ML20030B123
| ML20030B123 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 07/31/1981 |
| From: | Rapkin A ILLINOIS, STATE OF |
| To: | NORTHERN INDIANA PUBLIC SERVICE CO. |
| Shared Package | |
| ML20030B125 | List: |
| References | |
| NUDOCS 8108060100 | |
| Download: ML20030B123 (8) | |
Text
..
sO
}gl.ATED CORBgspOSDENCE
\\
UNITED STATES OF AMERICA N
NUCLEAR REGULATORY COMMISSION
' C As i!08l 3 Lf g
BEFORE THE ATOMIC SAFETY AND LICENSING BOA
'l,e n
g 4
In the Matter of
)
k> lf i ef
//
)
NORTHERN INDIANA PUBLIC
)
Docket No. 50-367 SERVICE COMPANY
)
(Construction Permit. 8_ /p (Bailly Generat'ing
)
Extension)
%\\
Station, Nuclear-1)
)
& G{fff[
+
PEOPLE OF THE STATE OF ILLINOIS' SECOb SET OF INTERROGATORIES TO NIPSCO g
f;fjg Os 7g
.p E*740;%
g People of the State of Illinois, by its attorne j
rone C.
I 50 Fahner, Attorney General, pursuant to 10 CFR S2.740b, he serves upon Northern Indiana Public Service Company ("NIPSCO")
the following Interrogatories to be answered separately and fully in writing under oath by its officer or agent, within 14 days of the date of service.
If any of the following Interrogatories cannot be answered in full, please so state, and answer to the fullest extent possi-ble.
" Identify" when used in reference to a person means to state his/her full name and present address, if known, and his/her pre-sent or last known positica and business affiliation.
For any study or report identified in answer to any Interro-gatory, identify the page (s) at which the relevant information appears.
"NIPSCO," when referred to in these Interrogatories, includes NIPSCO's employees, agents, and contractors.
8108060100 810731' I
PDR ADOCK 05000367 G
PDR g
1.
With respect to the sheet piling at the Bailly N-1 site:
a) Describe such sheet piling.
b) Why was sheet piling installed?
c) Did the NRC Staff require that NIPSCO install the sheet piling?
d) Did the NRC Staff request that NIPSCO install the sheet piling?
e) When was sheet piling installed?
f) By wnom was sheet piling installed?
g) Was sheet piling installed because the slurry wall was inadequate in some way?
h) Why was cheet piling not included in NIPSCO's dewatering plan at the time the Construction Permit was issued?
i) When did the concept and/or feasibility of sheet piling as a method of dewatering first become known to NIPSCO?
j) Why was a slurry wall rather than sheet piling installed around the perimeter of the excavation?
2.
a) Does the slurry _ wall in any way create, or create additional, hydrostatic pressure in Unit 3?
b) If so, why?
3.
a) What is the present elevation of the bottom of the excava-j tion for Bailly N-l?
b) What is the lowest elevation that the excavation will reach if construction is resumed and completed? -.
4.
What is the lowest depth of the slurry wall?
5.
What is the lowest depth of the. sheet piling?
6.
What is the depth of Unit 2 at the slurry wall?
7.
a) When did NIPSCO first learn that it would be necessary to dewater from Unit 3?
b) Describe all tests or studies performed prior to the Construction Permit hearing to learn about the location and amount of groundwater at the Bailly N-1 site.
c) Were studies of materials from Unit 3 conducted at the Bailly N-1 s.ite prior to Construction Permit hearing?
d) When did NIPSCO first know of the existence of Unit 3?
e)
- 1) Are Bailly Generating Units 7 and 8 founded on piles?
?) If so, to what depth do their piles extend?
- 3) Did NIPSCO dewater from Unit 3 when constructing either Bailly Generating Unit 7 or Bailly Generating Unit 8?
- 4) Approximately how many gallos.s of water per day at I
the maximum were removed from the excavation sites during peak periods of dewatering for the construction of Bailly Generating Units 7 and 8?
- 5) What was the approximate total amount, in gallons, of water removed from the excavation sites during dewatering for the construction of Bailly Generating Units 7 and 8?
i 8.
R. J.
Bohn at his deposition on July 28, 1981. referred to an underground tunnel encircling the Bailly N-1 excavation.
Pleas. describe this tunnel, its elevation, dimensions, and !
precisa location, its purpose or function, when it was installed, its relation to and effect on, if any, the slurry wall.
9.
R.
J.
Bohn at his deposition on July 28, 1981 referred to NIPSCO's submission to the NRC of NIPSCO's plans with respect to the pumphouse for Bailly N-1.
a) Describe the plans which have been submitted.
b) When were such plans submitted?
c) Did the NRC require that such plans be submitted?
d) Did the NRC request that such plans be submitted?
e) Why were such plans submitted?
f) Will NIPSCO begin construction of the pumphouse prior to completion of the NRC's consideration of such plans?
g) When does NIPSCO expect the NRC to complete consideration of such plans?
- 10. Are there gravity drains presently at Bailly Generating Units 7 and 8?
a) If so, how many gravity drains are there at each of those Units?
b) What purpose do they serve?
c) Approximately how much water flows through each such drain per day?
d) To where is such water diverted?
i
- 11. Are there presently internal pumps at Bailly Generating-Units 7 and 8 to deal with groundwater seepage?
J a) If so, how many such internal pump 3 are there at each of those Units?
b) Approximately how much water is pumped by each of them. -.
-. =.
\\
per day?
c) TO where is such water diverted?
12.
a) Does NIPSCO expect groundwater seepage into Bailly N-1 after construction is completed?
b) Describe the basis for the answer to Interrogatory #12 (a).
c) Identify and describe all communications, whether verbal or written, between NIPSCO and its consultants and between NIPSCO and the NRC regarding post-construction groundwater seepage into Bailly N-1.
13.
a) Does NIPSCO plan to seal, in any way, the foundation of Bailly N-l?
b) If so, describe such plans in detail, c) Describe the basis on which NIPSCO believes that such sealing will be adequate to reduce or eliminate groundwater seepage.
1 i
- 14. What effect, if any, will hydrostatic pressure from either Unit 1 or Unit 3 have on:
1 a) the Bailly N-1 plant foundation?
b) the piles?
c) the plant as a whole?
l
- 15. Does NIPSCO plan to seal, at any time in the future, any or i
all of the 49 monitoring wells described in NIPSCO's answer to Interrogatory #18 (c) of Illinois' First Set of Interrogatories?
a) If so, when?
b) If so, how?...
I j
o 16.
At the time the Construction Permit for Bailly N-1 was issued, what was the maximum amount of groundwater, measured 1
in gallons per day, which NIPSCO estimated would be removed from the excavation at peak periods of dewatering?
17.
At the time the Construction Permit for Bailly N-1 was issued, what was the overall total amount of groundwater, measured in gallons, which NIPSCO estimated would be removed from the excavation?
i 18.
What is the overall total amount of groundwater, measured in gallons, which NIPSCO now estimates will be removed from the Bailly N-1 excavation?
19.
With respect to NIPSCO's answer to Interrogatory #18(a) of Illinois's First Set of Interrogatories:
a) How many holes were made in the ground during the 9 test programs?
b) What percentage of such holes were made under the site of Class I structures?
c) What percentage of such holes penetrated Unit 27 d) What percentage of such holes penetrated Unit 3?
- 20. With respect to NIPFPC's answer to Interrogatory #18 (b) 4 of Illinois' First Set of Interrogatories:
a) Did NIPSCO attempt to install piles more than 25 times by some form of jetting?
b) If so, how many times in total did NIPSCO attempt to install piles by some form of jetting?,
c) What percentage of such total -jetting attempts were made under Class I structures?
d) What percentage of such total jetting attempts penetrated Unit 27 e) What percentage of such total jetting attempts penetrated Unit 37
- 21. With respect to NIPSCO's answer to Interrogatory #26 (a) of Illinois' First Set of Interrogatories, describe in detail the manner in which the proposed method of dewatering is designed to preclude subsidence of subsoil structures at Bailly N-l?
- 22. With respect to NIPSCO's proposed groundwater recharge system:
a) Does NIPSCO have any plans to test for differences in water quality between the groundwater in its natural state in the Indiana Dunes National Lakeshore and the water which will be injected into the ground by means of the recharge system?
b) Does NIPSCO have any plans for dealing with any differences in water quality between the groundwater in its natural state in the Indiana Dunes National Lakeshore and the water which will be injected into the ground by means of the recharge system?
Respectfully submitted, TYRONE C.
FAHNER Attorney General State of inois BY:
ANNE p PKIN
~
Ausistant Attorney General ANNE RAPKIN MARY JO MURRAY Assistant Attorneys General Environmental Control Division I
188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312] 793-2491
, _ _ _ _ _ _ _ _ -.