ML20093N633
| ML20093N633 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/18/1984 |
| From: | NRC |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX17-006A, CON-BX17-6A, FOIA-84-96 OL, OM, NUDOCS 8408020074 | |
| Download: ML20093N633 (87) | |
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- j UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Scdw % G A ub,4/4 d & b d V
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In the Matter of
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Docket Nos. 50-329-0M CONSUMERS POWER COMPANY
)
50-330-0M (Midland Plant, Units 1 and 2)
)
50-329-OL 50-330-OL NRC STAFF'S ANSWERS TO INTERROGATORIES FILED t
BY CONSUMERS POWER COMPANY f
Interrogatory 1 Define " acceptance criteria," as that term is used at page 3 of the Order.
Answer Acceptance criteria are the standards on which a judgement or 1
decision is based.
As used in the December 6, 1979 Order on l
Modification, Cthe standards to be used by the licensee to make]
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the judgment or decision Cthat proposed re me
- -are acceptable was3 sought b~y the NRC for its review s
whether the information submitted by the licensee provided reasonable assurance that the facility, as modified by the i
proposed remedial measures, can be constructed and operated without undue risk to the health and safety of the public.
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The NRC practice in performing radiological safety reviews is
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such that the. term " acceptance criteria" has a wide meaning
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-and it is this broader meaning that applies as the term'is used d
i within the Order.
The'NRC practice is to use a document entitled 4
" Standard Review Plan for the Review of Safety Analysis Reports i
O' for Nuclear Power Plants," NUREG-75LO87, for the radiological t
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safety review of applications for-licenses of nuclear power plants such as the Midland Plant. 'Each section of the Standard Review' Plan (SRP) is organized into four subsections, and one of these subsections is entitled " Acceptance Criteria".
This 6
subsection contains a statement of the purpose of the review i
and the technical basis for determining the acceptability of the design or the programs sithin the scope of the area of review of the SRP section.
The technical bases cons of specific criteria such as NRC Regulatory Guides, General-Design Criterib
.,;I Codes and Standards, Branch Technical Positions, and other _ criteria.
This subsection is further discussed in the first section of the
- 7 Standard Review Plan, which is entitled " Introduction".
To illustrate the term " acceptance criteria" refer to Standard S
I; Review Plan Section 2.5.4II, page 2.5.4-3 and Section 2.5.5II, page 2.5.5-1.
From these examples it is seen that " acceptance criteria" Cfor an applicant's proposed geotechnical design submitted in its Safety Analysis Report 3 would include, for
,4 each specific and important engineer.ing feature, a thorough evaluation of the particular en*gineering aspect based on knalyses
.of basic data that support atL conclusions.
These analyses a
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and basic support data are required to allow the Staf conduct 7
independent analyses and reach independent conclusions on whether reasonable assurance of plant safety exists.
h (rlt e r r o a a t o r y 2 State which "of the Staff's requests were directed Cas of or before December 6, 19793 to the determination and justifica. tion r
of acceptance criteria to be applied to various remedial measures taken" (Order at page 3) and which portion o f e a c ts 4
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request was so directed.
Answer Attached Table 2-j Lists Staff's requests that were directed to i
the determination and justification of acceptance criteria to be applied to various rem (dial measures taken and proposed by Licensee.
As of December 6, l979, the only remedial action that had been taken was the placement of the sand surcharge inside and around the Diesel Generator Building, which had reached the maximum height of 20 feet above final plant grade i
on April 7, 1979 and which had been removed by August 31, 1979.
The requestsinTable2-jrelevant to the remedial action for th the Diesel Generator were Requests number 4, 5, 8, 12, 13, 14, j
4 18, 19, 20, 21 ( c ), 25, 26, 27, 28, 30, and 35.
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HoweLL Letter of April 30 1979 to J. Keppler, forwarding MCAR I-l 24 Interim Report 5.
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HowelL Letter of November 2, 1979 to J. Keppler, forwarding MCAR 24 Interim Report 8.
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In addition to the requests Listed in Table 2-1, the Staff had previously submitted other requests to the Licensee dicected to the determination and justification of acceptance criteria to be applied to various remedial measures taken and proposed by the Licensee.
These requests are identified in Appendix A hereto.
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TABLE 2-1 I
Staff's Signatory /Date of Applicable Portion
- 50. 54 ( f)
Request Letter of Request Request No.
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Request Letter of Request i
Request No.
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Rubenstein, 11/19/79/
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NOTES:
Portion of St af f's request di rect ed t o tie determinat i on and justification of acceptance criteria to be applied to various remedial measures taken or proposed.
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.I APPENDIX A f
ADDITIONAL NRC REQUESTS PRIOR TO DECEMBER 6, 1979_
Staff Request Signaturee/
Applicable Portion Date of Request Letter of Request 130.21 S.Varga, 12/11/78 AtL
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First sentence g 362.12
- 362.13 ALL but last g sentence I
40.106 S. V a r g a, 1/18 / 79 AlL 130.23 ALLS with respect to Category I structures other than Containment.
130.24 ALLS with respect to Category I structures other than Containment.
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362.15 ALL g 362.16 ALL 362.17 AlL i
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i Portion of Staff's request directed to the determination and justification of acceptance criteria to be applied to various I
remedial measures taken and prcposed.
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M W Interrogatorv 3 l
State and explain the reasons why "such Cacceptance criteria],
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coupled with the details of the remedial action, are necessary for 3
the Staff to evaluate the technical adequacy and proper implementa=
tion of the proposed action."
(Order at page 3.)
Answer Technical adequacy and proper implementation are two of the i
principal ingredients necessary to the Staff conclusion regard-t ing reasonable assurance as to whether the facility as proposed f
to be modified can be constructed and operated without undue risk to the health and safety of the pubLic.
The Clicensee's3 criteria, a3 defined in response to Interrogatory L, and the specific details of the remedial action constitute the basis
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of review from which such conclusions by the Staff are derived.
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_Interrocatorv 4 State and explain the basis for statement, at page 3 of the Order, that "the information provided by the Licensee fails to provide such criteria."
(Acceptance criteria.)
(Order at page 3.)
1 Answer 4
The repty to Interrogatory 6(d) identifies which of the Licensee's i'
responses the Staff found to be inadequate as of December 6, 1979.
And the response to Interrogatory 6(f) explains why.
The responses i
were inadequate, in part, because they did not provide the accept-t ance criteria, as defined in the response to Interrogatory 1, which the Staff requires for its radiological safety review.
Consider, for example, 50.54(f) Request 4 which on March 21, 1979 (1)k in part asked gw-t criteri the L censee wo'uld use to judge the acceptability of fitL, structures, and utilities upon conclu-sion of the preload program, (2) what extent of residual settle-ment would be permitted, and (3) the basis for the limit.
The,
licensee's most re:ent repty prior to December 6, 1979 (Revision
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3 to Amendment 72 dated September 13, 1979) stated that the criteria and the extent to which residual settle ents would be I
Dermitted would be provided by December 1979.
Therefore, the i
licensee's repty did not include acceptance criteria'and the Staff considered the response to be inadequate and the matter ll remains unresolved.
For further examples, refer to the response to Interrogatory 6(f).
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.I The Licensee's response was ultimately submitted February 28, 1980 5
.by Amendment 74; or about 10 months aftar the full surcharge for
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the Diesel Generator Building had been placed and 6 months after the surcharge had been completely removed.
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1 Interrogatory 5 t
i State with particularity each item of information the Staff i
requested up and until December 6s 1979 with regard to acceptance criteria.
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j Answer j
The items of information the Staff requested up, and until December i
j 6, 1979 with regard to acceptance criteria are given in the reply
-a to Interrogatory 2.
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IEWERS REGARDING INTERROGATORY p NO O
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, inct g Table 6-1s that It is important ecking the rept the information be acc e.
Thi als ans that the decision as to adequacy or inadequac tu d of Table) must reflect it 1
the decision as made by the na e
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79.
If a decision p
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j on adequacy or inadequ had not been reac e s of 12/6/79, j
the named review s d so indicate.
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4 Also let m ow if any of the named individuals were not the respon e reviewer at that time.
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Interrogatory 6_
With regard to each ites of information identified in response to interrogatory 5, state:
(a) the identity of the request; (b) whether Consumers responded to that rcquest; (c) the identity of the communication that the Staf f considered Consumers response to the request; (d) whether the Steff considered the response adequate; (e) the identity of the communication by which the j
Staff communicated its position as to the adequacy or inadequacy i
of the response; (f) the basis for the Staff's position regarding adequacy or inadequacy of Consumers response; and (g) the Staff
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personnel responsible for determining whether Consumers' response 1
was adequate or inadequate.
Answer With regard to each item of information identitifed in response to[nterrogat 5(which in tur refers to the answer to l
y interrogatory
, Table 6-1 hereto responds to parts (a), (b),
j (c), (d), Ce) and (g) of Interrogatory 6.
Answers to parts (e) and (f) of Interrogatory 6 follow.
1 For those requests shown in Table 6-1 to*be issued before December 6, 1979, but for which replies were initially made after December 6, 1979, refers to the answer to Interrogatory 8.
I Similar information for requests identified in Appendia A is provided by Appendfx 8.
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'j Regarding part (e) of Interrogatory 6, the means by which the
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Staff communicated its position as to the inadequacy of the Licensee's response was primarily by the issuance of additional questions on the same subject.
;;; fot owup requests are 4
l Listed in Table 6-1.
For example, 50.54(f) Request 35 specifically f,
indicated the response to previous Request 5 was unacceptable.
f It is not Staff practice to indicate Ii acceptable responses to Licensees, except by seperate request on 8 ;
'i a case-by-case basis.
Such indication of acceptance is typically s
l Left for issuance of the Staff's safety evaluation report for l
those responses which are of significance to that report.
l The basis for the Staff position of inadequacy shown by part g i
i of nterrogatory 6 is that the licensee's response faited to eaet the Staff's acceptance criteria as defined in response to Intierrogatory Specific reasons for failing are given below, and typically i nclude not being fully responsive to the Staff's requests or insufficient submittal of basic data to support the conclustosns or positions submitted by the Licensee.
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a k The response to 50.54(f)
Request 8 is Cwas3 inadequate because...
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.I The response to 50.54(f) Response 14 is twas 3 inadequate beca.se...
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The response to 50.54(f) Response 15 is Cwas3 inade quat e beca.se...
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The response to 50.54(f) 16, although responsives is :f j
a nature that additional work (by the licensee $ is required *:r I) an acceptabte reply.
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50.54(f) Request 17 asked how code-allowable conditions of underground Category I piping wilL be assured throughout plant Life.
The reply contains no commitment to use the 3.05c Limit of part NC-3652.3 of Section III, of the ASME Coder Division 1.
Howevers the response, in Table 17-2, does indicate that the Code calculations were used.
The response provides a comparison a
of the ASME Code limit to the calculated pipe stresses resulting from settlement for illustration purposes only.
C17?]
The reply provided no acceptance criteria for inclusion of future settlement of buried piping over the life of the plant.
Also, C1773 no acceptance criteria was provided for cases where the attowable stresses were exceeded. CA. Cappucci to confirm 3
- 50. 54 ( f) Request 18 asked for an iddntification and description of evaluations of seismic Category I piping to assure that it can withstand increased differential settlement between buildings, within the same buildings or within the piping systems itself without exceeding code-attowable stress crit'eria.
Request 18 also asks for the licensee's plans to assure compliance with code-allowable stress criteria throughout the life of the plant.
The i
response for seismic Category I piping between structures makes a general reference to applicable codes, but provides no indica-tion as to which codes or as to what specific acceptance criteria the piping is to meet.
Therefore, more specific criteria as to the stress limits to be used is required.
CA Cappucci to confirm or rewrite 3.
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1 50.54(f) Request 20 asked for' acceptance criteria required to j
define acceptable loads or components and supports produced by pipe deformations due to settlement.
The reply defined no acceptance criteria, but only stated that the loads on components were within the allowables.
The reply provides no acceptance
.l criteria as to when flanged joints wiLL be disassembled and the
.i methods for determining nozzle loads.
Acceptance criteria for the allowable differential settlement for the 2-inch and smaller diesel generator fuel oit Lines was not addressed. CA. Cappucci
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to confirm or rewrite 3.
l; criteria [was!not St.IThe raff 's final deci I
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t erm nati of a alterna ive.i hic requreshin ar,
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1 TABLE 6-1
- i id0ctity of nihether
Response
Staff's follou-up Responsible j
50.54 (f)
Consumer Identification M
Requests Staff Request Responded as of 12/6/79 Consideration Personnel i
as of of Response j
12/6/79 Adequa 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 4/
Ye Rev. 3, 9/13/79, Inadequate L. lleller &
Responses to NRC
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D. Gillen i
Requests Regarding l
Plant Fill 5
Ye Rev. O, 4/24/79, Inadequate 5, 3 L. IIeller &
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Responses to NRC D.
Gillen j,
Requests Regarding l.
Plant Fill 6/
Ye Rev. 3, 9/13/79, Inadequate [
3 L. Heller &[
u Responses to NRC T
D. Gillen W
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Requests Regarding
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Plant Fill g,,g,,fe 7
8 Yes Rev. O, 4/24/79 Adequate.
Ifel L
Responses to NRC D.
f Requests Regarding Plant Fill 9
Ye Rev. O, 4/24/79,
Response
L. Heller &
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Requests Regarding Question 12 f!
Plant Fill
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10 Rev. O, 4/24/79
Response
L. Heller &
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F Responses to NRC referred to D. Gillen Requests Regarding Question 12
.t Plant Fill 11 /
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Rev. O, 4/24/79 Adequate L. Heller &
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f Responses to NRC D. Gillen T
'*r Requests Regardin Plant Fill
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TABLE 6-1
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Identity of Whether
Response
Staff's follow-up Responsible 50.54 (f)
Consumer Identification M
Requests Staff i
Request Responded as of 12/6/79 Consideration Personnel as of of Response i
12/6/79 Adequacy 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g)
I' 12 Yesf Rev. 3, 9/13/79, Inadequate /
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L. Heller &
F Responses to NRC D. Gillen {
Requests Regarding Plant Fill 13 Yes Rev.
1, S/31/79
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25,48 R.
- Lipinski, Responses to NRC F. Rinaldi Requests Regarding F. Schauer i
Plant Fill 14 Yes Rev. 3, 9/13/79
?
25, 28, 29 R. Lipinski Responses to NRC F. Rinaldi Requests Regarding F. Schauer L
Plant Fill 15 Yes Rev.
3, 9/13/79
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25, 26 R.
Lipinski Responses to NRC F. RinaIdi 7
Requests Regarding F. Schauer Plant Fill k
16 Yes[
Rev. O, 4/24/79 Responsiv
, 34 L. Heller & g Responses to NRC but additiona D. Gillen r
Requests Regarding work required k
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Plant Fill to resolve i
17 Yes Rev. 2, 7/9/79, Inadequate 45 R.
Stephens f
Responses to NRC A. Cappucci Requests Regarding Plant fill j
18 Yes Rev. O, 4/24/79, Inadequate
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Responses to NRC A. Cappucci Requests Regarding Plant Fill U,
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TABLE 6-1 - -
Identity of Whether
Response
Staff's Follow-up Responsible 50.54 (f)
Consumer Identification M
Requests Staff Request Responded as of 12/6/79 Consideration Personnel as of of Response 12/6/79 6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) 19 Yes Rev. O, 4/24/79, Not determined
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R. Stephens Responses to NRC A. Cappucci Requests Regarding Plant Fill i
20 Yes Rev. 2, 7/9/79, Inadequate
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Requests Regarding Plant Fill i
21(c)
[s Rev. O, 4/24/79,
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Requests Regarding g
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APPENDIX B b
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Identity of Whether
. Communication Staff's Follow-up Responsible Request Consumer Identification Consideration Request Staff Responded as of 12/6/79 of Response M
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as of Adeq' ua y 12/6/79 y
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6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g) j.
l 362.1 Y
FSAR Rev. 24, 9/79, Adequate L. Heller s
n es to NRC gg D. Gillen I
362.13 /
Ye FSAR Rev. 20, 4/79, Inadequat /
L.
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Responses to NRC 1
D. Gillen I' '
Questions
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Postpone [ Responses to NRC FSAR Rev. 24, 9/79, Inadequate../
L. Heller
Response
D.
Gi,11en 4>
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future date.
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FSAR Rev.24, 9/79, Adequate
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L. Heller Yes[
362.15 l
Responses to NRC-D. Gille Questions
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362.16 Yes FSAR Responsive b M kiS L. Heller [
D. Gillen t'
Responses to NRC submittal of l
Questions needed revised settlement analysis
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362.17 Yes FSAR Rev. 24, 9/79, Inadequate /
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130.21 Yes FSAR Rev. 24, 9/79, Inadequate
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Responses to NRC F.
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Questions F. Schauer 1<
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APPENDIX 8.
!s Identity of Whether Communication Staff's Follow-up Responsible.
I Request Consumer Identification Consideration Request Sta f f Res nded as of 12/6/79 f Response i
12/6/79 g
6 (a) 6 (b) 6 (c) 6 (d) 6 (e) 6 (g)
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(?) 130.23 Yes FSAR Rev. 24, 9/79, Inadequate
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R.
Lipinski ?
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Responses to NRC F. Rinaldi Questions F.
Schauer l
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Yes FSAR Rev. 24, 9/79, Inadequate
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R. Lipinski ?
Responses.to NRC F. Rinaldt o'
Questions F. Schauer 1
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40.106
- Yes FSAR Rev. 24, 9/79 Inadequate
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H. Balujian i
Responses to NRC R. Stephens e
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Questions A. Cappucci hi D
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,l State With particula [i y eac[ item of information the Staff i
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PeQuested;3fter Decemcer 6s 19N with regard to acceptance criteria.
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Interrogatory 9 Excluding the in f orm a t i o.1 provided in response to interrogatory 5, state with particularity each item of information the Staff felt was necessary, as of December 6, 1979, for Consumers to provide in order for the Staff to have concluded that "the safety issues associated with remedial action taken or planned to be taken by the Licensee to correct the soit deficiencies wilL be resolved."
t (Order at page 3).
.1 An s we_c
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i As of December'6, 1979 the Staff had determined that, because Licensee had failed to supply certain acceptance criteria, it could not conclude that the safety issues associated with remedial action taken or planned to be taken to correct the soit deficiencies would be resolved.
The Staff had not determined, as of December 6, 1979 "each item of information the Staff felt was necessary, as of December 6, 1979 for Consumers to provide in order for the Staff to have concluded that thefsafety issues associated with remedial action taken or planned to be taken by the Licensee to correct the soit deficiencies wilL be resolved' order at page 3."
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N Interrooatory 10 For each item of information set forth in response to interrogatory 9, st at e (a) whether the Staff had requested Consumers to provide l
i such information; (b) the identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response to the request; (d) whether Consumers' response was deemed adequate by the St af f; Ce) the identity of the communication by which the Staff's evaluation of j
Consumers' response was communicated to Consumers; (f) the basis j
for the Staff's position regarding adequacy or inadequacy of 4
Consumers' response; and (g) the Staff personnel responsible for determining whether Consumers' response was adequate or inadequate.
Answer See answer to Interrogatory 9.
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Interrogatory 11 wt Excluding the information provided in response to interrogatory 7, t
state with particularity each
- 1. tem of information the Staff feels, as of the date of answering this interrogatory, is necessary for Consumers to provide in order for the Staff to conclude that "the safety issues associated with remedial action taken or planned to be taken by the Licensee to correct the soil deficiencies wilL be resolved."
(Order at page 3.)
i l
Answer
?
The Staff has not completed its review of information submitted by Licensee relative to the proposed remidial actions.
It is therefore impossible to delineate "with particularity each item of information the Staff feels, as of the "date of answering this i
interrogatory, is necessary for Consumers to provide in order for the Staff to conclude that 'the sifety issues associated with remedial action taken or planned be taken by the Licensee to correct the s o i l, deficiencies wiLL be resolved.'
(Order at page 3.)"
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6 Int errogat ory 17 r
Explain and provide the basis for the statement at page 2 of the Order that "This statement is material in that this portion of the
?
FSAR would have been found unacceptable without further Staff analysis and questions if the Staff had known that Category I structures had been placed in fact on random fill rather than
-t controlled compacted cohesive fitL as stated in the FSAR."
J i
Answer 13 Information submitted as part of an application for licenses in 1
]
accordance with 10 CFR 50.30 is " material" if that information would or could have an influence upon a safety conclusion of the NRR Staff.
A material statement which is false is of concern if I
I it could have resulted in an improper finding or a Less probing analysis by the NRR Staff.
As described on page 2 and Appendix B i
i of the Order, had the NRR Staff relied upon the statement in FSAR Section 2.5.4.5.3 which states that "alL fitL and backfitL were a
placed according to Table 2.5-9"i it would or could have erroneously j
concluded that the fitts and backfill placed for the support of E
structures and the Diesel Generator Building consisted of " clay" (Table 2.5-9 under " Soil Types") or " Controlled compacted cohesive fi t L" (Table 2.5-14 under " Supporting Soils") which had been
.}
compacted, as a minimums to 95% otASTM D 1557-66 T modified to j
get 20,000 foot pounds of compactive energy per cubic foot of j
soit (see Table 2.5-9 under " compaction criteria").
The reality of the situation is that the fills'and backfills beneath the 1
l structures and the Diesel Generator Building are not " clay" or l
a " controlled compacted cohesive fill", but consist of a hetero-geneous mixture of sands clays sitt and Lean concreter and the 2_
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t minimum compaction criteria implied as having been achieved by the quoted statement from FSAR Sec' tion 2.5.4.5.3 was not acheved.
I-Thereforer a conclusion by the NRR Staff that the fitLs and back-t ftLLs were of a different type or had been compacted to kncwn or could minimum standards would,have been erroneous and would contribute to or preclude a more probing analysis or further 4
questioning.
Based upon the FSAR informations the NRR reviewer would or could have conc _Luded that the structure was adequately supported, that it would not experience detrimental settlements that its foundations would remain stable under both static and j
earthquake loadings and.that the fill properties would be at t
least equal to design values provided in the PSAR.
The reviewer's conclusion would have been relevant to the NRC findings pursuant t o 10 C FR 50.57 (3) for Tssuance of operating Licenses and would have contributed to'a finding that there is reasonable assurance
'that the activities authorized by the operating License can be conducted without end' angering the health and safety of the public.
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Interrogatory 9 Excluding the information provided in response to interrogatory 5, state with particularity each item of information the Staff felt was necessaryr as of December 6, 1979, for Consumers to provide i
- i in order for the Staff to have concluded that "the safety issues associated with remedial action taken or planned to be taken by the licensee to correct the soit deficiencies will be resolved."
4 I
(Order at page 3).
. An s w e_r As of December 6, 1979 the Staff had determined that, because k Licensee had failed to supply.certain acceptance criteria, it could not conclude that the safety issues' associated with remedial action taken or planned to be taken to correct the soit deficiencies would be resolved.
The Staff had not determinedi as of December 6r 1979 "each item of information the Staff felt was necessary, as of u
December 6, 1979 for Consumers to provide in order for the Staff to have concluded that theIsafety issues associated with remedial action taken or planned to be taken by the Licensee to correct 1
the soit deficiencies will be resolved' Order at page 3." 6r.L, q
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The information the Staff felt was necessary, as of December 6,1979
]
was essentially that identified in answer to Interrogatories 2 and 5, in-f cluding Appendix A, relative to acceptance criteria.
It sho6Ld be noted,
]
however, that prior to December 6,1979, the full extent.of the plant fill
.t settlement problem was unknown and was under review.
For example, 50.54(f)
Request 12 from H. Denton letter of March 21, 1979 asked for documentation of the condition of the soils under all safety related structures and J
utilities founded on plant fill or natural lacustrine deposits.
This same j.
request asked for-discussions of measures to be taken if foundation materials j
are found to be deficient. Consumer's response to Request 12 (initially on April 24, 1979 and subsequently by Revision 1 on May 31,1979, Revision 2 on July 9, 1979, and Revision 3 on September 13, 1979) provided information which the Staf f fcund not to be fully responsive and, therefore, unacceptable.
The basis for the Staff's conclusion on acceptability is illustrated by the issuance of followup requests which seek to have Consumers provide its -
design and criteria in sufficient detail to enable the Staff to conclude i
whether there is reasonable assurance of plant safety considering those 7
modi fi cations. An example of this proUB4m is illustrated by the issuance of Requests 41 and 42 by the Staff's letter of August 4, 1980 in which the Staf f's geotechnical consultant, the U.S. Army Corps of Engineers, continue to seek basic information and data not previously provided in Consumers respenses regarding the fixes proposed for the Service Water Intake Structure f
and the Auxiliary Building which the Staff needs to reach a conclusion on the i
acceptability of plant repairs.
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-Certain' items of information, in' addition to that provided in response y
to interrogatories 2 and 5 were probably felt to be needed by'the staff i-prior to. December 6,1979 with respect to underground piping and f
associated components. The items are that:
j (a) All the seismic Category I piping be profiled.
,f.
.l (b) - Remedial action be specified for the case in which stresses i
due to settlement should approach or exceed Code allowable 1
values.
]
(c)
Details as to the calculational methods and assumptions for 1
determining stresses due to settlement and other combined loads be provided for review.
(d) Results of~the stress" analysis of nozzle loads be submitted.
(e) A suitable monitoring program be~ established to monitor future settlement for the life of the plant.
(f)
Future settlements be included in the planned stress analyses.
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The items identified
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. Mr.
R.' Stephens, is no longer employed with the tJRC.
]
reflect the opinion or recollection of the subsequent and present MEB Staff
~
reviewed, Mr. A. Cappucci, from' earlier personal' discu::sions and notes.
It is not known how or whether any of these possible needs may have been
~ conveyed to. Consumers.'
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- i Interrogatory 10 9
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For each item of information set forth in response to interrogatory j
9, state (a) whether the Staff had requested Consumers to provide ti
. information; (b) the identity of each request by the Staff to
~
'such Consumers; (c) the identity of the communication that the Staff considered Consumers' response to the request; 'd) whether Consumers' response was deemed adequate by the Staff; (e) the 1
l identity of'the communication by which the' Staff's evaluation of Consumers' response was communicated to Consumers; (f) the basis for the Staff's position regarding adequacy or inadequacy of
+.;
1 Consumers' response; and (g) the Staff personnel responsible for determining whether Consumers' response was adequate or inadequate.
Inswer\\
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Answer q..
See answer to Interrogatory 9.
Because the information the Staff felt.
f-was necessary as of December 6, 1979 was essentially that identified in answer to Interrogatories 2 and 5, the answer to interrogatory 10 is essentially
-provided by the. answers to Interrogatory 6, including Appendix 8, and by j'
that part of Interrogatory 8 relevant to indicated Requests 24 through 35.
1 With respect to certain items of information (a) through (f) identified in the answer to Interrogatory 9 with respect to underground piping and associated components, the answer to Interrogatory 10 is provided by Table 10-1.
The answer to Interrogatory.10(f) follows.
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(a).The criteria for selection of the piping to be profited -
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appears to be based onL the soils in the same proximity as 3
being homogeneous. There appears to be insufficient evidence that this is the case.
(b) The response to 50.54(f)
Request 17 stated that the stresses L;.
due to settlement would be well below the code allowable
..e values as indicated in Table 17-2 of that response.
Therefore,
~
it was indicated that remedial action was not planned by 3
consumers. This is not adequate because (1) not all seismic Category 1 piping was profited, (2) future settlements had not been predicted, and (3) the results of the surcharge program had not been established.
(e) The response to 50.54(f) Request 18 in July 1979 indicated no plans for a monitoring program if the settlements remain within i
j.
the predicted range. It was not clear as to the time frame and methods for verifying the predicted ranges.
(f) The response to 50.54(f) Request 17 provided no information on settlements over plant Lifetime.
The response to 50.54(f) Request 18 was adequate. The response to 50.54(f) Request 19 provided no information as to the predicted deformations.
4
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TABLE 10-1 Item from Whether Staff Identity of
Response
Staff's Con-How Position Responsible i
Interr.
Requested Request Identi fi cation sideration of Conveyed to Staff
'j 9
Information 10(b) 10(c)
Response
Consumers Personnel 10(a)
JAdequacy 10(e) 10(g)
<nra)
I 9(a)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17, quest 17, Rev.
A. Cappucci Denton 3/21/79 2, 7/79, Res-8j ponses'to NRC
,f Requests'Re-i
}
garding Plant
}
FILL 1
4:
9(b)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 17 quest 17, Rev.
A. Cappucci Denton 3/21/79 2 7/79, Respon-ses to NRC Re-1 2
quests Regard-t ing Plant FILL
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TABLE 10-1 p
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No None None Not applicable Not applic-R. Stephens
,1
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b i
9(d)
No None None Not applicable-Not applic-R. Stephens l-g 4
I able A. Cappucci 9(e)
Yes 50.54(f) 50.54(f) Re-Inadequate Unknown R. Stephens Request 18 quest 18, Rev.
A. Cappucci
[
2, 7/79, I
I; a
Responses to l
N i
NRC Requests i
Re'garding Plant q {
Nill 9(f)
Yes 50.54 (f) 5d.54(f) Re-Inddequate Unknown R. Stephens y
Requests 17, quests 17,18 A. Cappucci
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18 and 19 and 19, Rev. 2,
.b t'
7/79, Responses to-l-
NRC Requests Re-j.
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garding Plant FILL o
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Interrogatory 11 li ij Excluding the information provided in response to interrogatory 7, f'
state with' particularity each item of information the Staff feels, as'of the date of answering this interrogatory, is necessary for consumers to provide in order for the Staff to conclude that "the safety. issues associated with remedial action taken or planned to be taken by the licensee to correct the soil deficiencies will
'i be resolved."
(Order at page 3.)
i Answer _
i The Staff has not completed its review of information submitted by Licensee relative to the proposed remedial actions.
It is therefore impossible to delineate "with particularity each item of information the Staff feels, as of the date of answeri.1g this interrogatory, is necessary for Censumers to provide in order f or the Sta f f to concluue that 'the safety issues associated with renedial' action taken or planned be taken by the licensee to currect j
the soit deficiencies will be resolved.'
(Order at page 3.)"
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To illustrate-this inability, consider two recent occurrences:
1 (1) On January 21, 1981, consumers submitted a potentialy report-able 50.55(e) report advising of an error in the 1977 computer model used for the seismic analyses of the Control Tower and the main portion of the Auxiliary Building.
Pending further analysis by Consumers, it is not possible for the NRC to assess the ability of the Control Tower to assume the additional load resulting from i
the bridged support scheme proposed for the Electrical Penetration Area; (2) Consumers has also indicated that additional cracking of the concrete ring base of the-Borated Water Storage Tank has occurred during the' full scale load test.
The Staff is presently awaiting Consumers' assessment of this occurrence.
It should also be noted that resolution of the matter of establishing appropriate seismological input, as discussed in the Staff's i.etter of October 14, 1980 and in a December 22, 1980 " Summary of December 5, 1980 Meeting on seismic Input Parameters," is deemed to be i
relevant to the staff conclusion that the safety issues associated lf with remedial action taken or planned will be resolved.
.: 1
't The information needed by the staff for its review of the remedial
's actions is essentially that identified in response to interroga-lI tories 2, 6, 7 and 8, plus Appendices A and B, with respect to acceptance criteria for those response items indicated to be inadequate.
In Table 6-1 and Appendix A, the indication of
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i 1979.
However, the present staff position may be ascertained from
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the indicated disposition of the associated follow-up questions.
The occurrences and seismic matter discussed in interrogatory 11
{
also needs to be satisfactorily resolved.
i t
With regard to underground piping, and excluding the information needed from interrogatory 7, the following information is needed:
(a)
A final stress analysis of the seismic Category I piping.
(b)
An explanation for some of the relatively rapid changes in some of the piping profiles and the magnitude of the loads which cause these changes.
(c)
The actual and predicted clearances at end of plant life of seismic Category I piping at building pene-trations.
(d)
Tha loads and stresses on the piping at their termina-tion points (anchors, equipment, larger pipe, etc.).
(e)
From the January 20, 1981 meeting, provide method and basis for normalizing the profile data prior to per-j-
forming the stress analysis and use of 3-inch future a
settlement data.
It a non-linear analysis is to be 4
performed, provide the analysis methodology with a i
i summary of the results.
Include a presentation of the margin to the Code allowable value for settlement only IJ I
l
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49
- i and the same for the margin to failure considering all primary and secondary stresses.
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Interrogatory 12 (1
II I
For each item of information set forth in response to interrogatory 11 state: (a) whether the Staf f had requested Consumers 'to provide such infor-mation; (b) the identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response; (d) whether Consumers' response was deemed adequate by the Staff; (e) the identity of the communication by which the Staff's evaluation of Consumers' response was communicated to Consumers; (f) the basis for the Staff's f
position regarding adequacy or inadequacy of Consumers' response; ar.d (g) the Staff personnel responsible for determining whether Consumers' response was adequate or inadequate.-
5 Answer l
See answer to Interrogatory 11. With respect to the iriformation needed with' respect to underground piping, see Table 12-1.
l With respect to the adequacy of item 11a on Table 12-1, the Bechtel stress analysis appeared to be unconservative and did not give a true representation of the actual stress in piping. There were questions hs to which profiles were used and the justification for the boundary conditions assumed. An ETEC stress analysis demonstrated much higher stresses than those in the Bechtel a
report. At the 1/20/81 meeting Bechtet stated that subsequent analyses had shown higher stresses for some Lines.
I
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TABLE 12-1 5
5 Interr. 11 Whether Staff Request
Response
Adequacy How Disp.
Responsible 5
h Item p Requested Identifi-Identity Disposition Communi-Staff cation 12(c) 12(d) cated to Personnel 12(a) 12(b) consumers 12(f) 4 12(e) 11a Yes Tedesco Cook letter Inadequate Conference A. Cappucci Letter 11/14/80 with call 1/14/81 J. Brammer
- E 10/20/80 encl.
k 11 b,c & d Yes Meeting of No response No response No response A. Cappucci 1/20/81 J. Brammer 11e In progress Not Applicable None Not appl.
Not appl.
A. Cappucci
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Interrogatories 13 through 16. See separate objectims filed by the Staff.
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Interrogatory 17
[
Explain and provide the basis for the statement at page 2 of the 4
Order that "This statement is material in that this portion of the 1
{
FSAR would have been found unacceptable without further Staff
[
analysis and questions if the Staff had known that Category I structures had been placed in fact on random fill rather than r
(
controlled compacted cohesive fill as stated in the FSAR."
Answer Information submi.tted as part of an application for licenses in 1
accordance with 10 CFR 50.30 is " material" if that information would or could have an influence upon a safety conclusion of the NRR Staff.
A. material statement which is false is of concern if it could have resulted in an improper finding or a less probing analysis by the NRR Staff.
As described on page ? and Appendix B
{
of the Order, had the NRR Staff relied upon the statement in FSAR Section 2.5.4.5.3 which states that "all fitt and backfilt were placed according to Table 2.5-9",
it would or could have erroneously concluded that the fills and backfitL placed for the support of 1
i structures and the Diesel Generator Building consisted of " clay" (Table 2.5-9 under "Soit Types") or " Controlled compacted cohesive fitt" (Table 2.5-14 under " Supporting Soils") which had been compactede as a minimum, to 95% ofASTM D 1557-66 T modified to get 20,000 foot pounds of compactive energy per cubic foot of soil (see Table 2.5-9 under " Compaction criteria").
The reality of the situation is that the fitts and backfills beneath the
[
structures and the Diesel Generator Building are not " clay" or a " controlled compacted cohesive fill"r but consist of a hetero-geneous mixture of sand, clays sitt and lean concretes and the Nw
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miEimum compaction criteria implied as having been achieved by the s
s
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quoted statement from FSAR Section 2.5.4.5.3 was not acheved.
I a conclusioit by the h Staff that the fitts and back-Ac h
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+
fit.t,s were af a dif ferent, type or had been compacted to known
.i-a miliimuk standards wodt~d'have been erroneous and would or could
/
cont ribut'e to or preclude a moie probing analysis or further
~
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. quest ion' ng.
Based upon the FSAR informations the NRR. v. -; ; ; ;.-
wout'd oi could have concluded that the structure was adequately f
support e'dr.t hat it would not experience detrimental settlemente l
that its foundations'would remain stable under both static and
.,p'*
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earthqtahi toadings and that ~ the fitt properties vould be at
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teast equalvto design vatuesprovided in the PSAR.
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conclusiorf would ha've been rel4vant to the NRC findings pursuant 1
l.
t o 10 (. F R. 6. 57 - ( 3 ) f'o b. i ~s s Q a n c e o f operating Licenses and wnuLd l
l have cont /ib'oted to a finding that there is reasonable as.surance i
that the activiiios. authorized by the operating license can L
be conducted withoutJendangering the health and safety of the 1,
p u b t. i c.
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Darl Hood, being duty sworn, deposes and says that to the best of his knowledge and belief the above information and the answers to the above interrogatories are true and correct.
Da t Hood ii 1
L 1,
Subscribed and sworn to before me
!t i
i4 l-this day of February,1981.
I I li l
Notary Public,.
1 r
ity Commission Expires:-
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Define " acceptance criteria," as that term is.
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used at' page 3 of the Order.
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State which "of the Staff's requests were i
directed [as of or before December 6,1979] to thq determination,'
and justification of acceptance criteria to be applied to
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various remedial measures taken" (Order at page 3) and which portion of each request was so directed.
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State and explain t,he reasonjp wh "such
_ _ _[ acceptance criteria), coupled with the details of the j
tj remedial action, are necessary for the Staff to evaluate the
- t technical adequacy and proper implementation of the proposed action."
(Order at page 3.)
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State and explain the basis for the statement,'-
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licensee fails to provide such criteria."
(Acceptance
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criteria.) (Order at page 3.)
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State with particularity each item of information --
~t tlie Staff requested up and until December 6,1979 with regard to acceptance criteria.
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With rig:rd to each item of infarmatica identified in response to interrogatory 5, states (a) the identity of the requests (b) whether Consumers responded to that requests (c) the identity of the communication that the
- Staff considered Consumers response to the request; (d) whether the Staff considered the response adequate; (e)
{
the identity of the communication by which the Staff communicated its position as to the adequacy or inadequacy of the responses (f) the basis for the Scaff's position regarding adequacy or,
{
inadequacy of Consumers response; and (g) the Staff personnel responsible for determining whether Consumers' response was s
adequate or inadequate.
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-(g) the Staff personnel responsible for determining whether Consumers' response was adequate or inadequate.
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Response. With regard to each item of information identified in response to !
il 7
interrogatory 5 (for GES purpose this is actually interrogatory 4
- 2) the following table is provided in response to parts,6 (a),
6 (b), 6 (c), 6 (d) and 6 (g). Responses to parts 6 (e) and 6 (f) follow the table.
Identity of Whether Comunication Staff's Responsible Request Consumer Identification Consideration Staff Responded of Response Personnel Adequacy l
\\
ir 6 (a) 6 (b) 6 (c) 6 (d) 6 (a) i L. Heller & f f
O 362.12 Yes
. FSAR - Responses Adequate ij
'to NRC Questions D. Gillen i
362.13 Yes FSAR - Responses Inadequate L. Heller &
L-to NRC Questions D. Gillen 14 i '
FSAR - Responses Inadequate.
L. Heller &
362.14 g
to NRC Questions
Response
D. Gillen 1
postponed to
{ \\ M",, -
future date.
i \\
i 362.15 Yes FSAR - Responses Adequate L. Heller i
to NRC Questions D. Gillen 362.16 Yes FSAR - Responses Responsive but L. Heller to NRC Questions submittal of D. Gillen needed revised settlement analysis postponed to future.
362.17 Yes FSAR - Responses Inadequate L. Heller to NRC Questions D. Gillen J
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Identity of Whether Comiunication Staff's Responsible Request Consumer Identification Consideration Staff Responded of Response Personnel Adequacy 6 (a) 6 (b) 6 (c) 6 (d) 6 (c) 50.54(f) Questions-
-4 Yes Responses to NRC Inadequate L. Heller &
Requests Regarding D. Gillen Plant Fill 5
Yes Responses to Inadequate L. Heller &
Requests Regarding D. Gillen Plant Fill 6
Yes Responses to NRC Inadequate L. Heller &
1 Requests Regarding D. Gillen Plant Fill 9
Yes Responses to NRC
Response
L. Heller &
Requests Regarding referred to D. Gillen Plant Fill Question 12 10 Yes Responses to NRC
Response
L. Heller &
Requests Regarding referred to D. Gillen i
Plant Fill Question 12 Adequate er &
11 Yes Responses to NRC Requests Regarding Plant Fill 12 Yes Responses to NRC Inadequate L. Heller &
Requests Regarding D. Gillen Plant Fill 16 Yes Responses to NRC Responsive L. Heller &
Requests Regarding but additional D. Gillen i
Plant Fill work required Shob o' to resolve Yes Responses to NRC Adequate COE &
Requests Regarding J. Kane j
Plant Fill c
id ons.
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Identity of Whether Communication Staff's Responsible Request Consumer Identification Consideration Staff Responded of Response Personnel Adequacy 6 (a) 6 (b) 6 (c) 6 (d) 6 (a) 1 249 Yes Responses to NRC Inadequate COE &
Requests Regarding J. Kane Plant Fill 27 Yes Responses to NRC Inadequate COE &
Requests Regarding J. Kane 3
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N hhb-x 35 Yes Responses Inadequate COE &
Requests Regarding J. Kane Plant Fill In answer to interrogatory 6 (e), the means by which the Staff connunicated its position as to the adequacy or inadequacy of the Applicant's response s
would be by the issuance of additional questions on the same subject.
For example, 50.54 (f) question 35 specifically indicates the response to previous question 5 is unacceptable and then requires the completion of exploration, sampling and testing of soil samples.
The Applicant's responses which were found acceptable by the Staff should have been recognized by obsmce Consumers by thegumiss4Bn of further questions on th.ose specific items.
The basis for the Staff position on adequacy (interrogatory 6f) is that Consumers response failed to meet the Staff's acceptance criteria as defined in response to interrogatory 1.
N Specific reasons for failing include not being fully responsive to the questions asked or insufficient l
l submittal of' basic data to support the conclusions or positions submitted by x
Consumers. ( An example where Consume 3s has repeatel17~ fille [to fully respond h
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to the Staff's request is exemplified in the June 30, 1980 letter from A. Schwencer to J. W. Cook (copy enclosed). This letter clearly indicates that Consumers previous responses to questions 5 and 35 continue to be unacceptable and offers observations to better clarify the Staff's position and concern for the effectiveness of the preload program. As late as February 1981 Consumers has steadfastly refused to provide the requested infomation which the Staff and its Consultant feel is necessary to have reasonable assurance for plant safety.
I Interrogatory 7.
State with particularity each item of infomation the Staff requested after December 6,1979 with regard to acceptance criteria.
Response. The following table identifies each Staff request after December 6,
~
1979 with regard to acceptance criteria. The infonnation contained in each request has been available to Consumers since^the data listed in the third column when this information was transmitted to them.
Identification of Previous Applicable Portion Date Request /
Staff Request of Request Submitted to CPCo 50.54 (f) Questions' Entire requests June 30, 1980 36, 37, 38 50.54(f) Questions Entire requests August 4, 1980 39, 40, 41, 42, 43, 44 45, 46, 47, 48 d
6 t
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Interrogatory 8.
With regard to each item of information identified in response to interrogatory 7, state:
(a) the identity of the request; (b) whether Consumers responded to that request; (c) the identity of the cmanunication that the Staff considered Consumers response to the request; (d) whether the Staff e
considered the response adequate; (e) the identify of the connunication by which the Staff communicated its position as to the adequacy or inadequacy of the response; L
Response. The identity of the requests has been provided in response to interrogatory 7.
Consumers did respond to the staff's requests with their submission of FSAR Amendment 85 (Revision 10, dated November 1980). The adequacy of Consumers response to the requests identified in interrogatory 7 is currently being evaluated by the NRC Staff and its Consultant, the U.S. Army Corps of Engineers.
In the February 12,1981 Memorandum and Order from the ASLB (page 4) it is indicated that Mr. Kane should be made available for deposition questioning on Amendment 85 to the FSAR.
It is the intent of the Staff to formally respond to Consumers on the adequacy of their responses in Amendment 85 submittal following Mr. Kanets March 18, 1981 deposition.
6
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i.j-if Interrogatory 9.
Excluding the information provided in response to l
-interrogatory 5, state with particularity each item of information the Staff felt was necessary, as of December 6,1979, for Consumers to provide in order for the Staff to have concluded that "the safety issues associated with
- 7 remedial action taken or planned to be taken by the licensee to correct the 4
soil deficiencies will be resolved." (Order at page 3.).
2 Response. The information provided in response to interrogatory 5 (for GES purpose this is actually interrogatory 2) essentially identifies the infomation the Staff felt was necessary as of December 6,1979.
It should be noted, however, that prior to this date that the full extent of the plant fill settlement problem was unknown and was under investigation. For example, 50.54 (f) question 12 (submitted by NRC to Consumers on March 21,1979) requres the documentation
{
of the condition of the soils under all safety related structures and utilities founded on plant fill or natural lacustrine deposits.
In this same question the Staff requests the submittal of discussions on measuresto be taken if foundation materials are shown to be deficient. Consumers in their response to question 12 (initially on April 24,1979, then in Rev. 1 May 31, 1979; Rev. 2 July 9,
(,
1979; Rev. 3, Sept. 13, 1979) provides infomation that is evaluated
(
by the Staff to be not fully responsive and acceptable. The basis for the Staff's conclusion on acceptability is best illustrated by the need to issue additional questions.which seek to have
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,i Consumers provide their design and criteria in sufficient detail 1
'i to pemit the staff to conclude there is reasonable assurance on d-plant safety. An example of this problem is illustrated by the issuance of 50.54 (f) questions 41 and 42 (submitted to Consumers j
on August 4,1979) which were prepared by NRC Consutant, the 1
U.S. Anny Corps of Engineers. The Corps had become actively j
involved in the Midland review after the December 6, 1979 Order.
]
Questions 41 and 42, continue to seek basic infomation and data not previously provided in Consumers responses on the fixes proposed for the Service Water Structure and the Auxiliary Buildin which will permit the Staff to reach a conclusion on the acceptability of plant repairs.
Interrogatory 10. For each item of infomation set forth in response to interrogatory 9. state (a) whether the Staff had requested Consumers to provide such infomation; (b) the identity of each request by the Staff to Consumers; (c) the identity of thecomunication that the Staff considered Consumers' response to the request; (d) whether Consumers' response was f
deemed adequate by the Staff; (e) the identity of the comunication by which the Staff's evaluation of Consumers' response was connunicated to Consumers; j
(f) the basis for the Staff's position > regarding adequacy or inadequacy of Consumers' response; and (g) the Staff personnel responsible for detentining 4
j whether Consumers response was adequate or inadequate.
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i 21 Response. Our response to Interrogatory 9 indicates the infomation provided I
in reply to interrogatory 5 essentially identifies the infomation 10
.the Staff felt was necessary as of December 6,1979. For this reason no response to Interrogatory 10 is needed.
a Interrogatory 11. Excluding the information provided in respone to l
interrogatory 7 state with particularity each item of infomation the Staff feels, as of the date of answering this interrogatory, is necessary for Consumers to provide in order for the Staff to conclude that "the safety issues associated with remedial action taken or planned to be taken by the licensee to correct the soil deficiencies will be resolved." (Orderat page 3.).
Interrogatory 12. For each item of infomation set forth in response to interrogatory 11 state:
(a) whether the Staff had requested Consumers to i
provide such infomation; (b) the identity of each request by the Staff to Consumers;-(c) the identity of the conmunication that the Staff considered
+
Consumers' response; (d) whether Consumers' response was deemed adequate by the Staff; (e) the identity of the communication by which the Staff's evaluation of Consumers' response was communicated to Consumers; (f) the basis for the Staff's position regarding adequacy or inadequacy of Consumers response; and (g) the Sr.aff personnel responsible for determining whether Consumers' i
j response was adequate or inadequate.
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-l Response. Excluding the information provided in response to interrogatory 7
- i the staff has not identified, as of February 19, 1981, any
. additional infomation 't feels is necessary for Consumers to provide in order for the Staff to conclude that the safety issues associated with remedial action will be resolved.
For this reason a response to Interrogatories 11 and 12 is not required.
j It should be noted from the Staff's response to Interrogatory 8 however, that upon completion of our review of Amendment 85 there exists a possibility that additional requests for information and
~;.
questioning may result.
Interrogatory 14. As of December 6, 1979 with regard to each criteria identified in your. answer to interrogatory 13 state whether Consumers had submitted sufficient information to justify each acceptance criteria.
If e
Consumers had not submitted sufficient infomation, state with particularity I
which infonnation Consumers had failed to supply.
Interrogatory 15. Excluding the acceptance criteria identified in response A
2 to interrogatory 13, state with particularity each acceptance criteria which i!
Consumers has to date provided to the staff.
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1 Interrogatory 16. With regard to each criteria identified in your answer to interrogatory 15 state whether Consumers has submitted sufficient I
information to justify each acceptance criteria.
If Consumers has not i3 submitted sufficient information, state with particularity which infonnation i
I Consumers has failed to supply.
'b Response.
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Interrogatory 13. State with particularity each acceptance criteria which
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Consumers Power Companythad up until December 6,1979 provided to the staff.
p Response. Our interpretation of this, Interrogatory is that the particulars ti.
requested here have already been previously asked and responded to in i 3 j
Interrogatories 1, 2, and 6.
For example our response to Interrogatory 1 defines acceptance criteria and refers to the Standard Review Plans where
]
the basic data and infomation to address each particular engineering aspect are discussed in detail. Our response to Interrogatory 2 identifies the
}
Staff's requests [as of or before December 6,1979] that were directed to the detemination and justification of acceptance criteria and indicates which l'
portion of those requests were directed to acceptance cfiteria. Our response to Interrogatory 6 where we have indicated which of our previous requests (that have been identified as directed towards acceptance criteria) have been J
found adear. ate by the Staff would be the indicator to Consumers what acceptance criteria the Staff feels has been provided. There are portions of the information provided in Consumer's responses to the staff request
- j which responses in their entirety have bebn judged inadequate (NRC response to Interrogatory 6) that would also be consiered by the Staff to be a needed 1
portion of the supporting basic data in order to be found acceptable. As l,
previously indicated in our reqpones to Interrogatory 6, the relevant portions 1!
of Consumers responses which were found acceptable by the Stoff should havev 4
been recognized t,y Consumers by the absence of further questions on those
)
specific items.
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3 State with particularity each item of infoma- [ 'j-l tion the Staff equested after December 6,1979 with regard,
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to acceptance criteria.
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With regard to each item of information identified in. response to interrogatory 7, state: (a) the
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identity of the request; (b) whether Consumers responded to that request; (c) the identity of the communication that the Staff consider'ed Consumers response to the request; (d) 1 whether the staff considered the response adequate; (e)
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the identity of the communication by which the staff communicated its position as to the adequacy or inadequacy of the response l
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Excluding the information provided in respo se' to interrogatory 5, state with particularity each item of information the Staff. felt was necessary, as of December 6, 1
j 1979, for consumers to provide in order for the Staff to
_ have concluded that "the safety issues associated with
~~
remedial action taken or planned to be taken by the licensee to correct the soil deficiencies will be resolved." '(order
~
at page 3. )
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For each item.of information set forth in
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'l response to interrogatory 9, state,(a) whether the Staff had:
a requested Consumers to provide such information; (b) the identity of each request by the Staff to consumers; (c) the identity of the communication that the Staff considered Consumers' response to the request; (d) whether Consumers' response was deemed adequate by the Staff; (e) the identity of the communication by which the Staff's evaluation of Consumers' response was communicated to Consumers; (f) the basis for the Staff's position regarding adequacy or inadequacy p
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of Consumers' response; and (g) the Staff personnel responsible -f for determining whether Consumers' response was adequate or inadequate.
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h o p o w d ico n re 4) % T.n b g eor5 e.uedria,lh tdtd4hs % frmedice Mt. h' i
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Excluding the information 'provided in response
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to interrogatory 7, state with particularity each item of i
l information the Staff feels, as of the date of answering i
this interrogatory, is necessary for Consumers to provide in i
order for the Staff to conclude that "the safety issues
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associated with remedial action taken or planned to be taken
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by the licensee to correct the soil deficiencies will be 4
resolved."
(order at page 3.)
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For each item of information set forth in
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response to interrogatory 11 state: '(a) whether the Staff -
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identity of each request by the Staff to Consumers; (c) the identity of the communication that the Staff considered Consumers' response; -(d) whether Consumers' response was
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deemed adequate by the Staff; (e) the identity of the i
i communication by which the Staff's evaluation of Consumers' t
i response was communicated to Consumers; (f) the basis for 3
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i Consumers' responser and (g) the Staff personnel responsible I
for determining whether Consumers' response was adequate or
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e 7 % %. Mas d icw$ect as 4 b l d an3 s.Mba\\ mhrmaten kfh ss%.4DB), l 3 necesso j l Jio<c - s % p m. Ju 9 L.L.n 4 k I 'j _,... _.... ~. _. - __.._. _.-,___ _-,,'.~ _. - - e e . _.. ~ _
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s 4 1 ~ ~ 4 14. As of December 6, 1979 with regard to each criteria identified in your an'swer to interrogatory 13 state l i whether Consumers had submitted sufficient information to justify each acceptance criteria. If Consumers had not l submitted sufficient 16 formation, state with particularity t-I. which information consumers had failed to supply. hhM 15. Excluding the acceptance criteric identified in response to interrogatory 13, state with particularity each. acceptance criteria which Consumers has to date provided' -h. l .i to the Staff. ~ '~~ ~ l - - - ^ I hb 16. With regard to each criteria identified in your answer to interrogatory 15 state whether Consumers has ~ submitted sufficient information to justify each acceptance l criteria. If Consumers has not submitted sufficient'informa-tion, state with particularity which information Consumers ' y] has failed to supply. i I 4 i E I i ,s 1 L. 1,-. -...----------,,j ~ 3 -1 q[ i-- -
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g i l 2 s j.__..._...._.....-...__.._...._.__..-___...-....._.___.,_- _ J 13. state with particularity each acceptance criteric i j _, which Consumers Power Company had up until December 6, 1979 provided to the St'aff. ~- prb.ukv5 quem bat. %e drenoj h.yas.2 n.mmywwr pc.msh Asked _ t and res.pndui 4inkeyve boes t,>2i&4. For engour ~.mp.n x tuagdogi A b-s = <g lg(rrgag<Ebn q <J s: o beseC. O ~l. W15 (Y% O. GY % IY1Cf/ Mj 43 a l an, 6scussed i,i Ar.\\.ou respnse+ lanoa g2 a i ids b A sgsmmb h 4. Mg h,Wte,anj___ F' & rww dw.AJ A A d=6 e non wd auk 4acc.epv,cn. c.fika.4 adab Acn ph{u.boe _ o,,dlh** r tupsk wue. srw<b ccq6c. v.ba. ovaespise J i ko hkcWogo 4 d tyt., d vt. pxAce N d oh 4 ao< 7 1_l kva. h M6.mikJesWk.ds acceywe ca. l requ % c_b.ew $9 f ddep%. u,%jj w% sw? h N. b h h n b t so em iAkaccy 6 p M, % on.. p n o m 4 w. 4 %...- arwM m c ,6 's res p s., 4. 4 7 o Ge *gti c p ga i l M de h r M k.m p,2 Q d cair "1 WrMoid.as be co(m vespriro Lhuo@@ 4.A matfo.4 ,sWm a'k h S M W k a necid p< hon 4h sqpn3 ksic. scsr, m esedo a {o.,d
- ..j oa.esbx. As peus.onp4cowchn ow respos=% Tau %'
l lo 4 YtIt4cnf p(I6cri5 m. Conshers fes Mes ' uAicM o i j. wt(t %<d oc.t.t FEbe k N kr she h novt % ftqme, -) 5 Cowsurnets
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} l i F L e,'. u,% upwem,. c., bb v m3.,so.544) cpesb,(o = svLed hCesom. 3 hMeshe b vet.{af k tyG >nf t u) Ve&Inc,h skh + o @ W f p itIQ i m. c < W d p a h o o d M h 4. % 1AX1ktr (4 JA @ m q.,5. W o a.e, u., A soly-WW-T- .,.c., p e.nWJ $bs : 3 Queaeicn 6 Quuttl M 2AM ) You propose to fill the borated water storage tanks and measure the resulting structure settlements. (al on what basis do you conclude a surcharge no greater than the tank leading will achieve compac-tion to the extent intended by the criteria stated in the PSAR7 What assurance is provided by the technique that residual settle.ent for the life of the plant will not be excessive? (b) A similar procedure is proposed for other tanks, including the diesel fuel oil storage tanks, and should also be addressed. (c) The borated water storage tanks have not yet i been constructed and are to be located upon question-able plant fill of varying quality. Provide justifi-cation why these safety-related tanks should be constructed prior to assuring the foundation material is suitable for su;;crting these tanks for the life of the plant. For example, can the tanks be removed with reasonscle effort without significant impact? %3 byerdthe 4 (oh o (e wgyt, M @nQ l Mes;cnse (to Cuestion 6, Part alhih tuued4N9,M 1hhi k kl%kN he field explcratien progrart in the area of the horated watar storage tanks (BWSTs) shows that the material below approximately the tcy J feet is satisfactory All unsuitable material, as determined by scil testing, in the tank farm area will be removed and replaced by suitable compacted fill. The BWST foundations (bottom elevation 629'-0*) are underlain by suitable material. To confirm that the fill is parisfactory, the tanks will he constructed and filled with water in order to nake a full-scale test of the foundation soils. The tank tilling will pr= vide relistle information for predicting 1cng-term settlement. Although the degree of compaction set forth in the 75A2 may not be satisfied at all 4eints, the PSAA design intent will he et because the fill will have been subjected to a full-scale 1:ad test, which will allow a reliable prediction of 1cng-term settle ent. The full-scale load test provides direct and reliable assurance that unpredicted icng-term settlenents will not occur. 3ocause the piping connections will he ade to alicw startup ~~ flushing,. filling, and testing of the tank, selected points on the piping hetween the horated. water tank eM the auxiliary building will he monitored for differential sett.e. ent and A
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G ~ evaluated in accordance with the procedure described in. l Question 17 -ach borated water storage tank is constructed of 1/4-inch stainless steel plate. It is designed to have the tank bottem resting on the soil backfill inside the ring beam to transfer the vertical load directiv to the ' soil. The tank bottem is flexible enough to accocinodate the settlement of i supporting fill and maintain proper lead transfer capability. -l The stresses thus induced in the tank bottom are secondary in nature, and would not affect the integrity of the tank. s .... ~....:2 ~.._, l Responee-ito Question 6, Part c) As described in the response to Part a, the exploratory program in the area shows the materials to be suitable for ~ ~ ~ support of the tanks. flowever, in order to provide justifi-cation for this conclusion, the tanks will be constructed and filled as a full-scale test of the soils beneath them. A reliabit estimate of long-term settle =ent will be deter =ined - - ~ - based on the measured settlements of the loaded tanks. Although re.mcval of the tanks af ter construction would be both costly and recuire a schedule delay,, the tanks are ~ ~ ~ accessible, and re=cval re=ains a viable alternative if unantiri.:ated settleoents that require re=edial action OCOUI. %&S M b0 C.OM RYE Ak "~ ~ A witc. t d ressin3 hp gue n % - & hy &asy (a b conc.use A-L sud.p w t 61 p h aco h om m & ~ a< m,,%) ? .c* % % d i nden % s e<T u o ,o e C.Afm Derause. S h. ee e.nTinevu QWpent Yo Yate. eggft:: 9 ,d g g wund,y cq pn%uvdvoga ,odi ] eor & j %k l tssue. ms,ap adaes= $ issum h.s4(.9 goo,, s. I i 1 1 i i 1 - t ~ . ~ . ~. -... y n.
5Y.- i l ,hf.\\ l %I.GT100 31 Qt ~ \\ Your reply to Ouestion 6a does not provide the information roguested. Your " full scale load test" proposed for the borated water storage tanks fails to provide any margin to account for additional loadings on the tank such as seismic forces, snow or ice packs, design and measurement uncertain-ties, etc. Your reply also fails to address the fact that the actual content of the tanks will be other than pure j water. Consequently the test as currently proposed, will not produce conservative results and is unacceptable. Revise j a your proposed test to provide for worst case loadings or loading combinations, with allowances for uncertainties. j Specify and describe the basis for the margins to be provideo by revised test. Also define your minimum test duration. Describe the extent and type of measurements to be taken af ter completion of the load test to ascertain actual material properties.. t QfvWV f.5 W. 45 n W Q4.CLE OWE ~. - - RESPONSE h sQ m b n m,, 5, 7. M % c ) General The 32-foot high and 52-foot diameter borated water storage tanks are, designed to store fluid with a density of approxi-mately the same as water (63 lb/cu f t at 40F) and will be operated at above freezing temperatures by means of internal heaters. Each tank ir constructed of 1/4-inch thick stainless steel plate. Figure 31-1 shows the arrangement of the tanh and the foundation. The tank is designed to have the bottom a plate resting on the sand fill inside the foundation ring to transfer the vertical load directly to the fuundation soil. The tank bottom is flexible enough to accommodate the settle- ~ ment of the' foundation and maintain proper load transfer ~ capability. The stresses induced in the tank bottom are 'I secondary in nature and would not affect the integrity of the tank. The maximum contact stress beneath the ring wall ^ due to dead load, live load, and wind load is 1.2 ksf. The maximum contact stress under the bottom plate of the tank due to weight of the fluid is approximately 2 ksf. Figure 31-2 shows boring locations in the tank farm area and Figures 31-3 through 31-8 show standard penetration test blowcount results for the borings within and around the tanks. These blowcounts are also summarized in Table 31-1. Based on the blowcount information in Table 31-;, it is concluded that the condition of the fill is satisfactorf for support of the tanks.
- J Settlement i
A' Two plate load tests were conducted near the, ring wall ,? I foundations of the east and kost tanks at the locations J shown on Figure 31-9. The results of these tests are shown ~ ~' - n,j +~-~.- A s~u~~~A ~ ~<-
n i --7. . n -,.. -.~ w -.--1._ ag mm. .= : . - m.-... ; - ~. .=
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? s Li 3 F _... _. ~,. on Figure 31-10. Dansed on thene results it~is estinated that the settic. ment of the tanks due to filling with water will be on the order of 3 inches. The differential settlement 'h between the center and edg'e of the tanks is estimated to be on the order of 1 inch. Piping connections to the tanks ~ will be disconnected during the load tests. Based on the experience of the diesel generator building, it is estimated i that the long-term settlement of the tanks will be on the . order of 1-1/2 inches. The estimated differential settlement is about 3/4 inch, which is half of the total. -i The estimated values will be confirmed by the results of the ~~~ full-scale tests _to be performed by filling the. tanks with -l water and monitoring them until the rate of movement becomes small, thus allowing prediction of residual settlement by cxtrapolation. The minimum duration of the test will be 4 l 4 months. No significant sand fill was encountered in the borings below and around the tank foundation elevation and, f
- l
- 2 therefore, settlement due to earthquakes is not applicable.' The sand within the ring wall was placed at 85% relative density and, therefore, it is not expected to settle during an earthquake. As a result of plant area dewatering, the fill supporting the tanks will settle an estimated 1/2 inch due to consolidation of the fill material. The corresmonding dif ferential settlement will be on the order of 1/4 inch. In addition, a uniform settlement on the order of 1/3 inch will also occur in the natural soil below the fill. Shear Wave Velocity Cross-hole shear wave velocity tests were conducted near the - - ~ ~ 4 borated water tanks at the locations shown in Figure 31-9. } The results are shown in Figure 31-11. It can be seen from ~~ this figure that the shear wave velocity increased with depth 8 of the fill and was greater than 600 feet /second except near '~~^' ~l the surface. ]l ^' nearing Capacity .i -j nearing capacity calculations were made for the horated .~ ~ S] water storage tanks uning the shear strength data presented in Figure 35-3. The computed ultiinate bearing capacity was about 11 ksf. This results in a' factor of safety greater er ~ than 3 for dead and live loads and a factor of safety of f 2 for dead, live, and seismic loads. ] Conclusions 3 Based on the settlement, bearing capacity, and shear wave velocity information discussed aboe1, it is concluded that. i-the engineering proporties of the till are sufficient for _ _._ _.Q .t ..._..__.7_ N y ,.g.-.__g.4 . _.i. 2.._ i_i_.-.
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@) i ~ 1 nupport of the tanks and, therefore, preloading in excess of i the tank pressures is not needed. The test to verify the i predicted long-term settlenent will be interpreted conserva-i tively to account for uncertainties in measurements. Regard- ~ l ing the need for additional measurement, the procedures j adopted to obtain the significant engineering properties provide a reliable means for predicting the required design parameters, and additional drilling, sampling, and testing would not provide better data to refine predictions. Further details are given in the response to Question 35. The load-ing from snow and ice will be small and will not significantly affect settlement or bearing capacity. The capacity of the supporting fill to resist seismic loading is accounted for by the factor of safety of 2 for this loading. condition. Structural analyses of the tank foundation are addressed in the response to Question 14. ^ ..n_ tonommresp+L. MRc. sk .h,am phons oc % me +o qwb 31 was conside<ed modecuah h es%wse o Quehoa) J, do 70vidt 6tc. ch. Ar sugoch%ste7s ce%6to,s and ts cowstdo<td meded mo $nce c.v,bo inpe mr MbobcWe h aen% 6. sW,% ___ g sk shed in ik bes,%A-Ess%y 4 AL4 Wsses Wn, A l im3.woIs ono ranks 3 k h nn3 oco hon 3 San __ so-anwken 4 ser &r seo< woe.w och.s % h,W. p ah. oaf test resA a 1 Ne. 9edtops chnsumers res's,-es og s.%c., bost 'b QVesaon $1 ,L-, wat,Fm 4macc.enn u.a. cubssec $ _. Mc. so.s4p3 mbn43 Ac@ows : x: ,1 1 G ..--e = ~ ' ' ' ~ * * * * ' ' ' ' " * ' ' * * ' 4 . A. .., ~. . ~_-_,_.-_~__-_~_-----~A~--
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'[ JUI. NO M i A { ,:aragency Agree::ent No. NRC-03-79-167, Task No. 1 - Mid and Plant - l c:its I and 2, Subtask Ns.1 - I.atter Rapp l ( (h Identi specific rdo tion, datafand method of presen ation to l ,,,picted for reg atory review a,e completiod of underhinning opera ion., [ ', repott sho61d sun, =arize n acti ities, fiel inspection ,eords, rbrits of fi Id 1p/constniet ns and piles, gan evaluation ad tests on is of the co:pleted fix f r atsuring the stable foundatior. L pJ[ Eorated Water Tanks. j! j. I (1) Se t tleme nt. The settle: bent estimate for the Borated Water Storage Tanks furnished by the' applicant in response to NRC Question 31 (10 CyR 50.54f) is based upon the,'results of tv'o plate load tests. conducted at the fcundation elevation (EL 627.004): of the ta'nks. Since a plate load test is ~ i not effective in providing inforeation regarding the soil beyond a depth : ore thnn twice the diameter of the be'aring plate used in the test, the esti= ate of ~' tho settlecent furnished by the' pplicint. does not include the contribution of tha sof t clay layers loca':ed at epth mor's than 5' below the bottom of the ta=ks (see Boring No. T-14 and T-15, and T-22 thru T-26). (a) Compute settle =ents which include ' contribution of all the soil layars influenced by th' e total load on the tanks. Discuss and provide for review the analysis evaluating differential settlenent that could occur 3 1 between the ring (foundations) and the center of the tanks. (b) The bottom of the borated tanks being flexible could varp under df.fferential settlement. Evaluate that additional stresses could be induced i= the ring beams, tank valls, and tank botto=s, because of the settlecent, and compare with allevable stresses. Furnish the computations on stresses including -athod, assumptions and adopted soil : properties in the analysis. (2) Bearing Capacity. Laboratory. test results on saspies from boring. I-15 shev a sof t stratus of soil below the tank bottom. Consideration has not been given to using these test results to evaluate bearing capacity i=.for=ation furnished by the applicant in response to NRC Question 35 (10 CFR 50.54f). Provide bearing capacity cT>opotations, based on the test ' results of.the samples fron relevant borings. "Ihis infor=ation should include s cethsd used, foundation design assu=ptions, adopted soil properties, ultimate ~ q >j beering capacity and resulting factor of safety for the static and the seismic ! loada. m .f-f Underground Diesel Tuel Talk Tounda on Design. \\ N (1) Bearing capacity. Provide b' earing capacity computation based on jj the test results of samples from relevent borings, including method used,
- foundation design assumptions, adopted soil proper-ies, ultit
- are bearing capacity and the resulting factor of safety.
s } (2) Provide' ta:3c settlement analysis due to static and dynamic loads
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