ML20093B747
| ML20093B747 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/10/1980 |
| From: | Lear G Office of Nuclear Reactor Regulation |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX17-008, CON-BX17-8, FOIA-84-96 NUDOCS 8011240409 | |
| Download: ML20093B747 (3) | |
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UNITED STATES
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NOV 1.01980 i
MEMORANDUM FOR: Robert L. Tedesco, Assistant Director for Licensing Division of Licensing THRU:
\\ James P. Knight Assistant Director for Components and Structures Engineering l
q Division of Engineering FROM:
)
George E. Lear, Chief Hydrologic and Geotechnical-Engineering Branch Division of Engineering
SUBJECT:
INTERROGATORIES FOR PERMANENT DEWATERING SYSTEM -
MIDLAND PLANT - UNITS 1 AND 2 Enclosed are interrogatories on the dewatering system at Midland. These interrogatories are similar to those furnished to Darl Hood, LPM on September 25,1980. However, the fonn and tone of those interrogatories required additional field testing and analyses.
The form used here permits the applicant to base its responses on data and infomation already available.
A preliminary copy of the enclosure was provided to Darl Hood on November 7, 1980. These interrogatories were prepared by R. Gonzales.
W George f. Lear, Chief Hydrologic and Geotechnical Engineering Branch Division of Engineering
Enclosure:
As stated cc: w/o enclosure R. Vollmer w/ enclosure G. Lear L. Heller J. P. Knight J. Kane #
F. Miraglia F. Rinaldi W. Divins A. Cappucci H. Levin D. Hood W. Paton 9 c/ n M p Y p 9 l
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Midland Plant. Units 1 and 2 Hydrologic Engineering Section Interrogatories Docket Mos. 50-329/330
- 1) In your response to request 24-a, you used an error function equation to define water level rise. The equation used should have a 4 in the denominator instead of a 2 (i.e., "4Kiit/n,").
Have any changes been made to this equation since preparation of your response? Have any revised analyses, to detemine rebound time following a prolonged dewatering system failure, been made since your response to request 247 If so, wh'at was the effect of these reanalyses on rebound time?
- 2) Have any calculations been made to determine how failure of non-seismic pipes would affect the capability of the dewatering system to maintain water levels at a safe elevation? If so, for which pipes and at what locations 'did you postulate failure? What was the impact of these pipe 1
failures on the effectiveness of the dewatdring systen.
If failure of the circulating water pipes was not considered, why not?
l
- 3) In your response to request 24-b, you concluded that there is very little t
recharge in the area of the circulating water discharge structure. This I
j conclusion is questionable because it is based on a pumping test whose j
results were subject to interpretation because of the difficulty encountered in maintaining a constant pumping rate. Have you conducted
'l any additional tests or done any calculations to verify your conclusion?
If so. describe any additional tests and the results obtained. How did t
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these results influence your initial conclusion that there is very little I
recharge in the area of the circulating water discharge structure?
- 4) In your response to request 24b, you used a specific yield coefficient of 14 percent for detemining the voltane of water to be removed from storage within the plant dikes.
In detemining average permeability, you used a value of 30 percent. Under water table conditions such as exist at Midland, the tems " specific yield" and " effective porosity" are equal.
Why then were two d'ffferent values used?
- 5) Have any tests been conducted to detemine if Dow Chemical's Tertiary Treatment Pond, located west of the Midland Plant, could seep through or bypass the plant dike and be a source of groundwater at the plant?
If not, are such tests needed? If not needed, why not?
- 6) Are there any chemical substances in the Dow pond which could reduce the effectiveness of the west plant dike or the groundwater dewatering system at the Midland plant.
- 7) On what basis do you conclude in your response to request 24-b that the jf intake and pump structures cut off seepage from the cooling pond? Does 1
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- i titis conclusion recognize the existance of 5 to 10 feet of natural sand l!:
below the intake and pump structures? If not, why not?
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e.n Gene'ee oMises: 212 West Mkhtena Avenue. Jacason. Ms de201. (S17) 7864880 J
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aMeO William D. Paton My 5'""
Counsel for the NRC Staff eg g U.S. Nuclear Regulatory Commiesion an
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Washington, D.C.
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Dear Mr. Paton:
Attached hereto are Responses to NRC Staff Interrogatories dated November 26, 1980. The Applicant will file Responses to the Third Set of NRC Staff Interrogatories prior to the prehearing conference presently scheduled for April 2, 1981.
Very truly yours, M
sJu James E. Brunner Enclosure I
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- O-i INITED STAT 25 0F AMRICA
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NUCLEAR REGULATORT COMMI!3 ION a
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BEPORE THE ATOMIC SAFETT AND LICENSING BOARD v..
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Docket Nos. 50-329-0N CONSUMERS POWER COMPANT
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50-330-0K
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50-330-OL (Midland Plant, Units 1 and 2)
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50-329-OL
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CONSUMERS POWER COMPANT'S (APPLICANT'S)
ANSWER TO NRC STAFF INTERROCATORIES DATED 11/26/80 e
i Interroaatory 1.
As a result of settlement and inadequate compaction in the fill area, you t
j have proposed remedial actions and you have agreed to re-analyze the seismic /
structural analyses of the Category 1 structuras located in this area.
i 1(a) Have you verified and evaluated any changes in the design safety margins available for any Category I structures by performing structural re-analysis?
Response
For the diesel generator building, a seismic re-analysis using FSAR seismic design criteria and a structural re-analysis have i
been completed.
For the service water pump structure, the auxiliary building, and the borated water storage tanks, seismic /
structural analyses are in progress.
1(b) If the answer to (a) is yes, please provide documents related to any structural re-analysis performed.
Response
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Documents pertaining to re-analyses df the diesel generator d fespnMW, 4
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building referred to in part 1(a) will be provided for inspection 4n be.
n pwi now at Bechtel Associates Professional Corporation in Ann Arbor in the i
i near future. Documents respecting design analyses of other structures l
identified in part 1(a) will be provided when such s.siv n: nre co:31stM.
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1(c) If the answer to (a) is no, please state the reasons for not performing '
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Response
Not applicable.
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1(d) If the answer to (a) is no, but you plan to make such re-enalysis, please state when you plan to do so.
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Response
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The schedule for structural re-analysis of pertinent structures is as l'
i follows:
6/15/81 Service water pump structure - detailed design, including
'I structural and seismic considerations sufficient to lac Q
contracts to facilitate conscruction.
1' 6/15/81 Auxiliary building - updated conceptual design for under-pinnings, including structural and seismic consideration sufficient to let contracts to facilitate construction.
5/1/81 Borated water storage tanks - detailed design includius structure and seismic considerations sufficient to allow initiation of remedial measures on or before this date.
It is anticipated that conceptual designs, based upon preliminary
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structural and seismic analyses, will be complete by 4/15/81 for the service water pump structure and boracid water storage tank fixes.
f Further, an update of the conceptual design for the. auxiliary building underpinnings will be completed by 4/15/81, based upon preliminary structural and seismic considerations.
(The above seismic analyses are f1 being performed according to the method spelled out in the response to i
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1(e)).
4' 1(a) Have you factored into any re-analysis information contained in, or resulting from, a letter from Robert Tedesco to Vice President J. Cook dated October 14, 1980, concerning seismological input data acceptable to the Staff 7 i
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~l Applicant objects on the ground that this question goes beyond the
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limited jurisdiction conferred by the December 6,1979 Order, that
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the seismic re-analysis requested by Mr. Tedesco in the October 14,
- g 1980 letter should be reserved for the operating license hearing, and, hence, that it is irrelevant to these proceedings. Subject to that 3
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objection, Applicant answers sa follows: The pending seismic re-analy-sis requested in the October 14, 1980 Tedesco letter has been considered
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in arriving at the following approach towards designing and analyzing M
the remedial fixes for the auxiliary building electrical penetration area, the service water pump structure, and the barated water storage tank ring foundation: Seismic forces obtained by application of FSAR
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input criteria (i.e. modified Housner spectra and maximum accelega-i gM unm64 eh(af -
tion anchored at.12 g) will be multiplied by a factor of 1.5.
Forces thus determined will be combined with other loads in accordance with i
i*:i applicabla load combinations in arriving at design (cont'd) 4 a
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' parameters for the remedial asasures. In addition, with respect to the t..a Diesel Generator Building, Bechtel is attempting to evaluate the total I
1 margin which actually uists in excess of FSAR seismic design criteria.
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- 4f' IJhen discussions with the NRC Staff respecting possible redefinition of j;i seismic criteria applicable to the entire Midland site are complagted,S h. P i'
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4-d Applicant will evaluate the necessity for sei e re-analyses ol any or
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- all Category I Structures, including those founded partly or entirely on plaec fill.
- i 1(f)
If the answer to (e) is yes, please provide copies of all docssments
- j relating to that re-analysis.
Resnonse 4
The documents pertaining to the design analyses of the remedial fixes 7
for.the service water pump structure, the auxiliary building, and the
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' i borated water storage tank ring foundation (using the 1.5 margin j
factor) as stated in the response to part 1(b) will be provided. Applicant s.
1 objects to providing documents relating to the analysis of total margin in ii; excess of FSAR seismic design criteria for the Diesel Generator Building, i
for the reasons ' stated in the first sentence of Applicant's response to i i!i part 1(e).
For the same reason, Applicant objects to providing in this n
li proceeding future seismic re-analysos of Midland structures as requested 4
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by the October 14, 1980 Tedesco letter.
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1(g)' If the answer to (e) is no, please state if you plan to make an analysis y
incorporating that data, which structuras you plan to re-analysis, sad l
when you plan to do so.
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Response
See the response to 1(e).
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-5 1(h)
If you believe re-analysis is not required for any sucha category I
,l structure, please state for each structure why such re-analysis is not I
required.
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Response
f See the response to 1(a).
.s 1(i) Was the floor response spectra for the diesel generator building generated on the assumption that the shear wave velocity would not be lower than 500 feet per second?
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Response
i Yes.
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1(j)
If the answer to Question (1) is negative, please state the assumption used with respect to shear wave velocity.
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Response
Not applicable' 1(k) How have you assured yourself that the soil shear wave v elocity will not be less than 500 feet per second for the life of then planc?
Responsa j
See the Response to 10 CFR 50.54f Question 24 (a) regarding plant fill.
Interrogatory 2 The fill material under the northern wing of the service water pump structure has been found to provide inadequate support. While the portion of the structure over the fill material is being supported by the main structure founded on
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natural material, through cantilever action, it is stated in Management i
l, Corrective Action Report No. 24, Interim Report 6, issued September 7, 1978,
!j that the total design loads cannot be supported by the main structure. Your I
proposed remedial action will utilize corbels attached to the side of the l
structural wall by bolts. The corbels are to be supported by pilings plac'ed underneath them.
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2(a) What alternative corrective actions did you consider for supporting the cantilevered portion of the Service Water Pump Structure?
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Response
- f II The present design proposal for the service water pump structure makes use of a continuous wall footing which penetrates to the till level.
r In the past the following alternatives wer. considerad:
(1) removal
- i and replacement of fill, (2). jack piles, (5) caissons and (4) piles j
connected to the structure with corbels.
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<i 2(b) Was one of the alternatives considered to provide a stable solid
- l foundation support of the cantilever portion of the structure down to the. glacial till rather than the concentrated support design eventually chosen?
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Response
Both the present proposal (wall footings) and the previous proposal d,
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(piles) t:ould provide a stable foundation for the structure.
N 2(c) What structural analyses for each cf these alternatives did you perform?
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Responsa j!
A structural analyeis, together with a design analysis, ir being performed
- +,j for the design based upon wall footings. Prior to the recent design change
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,t 2(d) Please provide copies of documents relating to any analysis described in lj 2(c) above, ii
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Documents pertaining to the analysis of the wall footings will ba j
.j provided when the analysis is completed.. Documents pertaining to analyses of any other design approach are not relevant to this mattsr.
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2(e). Did'you factor into any analysis identified in 2(c) above the information 2
contained in a letter from Robert Tedesco to Vice President J. Cook, dated October 14, 1980, concerning seismological input duca acceptable to the Staff.
4
Response
- I See the answer to 1(a).
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2(f) Explain why each of the alternatives identified in 2(a) above was rejected or accepted.
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Response
Alternative (1) (removal and replacement of fill) was rejected for two I
reasons, i.e. cost and difficulty of dewatering during construction.
Alternatives 2 'sud 3 were rejected because the continuous footings approach would provide a design which is believed to be more acceptable to the NRC Staff, although eicher approach would provide an adequate solution. Alternative 4 was rejected because other designs would provide larger margins for seismic forces.
- i 2(g)
For those alternatives that were rejected, but for which no analysis was
- 1 identified in 2(c) above, give the reasons for not considering those ij alternatives.
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Response
See 2(f).
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2(h) What anni.yses have you done to assure yourselves that the long icagitudinal bolts which will be used in the remedial action will withstand the force
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produced in the bending mode?
2(i) Please provide copies of documents relating to any analysis identified in 2(h).
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f1 2(j) If no such analysis has been performed do you plan to do an analysis and if so when?
j 2(k) Do you have a plan for pre-service and in-service inspection of the
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integrity of the bolts during the life of the plant?
2(1) If the answer to 2(k) is yes, provide a copy or description of that plant.
2(m)
If the answer to 2(k) is no, state the reasons that such a plan is noe necessary.
2(n) Wat type of bracing.(if any) will be provided to assure that the vertical c'
piling vill resist horizontal forces?
2(o) What analysis have you done to assure the adequacy of any horizontal braces identified in 2(n).
2(p) Please provide a copy of any analysis identified in 2(o).
Response
Applicant objects to these questious, as they pertain to a design option which is no longer being proposed.
,t 2(q) What analyses have you done to assure yourselves that the piling under the service water pump structure will provide adequate vertical support after the occurrence of a postulated epthquake (OBE)?
Response
Applicant is presently in the process of analyzing the latest design f
proposal for adequacy under OBE and SEE stresses. Applicant will respond f
j to this question when such analysis is completed. Obviously, the adequacy 1
of the pile-corbel design is no longer relevant to these proceedings.
'1 2(r) What analyses have you done to assure yourselves that the piling under l
the service water pump structure will provide adequate vertical support i
after the occurrence of a postulated earthquake (SSE)?
Response
i, See 2(q).
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4 2(s) Please provide a copy of any analysis identified in 2(q) and 2(r).
Response
See the response to Question 1(a).
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2(t) Did you factor into any analysis identified in 2(r) above the information
' contained in a letter from Robert Tedesco to Vice President J. Cook dated October 14, 1960, concerning seismological input data acceptable to the Stafft
Response
See Applicant's Response to 1(e).
Interrogatory 3 The following questions refer to the remedial actions at the service water pump structure.
3(a)
Is the corbel design such that it depends upon a friction-fit with the service water pump strucute's north wall resulting from the pre-tensioning of the long longitudinal bolts.
3(b) How have you assured yourselves that this friction-fit will be maintained under all the design loads for the building?
j 3(c)
If the answer to 3(b) is based on tests or other analysis please identify and provide copies of tha analysis or test results.
a 3(d) How have you assured yourselves that the concrete at the interface between y
the corbel and the Service Water Pump Structure can adequately resist bearing pressures developed as a result of pre-tensioning of the bolts.
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3(a)
If the answer to 3(d) is based on tests or other analysis please identify i
and provide copies of the analysis or test results.
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Response
See the Rispense to Interrogatories 2(h) - 2(p).
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'?i Interrogatory 4 In the response to Question 15 of the NRC request, regarding plant fill, it is stated that, " differential settlement primarily induces additional strain, which is a self-limiting effect and does not affect the ultimate strength of r
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the structural members." Additional clarification of this statement is needed.
4(a) Why do you classify the resulting strains as self-limiting in nature?
4(b) How do you reconcile your statement quoted above with your statement j
concerning the Service Water Pump Structure in the Management Corrective Action Report No. 24, Interim Report 6, issued September 7, 1978 that the total design loads cannot be supported by the main structure.
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Response
Applicant will provide a response to this Interrogatory prior to the 4
prehearing conference scheduled April 2, 1981.
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i Interrogatory 5 3
Your response to Questions 14, 28 and 29 of the NRC request regarding the e
causes of cracks due to settlement, the significance of the extent of cracks, and the consequences of cracking, addressed only the existing condition of the Category I structures.
5(a) Have you performed analyses which provide tension field data under design load combinations at any crack locations for each Category I structure.
' Response There is a possibility that future differential settlement could cause larget rebar stresses and new or larger cracks.
In such an instance, the larger cracks may be indicative of increased rebar stresses. However, 1
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for concrete, the existence of any crack would not be significant except
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as an indicator of rebar stresses (and except for corrosion affects).
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!5 To account for the possibility of increased rebar stresses due to future differentialsettlement,Applicanthasconservatigefy ge gg I
rebar stresses which would be produced by future differential settlement.
The method directly predicts future rebar stresses without predicting future crack sizes.
With regard to the auxiliary building and the service water pump. structure, t
since neither building is expected to undergo appreciable differential settlement in the future, the problem of " crack propagation", which t
evidences rebar stresses produced by such settlement, does not exist.
With respect to the borated water storage tank, Applicant will determine the necessity of further crack evaluation following its decision on 4
remedial actions to be undertaken.
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5(b) Provide documents relating to data or analysis described in Part(s).
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Response
Applicant will provide such documents as a part of its structural re-analysis hbh T W T-package described in the answer to Question 1(b).
5(c)
If the answer to (a) is no, state why it is not necessary to perform that analysis.
Response
See Response 5(a).
e 5(d) Have you perfonned any analyses to show the limiting tensica field conditions in which a c-ack will not propagate.
4
Response
No.
5 (e) Pr6 vide documents relating to data or analysis described in Part(d).
Response
Not applicable.
5(f)
If the answer to (d) is no, state why you do not believe it is necessary to perform that analysis.
Response
The problem of crack propagation is accounted for in Applicant's present analysis by the approach taken in the response to Question 5(a), supra.
In Applicant's opinion, that analysis is equivalent to a " limiting tension field snalysis", since the important result of such an analysis would be a predicted rebar stress.
5(g) What analyses have you performed prior to loading or surcharging of any structures or tanks to assure that existing cracks will not further propagate?
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Response
None.
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'i Interrogatory 6 Since the fill was replaced by other material, such as lean concrete, in the vicinity of the auxiliary building and of the feedwater valve pits, the soil 1
properties of the foundation material have been changed.
6(a) Have you performed new seismic / structural analyses that utilizes the.
new soil properties, (e.g. damping valves and shear modules).
Response
't Such an analysis is presently in process.
6(b)
If the answer to (a) is yes, please provide documents relating to such seismic / structural analysis.
Response
Documents relevant to such analysis will.be,probided along with the structural re-analysis package specified in the response to Question 1(b).
6(c)
If the answer to (a) is no, please state the reasons for not performing such new seismic-structural analysis.
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Response
Net. applicable.
6(d) If the answer to (a) is no, please state your basis for concluding that these structures will comply with current NRC criteria.
Response
t Not applicable.
- f 6(e) If the answer to (a) is yes, have you performed a new soils structural interacticn analysis for the auxiliary building and the feedwater isolation valve pits.
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Response
e The seismic / structural analyses currently in progress considers the i
effects of soils-structural interaction.
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6(f) If the answer to' (e) is yas, please provide documents relating to that analysis.
Response
Refer to the response to Part (b) of this Interrogatory.
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Interrogatory 7 Your replies to date indicate that the effectiveness of the proposed ground i
water well system has not yet been established. These wells will be needed i:o control the ground water level and pre ent soil-liquefaction.
7(a) Will the permanent dewatering system be designed to virhatand the safe 44.Y shutdown earhquaka (SSE)?
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Response
I No.
See the response to 10 CFR 50.54 f, Question 24(c).
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7(b) If no, will the permanent dewatering system be designed to withstand any lesser grotm 1 vibratory motion?
Response
4 No.
7(c) If the answer to (a) is no, have you evaluated the impact of soil liquefaction on any soil supported Category I structures.
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7(d) If no, why not?
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Response
l As discussed in the response to NRC Questics 24 and 47, the permanent J
site dewatering system will be designed to maintain groundwater at a sufficiently, low. level to preclude the possibility of soil liquefaction.
7(e)
If the answer to (b) is yes, what ground vibratory motion has been considered?
Response
Not applicable.
7(f) If the answer to (a) is yes, have you performed any analysis based upon information contained in or resulting from a letter from Robert Tedesco to Vice President J. Cook dated October 14, 1980 concerning seismological' input data acceptable to the Staff?
Response
i Not applicable.
I 7(g) If the answer to (f) is yes, what changes in the d.ewatering system design and ground water drawdown levels were determined to be needed.
Response
Not Applicable.
l Interrogatory 8 In connection with your seismic analysis of the service water pump structure and the diesel generator building have you developed:
(1) Iump mass models (2) Sciffness value for each member (3) Mass at nach nodes point (4) Spring l
constants used in the analysis (K,, C,, K,, C,, K,, C ) and (5) Seismic 7
inputs of the modified Taft N21E 1952 record used in this analysis. As to i
any affirmative answer, please provide copies.
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Response
For the seismic analysis of the diesel generator building, values 1E have been developed for the following:
i 1.
Lump mass models.
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Stiffness value for each member f
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Mass at each node point 4.
Spring constants i.
5.
Seismic inputs for the modified Taft N21E 1952 record non-W5Iv6)A For the diesel building, the values will be provided along with the
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documents pertain 2 s to the structural reanalysis referred to in the response to question 1(b). For the service water pump s*cucture, this information will be supplied when the analysis has been developed.
Interrogatory 9 i
With respect to the seismic Category I valve pits located in the fill adjacent
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of the east and west side of the diesel generator building:
'l 9(a) What chang *.s if any, occutced to these pits during the diesel generator surcharge program?
Response
!i As expected, the valve pits have experienced settle==nt as a result of
'.]
the surcharge program. The east pit has settled 0.52 inches and the l
west pit 1,49 inches.
ll'j 9(b) Do any cracks exist in these pits?
I
Response
No cracks exceeding 5 mils have been identified in these pits.
I t
e
,m---,,-
u.a.- n. w.i
==
s
- y. i.
j 9 (c) What changes, if any, occurred in the rattle space for the piping during
~
j_
the diesel generator building surcharge program?
4 i
e l
Reponse' i
}
The initial readings were taken of service water piping on 11/13/78 prior to i
j isolating the D.G. building footings from the duct banks. The final readings were taken on 5/2/80 after removal of the surcharge.
I I
D.C. BLDC.
VERTICAL HORIZONTAL
' PEN. #
LINE i MOVEMENT MIN. CAP MOVEMENT MIN. GAP i
j 1
+ 1/8 1 1/4
+ 1/4 1 1/4 2
+ 1/8 1 1/4
+ 3/8 1 1/4 5
- 1/2 1/4 0
1 1/4
(#
~
1 3/8 6
- 3/4 7/8 0
8 1HBC-310
- 1/2 5/8 0
1 1/2 9
- 5/8 3/4 0
1 1/4 11 2HBC-81
- 1/4 3/4
- 1/8 1 3/8 12 2HBC-82 0
1
- 1/8 1 3/8 Directions:
Vertical + pipe moves up relative to penetration ii pipe moves down relative to penetration i
Horizontal + pipe moves east / north relative to penetration
,t 1
pipe moves west / south relative to penetration l
h
_ _ _. _. ~. _.
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' i UNITED STATES OF AMERICA
..I.
NUCLEAR REGULATORT ColetISSION j
i 1
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
(;
e In the Matter of
)
)
Docket Nos. 50-329-OH CONSUMERS POWER CLEANT
)
50-330-0M
)
50-329-OL (Midland Plant, Units 1 and 2)
)
50-330-OL
{
}
CERTIFICATE OF SERVICE I hereby certify that copies of " Consumers Power Company's (Applicant's) Answer to NRC Staff Interrogatories dated November 26, 1980, and attached affidavits were served upon the following persons by depositing copias thereof in the United Stated mail, first class postage prepaid on this lith day of March, 1981.
Frank J. Kelley, Esq.
Dr. Frederick P. Cowan Attorney General of the 6152 N. Verde Trail State of Michigan Apt. 3-125 Stewart H. Freeman, Esq.
Boca Raton, Florida 33433 Assistant Attorney General Gregory T. Taylor, Esq.
Michael Miller, Esq.
Assistant Attorney General Isham, Lincoln & Beale Environmental Protection Div.
One First National Plaza 720 Law Building Suite 4200 Lansing, Michigan 48913 Chicago, Illinois 60603 Mr. Steve Gadler
.Myron M. Cherry, Esq.
One IBM Plaza 2120 Carter Avenue i
Suite 4501 St. Paul, Minnesota 55108 Chicago, Illinois 60611 D. F. Judd, Sr. Project Manager
~f Mr. Wendell H. Marshall Babcock & Wilcox
' RID 10 P. O. Box 1260 Midland, Michigan 48640 Lynchburg, Virginia 24505 j
Charles Bechhoefer, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Const.
Washington, D. C. 20555
. Washington, D. C. 20555 Mr. C. R. Stephens, Chief Gustave Linenberger Docketing & Service Section Atomic Safety & Licensing Board Office of the Secretary U. S. Nuclear Regulatory Comm U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 t
, a.
u
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Ms. Mary Sinclair 5711 Summaarset Street 3
~
Midland, Michigan 48640 William D. Paton, Esq.
Counsel for the NRC Staff.
1-U. S. Nuclear Regulatory Commission Washington, D. C. 20555, Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Comunission Washington, D. C. 20555 Barbara Stamiris 5795 North River Road Route 3 I-Freeland, Michigan 48623 1
Lester Kornblich, Jr.
l Atomic Safety & Licensing Board i
U. S. Nuclear Regulatory Conan.
Washington,~D. C. 20555 h
Jaznes E. Brunner Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 O
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BEFORE THE ATOMIC SAFETT AND LICENSING BOARD e
In the Matter of
)
DOCKET NOS.
50-329-OM CONSUMERS POWER COMPANY
)
50-330-0M i
)
50-329-0L
)
50-329-OL (Midland, Units 1 and 2) i
)
)
COUNTY OF WA3HTENAW)
)ss STATE OF MICHIGAN )
i 4
AFFIDAVIT OF WILLIAM C. PARIS, JR.
t i
t Willism C. Paris, Jr., being duly sworn, deposes and says that he is employed by Bechtel Associates Professional Corporation, as an Engineering Supervisor; that he is jointly responsible with Neal Swanberg for providing answers to NRC Staff Interrogatories to Consumers Power Company Number 7, and that to the best of his knowledge and belief the above infor-1
- nation ar.d the answers to the above interrogatories are true and correct.
4 i
M William C. Paris, Jr.
/
Subscribed and sworn to before me this d
day of
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1981.
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AJ 6 L-Notary Public, Washtenaw Cou,nty,, Michigan id M,r,-j... --... g i
,1 My Commission Empires: If[c$i-55sii5'IdifE33t.35,'Ijlf lt j\\~
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NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.j In the Matter of
)
DOCKET NOS. 50-329-0M
- j CONSUMERS POWER COMPANT
-)
50-330-ON i(
)
50-329-OL j
(Midland, Units 1 and 2)
)
50-329H)L
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COUNIY OF WASHTENAW) j
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STATE OF MICHIGAN )
i 4
l AFFIDAVIT OF BIMAL DEAR f-I Bimal' Dhar, being duly sworn, deposes and says that he is employed by Bechtel Associates Professional Corporation, as an Engineering Supervisor; that he is responsible for providing answers to NRC Staff Interrogatories to Consumers Power Company Numbers 5, 9a and 9b, and that to the best of his i
knowledge and belief the above information and the answers to the above inter-rogatories are true and correct.
Il
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BimagDhar I
Subscribed and sworn to before me this
[
day of
'#/74 td 1981.
.4
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Notary Public, Washtensw' County, Michigan
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UNITED STATES OF AMERICA
)
NUCLEAR REGULATORT COCGSSION J
BEFORE THE ATONIC SAFETY AND LICENSING BOARD 1
!I It: r.he Matter of
)
DOCKET NOS.
50-329-0K
].
CONSUMERS POWER COMPANT
)
50-330-0M
- .}
}
50-329-OL L*
(Midland, Units 1 and 2)
)
50-329-OL
)
1
)
Li d>
COUNTT OF WASBTENAW)
)ss STATE OF MICHIGAN )
d l
-l AFFIDAVIT OF NEAL SWANBERG
~
a Ne'al Swanberg, being duly sworn, deposes and says t'. u he is employed by Bechtel Associates Professional Corporatica, as Assistant i
Project Engineer; that he is responsible for providing a.
.o NRC Staff Interrogatories to Consumers Power Company Numbers ',
5, 7 (jointly with W. Paris), 8, and 9c, and that to the best of his knowledge j
and belief the above information and the answers to the above interroga-1 4
9 tories are true and correct.
.1 Neal Swanberg F
i ii Subscribed and sworn to before me this b
day of h/7 i,,,2 1981.
a
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- 8. o Notary Public, Wash'tensta_ County.. Michigan 1
- .cM.2 T::..::, 2J...
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4 UNITED STATES OF AMERICA b
NUCLEAR REGULATORY COMMISSION L
BEFORE THE-ATOMIC SAFETY AND LICENSING BOARD l
l f
In the Matter of
..)
d J
Docket Nos. 50-329-0M
.g CONSUMERS POWER COMPANY
)
50-330-OL
)
50-329-OL (Midland Plant, Units 1 and 2)
)
50-330-OL
~'
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)
)
I
~i AMENDED AND ADDITIONAL RESPONSES TO 4
CERTAIN NRC STAFF INTERROGATORIES DATED 11/26/80 4
Interrogatorv 4 In the response to Question 15 of the NRC request, regarding plant fill, it is i
stated that, " differential settlement primarily induces additional strain, which I
is a self-limiting effect and does not affect the ultimate strength of the structural members." Additional clarification of this statement is needed.
-~(yi 4(a) Why do you classify the resulting strains as self-limiting in nature?
Response
The term "self-limiting" is a shorthand expression for the behavior of a structure under strain-induced loads such as settlement in the absence of a bearing capacity failure.
i 1
Based on the characteristics of supporting soils and the imposed load from a structure, the predicted rettlement of the structure can be calculated over its 1
il its lifetime. To evaluate the effect of settlement on the structure, the
!{
!j settlement can be divided into the following:
i l
(1) Uniform settlement (rigid body translation)
Ii j
(,
(2) Dif ferential sectiement (a) Tilting (rigid body rotation)
)
(b) Curvature l
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t
, f *l-ll
'T J wT
q c,
- i. l,,,.,.-
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Rigid body motion of the structure, both translation and rotation, does
~
not cause any strain in the structure. Therefore, it.is of no concern 3
.y 2
in the evaluation of structural adequacy.
In contrast, curvature in the t-f structure due to settlement will cause additional strain in the structure.
Therefore, the effects of curvature induced due to settlement need to be investigated.
9"vature and Stress
)
When a structural element is subjected to curvature (6), tensile strain j
a is induced in the convex side and compressive strain in the concave side
'i i;
of the element (Figure 1).
For a concrete structural element, the
'f theoretical relationship between curvature and moment can be established based on the stress-stn.in relationship of concrete and reinforcing steel.
An idealized moment-curvature plot of an under-reinforced concrete section s,/
similar to those used in the Midland Diesel Generator Building is shown in Figure 2.
As can be seen from Figure 2, the curvature increases linearly as the moment is increased, up to the moment My, corresponding to the point
'I of yielding for the tensile steel. Beyond that point, any increase in curvature would not increase the moment in the structural element. The anvinum curvature that can be induced in the element is Gu, corresponding
,1
- l co an ultimate concrete strain of.003.
- ,o
.. t l;
Behavior of Structures Subjected to Loads
!i
- 1 The loads applied on a structure can be divided into two categories:
1 4q j
(1) Externally applied forces c..
~j (2) Externally applied strains l '.
s
(-
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_3 When structures are subjected to externally applied forces, internal Mf forces and moments must be it.duced in the structure to restore static j
equilibrium between external and internal forces. An increase in
)
curvature beyond Wy* is not useful in resisting such external forces.
I as no additional internal moment is mobilized due to the additional j.
curvature.
s i
j When an externally applied strain due to settlement is applied to a d
structure, the structure must be capable of accommodating additional strain imposed on it without failure.
Since no met external forces are i I applied by that process, the induced strain need not cause internal forces in the Lia
.l j structure. Therefore, even if a structure has already reached fydue l
co an externally applied force, the structure can still resist externally I
applied strain so long as the resultant curvature is less than fu. More-y\\
j over, the behavior of the structure would be the same regardless of which influence-the settlement strain or the external force -is applied first.
1 j]
For example, let "M " be the moment induced in the structure due to g
external forces and 49 be the additional curvature induced due to
!f settlement.
In the elastic range, let AM be the increase in moment due l'
to 49.
If (M4 + AM) is less than My, the additional curvature due to settlement will cause the additional moment corresponding to the curvature (A9).
(Figure 3)
On the other hand if (M
+ A M) is greater than My as in (Figure 4),'he t
l{
structure will see a moment equal to My with an increase in curvature equal-to O 9.
The increase in moment due to curvature in this instance (i.e.
l
- See attached figure 2 I i, -
1
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[ i._ _ _. _
4-Figure 4) is lesa chan it would be were the yield moment high
- ]
enough such that M
+A M < My If M My, there is no increase
=
-0, in moment.
Since A M is not required to restore static balance,
. l the structure will be stable even ifAM = 0, as long as the
- l additional curvature A6 does not result in a curvature of the i
structure greater than fu.
P Conclusion f
The stress induced in a structure due to settlement can vary from zero to a maximum of a proportionality constant
- multiplied by the induced j l curvature. The actual stress is assigned by the structure itself 4
. f depending on its capacity to resist stress after allowing for any stress
- )
- l requirements due to external forces.
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., 'O 4(b) How do you reconcile your statement quoted above with your statement concerning the Service Water Pump Structure in the Management Corrective 1
Action Report No. 24, Interim Report 6, issued September 7, 1978 that the total design loads cannot be supported by the main structure.
4
Response
For purposes of the underpinning design of the foundations of the service water pump structure, no credit was taken for any bearing capacity in the fill material. Under these circumstances the self-ifniting analysis described in the Response to Interrogatory 4(a) l does not apply, since the mechanism for producing possible strains in
.i the structure is not limited to settlement.
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g Interroaatory 1(e) and 1(f) (Amended Responses)
{
)
1(e) Have you factored into any re-analysis information contained in, or resulting from, a letter from Robert Tedesco to Vice President J. Cook dated October 14, 1980, concerning seismological input data l
acceptable to the Staff?
~
Response
' Applicant objects on the ground that this question goes beyond the limited jurisdiction conferred by the December 6,1979 Order, that the seismic re-analysis requested by Mr. Tedesco in the October 14, 1980 letter should be reserved for the operating license hearing, and, hence, that it is irrevelant to these proceedings.
Subject to that objection Applicant answers as follows: The pending seismic re-analy-sis requested in the October 14, 1980 Tedesco letter has been considered
.i in arriving at the following approach towards designing and analyzing r%
the remedial fixes for the auxiliary building electrical penetration area, the service water pump structure, and the borated water storage I'
tank ring foundation: Seismic forces obtained by application of FSAR n
input criteria (i.e. modified Housner spectra and maximum acceleration anchored at.12 g) will be increased by a reasonable margin. Forces b
thus determined will be combined with other loads in accordance with
.]j applicable load combinations in arriving at design parameters for the I
remedial measures. In addition, with respect to the Diesel Generator k
Building, Bechtel is attempting to evaluate the total margin which ty actually exists in excess of FSAR seismic design criteria.
!!il ij When discussions with the NRC Staff respecting possible redefinition i
- j of seismic criteria applicable to the entire Midland site are completed,
!i'i m.
Applicant will evaluate the necessity for seismic re-analyses of any.or i
[f I
all Category I Structures, including those founded partly or entirely on
}
l ll plant fill.
i.
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,_l.
m m
s se, (
9 g,
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/P 1(f) If the answer (e) is yes, please provide copies of all Q-)y documents rela ing to that re analysis.
1 Response +
'l The documents pertaining to the design analyses of the remedial
'?
I fixes for the service water pump structure, the auxiliary building i
and the borated water storage tank ring foundation (using the
.l approach spelled out in the response to 1(a)) will be provided, 4
l-as stated in the response to question (b). Applicant objects to
'l t..
providing documents relating to the analysis of total margin in excess of FSAR' seismic design criteria for the Diesel Generator
~
-l Building, for the reasons stated in the first sentence of Applicant's response to question 1(e). For the same teason, Applicant objects to providing in this proceeding future seismic re-analyses of i
Midland structures as requested by the October 14, 1980 Tedesco i
letter.
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UNITED STATES OF AMERICA l-I' NUCLEAR RECU MTOP.Y COMMISSION I
ff BEFORE THE ATOMIC SAFETY AND LICENSING-BOARD j
t 5
I I
In the Matter of
)
CONSUMERS POWER COMPANY
)
Docket Nos. 50-329-0M
[
)
50-330-0M g
(Midland, Units 1 and 2)
)
)
50-329-OL COUNTY OF WASHTENAW)
)ss STATE OF MICHICAN )
AFFIDAVIT OF BIMAL DEAR b
j Bimal Dhar, being duly sworn, deposes and says that he is employed by Bechtel Associates Professional Corporation,'as an Engineering Supervisor; that he is responsible for providing an answer to Consumers Power Company's O
Answer to NRC Staff Inter ogatory No. 4 dated 11/26/60, and that to the (v) best of his knowledge and belief the above information and the answer to the above Interrogatory is true and correct.
t finalDhar i
Subscribed and sworn to before me this
/.3 day of March, 1981.
t t. d. h Y.w I
Notary Public, Washtenaw County, Michigan i
My Commission Expires: N A..
4+v M 6f[ (
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UNITED "TArdS OF AMERICA
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BEFORE THE ATOMIC SAFETT AND LICENSING 80ARD 4,
iy i
.? !
In the Matter of
)
DOCKET NOS.
50-329-0M
_y, CONSUMERS POWER COMPANY'
)
- 50-330-0M J
)
50-329-OL (Midland, Units 1 and 2)
)
50-329-OL
)
)
COUNTY OF WASHTENAW)~)
l
)ss STATE OF MICHIGAN )
d l
, 1 Neal Swanberg, being duly swoca,' deposes and says that he is
.s, employed by Bechtel Associates Professional Corporation, as an Assistant t
(N Project Engineer; that be is responsible 'for providing amended responses
' i.
i.
1 C
to NRC Staff Interrogatories to Consumers Power Company Numbers 1(e) 4 and (f) and that to the best, of his knowledge and belief the above infor-mation-and the answers to the above interrogatories are true and correct.
< l.,
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Neal Swanberg'
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Subscribed and sworn to before as this / h day of M -i c e.Jv 1981.
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Notary Public, Washtenew County, Michtgan My Commission Empires: %,%e,, p.e_, E/* /f/4
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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION In the Matter o'
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f CONSUMERS POWER COMPANY
)
30- M 50 3 (Midland Pir.nts, Units 1 and 2
)
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)
i
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4 CERTIFICATE OF SERVICE I
~
I hereby certify that copies of Amended and Additional Responses to Certain NRC~ Staff Interrogatories Dated 11/26/80, with attached affidavics,.were served upon the following persons by depositing copies thereof in the United States Mail, first class postage on this 20th day of March, 1981.
r.,
(
L.
Frank J. Kelley, Esq.
Michael Miller, Esq.
Attorney General of the Isham, Lincoln & Beale State of Michigan One First National Plaza
}
Stewart H. Freeman, Esq.
Suite 4200 Assistant Attorney General Chicago, Illinois 60603 Gregory T. Taylor, Esq.
Assistant Attorney General Mr. Steve Gadler 720 Law Building 2120 Carter Avenue Lansing, Michigan 48913 St. Paul, Minnesota 55108 i
j Myron M. Cherry, Esq.
D. F. Judd, Sr. Project Manager
?
One IBM Plaza Babcock & Wilcox 3
Suite 4501 P. O. Box 1260 I
Chicago, Illinois 60611 Lynchburg, Virginia 24505 k
Mr. Wendell H. Marshall Atomic Safety & Licensing Appeal Board RFD 10 U. S. Nuclear Regulatory Conunission Midland, Michigan 48640 Washington, D. C. 20555
.j Charles Bechhoefer, Esq.
Mr. C. R. Stephens, Chief d
Atomic Safety & Licensing Board Panel Docketing & Service Section
,j U.S. Nuclear Regulatory Comm.
Office of the Secretary U. S. Nuclear Regulatory Conunission j
(, s) Dr. Frederick P. Cowan Washington, D. C. 20555 6152 N. Vet.le Trail L./
Apt. B-125 Boca Raton, Florida 33433
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Lester Kornblith, Jr.
Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission i.
Washington, D. C. 20555 i
Ralph ~S. Decker, Esq.
Route 4, Box 1900 Cambridge, Maryland 21613 Ms. Mary Sinclair 5711 Summerset Street Midland, Michigan 48640 t
William D. Paton, Esq.
Counsel for the NRC Staff U.RS. Nuclear Regulatory Co.amission Washington, D. C. 20555
. Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Barbara Stamiris 5795 North River Road (r",
Route 3 fp v'
Freeland, Michigan 48623 n~4 e L;t'me
'l James E. Brunner Consumers Power Company 212 West Michigan Avenue j
Jackson, Michigan 49201
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00:SU"E2.5 DOUER C9f';A"Y
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Pocket Nos. 50-329-0!' & OL
)
50-330-0" & 01.
("idland Plant, Units 1 and 2)
)
i fi?C STAFF'S ArtSWER !*4 OPPOSITI0': TO CONSUtiEP.S POWER C0ftPANY f*0TI0'l TO C0f!PEL ANSWERS TO INTERROGATODIES Pursuent to 10 CFR 6 2.730(c), the NRC Staff answers Consu 'ers Power Conpany f!stion to Conpel ffRC Staff to Answer Interrogatories 13 through
- 15..The NRC Staff opposes the motion because (1) it is an attempt on Consumers Power Company (hereafter Consu11ers) part to force the Staff to create a conpilation of a large volume of Consu'1ers' data that is wailable to then but which does not presently exist in the specific format that Consumers has reauested and (2) the infornation sought is not relevant to the issues before this Board.
BACKGROUND On February 25, 1981 the NRC Staff filed answers to interrogatories that had been subnitted by Consu!1ers on November 12, 1980.
In a separate document filed on that same day, the NRC Staff ob,ietted to Consumers interrogatories 13 through 16 which read as follows:
- 13. State with particularity each acceptance criteria l
which Consumers Power Conpany had up until December 6,1979 provided to the Staff.
14 As of Decenber 6,1979 with regard to each criteria identified in your. answer to interrogatory 13 state whether Consumers had subnitted sufficient information to justify each 1.s n A '2 __
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acceptance crit::ia.
If Consumers had not submitted sufficient
. infor13 ion, state with particularity which infornation y
Consurers.had failed to supply.
- 15.. Excluding the acceptance criteria identified in response to interrogatory 13, state with particularity eacq acceptance criteria which Consu.,ers has to date provided to the Staff.
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16 Witn regard to each criteria identified in your Hj answer to interrogatory 15 state whether Consumers has
,i sub".itted sufficient infomation to justify each acceptance
- d criteria.
If Consumers has not subnitted sufficient inforration, state with particularity which information Consumere has failed to supply.
j ARGUPENT A.
Consumers reouest is not within the limited scope of discovery acainst the Staff l~
The Appeal Board recently. discussed the limited scope of discovery against the NRC Staff. After discussing discovery fran parties other than the NRC Staff, the Appeal Board stated that "[d]iscovery against the Staff is on a different footing."1/ The Appeal Board stated that the Rules of Practice allows interrogatories addressed to the Staff only where the infomation is not obtainable elsewhere. The infornation Consumers is requesting here is fron its own documents.
B.
The compilation of data Consumers seeks does not exist and would have to be derived from Consumers' docurents Consumers asks for a_ compilation of criteria they have provided the Staff both before and after December 6,1979.
They argue that the f
compilation of data that they are reouesting "must" exist. At page 4 of their motion they state, "therefore, the infomation responsive to 1
1/ Pennsylvania Power and Light Company, (Susquehanna Steam Electric l
Station), ALAB-613,12 NRC 317, 323 (1980).
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interrogatories 13 and 14 must have been in existence as of December 6,
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1979." Also on page 4 of the~ notion states, "the NRC Staff nast also nave compiled the requested infomation and data [recuested by interrogatories 15 and 15] in order to support that position."
In fact, the compilation of data they seek does not exist.
Consuners' notion to conpel denonstrates their nisunderstanding of the N7C Staff's regulatory role and review process.
The NRC Staff does not' design nuclear power plants. As a regulator, it-reviews information subnitted by applicants. Applicants subnit :riteria for their design j
whicn the NRC audits in their reviews to detemine acceptability.
NRC does not review every criteria in an application.
Engineering judgment is used to detemine which portions of the application should be subjected to more detailed review. Thus, the infomation requested in Consumers' interrogatories 13 through 15 has never been compiled by the NRC.
If this Board were to compel the Staff to compile the data Consuners is requesting, the Board would, in effect, be ordering the Staff to start the review process over again and review each and every criteria -
. including criteria which in an audit review had not previously been reviewed. A'/
Section 33.20 of Moore's Federal Practice sets forth some " general t
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principles" with respect to interrogatories calling for investigation or t
- ompilation of data. One of those general principles is that 2/ In the event the Staff were ctr'nelled to r'ake the conDilation which 4
Consumers has requested, a prelininary estinate is that it would
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take several nonths.
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. j While a party must furnish -in his answer to interrogatories 1
whatever information is 'available to it. [ footnote omitted]
j' ordinarily.a party will not be required to "nake research and
. compilation of data not readily known to him" [ footnote omitted] - at least if the data is equally]available to the 1
interrogating party [ citing numerous cases.
f in 'Jebb v. Westinchouse Elec. Corp., 81 F.R.D. 431 (1973)', a class i
action discrinination suit, plaintiff moved to compel answers to j
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interrogatories.
Defendants objected to requests for conpilations of lj infocution on the ground that the docuuents from which the compilations yj were to be derived had already been nade available to plaintiffs.
The court refused to compel defendants to compile the information holding
.]
I that plaintiffs were,-in effect, asking the court to shift the cost of l!
triel preparation to the defendant.
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in the instant proceeding, the docunents from which the compilation is sought were not merely made available to Consumers - they were created by Consumers. This Board should not compel the Staff to create a
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compilation of data from Consumers' own docunents.
C.
The information Consumers seeks is irrelevant to the issues.
j The December 6,1979 Order liodifying Construction Pernits states, at page 3, that the infonnation provided by Consumers fails to provide acceptance criteria necessary for the Staff to evaluate the technical adequacy of Consumers' proposed remedial actions.
In the Staff's I
February 25, 1981 voluninous answers to Consumers' interrogatories, we identify the information needed by the Staff for further review of I
renedial actions proposed by Consumers. We identify in response to interrogatories 2, 6, 7 and 8 and appendices A and B where we have found 4
criteria to be inadequate.
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The Staff's dissatisfaction with identified criteria is what is at I
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. issue here., Those natters are fully. discussed in' the Staff's answers to 6:
4-Tonsumers' interrogatories.
q; that Consumers is seeking to discovery is not really relevant to the j
. issues before the Board. The Staff has identified, as discussed above, t.
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' all criteria found to be unacceptaSle and has indicated the reasons for
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unacceptability.. The only other criteria within the Staff's possession are: (1) criteria that have been found acceptable and (2) criteria that have not been reviewed. These other criteria are not relevant to the d
issues before the Board. What is relevant is the dispute regarding criteria that have been subnitted and have been found unacceptable.
CONCLUSION
-For the reasons stated above, Consumers notion to compel should be
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disnissed.
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Respectfully submitted, 1.?
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}jt.4^.t k, jdNa (s4filliam D. Paton Counsel for NRC Staff Dated at Bethesda,ftaryland this 1st day of April, 1981.
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UNITED STATES OF AMERICA NUCLEAR REGUL% TORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.f In the Matter of
)
)
CONSUMERS POWER COMPANY
)
Docket Nos. 50-329-0M & OL
)
50-330-0M & OL (Midland Plant, Units 1 and 2)
)
t CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF'S ANSWER IN OPPOSITION TO C0llSUMERS POWER COMPANY. MOTION TO COMPEL ANSWERS TO INTERR0GATORIES in the above-captionec proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 1st day of April, 1951.
- Charles Bechhoefer, Esq.
Ms. Mary Sinclair Atomic Safety and Licensing Board 5711 Summerset Street U. S. Nuclear Regulatory Commission Midland, Michigan 48640 Washington, D.C.
20555 Philip P. Steptoe, Esq.'
Administrative Judge Ralph S. Decker Michael I. Miller, Esq.
Route d4, Box 190D Ronald G. Zamarin, Esq.
Cambridge, MD 21613 Alan S. Farnell, Eso.
Isham, Lince!n & Beale One First National Plaza Dr. Frederick '. Cowan 42nd Floor 6152 N. Verde Trail Chicago, Illinois 60603 Apt. B-125 Boca Raton, Florida 33433
- Atomic Safety and Licensing Board Panel Frank J. Kelley U. S. Nuclear Regulatory Commission e
Attorney General of the State Washington, D.C.
20555 i
of Michigan Steward H. Freeman
- Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel Gregory T. Taylor U. S. Nuclear Regulatory Commission i
Assistant Attorney Generul Washington, D.C.
20555 i
Environmental Protection Division
(
720 Law Building
- 0ccketing and Service Section
[
Lansing, Michigan 48913 Office of the Secretary U. S. Nuclear Regulatory Commission Myron M. Cherry, Esq.
Washington, D.C.
20555 i
1 IBM Plaza
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Chicago, Illinois 60611
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. James E.' Brunner. Esq.
Jeann Linsley
. Consumers Power Company-Bay City Times 212:1-lest Michigan' Avenue.
311 Fifth Street i
LJackson, Michigan 49201 Bay City, Michigan 48706~
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'Ms. Barbara Stamiris
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5795 !!. River Freeland, Michigan 48623 Mr. Steve Gadler 2120 Carter Avenue.'
St.-Paul, "inneseta 55108 i
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klendell H. Marshall, Vice President
':idwest Environmental Protection F
Associates w, in 1
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Counsel for NRC Staff l*
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u8.g;gumaAJ, NUCLEAR REGULATORY C0t1 MISSION O;&gW'-[/
BEFORE THE ATOIIIC SAFETY AND LICENSING BOARD i
In the Matter of
)
CONSUMERS POWER COMPANY Docket Nos. 50-329 0!! & OL
)
50-330 OM & OL (Midland Plant, Units 1 and 2
)
NRC STAFF RESPONSE IN OPPOSITION TO APPLICANT'S it0 TION TO DEFER CONSIDERATION OF SEISti!C ISSUES UNTIL THE OPERATING LICENSING PROCEEDING On liarch 18, 1981, Consumers Power Company (Consumers or Applicant) filed a fiotion To Defer Consideration Of Seismic Issues Until The Operating Licensing Proceeding. Pursuant to 10 C.F.R. 92.730(c), the NRC Staff hereby responds to Applicant's motion. The NRC Staff opposes the motion because (1) the instant proceeding is both an enforcement (0M)M and a licensing (0L)E roceeding, (2) Applicant's affirmative defense p
to the Order modifying its construction permits could involve proposed remedial acticns which require seismic considerations and (3) the Licens-ing Board in deciding the issues in this proceeding could modify the i
construction permits by its findings on certain design matters which require seismic considerations.
s e9 y
On itarch 14, 1980 the Comission issued a Notice of Hearing on the Order Modifying Construction Permits. 45 Fed. Reg. 18124 (March 20, 1980).
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On October 12, 1978 the Chairman of the Board issued a Notice of i
Hearing on the application for a facility operating license. 43 Fed. Reg. 48089 (October 18,1978).
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BACKGROUND On December 6,1979, the Nuclear Regulatory Commission issued an
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Order todifying Construction Permits No.- CPPR-81 and No. CPPR-82. This Order was based on the following: quality assurance deficiencies involving the settlement of the Diesel Generator Building and soil i
activities at the 111dland site, a naterial false statement in the FSAR i;
and the unresolved safety issue concerning the adequacy of the remedial I
action to correct the deficiencies in tne soil construction under and around safety-related structures and systems. The Order, if sustained, t
would prohibit Consumers from performing certain soil related activities
't pending approval of amendments to the construction permits.
4 On December 26, 1979 Consumers filed a Request for Hearing on the 1
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!j Order. In that Request Consumers stated its intention to move, pursuant to 10 C.F.R. 92.716, to consolidate the OM proceeding with those issues j
relating to soil conditions and plant fill materials raised in the OL proceeding. Consumers filed such a Motion for Partial Consolidation on 3
l' May 27, 1980.
In the Prehearing Conference Order dated October 24, 1980, e,
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the Board granted the Motion for Partial Consolidation.
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ARGUMENT A.
The instant proceeding is in part an operating licensina
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proceeding
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Censumers' Motion repeatedly urges that consideration of seismic issues should be deferred until the operating licensing proceeding. This argument ignores the fact, however, that the instant proceeding is in ll part an operating licensing proceeding.
Indeed, it was in response to a t!
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motion by Consumers that the Board ordered the consolidation of the OM u
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-- n i i proceeding with those -issues relating to soil conditions and plant fill materials raised in the OL proceeding. Thus, insofar as an evaluation of the soils and plant fill issues at the OL stage involves seismic inout.
I the Staff submits that sef snic issues must be considered in this consolidated proceeding.
B.
An evaluation of Consumers' proposed remedial actions could require seismic analysis If the scheduled hearing was restricted to the issues stated in the Order Modifying Construction Pennits, the Staff concedes that seismic issues would not be relevant to that proceeding.E This concession is the only seismic " agreement" that the Staff had with Consumers.
In this regard, the Staff never agreed that seismic issues would have absolutely no relevance to the consolidated OH-OL proceeding. Thus, Consumers' allegations that the Staff " reneged", on an agreement and " affirmatively I
misled" the Applicant with respect to seismic issues are untrue.
i' Since the scope at the hearing will not be limited to the issues f n the Order, it is likely that Consumers will raise the affinnative defense that the problems identified in the Order either have been remedied or are the subject of proposed remedial actions.
In this regard, the Pre-hearing Conference Order stated that "the soil settlement aspects of the OL Proceeding... essentially will involve whether any ' fixes' that may be ordered in the OM Proceeding have been successfully implemented."
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y Such a limitation would be appropriate in an enforcement proceeding.
'I Public Service Co. of Indiana (Marble Hill Generating Station Units 1 and2),CLI-80-10,11NRC438,441(1980). However, a broader view is appropriate in this combined enforcement and licensing case. cf.
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Consumers Power Company (Big Rock Nuclear Plant) ALAB-636, p. 23
- n. 22 (liarch 31, 1981).
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l If Consumers does raise this defense, the Board would be called upon to l
determine whether the " fixes" would require an amendment to the construc-tion pemits. The Board's detennination would include deciding whether seismic issues are relevant to the " fixes". Consequently, they must be t
considered by the Board.O For example, if Consumers proposes to remedy the settlement problems associated with the Service Water Structure by extending a wall down to the glacial till, it would be necessary to consider seismic issues in approving such an amendment to the construction permits. Specifically, the Board would have to conclude that the wall structure as proposed to be modified can reasonably be expected to withstand the Safe Shutdown Earthquake (SSE).
In reaching such a conclusion, the Board must use a seismic design basis based on current seismic information rather than the 1972 seismic design basis established in the course of the construction pemit proceeding.
Consumers argues that the Dairyland casesM are factually distinguishable from Midland. While the Staff agrees that Midland is not absolutely on point with the Dairyland casesN it contends that the
-l l
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y It must be noted, however, that the Staff will not have completed, i
its review of seismic issues by the start of the hearing in July.
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y Dairyland Power Cooperative (Lacrosse Boiling Water Reactor),
L5P-80-26, 12 NRC 367 (1980); ALA8-618, 12 NRC 551 (1980).
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Dairyland was strictly an enforcenent proceeding whereas Midland is an enforcement and OL proceeding; an SSE had never been approved for I
the Lacrosse reactor whereas an SSE had been approved for the i
Midland reactors.
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reasoning used and conclusion reached are applicable to the instant
.i proceeding.
In Dairyland the Board had to detemine whether a dewatering system should be designed and installed on a stated schedule. The Board i
opined and the Appeal Board agreed that in order to produce an adequate record on the necessity of a dewatering system, it was essential that the reactor's SSE be ascertained, not assumed.E Similarly, in order to
,i develop an adequate and complete record on any proposed remedial actions at Midland which would require an amendment to the construction pemits.
l it is important to ascertain the current SSE rather than to assume that the 1972 SSE.is still valid.E This same view was expressed by two members of the instant Board at the paehearing conference on January 29, 1981. Mr. Linenberger stated:
Th.3 only thing I can tell you is that this Board will absolutely nce ignore seismic criteria questions in arriving at its decision about the adequacy of-proposed remedial-actions..The considera -
tions are not separable, and to try to separate them would be a contrivance that is not in anyone's best interest.
(Tr. 790-91).
Chairman Bechoeffer, concurring with Mr. Linenberger, stated "we won't accept as a given the 1972 value." (Tr. 792). Thus, it is apparent that the Board will want to evaluate the proposed remedial actions in light of current seismic infonnation.
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12 NRC 367, 378; 12 NRC 551, 556 (1980).
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A letter from Robert L. Tedesco, Assistant Director for Licensing dated October 14, 1980 stated that the establishment of acceptable i
seismological input parameters is an open item in the NRC Staff's
,t radiological safety review of the OL application, i
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If the Board modifies certain design bases of the construction Demits, a seismic analysis would be required Assuming arguendo, that the Board does not sustain the Order but instead decides to grant a lesser included remedy, such as certain 4
modifications to the construction pennits, that decision could require seismic analysis.
In other words, depending on the nature of the ordered modification, seismic infonnation may or may not become relevant.
For example, if the ordered modification changes a design assumption that was based in part on seismic analysis, clearly the Board would have to consider seismic issues in approving that modification. Conversely, i.f the Board orders a modification which has no seismic implications, that order would not involve any analysis or consideration of seismic issues.
Thus, the relevance of seismic information in this OM-OL proceeding depends in large part on the initial decision reached by the Board. To exclude in advance any consideration of seismic issues in the OM-OL pro-ceeding could amount to restricting the Board decisionmaking powers.
Accordingly, the Staff submits that seismic issues must be considered in the event the Board orders a modification of any seismic-sensitive design assumptions.
CONCLUSION For the reasons stated above, Consumers motion to defer consideration of seismic issues should be denied.
.l Respectfully submitted.
ll FA R. % -
William D. Paton Counsel for NRC Staff
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i Dated at Bethesda, Maryland this 7th day of April,1981, f
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UNITED STATES OF AMERICA l
NULEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOA'D R
In the Matter of Docket Nos. 50-329-0M CONSUMERS POWER COMPANY
)
50-330-0M
)
50-329-OL (Midland Plant, Units 1 and 2)
)
50-330-OL
[
NRC STAFF OBJECTIONS TO INTERROGATORIES FILED BY CONSUMERS POWER COMPANY The Staff is today filing answers to interrogatories filed by Consumers Power Company except for interrogatories 13 through 16.
For the reasons stated below, the Staff ob.iects to interrogatories 13 through 16 which read as follows:
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- 13.
State with particularity each acceptance criteria h"dL b
~M*gh with Consumers Power Company had up until December 6,1979 C'd"* **
provided to the Staff, ovw At-
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- 14. As of December 6,1979 with regard to each criteria C'ikna 44-u.cr.,964 identified in your answer to interrogatory 13 state whether pN%h Consumers had submitted sufficient infomation to justify each acceptance criteria.
If Consumers had not submitted M* ' *
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sufficient infomation, state with particularity which infomation Consumers had failed to supply.
15.
Excluding the acceptance criteria identified in
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response to interrogatory 13, state with particularity UCo whvuxph(A G-b each acceptance criteria which Consumers has to date a<= nck docavevuut 6ecom provided to the Staff.
h a<t.o h g u,c to % e 1
dda %#it Y% awlable
- 16. With regard to each criteria identified in your to Se4 and is not-answer to interrogatory 15 state whether Consumers has itkvoWt.4kis r&voJb submitted sufficient infomation to justify each acceptance h6,,q is 4.r h criteria.
If Consumers has not submitted sufficient infor WW mtact.p s,J mation, state with particularity which infomation Consumers g
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- f 2-4 The Staff objects to these interrogatories. The interrogatories are directed to infonnation which was originally provided by Consumers. To select the requested infomation wuld require the Staff to sort through all of the. voluminous documents provided by Consumers since the soil settlement problem was first reported in August 1978, and tabulate any acceptance criteria that may be found therein.
In the course of the Staff's nonnal review, it considers all the information submitted by Consumers, but would not ordinarily and did not in this case tabulate any acceptance criteria found in Consumers' documents.
If the purpose of these interrogatories is to obtain the definition of the expression acceptance criteria, that has been provided in the answer to interrogatory 1.
The Staff has provided, in answers to other interrogatories, specific information concerning the adequacy of Consumers' responses, details as to specific infonnation needed by the Staff, and the relevance of acceptance criteria to those matters.
In light of the above, the Staff submits that forcing the Staff to sort through voluminous documents provided by Consumers for the purpose of tabulating any acceptance cricuria that may be found therein would be s
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!' i an inappropriate burden on the Staff.
If Consumers believes such a tabulation would assist the resolution of the issues in this proceeding, it would be more appropriate that it extract this information from documents it prepared in the first instance.
Respectfully submitted,
'k (..
William D. Paton Counsel for NRC Staff
. j Dated at Bethesda, Maryland j
this 25th day of February,1981
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UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION I
BEFORE THE ATOMIC SAFETY AND LICENSING GOARD
-4 In the Matter of CONSUMERS POWER COMPANY Docket Nos. 50-329-0M & OL 50-330-0M & OL (itidland Plant, Units 1 and 2)
)
1 CERTIFICATE OF SERVICE I
I hereby certify that copies of NRC STAFF OBJECTIONS TO INTERROGATORIES f
FILED BY CONSUMERS POWER COMPANY in the above-captioned proceeding have been served on the following by deposit in the United States mail, first l
class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 25th day of February 1981.
- tharles Bechhoefer,- Esq..
Ms. Mary Sinclair Atomic Safety and Licensing 3oard 5711 Summerset Street
,'I U. S. Nuclear Regulatory Commission-
- Midland, Michigan 48540 Mashington, D.C.
20555
- Mr. Gustave A. Linenberger Michael I. Miller, Esq.
Atomic Safety and Licensing Board Ronald G. Zamarin, Esq.
U. S. Nuclear Regulatory Commission Alan S. Farnell, Esq.
Mashington, D.C.
20555 Isham, Lincoln & Beale One First National Plaza Dr. Frederick P. Cowan 42nd Floor j
6152 N. Verde Trail Chicago, Illinois 60603 Apt. B-125 Boca Raton, Florida 33433
- Atomic Safety and Licensing Board Panel Frank J. Kelley D. S. Nuclear Regulatory Commission
.i Attorney Gcneral of the State Washington, D.C.
20555 of Michigan Steward H. Freeman
- Atomic Safety and Licensing Assistant Attorney General Appeal E.ard Panel i
Gregory T. Taylor U. S. Nuclear Regulatory Comission j
Assistant Attorney General.
Washington, D.C.
20555 Environmental Protection Division 720 Law Building
- Docketing and Service Section Lansing, Michigan 4S913 Office of the Secretary i
U. S. Nuclear Regulatory Commission j
"yron M. Cherry, Esq.
Washington, D.C.
20555 i
1 IBM Plaza Chicago, Illinois 60611 i
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James E. Brunner, Esq.
Jeann Linsley Consumers Power Company Bay City Times 212 West Michigan Avenue 311 Fifth Street Jackson, Michigan.49201 Bay City, Michigan 48706 l
Ms. Barbara Stamiris 5795 N. River j
Freeland, Michigan 48623 Mr. Steve Gadler 2120 Carter Avenue St. Paul, Minnesota 55108 Hendell H. Marshall, Vice President Midwest Environmental Protection ll Associates RFD 10
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William D. Paton i
Counsel for NRC Staff I
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