ML20082N671

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Discusses Recommendation for Suppl to Board Notifications83-165 & 83-153 Re Diesel Generator Bldg.Comments & Recommendations of J Kane & F Rinaldi on Task Group Rept & Reopening of Hearing Provided
ML20082N671
Person / Time
Site: Midland
Issue date: 11/22/1983
From: Hood D
Office of Nuclear Reactor Regulation
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20080T401 List:
References
FOIA-83-707 ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8312070298
Download: ML20082N671 (4)


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November 22, 1983 Docket Ros: 50-329 OH, OL DISTRIBUTION:

and 50-330 OM, OL Docket Nos. 50-329/330 L,B f4 r/f nsam MEMORANDUM FOR: Darrell G. Eisenhut, Director 1L Division of Licensing TNaak MDuncan FROM:

Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing SUDJECT:

RECOMMENDATION FOR SUPPLEMENTAL BOARD NOTIFICATION REGARDING MIDLAND DIESEL GENERATOR BUILDING f

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Board Noti'fication 83-165 dated October 26, 1983, transmitted the report cf a special _ task group on the re-evaluation of the structural design and construc-tion adecuacy of the Midland Die el Generator Building (DGB). The re-evaluation had been pronoted by the concern of Dr. Landsman in BN 83-109. Also, BN 83-153

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dated October 11, 1983, had transmitted a reply to an inquiry by NRR's Director of tha Division of Engineering as to whether or not any member of that Division p

or NRC consultant shared Dr. Landsman's specific technical concerns <

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. Review'oftbetasigroup'sreportby6thers,'uidtEeNRC'sinternalprocessof i

soliciting comments on the Applicant's Proposed Findings of Fact and Conclusions of Law on Renedial Soils Issues, have resulted in recent coranents on the DGB which are material and relevant to issues before the. Board.The connents fur-ther indicate the views of NRR members and consultants regarding Dr. Landsman's concerns as expressed in BN 83-153.

Because of the contents of the task group's report, but also, in part, because of these supplemental corrients, the NRC staff stated during the Midland OLOL hearing session of November 19, 1983, it would advise the Board by December 1,1983, of its position on the need to reopen the record on the special task group's re-review of the DGB. The staff also noted during the November session that if it takes the position that the record need not be re-opened, it will file responsive findings with respect to the DGB on December 9, 1983.

As part of this decision process, Messrs. J. Kane and F. Rinaldi were requested to provide coranents on the task group's report i

arid to provide their reconnendation as to whether of not the hearing should be reopened. Beth replied November 18, 1983.

I reconnend that the Board be notified of these supplemental connents relative to the DGB.

These are discussed below.

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Comrents of Joseph Kane on Applicant's Fir.dinos 1,

8 The task group's report, in part, discussed the results of an interview with Mr. J. ' cne:

5 "With regard to the structural analyses using actual 56ttle-ment data. Mr. Kane observed 70-80% of the cracks to be in areas where the analyses indicated areas of high stress.

Mr. Kane has documented his concerns in menos dated August 2 1983, and are included in Attachments 1 and 2."

[page AII-3.

In Attachment 1 of the task group's report, page ?, Mr. Kane noted he per-sonally had sericus problems and questions with a report documenting an analysis perforred by an NRC consultant, the U.S. Naval Surface Weapons Center (NSWC), and explained why he had not pursued his concerns at that time. He acknowledged that the staff position does not rely on the results or conclusions of the NSWC study.

In Attachnent 2 of the task group's report, second paragraph, Mr. Kane questions why total settlenents were used in the NSWC study to compute 1

maximum stresses and movements in checking for areas of cracking.

Mr. Kane noted the need to clarify this with NSWC and re-examine conputed-i stresses and movenects with availabl6 track" mapping.

He 'elso' noted'tha t in several of the walls there does appear to be correlation of cracks with high stress-areas and that this should be discussed with NSWC.

. Supplemental information regarding 'the ebove concernt in BN'83-165 is con-e tained in a memorandum from G. Lear dated October 14, 1953, which transmits to OELD the Geotechnical Engineering review connents on the app 11: ant's proposed findings of fact and conclusions of law regarding technical aspects of-the OM-OL proceeding. The comments were prepared by J. Kane.

On page 12 (Enclosure 11 Mr. Kane notes the results of his examination of the results of the NSWC report and attaches a table showing the results of his comparison from which he concludes that in the majority of locations, cracks do appear in the identified areas of high stress. Mr. Kane notes the need to resolve this difference with NSWC, and that if his conclusions are correct, "both the applicant's findings and the hearing record need to be corrected in order for the Board to make the proper findings."

I recommend that Enclosure 1 be forwarded to the Midland Board for supple-mental information to BN 83-165 and BN 83-153, even thou'gh the staff did not rely on the NSWC study nor the applicant's analyses, for its conclu-sion regarding the adequacy of the DGB. The information is potentially

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relevant since the concern, if valid, would be contrary to other 'nforma-tion on the record, which if relied upon by thq Board, could lead to

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improper findings or cause the issue to be viewed ir. a different light.

Specifically:

The NSWC report (Consumers Power Company Exhibit 30) concluded, in part, that:

"the analyses show that other areas [other than at the duct bank areas] of the DGB walls still have high strerses and in all pro-bability should also be cracked. But no cracks were observed in these areas." [Statments in brackets ano underlining added.J and that:

"2. The measured settlement values imposed on the analytical nodels resulted in very high stresses (over ten times yield) in areas where no cracks now exi:t. Thus indicating that this settle-ment value more than likely was not seen by this structure."

Similar statements are made in the hearing by J. Matra of NSWC (Tr. pp.

11094 - 11127) and K. Wiedner (Tr. p. 10815).

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'CommentsbyO'.S.Arv(v'Coros'ofE'ndineers Mr. G. Lear's nemorandum of November 16,1983 (Enclosure 7) transmits to i

LB #4 an October 28,.1983, coverletter f.ron the Corps. of Engineers (COE) with' iwo memoranda containing the cornents of H. N. Singh. Mr. Singh's comments further explain why "the Corps is not in a position to certify the adequacy of the structure." Mr. Singh expresses numerous differences with the Applicants proposed findings of fact, and presents significant conclusions of his own.

For exanple, Mr. Singh finds " surcharging has created major structural distress in different aarts of the building,"

"The Applicant's decision to cast concrete :to complete construction of the DGB) during the surcharge does not comply with the sound construc-tion practices."... "There has been considerable warping of the structure during and subsequent to the removal of the surcharge"... " numerous cracks which have developed due to the settlement have been ignored for o

the purpose of stress evaluation."... "The soil spring constant used in the analysis is not appropriate"... "It is clear from the east wall that i

all the cracks which are inclined and have developed after the release of

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l the duct banks are shear cracks"... "Obviously, all of the Applicant's j

analyses are erroneous.. If the structure can not be correctly analyzed, i

that is not a justification to declare it structurally adequate." 11 also relevant to the Board because as a composit document, it may cause the Board to view the Corps' position on the DGB in a dif-ferent light.

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4 III. Coments of J. Kane on Task Group's Report and Recommendations to Reopen Hearing In Enclosure 3, Mr. J. Kane notes numerous conflicts between hearing testimony and the Task Group's report. Paragraph 4C of Enclosure 3 states that an incorrect conclusion has not yet been brought to the Board's atten-tion. Mr. Kane presents several reasons why the hearing should be reopended on the DGB. Enclosure 3 speaks for itself as to why it is material and relevant to the issues before the Board. Accordingly, the Board should be netified of this document.

IV.

Evaluation of F. Rinaldi on need to Reopen Hearing In Enclosure 4, Mr. Rinaldi, using the same criteria es Mr. Kane in III above, reaches the contrasting view that the hearing record need not be reopended on the DGB. The issue of whether the Task Group's report pro-vides a sefficient basis to reopen the hearing is material and relevant to issues before the Board. Hence, Mr. Rinaldi's views should be for-warded to the Board.

Dr S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing

Enclosures:

As stated cc: See.next page M'

DL:LB #4

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DHood/hmc M TN a 11/ ;/83 1

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