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NUCLEAR REGULATORY COMMISSION BEFORE THE1TUM(C, SAFETY g D LICENSING BOARD
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In the Matter of
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Docket Nos. 50-329-CM CONSUMERS POWER COMPANY
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50-330-OM I
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(Midland Plant, Units 1 and 2))
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In the Matter of
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Docket Nos. 50-329-OL CONSUMERS POWER COMPANY
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50-330-OL
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(Midland Plant, Units 1 and 2))
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MOTION FOR PARTIAL CONSOLIDATION
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Pursuant to 10 C.F.R. 52.716, Consumers Power Company (CPCo) hereby moves the Atomic Safety and Licensing Board (Board) to consolidate for discovery, evidentiary presentation and fact finding purposes the issues relating to soil conditions for safety-related structures and systems founded in and on plant fill material in the hearing con-sidering the December 6, 1979 Order Modifying Construction Permits (Order), the operating license hearing, and any hearing which_may be requested and ordered in connection M
with CPCo's requested Amendment Nos. 72, 74, 76, 77 and others to its application for construction permits and operating licenses.
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I.
Background - The Proceedings A.
Soil Conditions Issues. in the Order Modifying Construction Permits Proceeding.
CPCo is a holder-of Construction Permits No. CPPR-81 e
and-No.. CPPR-82 which authorize the : construction of two
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pressurized water reactors in Midland, Michigan.
During its-construction settlam nt. monitoring' program CPCo observed a larger than predicted settlement of the Diesel Generator Building and reported this to the NRC.
From late 1978 to December 6,1979 Applicant and the Nuclear Regulatory Commission Staff (Staff) investigated the settlement of the Diesel Generator Building and soil conditions for other l
' safety-related. structures and systems founded in-and on plant fill material.
During this period CPCo responded to numerous
\\s, Staff inquiries concerning both what caused -the soil condi-tions and the remedia,1 action undertaken or proposed to be undertaken by CPCo.
On December 6, 1979 the Staff issued the Order by which the Staff seeks to prohibit CPCo from continuing certain remedial actions associated with the soil conditions i
for safety related structures and systems founded in and on plant fill material until issuance of an amendment to the i
construction permits authorizing the remedial action.
CPCo requested a hearing with respect to the Order f
and has filed requested Amendment Nos. 72, 74, 76 and 77 to its application for construction permits and operating u._-__.__
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' licenses setting forth the remedial action it proposes to take to ensure that the plant can be constructed and operated without undue risk to the health and safety of the public.
Since the Order CPCo has had several meetings regarding the P
soil conditions issues with the Staff'and their consultants.
B.
Soil Conditions Issues in the Operating License Proceeding.
In her Contention 24, Mary Sinclair, Intervenor raised an issue in the operating licenses proceeding which the Board interpreted as raising an issue relating to soil 1/
conditions.-
The Board in the Special Prehearing Conference order dated February 23, 1979 accepted Contention 24, stating:
No. 24 - The contention...is accepted... conditioned by our agreement with Staff's comment (November 28, 1978 response, page 6) that the question appears not to be one of site suitability, but rather of the type of material used by the Applicant under the building in' question.
A suitable restatement of the Contention shall be provided by the Intervenor at the time required by the schedule below for submission of other related contentions.
1/
"No.
24.
The present site for the Midland facility Is... affirmatively unsafe.
Serious questions have been raised concerning the ground stability of portions of the site.
At lease [ sic) one of the essential buildings of the reactor complex is reported sinking, and construction has I
been halted on that building.
As a result of the serious and unresolved questions concerning ground stability, the findings required by 10 C.F.R. SS50. 57 (a) (3) and 50.57 (a) (6) can not be made."
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Mapleton Intervenors raised the same soil condi-2_/
l tions issue which~was also accepted by the Board.
C.-
Current Status of Soil Conditions at Midland Site.
e After observing the larger than predicted settlement of the Die'sel Generator Building CPCo -conducted an. exhaustive investigation concerning the soil conditions 'for the Diesel Generator Building _and other' safety-related structures and systems founded.in and on plant fill material.
On the. basis of this investigation CPCo believes the actions it then took recedied the soil conditions under and'around the Diesel
. Generator Building.
CPCo has submitted extensive technical analyses to the Staff, including submittals in the aforementioned l
amendments to the Application for construction permits and operating licenses to the Staff and has had several meetings s,
with the Staff and their consultants during which CPCo and its consultants detailed the remedial action it proposes to take with regard to the soil conditions under and around safety-related structures and systems other than the Diesel Generator-Building.
CPCo is awaiting Staff approval of the l;
amendments and at present no remedial action has been taken in regard to these structures.
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The Board in its Special Prehearing order dated Feb-j ruary 23, 1979 stated:
Contention 2 - This is the same issue as 71nclair Contention 24.
It is accepted as it relates to i
settling of the Midland diesel generator building.
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-II.
Issues to be Consolidated CPCo requests that the following issues be consolidated for discovery, evidentiary presentation and fact finding:
'1.
Whether the remedial actions taken by CPCo with' regard to soi1' conditions under'and around the Diesel,
Generator Building.,
i' (a) ratisfy the relevant requirements of the Order in that they provide reasonable assurance that the Diesel Generator Building will be con-
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el structed and operated without undue risk to the d. ' M' nd safety of the public; p,[v; ~p
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(b) sat sfy the relevant requ ments of 10 C.F.R. S50.91 and 10 C.F.R. 550.35 (a) in that they provide reasonable assurance that the Diesel emy Generator Building \\can be constructed and operated without undue risk to the health and safety of the public; (c) s D y the relevant requirements of s,. -
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10 C.F.R. 550. 7 (a) (3) and (6) in that they provide h( *fjf
- i reasonable assurance that the Diesel Generator Building can be operated without endangering the f
health and safety of the public and that its operation will not be inimical to the health and safety of the public.
- t 2.
Whether remedial actions proposed by CPCo with regard to soil conditions under and around safety-related I
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structures ~and systems, other than the Diesel Generator y
L Building,~will-E4 h d _Ei.,.'?.J ] ;y satisfy the relevant requirements of the Order:in.that they-prqvide reasonable assurance Ethat these -structures and systems will be con-I structed and operated without undue risk to the health and safety of the public; (b)
. satisfy the relevant requirements of 10 C.F.R. S50. 91 and 10 C.F.R.E S50.35 (a) ' in that they l
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provide reasonable assurance-that these structures and systems can be constructed and operated without undue -risk to the health and safety of. the public; 4
(c)
Satisfy the relevant requirements of 10 C.F.R. 550.57(a) (3) ;and (6) in.that they_ provide reasonable assurance that these structures and systems ~can be operated'without endangering the health and safety of the public and that their operation will not be inimical to the health and safety of the public.
III. Discussion The Nuclear Regulatory-Commission's Rules of Practice, 10 C.F.R. 52.716 Consolidation of Proceedings, provide, in pertinent parti On motion and for good cause shown.
., the presiding officers of each affected proceeding may consolidate for hearing or for other purposes two or more proceedings
. if it is found that-such action will be conducive to the proper dispatch of [the NRC's] business and to the ends of justice and will be conducted in accordance with the other provisions of this subpart.
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In addition to the above guidelines, the Nuclear
_ Regulatory Commission requested, at page 2 of its March 14, 1980 Noti.ce of Hearing, the Board to " consider whether'such e
.o consolidation (of the hearing regarding the Order with other NRC proceedings wh'ich involve substantially identical t
I issues] would adversely affect the expeditious resolution of I
the issues (to be-decided in the hearing regarding the 3/
Order]....".-
A discussion of the factors the Board should consider-in ruling on'the motion for partial consolidation follows.
A.
The Soil Conditions Issues in-All Proceedings are Substantially Similar.
e A chief issue.to be resolved in the Hearing con-cerning the Order is whether the remedial actions taken and the information provide'd by CPCo provides " reasonable assurance that the affected safety-related portions of the Midland facility will be constructed and operated without undue risk to the health and safety of the public".
(order at page 3. )
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The NRC had been made aware of CPCo's intention to move for partial consolidation.
As stated at page 2 of the March 14, -19 80 Notice of Hearing:
i On December 26, 1979, CPCo filed a Request for Hearing pursuant to Part V of the Order.
See, 10
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CFR 2.204.
In that Request, CPCo referred to other pending NRC proceedings which it believes involve issues substantially identical to those addressed by the j
Order of December 10.
CPCo also stated its intention to move, pursuant to 10 CFR 2.716, to consolidate all
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l-In-regard to CPCo's requested Amendments Nos. 72,
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. 74,~76'and 77 to its application for construction permits il-and operating licenses, "in determining whether an amendment
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to a license or construction. permit Jill-be' issued to the
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' Applicant -the Commission will be guided by - the considerations which govern the issuance of initial licenses or construction D
-permits to the extent applicable and appropriate."
One of the considerations in determining whether to grant.the initial' construction permit is whether
- the " proposed.facilityfcanbe) constructed and operated...without
' N undue risk to the health and safety of the public."
10 C.F.R. 550. 35 (a). - Any hearing.which may be requested and ordered in connection with'the above-mentioned requested
. Amandments will consider this issue.
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As. stated previously, Mary Sinclair, Intervenor, and Mapleton Intervenors, contend in the operating licenses proceeding that the soil conditions issues prevent the 4
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Commission from finding, as it must pursuant to 10 C.F.R.
S50.57, that:
(3)
There is reasonable assurance (i) that the activities authorized by the operating license i
,..t can be conducted without endangering the health 1-and safety of the public, and (ii) that such activities will be conducted in compliance with j
the regulations in this Chapter.
(6)
The issuance of the license will not be i
inimical to the common defense and security or to
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the health and safety of the public.
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issues have substantially the same issue in common: whether the affected safety-related portions of the Midland facility can be constructed and operated without undue risk to the health and safety of the public.
This satisfies the Com-mission's consolidation admonition that the issues be substantially the same.
While CPCo recognizes that in some instances an cperating license review is more detailed than a construction permit review, in this instance the reviews as to the soil 1
conditions issue will be nearly4 entical.
All repairs except id for. general site dewatering have been completed on the soils under and around the. Diesel Generator Building and hence for all practical purposes review of the soil conditions issues for that structure will be conducted as if an operating license were being sought.
The design details on general site dewatering have been submitted and discussed with the
-Staff and its consultants.
As to the other safety-related structures and systems, CPCo has not taken any renedial action but has submitted detailed explanations and justifications of the reredial actions it proposes to take and has had discussions with the Staff and its consultants.
It is CPCo's position that all the required technical information has been sub-lf citted and that, therefore, the design concept is final.
No core information will be available at the operating license
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-hearing than will be present prior to the hearing considering
-the' order, except insofar as implementation of any remedial 4
action = approve'd in this proceeding may be at issue, j
Partial Consolidation,"Will be Conducive to f-B.
the Proper Dispatch of NRC Business". and "To the Ends of Justice."
since, as demonstrated above, the issues in all proceedings are substantially 'similar, the evidence to be q
. presented in-each proceeding will necessarily be the same.
Consolidated discovery evidentiary presentation and fact finding would eliminate the presentation of the same evidence 4/'
at least two times.~
Moreover, L since the Board in both pro-i l-ceedings is comprised of the same individuals, it would not be required to hear the same evidence several times and make
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several separate rulings.
Also, the consolidation would have the benefit of precluding needless litigation of issues i
as to res judicata or* collateral estoppel which would occur if each proceeding were held separately.
A partial consolidation would avoid needless 2
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To date no hearing has been ordered with regard to CPCo's requested Amendment Nos. 72, 74, 76 and 77 to its application for construction permits and operating licenses, although pursuant to 10 C.F.R. 550.91 a hearing is a distinct possi-bility.
i If such a hearing is held the consolidation would i
satisfy the Appendix A Statement of General Policy and Procedure: Conduct of Proceedings for the Issuance of Construction Permits and Operating Licenses, that construc-tion permit hearings ~be " conducted expeditiously" with
" efficiency and economy" and that procedures relating to these proceedings " maintain significant flexibility to accommodate that objective."
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duplication of preparation and effort for the Staff.
It will not require any additional time by the Staff since the SER to. be issued in connection with the Construction Permit e
Amendment will be based on the same facts which will ultimately I
.m form the basis for the Operating License SER.
The only factual matters regarding soils conditions which will not be known prior to the hearing considering the Order involve the efdicacy of the remedial actions proposed for safety-related structures and systems other than the Diesel Generator Building.'
The only parties not subject to all proceedings are the intervenors.
A partial consolidation would give them the opportunity to participate in an evidentiary and fact finding hearing regarding the soil conditions issue at an earlier date than if the presentation occurred at the operating license hearing.
To the extent that this is an inconvenience to them, a flexible discovery and hearing schedule can be developed.
CPCo believns that the intervenors will not suffer any denial of righ:b :
the motion is granted.
If, however, lintervenors opp.y,. c o motion it should be noted that their consent is'not necessary.
5/
The NRC noted Ir. the Matter of Edlow International company, 5 NRC 1327, 1328 (1977) that 10 C.F.'R.
52.716:
mirrors Rule 42 (a) of the Federal Rules of Civil Procedure which establishes general standards used by Federal courts in determining whether consoli-r (cont.)
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4 In short, a partial consolidation is the most
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efficient and least expensive manner in which to handle the soil conditions issues.
1C.
Partial Consolidation *Will Not Adversely Affect the Expeditious Resolution of the
' Order Modifying Construction Permits Hearing.
Since,~'as demonstrated earlier, the issues to be s
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g the partial, consolidation will not inject any new issues or evidence into the hearing considering the Order.
- Further, even if any delay were to occur, the delay would not harm the Board or any of the intervenors.
This is because, as stated at pages 1-2 of the March 31, 1980 Staff's " Summary of February 27 and 28, 1980 Meeting And Site Tour With Con-4 sultants To Review Soil Settlement," " Consumers Power Company has elected to defer all remedial work on inadequately supported structures until acceptance of the proposed work is received from the Staff."
Any delay caused by the (5/ cont.)
dation of proceedings is appropriate.
Rule 42 (a) provides that, if actions involve common questions i
of law or fact, they may be consolidated if consolidation would ' avoid unnecessary costs or delay.'
An examination of the case law interpreting Federal Rule 42(a) demonstrates that "If a common question exists, courts have often consolidated actions despite differences in parties,"
Wright & Miller, Federal Practice and Procedure, Civil Volume 9, S2383 at 264.
Moreover, "The consent of the parties is not required."
Id. at 259.
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consolidation-:will,. therefore, only; harm CPCo and it is willing to risk this possibility in order to have a single evidentiary presentation and fact-finding determination on the-soil' conditions issue.
IV. : Conc 1'usion The foregoing demonstrates that there is good reason to grant the partial consolidation motion, that
. partial consolidation will be conducive to the proper dispaten of NRC business and to' the ends of justice and.that-it will
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not in any way affect the expeditious resolution of the Order.
There' fore, CPCo requests the Board to consolidate for: discovery, evidentiary presentation and fact finding purposes-the. issues relating to soil conditions for safety-related structures and systems founded in.and on plant-fill material in the hearing considering the Order, the operating license hearing, and any hearing which may be requested and ordered in connection with CPCo's requested Amendment Nos.
72, 74, 76, 77 and others to its application for construction permits and operating licenses.
Respectfully submitted,
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Michael I. Miller Attorney'for Consumers Power Company I S P.A M, LINCOLN & BEALE Suite 4200 Cne First National Plaza Chicago, Illinois 60603 312/558-7500 DATED:
May 27, 1980
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UNITED STATES OF AFERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e
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-In.the' Matter of-
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Docket Nos. 50-329-OM-CONSUMERS POWER COMPANY
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50-330-OM
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.(Midland. Plant, Units 1 and'2))
)
)
In the Matter of-
)
)
Docket Nos. 50-329-OL CONSUMERS POWER COMPANY
)
50-330-OL
)
(Midland Plant, Units 1 and 2))
)
CERTIFICATE OF-SERVICE
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I, Alan S.,Farnell, hereby certify that a copy of Consumers Power Company's Motion For Partial Consolidation was served upon all persons shown in the-attached service list by deposit in the United States mail, first class, this 27th day of May, 1980.
Ob A. M Alan S. Farnell
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- SERVICE LIST t
Grant Merritt, Esq.
Frank J. Kelley, Esq.
Attorney General of the Thompson, Nielsen, Klaverkamp & James
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4444 IDS Center-State of Michigan Stewart H. ~ Freeman, Esq.
80 South Eighth Street Assistant Attorney General Minneapolis, Minnesota 55402 7
Gregory T. Taylor, Esq.
Atomic Safety & Licensing Appeal Panel Assistant Attorney General
- Environmental Protection Div.
U.S. Nuclear Regulatory-Commission
. 720 Law Building Washington, D.C. 20555 Lansing, Michigan 48913
.Mr. C. R. Stephens Chief, Docketing & Service Section Myron M. Cherry, Esq.
Office of the Secretary One IBM Plaza U.S. Nuclear Regulatory Commission Suite 4501 Chicago, Illinois 60611 Washington, D.C. 20555 Mr. Wendell H. Marshall Ms. Mary Sinclair r
5711 Summerset Street RFD 10
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Midland, Michigan 48640 Midland, Michigan 48640 Ivan W.
Smith, Esq.
William D. Paton, Esq.
Atomic Safety & Licensing Bd.
Counsel for.the NRC Staff U.S. Nuclear Regulatory Com.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C. 20555 Mr. Gustave A. Linnenberger Atomic Safety & Licensing Board Panel Atomic Safety'& Licensing Bd.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory-Com,.
Washington, D.C. 20555 Washington, D.C.
20555 Dr. Frederick P. Cowan 6152 N. Verde Trail Apt. B-125 Boca Raton, Florida 33433 Carroll E. Mahanay Eabcock & Wilcox P. O. Box 1260 Lynchburg, Virginia 24505 4
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DISTRIBUTION:
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I Docket Nos. 50-329/330 OM, OL g(,$,)(y -? MSS. 2, D
NRC PDR CNT5TMDIM6 DEW H54E.5 Local PDR ABrauner, NRR Docket I:os: 50-329 OH, OL NSIC BPCotter, ASLBP
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and 50-330 GM, OL EAdensaa ACRS(16)
- DHood, CMiles, OPA MDuncan.
fir. J. W. Cook RTedesco Vice President DEisnehut/RPurple Consumers Power Con;iany JRutberg, QELD 1945 West Parnall Road JSaltzman, AIG Jackson,111chigan 49201 I&E
. Attorney, OELD
Dear ftr. Cook:
Subject:
Completion of Soils Remedial Activities Review In several meetings and discussions held during the months of April and May 1982, you were informed by the staff of the approach to be used for the review of the soils recedial activities at Midland Plant, Units 1 and 2.
This approach is intended to make the review process raore consistent with that followed by the staff for license applications and improse the efficiency of the staff review.
Specifically, the previous staff practice of approving each individual construc-tion step for each remedial nacsure as the review progresses will generally be discontinued by the staff.
The staff intends to corplete the entire review of the soils remedial activities and related matters as an integrated package and then proceed with ACRS reetings and hearing sessions in the normal fashion.
Althougn no activities directed to recedial actions for the soils deficiencies are expected to be approved price tc cocpletion of the staff's integrated review, those for which staff review was sub tantially completed as.of April 1,1982, are, however, approved. These are discussed below.
On the basis of the staff techecal review of docwents listed in Enclosure 1, the staff concurs with your plca to proceed with Phase 2 underpinning activities (which involve excavation under the feedwater isolation valve pit qnd the turbine building) subject to'the successful completion of conditions listed in Enclosure 2.
Accor.plisbment_oLthes_e_ conditions _should be_docu.cented and Region III noti-
.fie1 provides a definitidn of Phase 2 on which the staff's approva'l is based, and further discusses the staff's understanding of approved quality assurance plans for this. and other soils work.
He are further responding to your letter of liay 10, 1982, which addresses certain Board's itenorandum and Order of Apri'lsoils construction work you be 30, 1982.
on Paragraphs I and II are provided. in Enclosure 4. Staff comments and conclusions-
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Mr. J. W. Cook 2-I L With respect to your Paragraph III, you note you are continuing with certain soils
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remedial work with full awareness and concur ence of the staff for which explicit written approval had not been obtained.
You also noted that this work has been stopped in accordance with the Order and requested that the staff verify its con-currence so that-the work can be reactivated.
' n this category are:
The three work. items you identiffe'd i
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(1) installation of deep-seated benchmarks.
(2) installation and operation of construction dewatering wells that were not previously operating, and E
.(3) installation of monitoring system instruments and' mounting.
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Items..(1) and (2) are conditionally approved as addressed 'by Enclosure 5 and,6 respectively. With respect to item (3), your letter notes that work on the moni-toring system instruments and mounting for the auxiliary building is presently stopped because Region III concurrence has not been obtained.
We are advised that Region III will provide explicit written confirmation of HRC approval fol-lowing resolution of existing QA deficiencies.
Your letter of May 10, 1982, also forwarded Drawing 7220-C-45 for purposes of defining which soils at the Midland site are safety related (i.e., are considered to be under and around safety-related structures and systems). During a May 5, 1982, conference telephone call with the Licensing Board and hearing parties.
Consumers proposed to use this drawing to define the bounds for the term "around" in Sections VI(1)(a), (b) and (c)'of the Board's April '30,1982 Hemorandum and Order.
The Board's s'ubsequent Memorandum and Order of May 7,1982, requested the staff to advise the Board of the results of its review of Drawing 7220-C-45.
results of our review are presented in Enclosure 7; and, on the basis of your com-The mitments to modify the drawing, we find this drawing to be acceptable for the pur pose of defining areas around safety-related structures and systems.
In addition. Enclosure 8 lists the information required by the st'aff to conclude
.its revicu of the soils remedial work.
information provided by your letter of MarchThis list is based upon staff review of 31, 1982, and earlier submittals.
Certain of the information needs Jnay already have been transmitted by you.
You are requested to p'rovide your response schedule within seven (7) days of receipt i
of this letter.
Once your schedule is received, the staff will develop the review l
corpletion schedule for this effort.
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Mr. J. W. Cook -
s a The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore OFB clearance is not required under P.L.96-511.
Sincerely,
- prig'.nal signe$p 1)arte11 G. Eise@g
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Darrell G. Eisenhut, Director Division of Licensing,
Enclosures:
'As stated cc: See next page
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- MIDLAND
'Mr. J. W. Cook
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'Vice President
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,1945 West Parnall Road Consumers Power Cospany Jackson, Michigan 49201-
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Michael I. Miller, Esq.
Mr. Don van Farrowe, Chief
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Ronald G. Zamarin, Esq.
Division of Radiological Health LAlan S._Farnell,-Esq.
Department of Public Health Isham, Lincoln & Beale.
P.O. Box 33035 Suite 4200.
Lansing, Michigan 48909 1 First National Plaza
- Chicago, Illinois 60603 William J. Scanlon, Esq.
2034 Pauline. Boulevard James E.:Brunner, Esq.
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Ann Arbor, Michigan 48103 Consumers Power Company 212-West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711'Summerset Drive Midland, Michigan '48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General
. State of Michigan Environmental Mr. Paul A.. Perry, Secretary Protection Division Consumers Power Cospany 720 Law Building 212 W. Michigan Avenue i
Lansing, Michigan 48913 Jackson, Michigan 49201 s-i Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Max Clausen j
Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL!
1
- Battelle Blvd.
Mr~. Roger W. Huston SIGMA IV Building
's Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager I.
Mr. R. B. Borsum NRC Assistance Project Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne, Illinois 60439-7910 Woodmont Avenue, Suite 220 v.
Beth cda, Maryland 20814 James G. Keppler, Regional Administrata U.S. Nuclear Regulatory Commission,
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Cherry & Flynn Region III Suite 3700 799 Roosevelt Roa'd
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' Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602
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3 Mr. Steve Gadler 2120 Carter-Avenue St. Paul, Minnesota 55108-g.
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- Commander, Naval Surface Weapons Center cc:
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P. C. Huang White Oak Silver Spring, Maryland 20910 Mr..L. J. Auge, Manager Facilit Energy y Design Engineering Technology Engineering Center l
P.O. Box 1449-Canoga Park, Calir'ornia 91304 Mr. Neil Gehring
.U.S. Corps of Engineers NCEED - T
'7th Floor
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477 Michigan Avenue
,Detroi,t, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board.
U.S. Nuclear. Regulatory Commission Washington, D. C.
20555 Mr. Ralph S. Decker' Atomic Safety & Licensing Board U.S.-Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 l
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Jerry Harbour, Esq.
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Atomic Safety and Licensing Board' U.S. Nuclear Regulatory Commission
. Washington, D. C.
.20555 Geotechnical sngi'neers, Inc.
ATTH: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 4
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LISTING OF ENCLOSURES
" Basis for Staff Concurrence for Start of Phase 2"
~ " Conditions for Staff Acceptance of Phase 2"
- " Definition of Phase 2 Underpinning Activities and Quality Assurance Plans for Sofis Activities"
. Enclosure 4
" Staff Cornents on Continuing or Planned Soils Activities Previously Approved by the Staff"
" Installation of Deep ' Seated Benchmarks"
~ Enclosure 6
" Construction Dewatering Wells"
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~ " Staff Evaluation ~ of Drawing 7220-C-45"
" Additional Information Required to Complete Staff Review of Soils Reredial Work".
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EtiCLOSURE 1 BASIS FOR STAFF CONCURREfCE FOR START OF PHASE 2 1.
Letter to R. Vollmer from R. T. Hamilton, dated July 8,1975, transmitting Bechtel quality assurance topical BQ-TOPal.. Revision.1A 2.
Letter to H. R. Denton from J. W. Cook, dated September 30, 1981, Submitting the Auxiliary Building Dynamic Model,' Technical Report on Underpinning the Auxiliary Building and Feedwater Isolation Valve Pits 3.
Letter to H. R. Denton from J. W. Cook, dated November 16,.1981, on Response t the NRC Staff Request for Additional Information Pertaining to the Proposed Ur pinning of. the. Auxiliary Buil'dir.g and feedwater Isolation Valve Pits'
. 4.
Hearing testimony by CPC witnesses (Johnson, Burke, Gould, Corley and Sozen)~ c remedial underpinning work for the Hidland Auxiliary Building, Novesaber 19,15 5.'
Hearing'testinony of D. Hood, J. Kane and H. Singh concerning the Remedial Une 4
pinning of the Auxiliary Building Area, dated 11/20/81 6.
Hearing testinony of F. Rinaldi, dated 11/20/01 7.
Letter to H. R. Dantor. from J. W. Cook, dated 11/24/81 on Test Results Auxili Building, Part 2. Soil Boring and Testing Program 8.
Letter.to H. R. Denton from J. W. Cook, dated December 3,1981, with Addendum Technical Report On Underpinning the Auxiliary Building and Feeduater Isoloati
. Valve Pits e
9.
Letter to H. R. Denton from J. H. Cook, dated January 6,1982, on Auxiliary Building Underpinning - Freezewal.1; Effects of Freezewall on Utilities and Str-tures 10 Letter to H. Denton and J. Keppler from J. W. Cook, dated Ja'nuary 7,1982, tra:
nitting general Quality Plan for underpinning activities and Quality Plans and Q-Listed activities for SUPS and Auxiliary Building Underpinning
- 11. Design audits of January 10-20,1932 (Sumary dated March 10,1982); Feburary ".
y 1982; March 16a19,1982; and meeting of February 23-26,1982,,(Succary. dated March 12,1982) 12.
Letter to H. R. Denton from J. W. Cook, dated February 4,1982, on Auxiliary Building Access Shaft - Augering Method for Soldier Pile Holes
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. ENCLOSURE 1
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13.
1 Letter to J. W. Cook from R. L. Tedesco, dated February
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Concurrence for Activation of Freezewall 12, 1982, on Staff l
14.
Letter to H. R. Denton from J. W. Cook, dated March of Excavation Face - Auxiliary Building Underpinning. Shaft 10, 1982, on' Protection'
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15 Summary of March 8,1982 Telephone Conversation Regarding Soil' Spring S nesses for Auxiliary Building Underpinning and Phase II Construction, dated March 11,1982
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16 Letter to H. R. Denton from J. W. Cook, dated March l
'the HRC Staff Request for Addittorial Information Required for'Conpletion of 31, 1982, on Response to
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Staff review of Phases 2 and 3 of trie Underpinning of the Auxiliary Buildin and Feed > tater Isolation Valve Pits
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17.
Assurance for Retaedial Foundation WorkLetter to J. Keppler from J.
Letter to H.' Denton from J. W. Cook, dated April 18.
26, 1982, transmi'. tina quality assurance topical CPC-1-A, Revision 12 1
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- 1.. Deep-seated bench marks DSB-ASI and DSB-AS2.
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DSB-Asl and DSB-AS2 shall 'be.-
building which is founded at Elevation 562. installed at a distance not to e Actual locations of these installed bench marks and any modifications in tolerance criteria required on Drawing
'C-1493(Q) due to changes from the original DS8-AS locations shall be documented.
2.
l Monitoring instrumentation required to be installed.
The following deep seated j
benchmarks and relative-absolute measurement devices identified on audited drawings shall,be
' drifting under th, properly instal 3ed and op*erating for at least 7 days prior to e turbine building or Feedwater Isolation Valve Pit (FIVP):
_ Deep-Seated Benchmarks Relative-Absolute Measurement Devices DSS-lu DSB-A51 DMD-1W DSD-1E DSB-AS2 DMD-1E DSB-2W DSB-AN DMD-11 DSD-2E DMD-12 DSB-3W DSB-3E DHD-13 3.
Strain cauoe installation.
tion shown in drawing C-1495, " Instrumentation - ElevationRevisions shall be 695 - 0 5/16" for Building Settlement Monitoring". On the sectional view at the wall at Column Lines 7.4 and 7.8, change the orientation of proposed lower strain gauges between Elevations 584 to 614 to be perpendicular to the orientation shown on Drawing C-1495, Figure 3 in the March 31, 1982 subnittal. On this sane sectional view, add an additional strain gauge between Elevations 646 to 659 at an inclination similar to the above 'recomended orientation. Also, correct the labeling of column lines H an'd G which is reversed on the copy of the sectional view sub-s mitted to the staff.
4.
_ Pier load test procedures.
The following nodifications and additions shall be nace to the pier load test procedures provided by the April 22, 1982 submittal from J. Cook to H. Denton, " Response to the NRC Staff Request for Additional Infornation Required for Cocpletion of Staff Review of the Borated Water Storage Tank and Underpinning of the Seryice Water Pump Structure."
(Consumers Power' Co@any (CPCo) stated that, although the procedures were submitted for under-pinning work for the service water pucp structure, the procedures aro applicable to the pier Toad test to be conducte,d during Phase 2 underpinning work for the auxiliary building.)
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The maxinum. required test load shouid be equal to 1.3 times the' maximum a.
anticipated design load. ; As an alternative, should there be structural difficulties'in developing the required reaction-load.for the prior test, the staff would accept a procedure where the maximum test load for the -
pier load test was equal to 90 percent the maximum anticipated design load and a plate load test (ASTM D1194) was performed to a maxicum test / --
load equal to _130 percent of the maximum-anticipated design load.
(See Page12ofsubmittal).
b.
Significant modifications to the spectfind ASTM D1143-81 test procedures.-
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as may be appropriate, require advanced notification and approval of the Region III Office. '(See Page 12.of submittal.)
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The' rate of set'tlesnt'shall-n'ot e'xceed 0.005 inch per hour when control-l c.
ling the length of time that the 90% test load increment is to be main-l L
tained.
(See Page 12 of submittal).
l d.
In order to provide a more positive reduction of skin friction, plywood sheeting coated with 1/S-inch thick bitunen (or equivalent) shall be installed on all test pier sides prior to performing the pier load test as a replacement for the plastic sheeting proposed by CPCo.
(Seepage 12 of submittal).
e.
To permit correlation with the previously approved measures proposed by l
CPCo to demonstrate the adequate foundation capacity of the other installed piers, a minimum of two in situ density tests and five cone penetrometer tests shall be performed on the soil at the bottom of the pier selected for test loadin.g.
5.
Construction dewatering.
During undcrpinning of the auxiliary building area, below the bottom of any underpinning excavation at any given time.t
' plan for the dewatering system shall be established and implemented in advance The final of drifting under the turbine building or FIVP.
The dewatering plan should include the locations and depths of the, dewatering wells and piezometers (observation wells). Criteria for monitoring loss of soil particles due to
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j pumping shall b.e the same as those previously approved by the staff for the construction dewatering of the service water pump structure (R..Tedesco letter
~ f April 2,1982) or for the permanent dewatering wel,1s (R. Tedesco letters of o
g June 18, September 2, and October 22,1931).
6.
Monitoring movement of FIVPs.
Jackin*g of the FIVP back to its original position '
shall be required if the relative settlement between the reactor containant and the FIVP reaches a total settlement of 3/8-inches since the time piping connec-tions were mado.
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.i ENCLOSURE 3 DEFINITION OF PHASE 2 UNDERPINNING ACTIVITIES A FOR SOILS ACTIVITIES Phase.2 construction activities for the Midland auxiliary, building unde defined by Bechtel drawing C-1418-1(Q) Revision A. " Auxiliary Buildi Construction Sequence", and associated plan and logic drawing C-1418 Q both issued for information 3/19/82 and provided to the staff during Revision A,
on that date.
With respect to' quality assurance requirements, for Phase 2 work H. Denton/J. Keppler. dated January 7,1982, transmitted a genera,l Qua CPCo's letter to
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underpinning activities along with quality plans for the service water pump i
ture underpinning system and for the auxiliary building underpinning system FIVPs.
These plans describe the basic QA program controls to be applied to it and activities associated with the soils remedial work.
CPC-1A and Bechtel's QA Topical Report BQ-TO We find these plans, 1
. remedial work. However ance plans and prograns,are to apply to 1) all items and acti the ASLB !!emorandua and Order of April 30, 1982,.and 2 all of the to-go under-pinning Q-listed and non Q-listed work described in you)r April 5,1982 4
J. Keppler, except that work stated in attachment 1 of that letter. - We these plans and program to mean that the tiidland Project Quality Ass ment will be actively involved in reviewing contractor's, sub-contractor's, a consultant's quality assurance capabilities and assuring thorough revie cedures and verifications that hardware is built and work is performed in a ance with design, specification, and procedural requirements.
conclude that the above referenced Quality Plan is acceptable for implem Accordingly, we as described above.
Since the foregoing conforms to the April Order, any deviations must be reported to the staff.
30, 1982, Board 1
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s ENCLOSURE-4 STAFF COMMENTS ON CONTINUING OR PLANNED S0ILS ACTIVITIES PREV APPROVED BY THE STAFF
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The following coments are provided to clarify the staff's prior approvals'of
-renedial soils activities at the Midland Plant.
Each listed item in paragraphs
.I.and II of CPCo's May 10, 1982, letter is presented and addressed.
4 "I.a.
Phase 'I Work (Auxiliary Building Underpinnino)"
The specific activities for Phase I work referred to in our letter of j
concurrence (Reference 5) for installation of the vertical access shafts -
were those defined by Consumer's Orawing "U' derpinning Auxiliary Building n
Construction Sequency Logic" dated January 20, 1982.
"I.b.
Access Shaft (Auxiliary Building Underpinning)"
i This item is-included in the staff's definition of " Phase I work" and is discussed under paragraph I.a. above.
-"I.c.
Freezewall Installation, Underground Utility Protection, Soil Renoval Cribbing and Related work in Support of the Freezewall installation'.
Freezcwall rionitoring and Freezewall activation" j
References 5 and 7 provided staff concurrences for freezewall installation and activation, respectively. These approvals were based upon CPCo's pl to eliminate the inducement of stresses to the conduits and piping becau,an of heaving by excavating the soil directly beneath affected utilitfe's within se the projected area of influence of the freezewall before ground freezing i
begins. The approvals also recognized your cor.nitments (1) to demonstrate to the staff's satisfaction that'recompressilon of the foundation soils beneath the piping or ducts has been cogleted before backfilling the excavation, and (2) to notify Region III personnel prior tb drilling near seismic Category I underground utilities and structures.
Tiie approval was further contingent upon the successful audit by the NRC Regional Office III of the implementation procedures for excavation and monitoring.
The information which prayided the basis for staff review and approval was t
provided by CPCo's letters of November 16. and 24,1981, and by hearing testinony of your consultant,.J. P Gould.and January 6,1982, i
Consequently, the staff agrees that prior explicit concurrence for 'the activities listed by paragraph I.c. of CPCo's letter, May 10, 1982 had been obtained frcu the staff prior to the April 30, 1982 Order, except t
i for the anbiguous' phase you included "and related' work in support'of...".
Therefore, the staff did not approve "related work" in its letters of concurren.ce or oth.er records.
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2-ENCt.05URE 4 "I.d.
Installation and Operation of the Permanent Site Dewatering System" The identity and location'o'f the 65 permanent dewatering wells approved
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by the staff are given in References (1), (2) *and (4).. Installation and monitoring aspects of the permanent site dewatering system, exculding seismic aspects, was to be performed as Q-listed activities following staff review and approval.of associated quality assurance and quality
- 'ontrol documents.
c "I.e.
Operation of Existing Construction Dewatering Wells"
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The only construction dewatering wells approved by the staff are those identifiedbyReferences(6)and(1,0). This item is further discussed in Enclosure 6.. As noted'.therein, however, construction wells installed and monitored to procedures equivalent to those for permanent wells may ~ '
be considered acceptable.
"I.f.
FIVP Proof 1. cad Test" The staff has no record or recollection of concurrence for a FIVP proof load test. Therefore, this test is not approved.
"II.a.
Installation and Activation of Dewatering System for the Service Water Puno Structure" Staff approval was indicated by Reference (10), subject to certain com-mitted changes specified therein.
"II.b.*
The Repair of Cracks in the Borated Water Storage Tank Ring Wall" Staff approval was indicated by Reference (9), which noted your com-mitment to pressure grout at least all cracks with utdths in excess of 10 mils. This activity follows the completion of the valv'e pit sur-charge ptograns which were also the subjects of prior staff approvals.
(References (3) and (8)).
In sur.cary, anbiguity associated with CPCo's use of the terns " Phase I work" and "related [ freeze wall] work" preclude confirmation of specific prior approval of these activities.
Similarly, failure by CPCo to identify the particular existing construction deuatering wells precludes us from determining whether, previous staff concurrence had been indicated. No description or discussion is provided for a "FIVP proof load test" and no record of prior staff approval can be located.~ Con-
,sequently, continudtion of these activities in 'conformance with the foregoing staff coments wi.11 be in accordance with the Board llenorandum and Order of April 30,1982. Any deviations must be. reported and approved by t,he staff.
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References:
(1)
R. Tedesco letter of June 18,1981, " Staff Concurrence on.
1 Installation of Twelve Backup Dewatering Wells" (2)
R. Tedesco letter of September 2,1981, " Staff Concurrence
- on Inst'a11ation of Eight Backup Dewatering Wells" (3)
R. Tedesco letter of September 25,1981, " Staff Concurrence" on Surcharging of Valve Pits for Borated llater Storage Tank Foundations" (4)
R. Tedesco letter on October 22, 1981, " Staff Concurrence on Installation of Permanent Dewatering Wells and Request for Additional Information" (5)
R. Tedesco letter of flovember 24,1981, " Staff Concurrence for Constructiori of Access Shafts and Freezewall ia Pre-paration for Underpinning the Auxiliary Buildi'ng and Feed-water Isolation Valve Pits" (6)
R. Tedesco letter of December 28,1981, " Staff Concurrence for Five Temporary Dewatering Wells" (7)
R. Tedesco letter of February 12, 1982, " Staff Concurrence for Activation of Freezewall" (8)
R. Tedesco letter of February 26,1982, " Staff Concurrence on Renoval of Surcharge from Borated Water Storage Tank Valve Pits" (9)
R. Tedesco letter of Harch 26,1982, " Staff Concurrence for Grouting of Cracks in Concrete Foundations of Borated Water Storage Tanks" (10)
R. Tedesco letter of April 2,1982, " Staff Cortcurre..tce for Installation and Operation of Construction Dewatering and Observation Wells for the Service llater Pump Structure"
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-ENCLOSURE 5
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STAFF CONCURRENCE ON INSTALLATION OF DEEP SEATED BENCHMARKS CPCo's letter of May 10, 1982 states that installation of deep-seated benchmarks is being carried out by Woodward Clyde Consultants, which is subject to its own
. quality assurance program and procedures approved by Consumers and previously subject to staff inspections. We are advised that these NRC inspections have resulted in a finding that these activities are being conducted to an acceptable quality assurance program.
CPCo has also provided the staff.with information on the installation of deep-seated b'enchmarks and relative-absolute instrumentation beginning with the design audit of January 18-19, 1982 and continuing through the submittal of.
1 March 31,1982 (Letter from J. Cook to H. Denton, Response to the NRC Staff Request for Additional Information Required for Cogletion of Staff Review of Phases 2 a.nd 3 of the Underpinning of the Auxiliary Building and Feedwater Isolation Valve Pits). The information for the auxiliary building underpinning work which has been provided includes locations, depths, elevations, instru-nentation accuracy and typical installation details of the proposed instru uents. This information is contained in the following documentation:
Technical Specification for Monitoring Instrumentation for Underpinning a.
Construction, Specification 7220-C-198(Q), January 18, 1982 Rev. 0 (Provided at the February 3,1982 Design. Audit) b.
Drawings C-1490(Q) and C-1491(Q), Auxiliary Building, Instrumentation Location for Underpinning, Janurry 20, 1982; Revision 1 (Provided at the February 3,1982 Design ". adit)
Drawing C-1493(Q), Auxiliary Building and F.I.V.P., Instrumentation c.
System and Monitoring Hatrix. Hay 29, 1982 Rev. A (Provided b{
applicant's* letter of March 31,1982) d.
Sketches of Carlson Stress Meter and Telltale Installations. Hidland Plant Instruments for Pier Measurements January 15, 1982 On the basis of the ' technical review by the Staff and its' consultants of the info nation in the above documents, including the quality assurance program, the staff concurs with Consumer's proceeding with the installation of the deep-seated, bench marks and relative-absolute instrumentation for monitoring the auxiliary bti11 ding underpinning work, OM6CE)
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d CONSTRUCTION DEWATERING WELLS has been that this work was not permanent, it was being
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ance of construction activities and, therefore, the work did not require staff approval.
design and installation and did not seek staff approval for thes
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4 More recently the staff has concluded that certain aspects of construction dewater-1 ing activities related to underpinning the service' water pump structure (SWPS) a auxiliary building could potentially affect the foundation stability of these nearly corplated structures.
The staff has actively reviipted the temporary construction i
plan (April 2,1982 letter with enclosures from R. Tedesco t
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Wells for the Service Water Pump Structure).currence for Installation a The staff has not presently obtained underpinning but has specified conditions for Phase 2 co i
i It is the staff's position, with respect to the remaining construction dewatering wells that are already installed and operating, that these walls be nonitored for the 4
loss of soil particles due to pumping similar to the requirer.ents agreed upon and recorded in Enclosure 3 to the April 2,1982 letter.
The specifications for a construction dewatering well are dependent upon the spe application.
Consequently, approval for typical field practices, on other than a j
case-by-case basis is not meaningful.
Therefore, for the future, the design and i
installation details of construction. dewatering wells that have not yet been opera or installed should be addressed on a case-by-case basis following appropriate notif cation of the staff by the CPCo.
safety significance of the proposed well.This procedure Will permit an assessment of the However, any construction well for which to.those previously approved for permanent dewatering a staff approved quality assurance plan) may be considered acceptable, provided also that the upper phreatic surface is maintained two feet below the bottom of any exca i
. vation or as otherwise approved in advance by Region III.
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ENCL.0SURE 7 l
STAFF EVALUATI0?! 0F DRAWING 7220-C-45 Staff requirements for this drawing were provided by the~ staff on May 7,1982, to Messrs _ J. Mooney, J. Schaub and others of CPCc. These were:
(1) The seismic Category I retaining wall ts the east of the service water ow:ip structure is shown to be located in the non-Q zone.
CPCo should revise the drawing to provide for'Q-listed control in the vicinity of this wall.
(2) The drawing should be revised to p'rovide for Q control of soiIs activities for the emergency cooling water reservoir (ECNR), the.,
concrete service water ' discharge lines, and the perimeter and baffle dikes adjacent to -the ECWR..
(3) CPCo should implement Q. controls for certain aspects of work out-side the Q zone of Drawing 7220-C-45 which could impact safety
. related structures and systems. Exag les include potential removal of fines by dewatering wells, improper location of borings near the Q boundary, and soil excavations at the boundary involving both Q and non-Q areas.
(4) CPCo should re-confirm that no seismic Category I underground utilities extend beyond the Q area bounds of the drawing.
CPCo's letter of May 10, 1982 notes the intent to revise the drawing to address the ECHR components and other appropriate areas. CPCo has also identified during the Hay 7 telephone discussion additional measures being implemented to assure prop.er location for drillings.
On the basis of CPCo's commitment to extend the controls of soils activities to incorporate these staff requirements, the staff approves the uqe of Urawing-7220-C-45 for dofining the areas around safety-related structures and systems within which the restrictions and requirements of the April 30, 1982, Memorandum and 0rder shall apply.
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ENCLOSURE 8 ADDITION INFORMATION REQUIRED TO COMPLETE STAFF RE SOILS REMEDIAL WORK
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Provide the following information regarding the Auxiliary Building and Feedwat Isolation Valve Pits:
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1.1 redesign of stiffened bulkhead against earth pressur'es' during drift excavation to install needle beam assembly 1.2 revise report on crack evaluation to include consideration'of the effects of multiple cracks 5
1.3 analysis of the construction condition.using a subgrade modulus of 70 XCF and provide results 1.4
. allowable differential settlements for Phase 3 (based on 1.3 above),.-
1.5 horizontal movement acceptance criteria for Phase 3 for instruments at top of EPAs and control tower 1.6 as-built report with confirmatory detail on underpinning ~ in FSAR upon cogletion of construction
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1.7 acceptance criteria for strain monitors for Phase 3 l
1.8 acceptability of 1.5 FSAR SSE versus SSRS as bounding design 1.9 method to be followed for transfer of jacking load into permanent wall-1.10 corelete design analyses of permanent underpinning wall 1.11 updated construction sequence for Pleases 3 and 4 1.12 settlement monitoring program to be required during plant operation with action levels and remedial reasures identified (Tech. Spec.).
I Include RBA', EPA and Control Tower 1.13 plans and details for permanently backfilling underpinning excava-i tions including cogaction specifications for granular fill under-i FIVP l
1.14 procedure to be required for detecting 6xtent of planar openings uncovered in drift excavations and c'ontrols to minimize their effects.
2.
Provide the following information regarding the Service Water Pump Structure:
2.1 acceptability of 1.5 FSAR SSE versus SSRS as bounding design 2.2 sliding calculation using site-specific response spectra (SSRS l
satsnic loads and. provide results with. basis for assumed soil )
i input parameters 2.3 stress condition for existing parts of strveture:
a) Maximum stresses b
c)) Critical combinations Identify true critical elements based on actual rebar.
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calculation for determining lateral earth pressures under dynamic loading 2.5 settlement monitoring program to be required during plant operati.
with action levels and remedial measures identified (Tech. Spec.) on.
2.6 as-built report with confimatory data on underpinning in FSAR upon completior, of construction 2.7 report on crack evaluation to include consideration of the effects of, multiple cracks.
3.
Provide the following information regarding the Borated Water Storage Tanks:
3.1 adequacy.of. governing load combinatfori used in design 3.2~
acceptability of 1.5 FSAR SSE versus SSRS as bounding design, ~
3.3 settlement monitoring program to be required during plant operation
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with action levels and remedial measures identified (Tech. Spec.)
3.4 as-built report with confimatory data in FSAR on completed con-struction 4
Provide the following infomation regarding underground pipes:
4.1 basis for modeling of the piping inside the building in the teminal end analyses 4.2 controls to be required during plant operation to pervent placement of heavy loads over buried piping and conduits 4.3 as-built report with confirmatory data in FSAR on completed construc-
' tion 4.4 justification why the BWST lines are not to be rebedded from th' tank fam dike to the auxiliary building e
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4.5 a list of all penetrations for underground seismic Category I piping.
s Revise and submit your pipe monitoring program to include periodic measurements of rattelspace for plant operating life. Provide justifi-cation for all exceptions.
4.7 justificatio'n for the high (beyond limits) reporteo settlement ste'sses s
5 Provide the following information regarding the Diesel Generator Building:
I S.1 astructural reanalysis considering:
(a) Presurcharge conditions (b) Conditions during the surcharge (c) 40-year settlement effects (d) The combined effects of (a) through (c) above
.5.2 a structual reanalysis assuming reduction in soil spring stiffnesses between bays 3 and 4 on the south side and l'eneath adjacent cross wall 5.3 a statistical evaluation of' settlements to evaluate impact of survey inaccuracies versus actual differential settlements which have been experienced
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1 ENCLOSURE 8 l
" 5.4 acceptability of 1.5 X SSE (FSAR) versus SSRS for bounding. design 5.5 criteria relating crack width and spacing to reinforcing steel stress 5.6 settlement monitoring program te be required dur'ing plant operat1~on
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with action l'avels and remedial measures identified (Tech. Spec 5.7 evaluation of effect of past and future differential settlements to 3
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. diesel lines from the day tank to the diesels.
6.
with action levels and remedial measures identifie 7,.
underground Diesel Fuel 011 Storage Tanks. 2 7.
Provide the following information re.garding the permanent dewaterin
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7.1 results of the dewatering recharge tests.
m 7.2 technical specification requirements on the permanent dewatering system.
. 7.3 a summary dicussion of your contingency plans which would be impleme in the event groundwater levels at critical locations exceed limits in the technical specifications.,,__.,.
8 Provide a settlement monitoring program to be required for structures natural soils and plant fill which have not been identified above with actio levels and remedtal measures identified. (Tech. Spec.)
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Vice President - Projects, Engsneenng
.snd Construction Generea Offices: 1945 West Pernest Road, Jackson, MI 49201 e (517) 78&O453 June 1, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND PROJECT MIDLAND DOCKET N0 50-323, 50-330 SCHEDULE FOR RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON SOILS REMEDIAL ACTIVITIES FILE: 0485.16 SERIAL: 17293
REFERENCE:
NRC LETTER DATED 5/25/82 TO J W COOK FROM D G EISENIRJT v ur referenced letter requests a response to Enclosure 8 within seven days, o
noting when technical responses will be completed for each of the questions. lists several specific requests for " additional information required to complete staff review of soils remedial work."
A response to each of the requests in Enclosure 8 will be submitted by June 15, 1982.
For those questions that require dat.a based on future construction, the June 15 response will include a general discussion of the subject and an anticipated date for completing the response once the underpinning is complete.
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M E.LLDG UNDER.PWWWCP MEMORANDUM FOR:
Assistant Director 10 W K w % T 'n ##. A
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FROM:
James P. Knight Assistant Director M.Q for Components & Structures Engineering Division of Engineering
SUBJECT:
MIDLAND PLANT UNIT NOS. 1 AND 2 The applicants submittals regarding Phase 2 of the underpinning repair work at the Midland Plant have been reviewed fmm the standpoint of Structural and Geotechnical engineering. We conclude that the Phase 2 program is acceptable provided that certain modifications and requirements are incorporated. The enclosure to this memo entitled " Midland Plant, Pmvisions for Acceptance of Phase 2" lists the modifications and requirements we believe na:essary. Based on discussions with your staff we understand that the transmittal of these provisions to the applicant will include specific instructions to document the accomplishment of these actions and inform Region III as that documentation is available for the inspectors examination. We believe that this approach is appropriate.
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'Jimes P. Knight Assistant Director for Components & Structures Engineering Division of Engineering cc:
R. Vollmer D. Eisenhut R. Purple E. Adensam D. Hood R. Hernan F. Schauer G. Lear i
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,d,r To. G~ w g Midland Plant Provisions for Acceptance of Phase 2 1.
Deep-seated bench marks DS8-AS1 and DS8-A52. DS8-Asl and DSB-AS2 shall be installed at 'a distance not to exceed 5-feet from the wall of the Main Auxiliary Building which is founded at Elevation 562. Actual locations of these installed bench marks and any modifications in tolerance criteria required on Drawing C-1493(Q) due to changes from the original DSB-AS locations shall be documented. hkt.J,w2 'si i 't le dh. w.E ymE N
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Monitoring devices required to be installed. The following devices shall be properly installed and operating prior to drifting under the turbine building or FWIV pit.
),'"s{'*[,,I,'h' DS8-1W DSB-ASI OMD-1W Wl 23 ' - } 'e'4 * +
DS8-lE DSB-AS2 OMD-lE S'"' S " T' " 9 3 w DSg-2W DSB-AN DMD-ll h"-" "
DSB-2E OMD-12. -
j DSB-3W DMD-13 DSB-3E 3.
Strain gaae installation. The following revisions shall be made to the 1
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proposed' instrumentation shown on drawing C-1495, " Instrumentation -
El. 695 - 0 5/16" for Bldg. Settlement Monitoring".
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With' ference to drawing.C-1495 Sectional View-Wall at Cul. Line's t i 1
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Reorientate the proposed vertical s' rain ga/ge installation 5.3 and 5.6.
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. between Elevations 646 to 659 to a slope s milar to lowelr gage
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+. 4.Y. With reference to drawing C-1495, Sectional View-Wall at Col. Lines 7.4'and 7.8.
Change orientation cf prooosed lower strain gages between l
Elevations 584 to 614 to be perpendicular to orientation shown on Drawing C-1495 in the March 31, 1982 submittal (Figure 3). On this, tra x. Wia.
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same sectional view add an additional strain gage. between Elevations -bdkr-646 to 659 at an inclin'stion similar to the above recomended orientation.
(The labeling'of columr. lines H and G is reversed on th'e copy of this 1
sectional view submitted to the staff.') >
4.
Pier load test procedures. The following modifications and additions shall be made to the pier load test procedures provided by the April 22, 1982 submittal from J. Cook to H. Denton entitled " Response to the NRC Staff Request for Additional Infomation Required for Campietion of Staff Review of the Borated Water Storage Tank and Underpinning of the Service Water Pump Structure."
(It is the NRC Staff's understanding that, although the procedures were submitted for underpinning work for the Service Water Pump Structure, the l
procedures are applicable to the pier load test to be conducted during Phase 2 underpinning work for the Auxiliary B)ilding.)
a.
Page 12. The maximum required test load should be equal to 1.3 times the maximum anticipated design load. As an alternative, should there be structural difficulties in developing the required reaction loid for the pier test, the NRC Staff would ac ept a procedure where the maximum test 30 load for the pier load test was equal to'1fAKp rcent the max anticipated design load and a plate load test (ASTM D119 ) was perfomed to a maximum test load equal to 130 percent of the maximum anticipated design load, s
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Page 12. Significant modifications to the specified ASTM Dil43-81 test procedures, as the Applicant may deem ' appropriate, require early notification and the approval of the NRC Region III Office.
c.
Page 12. The rate of settlement shall not exceed 0.00 inch per hour when controlling the length of time that the T test load increment is to be maintained.
d.
Page 12.
In order to provide a more positive reduction of skin friction, plywood sheeting coated with 1/8-inch thick bitumenf or equivalent shall be installed on all test pier sides prior to perfonning the pier load test as a replacement for the plastic sheeting proposed by Consumers Power.
To permit correlation with the previously approved measures proposed e.
by the Applicant to denonstrate the adequate foundation capacity of the other installed piers, a minimum of two in situ density tests and five cone penetrometer tests shall be performed on the soil at the bottom of the pier selected for test loading.
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Construction Dewatering. During underpinning of the Auxiliary Buildin v
area, the upper phreatic surface shall be maintained a minimum of/2'fe 9 f, m
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A et in depth below the bottom of any underpinning excavation at any given time. $ N i o f, SW The final plan for the dewatering system shall be established and implemented
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piezameters (observation wells).
Tae+=' etia-det:th : d riteria for q
monitoring loss of soil particles due to pumping shall be the same as those 3
Qw m x. W 5s r previously approved by the staff for the dewatering of the Service Water i Q j--
3 Pump Structure. fr@d'L d'# 2b N N '*
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Monitoring movement of Feedwater Isolation Valve Pit (FIVP). Jacking of the FIVP back to its original position shall be required if the relative
[7 settlenent between the Reactor Containment and the FIVP esh.hetwoose=t!$ lits-o w~ 3 IdiT "' die; r,d 1. lif reaches a total settlement of 3/8-inches
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