level or surface water level at each of the points marked "1" through "10" with circles around the numbers on "Tttachment I" to these interrogatories:

Dewatering for 30 months at a rate sufficient to reach the lowest point necessary for construction of the Bailly plant; s--,

c In the absence of the slurry wall; In the absence of any mitigation program; and With no seepage from NIPSCO's ash ponds and no dewatering for the sealing of NIPSCO's ash conds.

(b) Please state all other assumptions used in calculating your responses to subsection (a), including but not limited to the rate of dewatering assumed and whether your assumptions include a hydraulic l connection between " Unit 1" and " Unit 3."

(c) Please give all calculations used in formulating your answers.

(d) Please state the bases for your answers.

ANSWER:

(a) The assumptions specified in this hypothetical question describe the conditions relied upon by NIPSCO and its consultants in the Bailly Nuclear-1 Construction Permit Hearing in 1973 before the slurry wall was considered or installed. The drawdown would be that which was reviewed by the Licensing Board in its initial 6ecision, 7 AEC 557 (April 5, 1974). No specific drawdowns were calculated for points 1 through 10.

l (b) Those described in the testimony of the Construction Permit Hearing, to which PCCI was a party.

(c) Those described in the testimony .f the Construction Permit Hearing, to which PCCI was a party.

(d) See (b) and (c) above.

21. In " Northern Indiana Public Service Company's Responce to the People of the State of Illinois' First Set of Interrogatories to NIPSCO," in response to Interrogatory 14 (b) (1) , you state, "When construction has resumed...a deep well point system will be installed." Please describe in detail the " deep well point system" to which that response refers.

ANSWER: The deep well point system is described in the Sargent & Lundy report titled " Supplementary Information, Hydro-geologic Evaluation of Construction Dewatering, Bailly Generating i

i Station, Nuclear 1" dated August 27, 1979 which has been provided to PCCI in response to its second document request.

22. In " Northern Indiana Public Service Company's Response to the People of the State of Illinois' First Set of Interrogatories to NIPSCO," in respcase to Inter rogatory 14 (b) (2) , you state, "The deep well point system will reduce hydrostatic pressures in the confined aquifer such that the uplift pressure is less than the overburden pressure." Please define the folle> wing terms as used in that response:

(a) The hydrostatic pressures in the confined aquifer; (b) The uplift pressure; (c) The overburden pressure.

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1 ANSWER:

(a) The hydrostatic pressure is the pressure exertad by a static head of water; (b) The uplift pressure is a pressure acting vertically upward; (c) The overburden pressure is that pressure exerted by the gravitational weight of overlying materials.

23. Please describe in detail how the deep well point system referred to in Interrogatory 22 above will reduce hydrostatic pressures in the confined aquifer.

ANSWER: The operation of the deep well point system is described in the document identified in response to Interrogatory No. 21.

24. Does NIPSCO have any plans to mitigate the effects of pumping water from the confined aquifer? If your answer is yes:

(a) Please describe such plans in detail; (b) State hpw you will determine whether to put such plans into effect; and (c) State all data on which you base your response to Interrogatory 24tt).

ANSWER: Yes. NIPSCO intends to install a mitigation system I

as required on page 10 of the NRC Environmental Impact Appraisal, l

l dated July 17, 1981.

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(a) Plans for the mitigation system are being developed.

but are not now available; (b) The method by which NIPSCO will determine whether to put such plans into effect will be a part of the overall mitigation plan; (c) This data has yet to be developed.

25. Does NIPSCO have any plans to mitigate the effects of pumping water from the unconfined aquifer? If your answer is yes:

(a) Please describe such plans in detail; (b) State how you will determine whether to put such plans into effect; and (c) State all data on which you base your response to Interrogatory 25(b).

ANSWER: Yes.

(a) The documents referenced in response to Inter-rogatory 4 provide a description of mitigation plans for the unconfined aquifer; (b) The documents referenced in response to Inter-rogatory 4 provide a description of the method which NIPSCO will use to put such plans into effect; (c) The documents referenced in response to Inter-rogatory 4 provi6e a description of the data upon which NIPSCO bases its response to Interrogatory ,

25(b).

26. Please describe all chemical and physical characteristics of the following:

(a) The ground water in Unit 1 on the r ailly site; (b) The ground water in Unit 1 within the Indiana Dunes' National Lakeshore; (c) The ground water in Unit 3 on the Bailly site; (d) The ground water in Unit 3 within the Indiana Dunes National Lakeshore.

ANSWER:

(a) Data on the chemical and physical characteristics of groundwater in Unit 1, which NIPSCO assumes to mean groundwater in the unconfined aquifer, is provided in the follcwing reports; all of which have been furnished to PCCI in response to its second request for documents or are otherwise in the possescion of PCCI.

(i) Bailly Generating Station N-1 Preliminary Safety Analysis Report, in Chapter 2.

(ii) Corrosion neport, Bailly Generating Station

- Nuclear 1. July 20, 1978 (in Table No. 1).

Prepared by I. Cornet, 470 Spruce Street, Berkeley, California 94708.

(iii) Supplementary Information, Hydrogeologic Evaluation of Construction Dewatering dated August 27, 1979. Pg. A-7, A-37.

)

(b) NIPSCO has no data on the chemical and physical characteristics of Unit 1 water within the Indiana Dunes National Lakeshore.

(c) Data on the chemical and physical characteristics of gtoundwater in Unit 3, which NIP 5CO assumes to mean groundwater in the confined aquifer, is provided in the reports listed in response to Interrogatory 26(a).

(d) NIPSCO has no data on the chemical and physical characteristics of Unit 3 groundwater within the Indiana Dunes National Lakeshore.

27. Please state the basis for each response in Interrogatory 26, and, if jour response was based on tests, studies, or samples state the date (s) of all such tests, studies or samples, and by whom each test, study or sample was performed.

ANSWER:

(a) The PSAR references two reports of physical and chemical ct..aracteristics of groundwater in the Bailly site aquifers. They are:

(i) Rosenheim, J. S. and Hunn, J. D., "Geohydrology and Groundwater Potential of Lake County, Indiana", Indiana Depo-tment of Natural Resources, Division of Water, Bulletin 31, 1968. PSAR S 2.4.3.

j .

i i

I (ii) "osenheim, J. S. and Hunn, J. D. "Geohydrology 4

and Groundwater Potential of Porter and La Porte Counties, Indiana", Indiana Department '

l

(

of Natural Resources, Division of Water, i

j Bulletin 32, 1968. PSAR S 2.4.3.

(b) Groundwater analysis for the July 20, 1978 Corrosion Report was perforned by Aqualab, Inc., Route 20 at Valley Lane, Streamwood, Illinois 60103.

Table I.

(c) Grcundwater analysis in the August 27, 1979, Sup-1 plementary Information, Hydrogeologic Evaluation of Construction Dewatering was performed by Northern 4

Laboratories, 158 South Napoleon Avenue, Valparaiso, i Indiana 46383 (P. A-7, A-37).

2;. In " Northern Indiana Public Service Company's Response i

to the People of the State of Illinois' First Set of Interrogatories l to NIPSCO," in response to Interrogatory 18 (a) you state, "NIPSCO has condt:ted 9 test programs during which a total of 251 piles have been utilized for testing purposes." For each of the 9 i

test programs please state

(a) A detailed description of the test program; (b) The sutject matter tested; (c) What NIPSCO expected to ascertain from the test program; (d) The date the test program was first proposed; I

l l

(e) The person or organization proposing the test program; (f) The date the test program was conducted; (g) The results of the test program; (h) A description of all documents on which you relied in answering this Interrogatory.

ANSWER:

(a) A detailed description of each of the nine test programs is contained !n the following documents:

(i) Report SL-3109 " Pile Test Analyses, Bailly Generating Station Nuclear 1" dated September 6, 1974 and prepared by Sargent & Lundy Engineers, Chicago, Illinois.

(ii) Report SL-3130 " Supplementary Foundation Evaluation - Bailly Generating Station Nuclear 1" dated September 6, 1974 and prepared by Sargent & Lundy Engineers, Chicago, Illinois.

(iii) Report SL 3205 " Analyses of Pile Driving Tests, Bailly Generating Station - Nuclear 1" dated September 15, 1975 and prepared by Sargent & Lundy Engineers, Chicago, Illinois.

(iv) Letter of October 27, 1977 from Mr. R. J.

Bohn of NIPSCO to Mr. E. G. Case of the NRC with attachments.

l (v) Report SL-3629 "Decign, Ailalysis and Installation of Driven H-Pile Foundations, Bailly Generating

I Station - Nuclear 1" dated March 8, 1978 and prepared by Sargent & Lundy Engineers, Chicago, Illinois and Dames & Moore, Pata ,

Ridge, Illinois.

(vi) Letter of July 14, 1978 from Mr. E. M. Shorb of NIPSCO to Mr. R. S. Boyd of the NRC with the attached responses to the June 22, 1978 NRC questions.

(vii) " Indicator Pile Program, Bailly Generating Station - Nuclear 1" dated September 26, 1978 and prepared by Sargent & Lundy Engineers Chicago, Illinois and Dames & Moore, Park Ridge, Illinois.

(viii) " Supplementary Information on Driven H-Pile Foundations" dated December 4, 1978 and prepared by Sargent & Lundy Engineers, Chicago, Illinois, and Damas

& Moore, Park Ridge, Illinois.

Each of the above documents, as well as their transmittal letters, was provided t's Porter County Chapter Int ervenors in response to its Second Request to NIPSCO for Production of Documents.

(b) The subject matter tested is described in the documents listed in (a) above.

(c) The information which NIPSCO expected to ascertain from the test programs is described in the documents listed in (a) above.

(d) & (e) The date that the test program was proposed and the organization making the proposal are listed below.

(i) The first test program was proposed in 1972 by Damer_ & Moore; (ii) The second test program was proposed in 1975 by Sargent & Lundy; (iii) The third test program was proposed in 1974 ,

by Sargent & Lundy; (iv) The fourth and fifth test programs were proposed in 1977 by Sargent & Lundy; tv) The sixth test program wt.s proposed in 1977 by Sargent & Lundy; (vi) The seventh test program was proposed in i 1978 by Sargent & Lundy; I

(vii) The eighth test program was required by the NRC in 1978; (viii) The ninth test program was proposed in 1978 by Sargent & Lundy.

(f) T;ie date that the test program was conducted is described in the documents listed in (a) above.

(g) The results of the test programs are described in the documents listed in (a) above.

.-. .- _ _ _ _ .= - - _ -- -. . .-- _ . _ . - -

i (h) Documents relied upon by NIPSCO in resTanding

to this Interrogatory are as listed below

{

(i) Documorts listed in responding to (a) above.

(ii) Specification T-2967 " Steel H-Piling Installation" dated April 22, 1974 and prepared by Sargent

& Lundy Engineers, Chicago, Illinois. (Page 2-1-4)

(iii) Specification T-2967 " Steel H-Piling Installation" i dated January 5, 1977 and prepared by Sargent

) & Lundy Engineers, Chicago, Illinois. (Pages

3-1 to 3-5 and 3-9)

(iv) Report 5676-005-07 'neport - Supplementary Foundation Investigation, Proposed Nuclear 4

Power Plant and Cooling Tower, Bailly Generating Station, Baileytown, Indiana, for Northern Indiana Public Service Company" dated March 31, 1972 and prepared by Dames & Moore, Park Ridge, Illinois. (Pages 11 to 14)

(v) Letter of June 22, 1978 to Mr. E. M. Shorb of NIPSCO from Mr. D. B. Vassallo of the NRC with attachments. (RSP 362.5)

(vi) Letter of May 26, 1978 to Mr. R. S. Boyd of the NRC from Mr. H. P. Lyle of NIPSCO with attachments.

i

. . - _ . . - . _ . . . . _ . , _ _ _ . _ . . . _ - . . , . . - . - . , - . _ . -- _- ._ - . - . _ _ . ~ .- - - - - , _ .

29. In " Northern Indiana Public Service Company's Response to the Peoplc of the State of Illinois' First Set of Interrogatories to NIPSCO," in responce to Interrogatory 18 (h), you state, "the i effects of any hydraulic interconnections between Units 1 and 3 will be controlled by (1) depressurizing Unit 3, (2) installing densification piles, and (3) using filter material." For each of the three proposed methods of "cor, trolling" the effects of i

hydraulic interconnections, please state:

(a) A detailed description of the method; (b) When and under what circumstances NIPSCO expects to employ that method; (c) How that method will " control" the " effects of hydraulic interconnections."

ANSWER:

(a) A detailed description of each method for controlling the effects of hydraulic interconnections is provided in the following documents:

(1) Depressurizing Unit 3: " Supplementary Information:

Hydrogeologic Evaluation of Construction Dewatering, Bailly Generatir.g Station, Nuclear 1" dated August 27, 1979 and prepared by Sargent & Lundy Enginegrsq hicago, Illinois; Dames & Moore, Park Ridge, Illinois and Ground / Water Technology, Inc., Denville, New Jersey. (Paget 7 and 20-24).

(2) Installation of Densification PileF:

l l

(i) Above teport listed in response to (a) (1) .

(ii) Letter of August 14, 1979 to Mr. D.

9 Vassallo of the NRC from Mr. E. M.

Shorb of NIPSCO with attachments in-cluding " Program for Densification of J

Preconstruction Ar( 1s" .

(iii) Letter of May 27, 1980 to Mr. R. L.

Tedesco of the NRC from Mr. E. M. Shorb of NIPSCO with attachments including a response to RSP 362.04.

(3) Use of Filter Material: A detailed description of the use of a filter material to control the effects of hydraulic interconnections is provided in the document listed in 29(a) (1) above.

(b) When and under what circumstances NIPSCO expects to employ ea h of these methods is described in the documents listed in response to 29 (a) above.

(c) How each of these methods will control the effects of hydraulic interconnections is described in the documents listed in response to 29 (a) above.

All documents listed in response to this interrogatory were provided to PCCI in response to its second request for production of documents.

l l _ _ , - _ , _ , __ - _ . _ . . . - . - _ _ _ . . . _ _ . . . _ _ _ _ . . . _ _ _ . . _ _ _ . _ . . _ _ - . . . ._

30. Please state the bases for y:^ur response to Interrogatories 19(a) thrcugh 19 (c) of the People of the State of Illinoir' First Set of Interrogatories to NIPSCO.

ANSWER: Accepted soil mechanics principles and engineering experience.

4

31. Please state the bases for your response to Interrogatories 20 (a) (1) througi 20 (a) (4) of t'a People of the State of Illinois' First Set of Interrogatories to NIPSCO.

ANSWER: The bases for NIPSCO's response to Interrogatory 20 (a) (1) threugh 20 'a) (4) of the People of the State of Illinois' First Set of Interrogatories to NIPSCO is the response to Inter-

, rogatory 19 (a) through 19(c) of Illinois' First Set of Interrogatories.

32. Please state the bases for your response to Interrogatory l 23(a) of the People of the State of Illinois' First Set of Inter-rogatories to NIPSCO.

ANSWER: The bases for NIPSCO's response to Interrogatory i

23(a) of the People of the State of Illinois' First Set of Inter-rogatories to NIPSCO is the response to Interrogatory 19(a) through 19(c) of Illinois' First Set of Interrogatories.

l

33. Please state the bases for your response to Interrogatory 24(a) of the People of the State of Illinois' First Set of Inter-rogatories to NIPSCO.

l

1 i i

! ANSWER: The bases fer NIPSCO's response to Interrogatory i

24(a) of th+ people of the State of Illinois' First Set of Inter-l rogatories to NIPSCO is the response to 19(a) through 19(c) of Illinois' First Set of Interrogatories.

34. Please state the bases for your response to Interrogatory i 25(a) of the People of the State of Illinois' First Set of Inter-rogatories to NIPSCO.

ANSWER: The bases for NIPSCO's response to Interrogatory i'

25(a) of the People of the State of Illinois' First Set of Inter-rogatories to NIPSCO is the response to Interrogatory 19(a) through 19(c) of Illinois' First Set of Interrogatories.

35. With reference to your response to Interrogatory 26(a) of the People of the State of Illinois' First Set of Interroga- l tories to NIPSCO, please state the bases for:

(a) Your response that "in theory" dewatering at the

Bailly site could result in subsidence of subsoil structure at Bailly; (b) Your statement that "the proposed method of de-watering at the Bailly site is designed to preclude

! subsidence of subsoil structures at Railly."

ANSWER:

(a) Without the proper controls to prevent soil removal during dewatering, the possibility of subsidence of subsoil structures could not be absetutely ruled out.

(b) NIPSCO will nonitor and control remeval of soil fines during dewatering, thereby precluding subsidence of subsoil structures at Bailly.

36. Please provide the following information for NIPSCO's system for esch of the years from 1973 through 1980:

(a) Peak load; (b) Net installed capacity (i) With peaking units; (ii) Without peaking units; (c) Purchased power; (d) Total capacity; (e) Total reserve; and (f) Percent reserve.

ANSWER: See attached Table.

t .'

l t

l

QUESTION 36 NIPSCO IIISTORIC IDAD AND CAPABILITY DATA Net Total Reserve-KW  %-Reserve Total Reserve-KW  %-Reserve Peak (1) Ins t.a l led Purchase Total With With Withoat Without I

Year load-KW Capacity-KW Power-KW Capacity-KW Peaking Units Peaking Units Peaking Units Peaking Units 1973 1,786,780 1,386,100 690,190(2) 2,076,290 289,510 16.2 203,410 11.4 1974 1,872,357 1,854,850(3) 690,190 2,545,040 672,683 35.9 586,583 31.3 1975 1,883,829 1,854,850 690,190 2,545,040 661,211 35.1 575,111 30.5 1976 1,978,066 1,054,850 690,190 2,545,040 566,974 28.7 480,874 24.3 l

1977 2,204,000 2,174,850(4) 490,190(5) 2,665,040 461,040 20.9 374,940 17.0 19/8 2,239,150 2,285,850(6) 590,190(7) 2,876,040 636,890 28.4 550,790 24.6 ,

l l fl979 2,243,650 2,214,850(8) 500,190(9) 2,715,040 471,390 21.0 385,290 17.2 )

!?80 2,223,600 2,685,850(10) 400,190(11) 3,086,040 862,440 38.8 621,440 27.9 NOTES: (1) 60 minute demand.

(2) Comprised of 90,000 KW Firm from CE; 200,000 KW Firm fr~m I6H; 400,000 KW Unit Power from 16M; 120 in-l from Star Milling; 70 KW from Rinkel & Son.

(3) Michigan City Unit 12 in service May 31,1974 at 468,000 KW.

(4) R. M. Schahfer Unit 14 in service December 31,1976 at 320,000 KW.

(5) 200,000 KW of I&M Unit Power ended in May, 1977.

(6) R. M. Schahfer Unit 14 uprated to 431,000 KW in September, 1977.

(7) Comprised of 90,000 KW Firm from CE; 400,000 KW Firm from 16H; 100,000 KW Unit Power from IPL.

(8) Michigan City Unit I at 71,000 KW retired December, 1978.

(9) 90,000 KW of CE Firm ended in June, 1979.

(10) Reflects the 156,000 KW derating of gcnerating capacity in 1979; R. M. Schahfer Unit'15 in service 10/31/79 @ 472,000 KW; R. M. S. Unita 16A&B in service 12/31/79 @ 155,000 KW. -

(11) 100,000 KW of IPL Unit Power ended in August, 1979.

S 8-6-81

r--

i

37. In " Northern Indiana Public Service Company's Response to Porter County Chapter Intervenors' First Set of Interrogatories, in response to Interrogatory 7, you stated "NIPSCO believes that a minimum reserve margin of 20% excluding combustion turbines

[ footnote omitted] is the minimum reserve margin required to maintain minimum system reliability." Please state the cases for chis statement.

ANSWER: NIPSCO experience has proven that when our reserve margin, excluding combustion turbine units, falls below 20% we have insufficient restrves to perform periodic scheduled maintenance and other repairs while still maintaining adequate system capacity to protect against forced or unforeseen outages on the remaining generating units. NIPSCO's electric system load factor, which is consistently one of the highest in the industry, results in less off-peak capacity to be used for maintenance and forced outages than systems with lower load factors.

38. What was NIPSCO's estimate of the minimum reserve margin required to maintain minimum system reliability at the time it made application for a construction permit for Bailly N-l?

ANSWER: Fifteen percent.

39. What was NIPSCO's estimate of the minimum reserve margin required to maintain minimum system reliability at the time of the issuance of the construction permit for Bailly N-l?

ANSWER: Fifteen percent.

40. Please state the basis for your response to Interrogatory 14 of Porter County Chapter Intervenors' First Set of Interroga-tories to NIPSCO.

ANSWER: The basis for our response to Interrogatory 14 of Porter County Chapter Inte>venors' First Set of Interrogatories to NIPSCO is stated in the first sentence of NIPSCO's response to Interrogatory 14.

41. Please state the basis for your response to Interrogatory 15 of Porter County Chapter Intervenors' First Set of Interroga-tories to NIPSCO.

ANSWER: The basis for our response to Interrogatory 15 of T>orter County Chapter Intervenors' First Set of Interrogatories to NIPSCO is the same as the basis for NIPSCO's response to Inter-rogatory 14.

42. In your response to Interrogatory 7 of Forter County Chapter Intervenors' Second Set of Interrogatories to NIPSCO, you state, "67 geological investigations are referenced in the PSAR and 21 geological investigations were referenced in the testimony of NIPSCO witnesses during the construction permit hearing." For each such " geological investigation," please provide the citation to the reference in the PSAR, and the page citation to the testimony of the NIPSCO witnesses during the construction permit hearing as referred to in your answer.

ANSWER: Objected to.

42. In your response to Interrogatory 7 of Porter County Chapter Intervenors' Second Set of Interrogatories, you state, "All geologic investigations performed by or for NIPSCO or available to NIPSCO prior to the date of issuance of the construction permit which are in NIPSCO's possession are as follows..." Please state

, 5. nether there are such geologic investigations which are not l

in NIPSCO's possession. If your answer is yes, please provide the following information for each suca geologic investigation:

(a) A description of the investigation; (b) The date of the investigatica; (c) By whom it was performed; and (d) In whose oossession the investigation or description or results thereof presently is.

ANSWER: Yen, the 67 geological investigations referenced in the PSAR and 21 geological investigations referenced in the testimon-, of NIPSCO witnesses during the construction permit bearing are not in NIPSCv't possetsion. Those documents are identified on attached Tables 1 and 2.

(a) See attached Tables 1 and 2.

(c) See attached Tables 1 and 2.

(c) See attached Tables 1 and 2.

(d) NIPSCO is uncertain as to who or what organiza-tions may presently have possesrion of t he documents listed in Tables 1 ar., 2 which are not in NIPSCO's possession.

1

. Table 1 l 67 GEDIOGICAL INVESTIGATICNS l REFERE2CED IN WE PSAR l

1. *Ayers, J.A. , The Currents of Lakes Michigan and Huron, Great Lakes Pesearch Institut5, University of Michigan, 1959.

2. Beck, M.E., Jr., Aermiagnetic Map of Northeastern Illinois and its Geolcgic Interpretation, Geophysical Inv. Map GP-523, U.S. Geological Survey, Arlington, Virginia 1965.

3.

• Bell, A.H., and others, Deep Oil Possibilities of the Illinois Basin, Illinois State Geological Survey, Circular 368, 1964.

4. *Buschback, T.C., Cambrian and Ordovician Strata of Northeastern Illinois, Illinois State Geological Survey, Report of Investigation 218, 1964.

5. Cady, G.H., The Structure of the LaSalle Anticlina_, Illinois Geological Servey Bull., 36, pp.85-179, 1920.

6. *Cumings, E.R. , and Shrock, R.R. , The Geoloay of the Silurian Rocks of Northern Indiana, Geological Survey, Indiana Department of Conservation, Publication No. 72, 1928.

7. *Dawson, T.A. , and Carpenter, G.L. , Undercround Storace of Natural Gas in Indiana, Geological Survey, Indiana Department of Conservation, Special Report No. 1, 1963.

8. *Dawson, T.A., Map Showing Generalized Structure of Trenton Limestone in Indiana, Ind w.a Geological Survey, Misc. Map 3.

9. *Emrich, G.H. , and Bergstrun, R.E., Des Plaines Disturban Northeastern Illinois, Geological Survey of America Bulletin, Vol. 73, pp. 959-968, August 1962.

10. Emrich, G.H. , Ironton and Galesville (Cambrian) Sandstones in Illinois and Adjacent Areas, Illinois State Geological Survey Circ.

403, 55 pp., 1965.

11. " Great Lakas Harbors Studv - Interim Recort on Burns Waterway Harbor, Indiana, House Docu: rent No.160, 88th Congress,1st Session, Congress of the United States,1963.

12.

• Green, D.A. , Trenton Structure in Ohio, Indiana, and northern Illinois, Annrican Association Petroleum Geologists, Bull. 41, 627, 1957.

13. Grey, H. and Dawson, T.A., Uhpublished Maps, Indiana Geole::ical Survey.

" Denotes primary r@rence; all other secondary reference.

(i) .

1 6 7 cmmmIcAL INVESTIGATICNS REFERENCED IN 'IEE PSAR

14. *Gustadt, A.M., Cambrian and Ordovician Stratigraphy and Oil an_d Gas Possibilities in Indic.na, Geological Survey, Indiana Department of Conservation, Bulletin No. 14, 1968.

15. *Hmderson, J.R. and I. Zietz, Interpretation of an Aermacnetic Survey of Indiana, U.S. Geological Survey, Professional Paper 316-B, 37 pp., 1958.

i A Hinze, W.J., Regional Gravity and Macnetic Ancmaly Maps of the Southern Peninsula of Michigan, Michigan Geological Survey Division, Dept. of Conservation, Report of Investigation 1, 26 pp. 1963.

17. *Lidiak, E.G., Marvin, R.F., Thomas, H.H., and Bass, M.N.,

Geochronoloay of the Midcontinent Recion, United States, and Eactern Area, Journal of Geophysics, Research, No. 71, No. 22, pp. 5427-5438, 1966.

18. Lyons, P.L., Lateral Faulting in Midcontinent fran Geophysical Data, Geological Society of America, Abstract, South-Central Section, 2, 1969.

4 19. McGinnis, L.D., Crustal Movements in Northeastern Illinois, University Microfilms, Ann Arbor, Michigan,1965.

20. *McGirnis, L.D., Crustal Tectrnics and Precambrian Basement in Northeart.crn Illinois, Illinois Geological Survey Report of Investigation 219, 29 pp., 1966.

21. *Mfdnnis, L.D., Glacial Crustal Bending, Geological Society of America, Bull. No. 79, pp. 769-776, 1968.

22. *McGinnis, L.D., Tectonics and the Gravity Field in the Continental Interior, Jour. Geophysical Research, No. 75, No. 2, pp. 317-33.:., 1970.

23. Muehlberger, W.R., Deninson, R.E., and Lidiak, E.G., Basement Rocks in Continental Interior of United States, Amer..:n Associaticn of Petroleum Geologist Bulletin 51, 2551, 1967.

24. Newcx: rte, R.B., Oil and Gas Field in Michigan, Michigan Geological Survey, 38, pp. 101-112, 1933.

25. Patton, J.B., Depositional-Erosional Evidence in Indiana for the Age of the Cincinnati Arch, (Abstract), Geological Society of America Spec. Paper 68, 1962.

26. *Pinsak, A.P. and Shaver, R.H., The Silurian Fourations of Northern Indiana, Geological Survey, Indiana Department of Conservation, Bull.

32, 1964.

• Denotes primary reference; all others secondary reference.

(ii)

67 GEDIOGICAL HNESTICATICNS utna<tzCED IN THE PSAR

27. Pirtle, G.W., Michigan Structural Basin and its Relationship to Surrounding Areas, American Association of Petroleun Geologists Bull. ,

Vol. 16, pp. 145-152, 1932.

28. Rooney, L.F. and Sunderman, J.A. , Lightweight Agarecate Potential of the Nea Albany Shale in Northwestern Indiana, Geological Survey, Indiana Depart:nent of Cmservation, Report of Progress 27, 40 pp. ,1964.

29. Rudman, A.J. , Sunmerson, C.H. , and Hinze, W.J. , Geolocy of the Basenent in Midwestern United States, American Association of Petroleum Geologist Bull. 49, 894, 1965.

30.

• Tectonic Map of the United States, American Association of Petroleum Geologists and U.S. Gcological Survey, Arlington, Virginia,1962.

31. *Woollard, G.P. and Joesting, H.R., Bouguer Gravity Ancrnaly Map of the United States, American Geophysical Union and U.S. Geological Survey, Arlington, Virginia 1965.

32. Zietz, I., King, E.R., Geddes. W.G., and Lidiak, E.G., Crustal Study of a Continental Strip fran the Atlantic Ocean to the Rocky bbuntains, Geological Society of American Bulletin 77, 1427, 1966.

33. Anbraseys, N. and S. Sarma (l?C9) " Liquefaction of Soils Induced by Earthquakes, " Bulletin of the Seisnological Society of America,"

Vol. 59, tb. 2, April, pp. 651 and 664.

34. Castro, G. , " Liquefaction of Sands," Harvard Soil Mechanics Series, No. 81, January 1969.

35. Gibbs, H.J. and Holtz, W.G., "Research on Determining the Density of Sands by Spoon Penetration Testing", Proceedings, 4th International Conference on Soil Mechanics and Foundation Engineering, Iondon, Vol.1, 1957.

36. Ice, K.L. and H.B. Seed, (1967) " Cyclic Stress Conditions Causing Liquefaction of Sand," Journal of the Soil Mechanics and Foundations Civision, ASCE, V;1. 93, No. SM1, January, pp. 47-70.

37. Seed, H.B. (1969), "The Influence of Iccal Soil Conditions on Earthquake Damage" Proceedings, 7th International Conference on Soil Mechanics and Foundation Engineering, Mexico City, Mexico.

38. Seed, H.B. , and I.M. Idriss (1967) " Analysis of Soil Liquefaction:

Niigata Earthquake, " Journal of the Soil Mechanics and Foundations Divisi,on. ASCE, Vol. 93, No. SM3, May, pp.83-108.

• Denotes primary reference; all other secondary reference.

(iii)

P 6 7 MO'UCAL DNESTICATICNS REFERENCED IN ' HIE PSAR

39. Barosh, Patrick J., "Use of Seismic Intensity Data to Predict the Effects of Earthquake and Underground Nuclear Explosives in Various Geologic cattings, " U.S. Geol. Sury., Bull, 1279, 1969.

40. Bradley, E.A. and T.J. Bennett, " Earthquake History of Ohio,"

Bull. Seisno. Soc. Amer. , 55, 4, pp. 745-752, August 1965. i

41. Bradley, E.A. , S.J. and R.B. Herrmann, "A Study of the Seismicity of the Cincinnati Arch," A Final Ret.crt of Grant AF-AEGR 677-64, Seisnological Obsuvr. tory, Xavier University, Cincinnati, Ohio, July 1967.

42. Brazee, R.J., " Attenuation of Madified Mercalli Intensities with Distance for the United States East of 106o W," Manuscript, November 1969.

43. Drake, Daniel, " Natural and Statitial View, or Picture of Cincinnati," Iock and Wallace, Cincinnati,1815.

44. Dutton, C.E., "The Charleston Earthquake of August 13, 1886,"

U.S. Geological Survey, 9th Annual Report, 1887-88.

45. Eppley, R.A. , "Eartiquake History of the United States," ESSA, U.S. Coast & Geod. Sury., Ser. No. 41-1, 1965.

46. Fuller, Myron L. , "The New Madrid Earthquake," U.S. Geolocical Survey Bull. 494, Washington, 1912.

47. Gordon, D.W. , T.J. Bennett, R.B. Hermann, and A.M. Rogers, "The South-central Illinois Earthquake of November 9,1968; Macroseismic Studies," Bull. Seisnological Society of America, (in press) ,1969.

48. Gutenberg, Beno, and C.F. Richter, " Earthquake Magnitude, Intensity, Energy and Acceleration (Second Paper)," Bull. Seismolocical Society of Anerica, 46, #2, April 1956. pp.105-146.

49. Heigold, Paul C. , " Notes on the Earthquake of Novaber 9,1968 in Southern Illinois," Environnental Geologv Notes, 24, :ll. Geol.

Survey, Decenber 1968.

50. Heinrich, R.B., "A Contribution to the Seismic History of Missouri," Bull. Seisnological Society of America, 31, 3, pp.

187-224, July 1941.

(iv)

6 7 GECIDGICAL I?NESTIGATICNS REFEREtCED IN 'IHE Pg

51. Hernmnn, R.B., "The Structure of the Cincinnati Arch as Deternined bf Short Period RayJeigh Waves," Bull. Seisnological Society of America, 59, #1, pp. 399-407, February 1969.

! 52. Hobbs, W.H., " Earthquake in Michigan," Michigan Geological Survey, Geoloaical Series No. 3, Publication 5, 1910. i

53. Jennings, P.C., G.W. Housner, and N.C. Tsai, " Simulated Earthquake Motions," ralifornia Institute of Technology,1968.

54. Kings, P.B., "Quarternary Tectonics in Middle Ncrth America,"

Quarternarv of the U.S. , edited by H.E. Wright, Jr. and D. G. Fry, The Princeton University Press, 1965.

55. Marvin, C.F., " Report Upon the Earthquake of Odwber 31, 1895" Weather Bureau, U.S. Department of Agriculture, Monthly Weather Review, Vol. 23, pp. 374-379, October 1895.

56. McGinnis, Lyle D. , " Earthquake and Crustal Movment as Related to Water Icad in the Mississippi Valley Region," Ill. State Geological Survey Circular 344, Urbana, 1963.

57. Mitchell, Samuel L., "A Detailed Narrative of the Earthquakes on the 16th Day of Decenber, 1811..." Trans. Literary and Philosophical Society of New Drk, Vol.1, pp. 281-307,1815.

58. bbneymaker, B.C., "Sme Early Earthquakes in Tennessca and Adjacent States, (16'ht-1950) , " Jour. Tenn.. Acad. Soc. , 29-33, 1954-1958.

59. Moneymaker, B.C., "The Earthquake of Kentucky," Uhpublished, 1969.

60. Rouse, J.T., and R.R. Priddy, "Pecent Earthquakes in WestJrn Ohio," Ohio Jour. of Science, 38, pp. 23-35,1938.

61. Snaler, N.S., " Earthquakes of the Western United States,"

The Atlantic Monthly, Vol. 24, p. 550, 1968.

l

62. Stauder, W. , S.J. and Otto Muttli, "The South-Central Illinois Earthquake of Novmber 9,1968; seismic Studies," Bull. Seismolooical Society of Arnrica, (in press),1969.

63. Udden, J.A., " Observations on the Earthquake in the Upper Mississippi Valley, May 26, 1909," Transaction Illinois State Arachny of Science, Vol. 3, pp.132-143,1910.

(v)

-.xs.

r 67 LmterTrAL BVESTICATIONS Nrrt2<t2EED IN 'IEE PSAR

64. Udden, A.D., "On the Earthquake of January 2,1912 in the Upper Mirsissippi Valley," Transactions Illinois State :,cadew of Science, pp. 111-115, 1912.

65. United States Earthquakes 1928-1968, ESSA, U.S. Coast & Geodetic Survey. i

66. Westland, A.J. and R.R. Heinrich, "A hacroseismic Study of the Ohio Eart. W of March, 1937," Bull. Seismological Society of America, Vol. 30, pp. 251-260, 1940.

67. Zietz, I., King, E.R., Gesses. W.G., and Lidiak, E.G., Crustal Study of a continental Strip fran the Atlantic 0 an to the Rocky Mountains, Geological Society of American Bulletin 77, 1427, 1966.

i (vi)

q Table 2 21 GEDIOGICAL INVESTIGATICNS mtrar2EED IN THE TESTIMCNY OF NIPSCO WITNESSES DURIlU

'IHE CONSTRUCTION PERET HEARIlU

l. Anon, 1968, Subsurfa Disposal of Industrial Wastes, Interstate Oil Ccmpact Ctmnission, June 1968.

2. Hollister, J.C. and Weimer, R.J., (editors) , 1968, Gecphysical and Geological Studies of the Relationships Between the Denver Earthquakes and the Rx:ky Fbuntain Arsenal Well, Part A, Colorado School of Mines Quarterly, i Volune 63, No.1, January 1968.

3. Warner, Don L., 1969, Perspective on the Regulation of Underground Injection of Wastewaters, Chio River Valley Water Sanitation remusion, Decenber 1969.

4. Winer, Richard M.,1967, 'Ihe Dism91 of Wastewater Underground, Ind C Jial Water Engineering, March 1967.

5. Ells, Garland, 1971, Future Oil.and Gas Possibilities in the Michigan Basin, Amrican Association of Petroleum Geologists, Nu::ber 15, Volume 2, pages 1124-1164.

6. Warner, Don L. (1972): Survey of Industrial Waste, Injection Wolls, USGS Contract No. 14-08-0001-12280, 2 v31unes.

7. Heigold, Paul, " Notes en the Earthquake of Septe::ber 15, 1972, in Northern Tilinois," Environmental Geolocy Notes, Illinois State Geological Survey, December 1972, No. 59, p. 6.

8. Nuttli, O.W., " State of the Art for Assessing Earthquake Hazards in the United States, " Recort 1: Desian Earthquakes for the Central United States, The U.S. Sn:rf Waterways Experinent Staticn, Misc. Paper S-73-1, January 1973, pp.12, 16, 20.

l 9. Atherton, Elwocxi, " Tectonic Develognent of the Eastern Interior Region of the U.S.", Illinois Petroleum, 96, Illinois State Geological, pp. 29-43.

10. Linebach, J.A.; Gross, D.L.; Meyer, R.P.; Unger, W.L.; "High Resolution Seismic Profiles and Gravity Cores of Sediments in Southern Iake Michigan," Environmntal GeolGcy Notes, Illinois State Geological Survey, June 1971, No. 47.

l l 11. Lineback, J.A.; Gross D.L.; Meyer, R.P.; " Geologic Cross Sections Derived frcm Seismic Profiles and Sediment Cores frcm Southern Lake Michigan," Environmental Geolocy Notes, Illinois State Geological Survey, August 1972, No. 54.

(i)

12. Hough, Jack, Geolocy of the Great Iakes, Chiversity of Illinois Press, 313 p., 1958.

13. Ayer, N.J.; Cbilinson, 01arles; Gross, D.L.; Teland, H.V.;

Lineback, J.A.; White, W.A.; " Preliminary Startigraphy of Uhconsolidated Sediments frcan the Southwestern Part of Iake Michigan, "Envuua;eital Geolocy tbtes, T11inois State Geological Survey, February 1970, No. 30.

14. Sh.urp, N.F.; taland, H.V. ; White, W.A.; " Distribution of 1 Major, Minor, and Trace Constiuents in Unconsolidated Radimants frcan Southern Lake Michigan," EnvhQumutal Geoloav Notes, Illinois State Geological Survey, March 1970, No. 32.

15. Linehm-k, J.A.; Gross, D.L.; " Depositional Patterns, Facies, and Trace Element Accumulation in the Waukegan M2 ster of the Late Pleistocene Iake Michigan Formation in Southern Lake Michigan," Envhuumntal Geclocy Notes, T11inois State Geological Survey, Decenber 1972, tb. 58.

16. Science and Enaineering, Enviseu=ntal Science Services Admini=tration, July 1, 1967 - June 30, 1969, p. 78.

17. Lineback, J.A.; Ayer, N.J.; Gross, D.L.; " Stratigraphy of Unconsolidated Sediments in the Southern Part of Lake Michigan", Environmental Geolocv Notas_, Tl1inois State Geological Survey, August 1970, tb. 35.

18. Ruch, R.R.; Kennedy E. Joyce; Shimp, Neil F.; " Distribution of Arsenic in Unconsolidated Sedinents frtan Southern Iake Michigan," Environmental Geolocy Notes, Illinois State Geological Survey, September 1970, No. 37.

19. Schliker, John A.; Kuhn, John K.; " Phosphorus Content in Unconsolidated Sedirents frcan Southern Iake Michigan",

Envircrr ntal Geoloav Notes, Illinois State Geological Survey, tcve:ter 1970, tb. 39.

20. Shu:p, Neil F.; Schliker, John A.; Pouch, R.R.; Hook, David B.;

roland, Harry V.; " Trace Elements and Organic Carbon Accumulated in the Most Pecent Sedirents of Southern Iake Michigan",

Enviiuaisital Geoloav Notes, Illinois State Geological Survey, January 1971, tb. 41.

21. Wayne, Dr. William J., "'1hickness of Drift and Bedrock Physiography of Irdiana North of the Wisconsin Glacial Boundary", Irviiana Geological Survey.

(ii)

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44. Does NIPSCO contend that it lacked authority to perform any tests of pilings or other foundation systems for the Bailly facility prior to the issuance of the Bailly construction permit?

Please state the basis for your answer.

ANSWER: No. In fact, tests were performed prior to issuance of the Construction Permit.

,/

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45. Did NIPSCO perform any tests of pilings or other foundation systems prior to the issuance of the Bailly construction permit?

(a) If your answer is yes, please state:

(i) The locations where such tests were performed; (ii) The reason for each test; (iiij A description of each test and the date on which it was performed; and (iv) The result of each test; (v) A description of all documents which relate to each test.

(b) If your answer is no, please state the reason (s) why such tests were not performed.

ANSWER: Yes.

(a) The locations, reasons, dn criptions, dates and results of all such tests are delineated in the  ;

following documents:

(1) " Soil Report - Proposed Indiana Public Service Co., Bailey Generating Station Unit #7, Bailey-town, Indiana" dated April 12, 1960 and prepared by Soil Testing Services, Inc.

(2) " Report of Gcological and Seismological En-vironmental Studies, Proposed Nuclear Power Plant, Bailly Generating Station, Baileytown, Indiana for the Northern Indiana Public Service Company" dated March 8, 1968 and prepared by Dames & Moore, Park Ridge, Illinois.

(3) " Report - Site Environmental Studies, Geology, seismology, Foundations - Proposed Nuclear Power Plant, Bailly Generating Station, Bailey-town, Indiana - Northern Indiana Public Service Ccepany" prepared by Dames & Moore, Park Ridge, Illinois.

(4) " Preliminary Safety Analysis Report, Bailly Generating Station - Nuclear 1, Northern Indiana Puolic Sert.ce Company" (Chapter 2).

(5) " Supplementary Foundation Investigation, Proposed Nuclear Power Plant and Cooling Tower, Bailly Generating Station, Baileytown, Indiana for N7tthern Indiana Public Service Company" dated March 31, 1972 and prepared by Dames & Moore. Park Ridge, Illinois.

1 (6) Report SL-3109 " Draft - Pile Testing Analysis

! for Bailly Generating Station - Nuclear-1" dated June 10, 1974 and prepared by Sargent

& Lundy Engineers, Chicago, Illinois.

(7) Report SL-3109 " Pile Testing AnalyFjs - Bailly Generating Station, Nuclear-1" dated September 6, 1974 and prepared by Sargent & Lundy, C.icago, Illinois.

(8) Report SL-3130 " Supplementary Foundation Evaluation - Bailly Generating Station, Nuclear- I 1" dated September 6, 1974 and prepared by Sargent & Lundy, Chicago, Illinois.

(9) Specification T-2983 " Pile Testing Work" including all correspondence.

Each of the above documents was provided to PCCI in response to its Second Request for Production of Documents or is in the possession of PCCI.

(b) Not applicable.

46. Did the NRC or its staff, or any of NIPSCO's contractors, subcontractors or consultants advise NIPSCO to perform piling tests prior to the issuance of the Bailly construction permit?

If your answer is yes, please state:

(a) The person or organization who so advised; (b) The nature of such test; (c) NIPSCO's response to such advice; and (d) The reason for NIPSCO's response.

(e) Identify all documents reliad on in answering this Interrogatory.  ;

ANSWER: Yes.

(a) Sargent & Lundy; Dames & Moore.

(b) Tests would be pe: formed to determine pile tir elevation, p:le type and pile bearing capacity.

t

i (c) NIPSCO did not authorize pile testing at the time of S&L's letter to NIPSCO dated 9/1/72, but NIPSCO did commit to a pile testing program 2/20/74.

(d) It was determined that 1974 was the proper time to proceed with pile testing.

(e) (i) Supplementary Foundation Investigation, Proposed Nuclear Power Plant and Cooling Tower, Bailly Generating Station, Baileytown, Indiana.

Dames & Moore, Match 31, 1972. Pages 6 -

14.

(ii) Letter from R. N. Bergstrom, Head, Structural Project Engineering Division, S&L to J. A.

Pelletier, Vice President, Engineering, Construction

& Research, NIPSCO dated September 1, 1972.

(iii) Letter from H. P. Lyle, Vice President, Electric Production and Engineering, NIPSCO, to R. N.

Bergstrom, S&L, dated October 4, 1972.

(iv) Letter from J. H. Waxman, Purchasing Agent, j NIPSCO to R. N. Bergstrom, S&L, dated February 20, 1974.

l These documents were provided to PCCI in response to its Second Request to NIPSCO for Production of Documents.

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47. In a letter frain E. M. Shorb to Robert L. Tedesco, Assistant Director of Licensing, dated July 3, 1981, served on' all parties by counsel for NIPSCO under letter dated July 6, 1981, it is stated, "in responce to a request by Mr. M. D. Lynch, Project Manager for Bailly, we are providing the following information..." Witn respect to the " request" referred to, please state:

(a) A complete description of the request; (b) Whether such request was oral or in writing; i (c) The date of such request; i

j (d) The reason for the request; and (e) To whom at NIPSCO the request was communicated.

(f) A description of all documents related to that request.

ANSWER:

(a) Mr. M. D. Lynch requested that NIPSCO provide a current response to Question #13 of Mr. Robert L.

Tedesco's lette; of December 18, 1980. Mr. M. D.

Lynch requested clatification of the last sentence of our Response to Question #14 submitted December 18,  ;

1980.

(b) Oral.

(c) During the week of June 14, 1981.

(d) NIPSCO assumes that the reason for the request is as stated in the answer to Interrogatory 47(a) above.

(e) Alan P. Severance.

., , . - . _ - . . - . . , _ , . . ,_.__..,-.7,. - ...-,.,r. - - - , , , - . - , _m ,, , ..r..r ,..-,-y....,-r-_,,,,,,._,.,,-y. _ , , , - - . , , . - , - , - .

(f) NRC letter from Mr. Robert L. Tedesco to Mr. H. P.

Lyle dated November 21, 1980. NIPSCO letter from Mr. E. M. Shorb to Mr. Robert L. Tedesco dated December 18, 1960. NIPSCO letter from Mr. E. M.

Shorb to Mr. Robert L. Tede1co dated July 3, 1981.

48. For each type of foundation, and for each method of installation of a foundation type, considered by NIPSCO for Bailly N-1, please state:

(a) A description of the type and/or method; (b) By whom it was proposed; (c) The date on which it was proposed; (d) A description of all tests, investigations and studies prepared by or on behalf of NIPSCO, or relied cn by NIPSCO, in relation to the foundation type or method; and (e) The results of each test, investigation and study listed in your response to Interrogatory 12(d) .

ANSWER:

(a) A description of each type of foundation, and each method of installation for those foundations, considered by NIPSCO for Bailly N-1 is provided in the following documents. Please note that in the absence of specific secticns or page numbers, the entire document is considered pertinent to this response.

i

' 1 (i) " Report of Geological and Seismological Environmental Studies, Proposed Nuclear Power Plant, Bailly Generating Station, Baileytown, Indiana, for the Northern Indiana Public Service Company" dated March 8, 1968 and prepared by Dames & Mcore, Park Ridge, Illinois (Peges 4.1 to 4.10).

(ii) "Repor t - Site Environmenta?_ Studies - Geology, Seismology, Foundations, Proposed Nuclea; Power Plant, Bailly Generating Station, Baileytown, Indiana, Northern Indiana Public Service Company" prepared by Dames & Moore, Park Ridge, Illinois. (Section 2.5.4)

(iii) " Northern Indiana Public Service Company Preliminary Safety Analysis Report" (Pages 2-5-49 to 2-5-55)

(iv) Report 5676-005-07 " Report-Supplementary Investigation, Proposed Nucl ear Power Plant and Cooling Tower, Bailly Generating Station, Baileytown, Indiana, for Northern Indiana Public Service Company" dated March 31, 1972 and p epared by Dames & Moore, Park Ridge, Illinois (Pages 6 to 17).

(v) Report SL-3109 " Draft - Pile Testing Analysis for Bailly Generating Station - Nuclear 1",

dated June 10, 1974, and prepared by Sargent &

r Lundy. Transmitted by letter dated June 13, 1974 to Mr. John F. O' Leary of the NRC by Mr. H. P. Lyle of NIPSCO.

, (vi) Report SL-3109 " Pile Testing Analysis - Bailly Generating Station, Nuclear-1", dated September 6, 1974, prepared by Sargent & Lundy. Transmitted to NRC in September, 1974 (vii) Report SL-3130 " Supplementary Foundation Evaluatic' - Bailly Generating Station, Nuclear-1", oated September 6, 1974 prepared by Sargent

& Lundy. Transmitted to the NRC in September, t 1974.

(viii) Report SL-3205 " Analysis of Pile Driving Tests - Bailly Generating Station, Nuclear-1", dated September 15, 1975, prepared by 1

Sargent & Lundy. Transmitted by a letter dated July 14, 1978 from Mr. E. M. Shorb of NIPSCO to Mr. Roger S. Boyd of the NRC.

(ix) Letter dated December 29, 1976 from Mr. F. G.

Hiple of NIPSCO to Mr. Bernard C. Rusche of the NRC.

(x) Letter dated September 21, 1977 from Mr.

R. J. Bohn of NIPSCO to Mr. Edson Case of the NRC.

(xi) Letter dated October 7, 1977 from Mr. H. P.

Lyle of NIPSCO to Mr. Edson Case of the NRC.

(xii) Letter dated October 15, 1977 from R. J.

l Bohn of NIPSCO to Mr. Edson Case of the NRC.

(xiii) Letter dated October 20, 1977 from Mr. J. W.

Dunn of NIPSCO to Fr. Roger S. Boyd of the NRC.

(xiv) Letter dated October 20, 19 77 f rom f'.: . J . W.

Dunn if NIPSCO to Mc. Roger S. Boyd of the NPC.

(xv) Report SL-3629 " Design, Analysis and Installation

' of Driven H-Pile Foundations" dated March 8, 1978, prepared by Sargent & Lundy and Dames

& Moore. Transmitted by letter dated March 8, 1978 to Mr. Edson G. Case of the NRC by M: .

j E.M. bb mo Of NIPSCO.

i (xvi) Letter dated April 13, 1978 from Mr. E. M.

Shorb of NIPSCO to Mr. Edson G. Case of the NRC.

(xvii) Letter dated May 26, 1978 from Mr. H. P.

Lyle of NIPSCO to Mr. Roger S. Boyd of the NRC.

(xviii) Letter dated July 14, 1978 from Mr. E M.

Shorb of NIPSCO to Mr. Roger S. Boyd of the NRC.

I i txix) Letter dated July 14, 1978 from Mr. R. J.

! Boin of NIPSCO to Mr. Roger S. Boyd of the f

NRC.

I i

I

k (xx) Letter dated July 20, 1978 from Mr. R. J.

Bohn of NIPSCO to Mr. P )qer S. Boyd of the NRC.

(xxi) " Indicator Pile Program, Bailly Generating Station - Nuclear 1" dated September 26, 1978, prepared by Sargent & Lundy and Dames

& Moore. Transmitted by letter dated Sep-tember 26, 1978 to Mr. Roger S. Boyd of the NRC by Mr. E. M. Shorb of NIPSCO.

(xxii) " Supplementary Information on Driven H-Pile Foundations", dated December 4, 1978, prepared by Sargent & Lundy and Dames & Moore. Trans-mitted by letter dated December 4, 1978 to Mr. Roger S. Boyd of the NRC by Mr. E. M.

Shorb of NIPSCO.

(xxiii) Letter dated December 15, 1978 from Mr.

E. M. Shorb of NIPSCO to Mr. Roger S. Boyd of the NRC.

(xxiv) " Supplementary Information, Clarifications e and Alternatives to the Foundation Pile Design" I

dated June 29, 1979, prepared by Sargent

& Lundy and Dames & Moore. Transmitted by letter dated June 29, 1979 to Mr. Dominic B.

Vassallo of the NRC by Mr. E. M. Shorb of NIPSCO.

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(xxv) " Response to NRC Requests for Information of June 28, 1979", dated August 14, 1979, prepared by Sargent & Lundy. Transmitted by letter dated August 14, 1979 to Mr. Dominic B. Vassallo of the NRC by Mr. E. M. Shorb of NIPSCO.

(xxvi) Letter dated May 27, 1980 from Mr. E. M.

Sho"' of NIPSCO to Mr. Robert L. Tedesco of the NRC.

(xxvii) Letter dated May 28, 1980 from Mr. E. M.

Shorb of NIPSCO to Mr. B. J. Youngblood of the NRC.

(xxviii) Specification T-2967 " Steel H-Pfle Installation" prepared by Sargent & Lundy Engineers, Chicago, Illinois, including all post award correspondence.

, (xxix) Specification T-2983 " Pile Testing Work" prepared by Sargent & Lundy Engineers, Chicago, Illinois, including all correspondence.

j All of the above documents have been provided by NIPSCO to PCCI in response to " Porter County l

Chapter Intervenors' Second Request to UTPSCO for Production of Documents".

(b) Unless specifically noted in the documents listed in (a) above, all foundation types and installation

)

i techniques that were considered by NIPSCO were proposed by Sargent & Lundy Engineers, Chicago, Illinois and their consultants.

(c) The date on whicn each foundation type and installation technique was proposed is given in the response i to 48(a) above.

(d) A description of all tests, investigations and studies prepared by or on behalf of N1PSCO in relation to the foundation type or method ic provided 3

in the response to 48(a) above. In addition to these tests, investigations and studies, NIPSCO rel.'.d upon common analytical techniques and research studies in foundations by recognized experts.

, inese techniques and research studies are noted as references in the response to 48 (a) above.

] (e) Not applicable. PCCI's Third Set of Interrogatcries to NIPSCO does not contain an Interrogatory 12(d) .

49. Please identify the person or organization who installed the peizometers [cic] and tb_ relief wells within the Bailly excavation.

l ANSWER: The piezometers within the excavation were installed by Raimonde Drilling Corporation. The relle1 wells were installea by Midwest Dewatering Company, Inc.

l l

50. Please describe all methods of recording ground water levels and ash pond and interdunal pond levels by NIPSCO at all times p.ior to May 1, 1974.

l 1

, _ . . _ _ . , , . , . , - , _ , . . .-4 .,,_.-m- ,_~,.._,..w.. -_ .,.-,,__,.,...c.-, ..~.e - ,

AN3WER: From March 1972 when NIPSCO first began monitoring of pond levels, through September 1973, NIPSCO's records of inter-dunal pond and ash por.3 levels consist of handwritten tabulations of water levels taken from measuring stakes located in the respective ponds. Beginning in October 1973 and continuing through April 1974, NIPSCO utilized standard survey instruments and techniques to measure pond levels, and recorded the necessary information, including pond levels, on special data sheets developed for the  ;

monitoring program.

From October 1973 when the first monitoring well was installed, through April 1974, groundwater levels were recorded on weekly charts t; automatic level recorders on the individual wells.

All of the above records have been provided in response to PCCI's Second Request to NIPSCO for Production of Documents.

51. Please describe all pile tests performed by or on behalf of MIPSCO atter May 1, 1974. For each test please state:

(a) The locations where such tests were performed; (b) The reason for each test; (c) A description of each test and the date on which it was performed; and (d) The result of each test.

(e) A description of all documents which relate to l each test.

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l ANSWER:

, (a) The locations where pile load tests were conducted after May 1, 1974 are described within the reports j listed in NIPSCO's response to Interrogatory 28(a),

i

! except for 28 (a) (i) .

(b) The reason for each test was provided in response to Interrogatory 28(b).

(c) A description of each test and the date on which it was performed was provided in response to Inter-rogatory 28 (a) and 28 (f) , respectively.

(d) The results of each test were provided in response to Interrogatory 28 (g) .

. (e) A description of all documents which relate to each test is as provided below:

(i) All documents listed in response to Interrogatory 28(a), except for 28 (a) (i) .

(ii) Specification T-2967 " Steel H-Pile Installation" including all correspondence following award of the contract.

(iii) Specification T-2983 " Pile Testing Work" including all correspondence relating to the contract.

52. Please give the following information for the person swearing to the answers to these interrogatories; I

d

+

(a) Name 4

(b) Address

(c) Title (d) Capacity ANSWER

1 (a) R. J. Bohn.

(b) R.R.3, Box 501, Chesterton, Indiana 46304.

(c) Manager, Nuclear Staff.

(d) In charge of the engineering and construction of the nuclear project.

1

53. Please give the following information of each person who has provided or furnished information to the person identi-fied in Interrogatory 13, consulted with that person in the preparation of the responses to these Interrogatories, or other-wise aided in the preparation of the responses:

(a) Name i (b) Address i

(c) Title (d) Number (including subpart) of each Interrogatory with respect to which that person consulted, aided i

or provided or furnished information; and l

(e) The nature of the information or aid furnished.

i

! ANSWER: NIPSCO assumes that this Interrogatory refers to

! Interrogatory 52, rather than to Interrogatory 13 as stated.

o (a) Alan P. Severance.

(b) R.R. 3, Box 501, Chesterton, Indiana 46304.

(c) Mechanical / Nuclear Supervisor.

(d) & (e) Performed research and provided draft responses for Interrogatories 40, 41, 42, 43 and 47.

Provided draft responses for Interrogatories 12 through 17, 37, 38 and 39.

(a) Mark R. Granback.

(b) R.R. 3, Box 501, Chesterton, Indiana 46304.

(c) Licensing Supervisor.

(d) & (e) Performed research and provided draft responses for Interrogatories 1, 4, 5, 7, 8, 21, 23, 50 and 53.

(a) Mark T. Maassel.

(b) R.R. 3, Box 501, Chesterton, Indiana 46304.

(c) Civil / Structural Engineer.

(d) & (e) Performed research and provided draft responses for Interrogatories 3, 6, 18, 19, 20, 22, 28 through 34, 48, 49 and 51.

Provided draft response for Interrogatory 2.

(a) Mark V. Kaldenberg.

(b) R.R. 3, Box 501, Chesterton, Indiana 46304.

(c) Nuc_ ear Systems Engineer.

(d) & (e) Performed research and provided draft responses for Interrogatories 24, 25, 26, 27, 35, 44, 45 and 46.

l

l (a) Dale E. Bell.

(b) R.R. 3, Box 501, Chesterton, Indiana 46304.

(c) Mechanical Engineer.

(d) & (e) Provided information for response to Interrogatory 2.

(a) Forrest G. Hiple.

(b) 5265 Hohman Avenue, Hammond, Indiana 46325.

(c) Vice President, Electric Operations.

(d)&(e) Provided information for responses to Interrogatories 12, 14, 16, 17 and 36 through 39.

(a) Horace P. Lyle.

(b) 5265 Hohman Avenue, Hammond, Indiana 46325.

(c) Vice President, Electric Production.

(d) & (e) Provided information for responses to Interrogatory 13.

(a) Richard F. Brissette.

(b) Canonie Environmental Services Corp., 1408 N.

Tremont Road, Chesterton, Indiana 46304.

(c) Fresident.

(d) & (e) Provided information for response to Interrogatories 3.a (i) , (ii) , 22 and 30.

(a) J. A. Nieting.

(b) 5265 Hohman Avenue, Hammond, Indiana 4C325.

(c) Director of Rate and Contract.

(d) & (e) Provided information fer response to Interrogatory 15.

. . _. __ ______ ___ - _ J

1 l

William H. Eichhorn, Counsel for NIPSCO, and Russell J.

Bohn, Manager, Nuclear Staff, assisted in the wording and preparation of all Answers to Inter-rogatories.

NORTHERN INDIANA PUBLIC SERVICE COMPANY 4

By

) Russell E b h#

STATE OF INDIANA )

) SS:

COUNTY OF LAKE )

The undersigned, Russell J. Bohn, being duly sworn upon his oath states that he is employed by Northern Indiana Public Service Company as Manager, Nuclear Staff, for the Bailly Nuclear Plant; that he is informed on the matters of inquiry of Porter County Chapter Intervenors' interrogatories; that in answering the above and foregoing interrogatories he has personally reviewed or caused others to review the files and records of Northern Indiana Public Service Company and has caused information to be gathered from employees and officers of Northern Indiana Public '

Service Company, its contractors and consultants; that the answers to the above and foregoing interrogatories are true and correct as he has been informed and veril believes.

7 Russel[,/J. "dohn Subscri ed and s 'orn to before me, a Notary Public, this

/,f_ day of , 1981.

A k L .L r d>f -

Notiry Pub._tc My Commission expires:

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