ML20094K140

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Documents Contacts by Kirkland & Ellis Attys Representing Dow Chemical in Suit Against Cpc.Summary of Meeting by Geotechnical Engineering,Inc Encl
ML20094K140
Person / Time
Site: Midland
Issue date: 01/23/1984
From: Kane J
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
Shared Package
ML19258A087 List: ... further results
References
CON-BX16-062, CON-BX16-62, FOIA-84-96 NUDOCS 8408140556
Download: ML20094K140 (14)


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UNITED STATES NUCLEAR REGULATORY COMMISSION h.'

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WASHINGTON, D. C. 20555 January 23, 1984 q N,-

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MEMORANDUM FOR: W hief 5tructural and Geotechnical Engineering Branch T

Division of Engineering k-j THRU:

Lyman W. Heller, Leader I Geotechnical Engineering Section Structural and Geotechnical Engineering Branch l

Division of Engineering FROM:

Joseph D. Kane, Senior Geotechnical Engineer Geotechnical Engineering Section Structural and Geotechnical Engineering Branch Division of Engineering

SUBJECT:

00W'S REQUEST TO DEPOSE H. SINGH The purpose of this memorandum is to document contacts Fj the attorneys from Kirkland and Ellis who are representing Dow Chemical in their suit against Consumers Power Company and to identify questions where I feel technical reviewers for the Midland project should be provided guidance by the NRC legal staff.

NRC Consultant, Mr. Hari Singh, from the U.S. Army Corps of Engineers has been contacted on two occasions by an attorney from Kirkland and Ellis who has requested that Mr. Singh make himself available for deposition questioning. On both occasions Mr. Singh has referred Dow's attorney to C0E management. The most recent contact resulted in Mr.

Andy Running from Kirkland and Ellis (312-861-2412) calling J. Kane on January 16, 1984 at the suggestion of Neil Gehring, Project Manager for the COE.

In response to Mr. Running's request to depose Mr. Singh, I indicated that it was necessary for me to contact 0 ELD before a response to Kirkland and Ellis's request could be made.

I called W. Paton, OELD on January 16, 1984 and apprised him of Dow's request and asked for OELD legal guidance on the following questions:

1 1.

Should NRC recomend that Mr. Singh appear voluntarily for the requested deposition or should it be under a subpoena? Both Mr.

i Singh and myself feel the Midland safety hearings have been l

lengthy, demanding and draining and would strongly prefer to stay out of the Dow lawsuit, particularly in recognition that these j

efforts are unrelated to our official duties and responsibilities to the NRC.

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O. January 23, 1984 2.

If directed to appear at a deposition, what arrangements should be made beforehand, for payment of time and travel expenses? The

.present interagency contract that the DE has with the COE did not anticipate this involvement, nor do we have funds available to cover these costs.

3.

Will OELD provide legal representation at Mr. Singh's deposition if he is directed to participate?

Mr. Paton indicated a desire to consider the impact of these questions and discuss them with his supervisors in OELD.

On January 18, 1984 Mr. Paton returned my call and advised me that all questions related to the staff and its consultants involvement in the Dow lawsuit should be directed to the Office of General Counsel and suggested that I contact Marty Malsch (634-1465).

In order to fulfill my verbal comitment to get back to Mr. Running from Kirkland and Ellis with a response from NRC, I called Mr. Malsch on January 18, 1984. Mr.

Malsch had apparently had previous discussions with OELD and was aware of Dow's request to depose Mr. Singh.

I repeated the three questions which sought legal guidance on this matter and was advised that Mr.

Malsch would get back to me. A preliminary respanse from Mr.

Malsch indicated that the party requesting the deposition would reasonably be expected to provide the funds to cover costs and that the Office of General Counsel would provide legal representation to our consultant if other arrangements could not be made. Possibly an

-attorney from the Corps of Engineers could attend Mr. Singh's deposition, if the deposition is ultimately scheduled. Mr. Malsch expressed an initial preferen i to proceed with interrogatories rather than deposition.

I have requestr that a copy of this memorandum be provided to D. Hcod and F. Rinaldi for their information, since it is likely that they will also be contacted by Dow's attorney in the future.

Joseph D. Kane, Sr. Geotechnical Engineer Geotechnical Engineering Section Structural and Geotechnical Engineering Branch Division of-Engineering, ONRR I

cc:

R. Vollmer M. Malsch J. Knight E. Adensam i

G. Lear D. Hood L. Heller F. Rinaldi l

P. Kuo H. Singh, COE T. Sullivan N. Gehring, C0E W. Paton J. Kane i

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/r 87 UCEED-T Geotechnical Engineering Assistance to the NRC Trip l

Report Meeting at Midland Neelear Flaat -

Unita 1 and 2 NRC FILE N.A. GEHRING 14 MAR SO GgMRING/vw/66793 1.

FURPOSE: P e purpose of the trip was to acquaint the new NCE team members with the site. None of the NCE oeople, encept Roa Erickson had yet been to the Midland site. It uma important for the NCE people to see the site to view the cise of the job, the amount of the plant constructed and the visable problems identified to date.

2.

DATE AND FLACE: The meeting teek place at the Midland Power Plant site on 27 cad 23 February 1980.

3.

SIGNIFICANT ELEMENTS: The NCE staff and WES consultant, Faml Hadala met the.

NRC staff and the applicant, Consumers Power Ceapeay (CFCo) and its consultants, viewed the site and were briefed on the fixes proposed for etructures in need of remedial actica. Structures identified as constructed on improperly eenpacted fill and, therefore, possibly requiring remedial action are the diesel generater building, service water pump station, borated water tanks, undem._ d diesel feel tanks, fee.d. water valve pits (between Aux. Elds and reactor containmaat) and underground utilities.- Of these structures only the diesel gemarator building, service water pump building and the food unter valve pite have remedial action planned. Another significant topic discussed was the site dauntering plan which to important during seismic events to prevent liquefaction.

4 PERSONS PARTICIPATING: See attendees list dated 27 Feb 80 Incl. 1.

Essentially the g people attended the 23 Feb 80 asating with the addition of the four principle, consultants; Gemid, Peek, Hendrea and Davisson.

5.

NARR TIVE: The aseting agenda is attached as Inclosure 2.

The agenda was followed exactly with completion of all presentations through No. 7 being completed on 27 Feb 80 and items 8, 9 and 10 being completed on 28 Feb 80. Lyman M 11er (NRC) made introductory remarks and turned the meeting over to Gil Keeley (CPCO). Gil mentioned that remedial work had been shutdown due to NRC December 6, 1979 show eause notice. He aise mentioned that 10 CFR 50.54(f) responses to questions 24-35 along with answer ebensee to previous questions would be provided to NRC the week of 3 March 80.

t Tom Cooks (CFCO) discussed the D.C. building problem which was first noted on 2 A:n 78 and followed by NRC notification on 7 Sept 78. This was the first indication of the improperly compacted fill problem. Fifty-six meetings resultad is selection of the pre-lead fix. A major investigative program was initiated h e f

ceructures,placed on fill and associated erack mapping. Tom Cooke outlined the probleme, all proposed remedial actions and the dauntering plans.

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r NCEED-T SUBJgCT: Geeteshaical Engineering Assistance to the NRC - Trip Report Meeting at Midland Neelaar Flaat - Units 1 and 2 The remaining agenda items 3.0 then 7.3 were sovered by primarily technical disemosions concerning the statue of designe completed. Handouts were provided by the_various speakere for agenda itene 2.0, 3.0, 4.0 (all), 6.0 and 7.0 (all).

These are included as Imel. #3.

Da the morning of 28 Feb 80, the site wee toured. h re were several tour leadere which provided tours on the particular interest. Our geotechnical tour leader wee Jim Wasseek (Bechtel). h areas we ebeerved were as follows:

a.

Diesel Genesator Building - N west and east baye only. We observed the doet banks and how they had been released from empporting the building and the d

cracking. Varisee settlement moeitering devices and crack mapping methode were else observed.

h.

h cooling pond at the guide dike une ebeerved. N various intake and outlet pilses were discussed (met visable). Comeera une expressed for these Category I utilities.

I c.

Service Water Building (cantilever portion) was obeerved siens with some ef the cracks. N retaining wella om either side of the building were also observed along with about a 1-1/2 differential settlement between wall sections (one each side of building). Os our way to the feedwater value pit, we observed the downtering eyeten that had just been turned on to begin initial pump deve tcete.

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Aux. Bldg - Feed unter valve pit (east). Previelene had been started for orpporting this area from above with very large structural members. Not usah was viemble coneerming the problem area.

e.

Borated Water Tank (weet) - observed the large diagonal erack in the ring foundation as well se creeks in the smils of the valve pit area. This completed the site toer.

Next the fear esaseltaats to CPCs gave their summaries for the fians.

Mr. Could discussed the feed water valve pit fim. A haedout was provided - Inci 4.

Basically the plan is to locally deseter at each pit (east and west), install SSF 1

i secess shaft elev 634 - 600', support valve pit from surface install emisson between reester and aus. building and test lead estesees.

install jacked r

siles er caissons under electrical penetraties area, esaavate under valve pit to till and backfill with reinforced eonerete lifts. Each esiesen lead is to be i

tested to 1.5 x design loed.

Mr. Daviseen deseribed the service water bar.1 ding fix which to placement of 32 -

75 Tea / pile,14" dia.1/2" thick piles drives into place with as 010 hemmer. See incl. 5 for details. h final driving capetity is to 20 bloes/in, 60 bleue last 3".

N piles will then be jacked agaiset tia cencrate korbole 1/4 of the 75 toa load applied to each pile until the full 75 '!/ pile is obtained. The above piles l

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l SUEJECTt Geetoshaisal Basinoertag Assistmase to the NRC - Trip Report Meeting at Midland Dam 1=me Plant - Unite 1 and I cre met to be subject to loads which_would equal or ascoed Euler solems buckling leads for me lateral pile support.

Mr. Mandrea described the D.C. building fix alternatives semeldered by the cyplicant.

a.

Me correcties plus great between feendation and soil - not selected becesse soil still settling.

b.

  • ledify festing to a unt foundaties - met seleeted as the soil is still not densified.

c.

Proleed the area and disseeneet dust beake, eliminate settlement before esomecties to utilities f0 is sempleted. Eew less to preleed was of mejor eeeeers.

d.

Combinaties of b + e - met selected Underpin the structure - sett====t of stility piping would aestiaue, no.

1 e.

fix for soil, therefore, met selected.

f.

Remove and replace building g.

Almiraative f. + removal of fill, piping, and replacement Alternative e.,seleeted Dr. Peek alas diseaseed the D.G. building fin. The preleed alt. had several advantages in that it would provide good data for future settlement prediatione cad provide a Isod proof lead test. Creating of peerly completed fill layers comid ast be an eseily defendible seleties in esort. Doestering womid eliminate liquefaction potential and useld be eney te semiter. It would slee reduce seismia thekedese settlements la esad layers. Each plaat repair has a legal precedent.

A question and seewer period felleend this presentatism. The initia oesttees l

that were asked were assuered threaghest the two day meeting.

6.

CONCLUSIOWS The propeeed ftaas appeared t'e be seeerally acceptable pending review of these designs when they benene available to NRC. Some additional data, heringj etc. are likely to be required la order to fully antisfy as seneerains the future plant safety.

7.

ACTIONS TO Sg TAKEN: Gese the fim desiga data and eseputatises are received, our resen d tione saa be ande se to their acceptability. Sene~arese of concera cre likely to esist se determined by the district technical staff that may require additional investigatten to eatisfy. These should be moda kneen/ o the IntC as t

seen se possible se that information saa be obtained gelekly and_ prevent further delays.'

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SUBJECT:

Geotechnical Engineering Assistance to the NRC - Trip Report Meeting at Midland Nuclear Plant - Unita 1 and 2 8.

RECOMMENDATIONS: Request additional data from NRC as soon as possible.

Additional inforestion and data required to be identified by the technical stuff to Project Manager so it can be requested from NRC.

W 5 Incis N.A. GEERING C'

Project Manger Technical Branch cc NCDED-g w/incis 1 & 2 only

/ NRC w/incie 1 & 2 only I

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"{l MEETING WITI! NRC ON MIDLAND PLANT FILL STATUS AND RESOLUTION February 27 & 28, 1980 j-Midland Site

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1.0. INTRODUCTION G. Keeley f

f 2.0 PRESENT STATUS OF SITE INVESTIGATIONS T. ",ooke i

2.1-Meetings with Consultants and Options Discussed (Ilistorical) 2.2 Investigative Program

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Boring Program 7

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Test Pits l

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Crack Monitoring and Strain Gauges i

D.

Utilities 2.3 Settlement A.

Area Noted B.

Preload C.

Instrumentation nt 3.0 WORK ACTIVITY UPDATE J. Wanzeck i

3.1 Summary of work activities and settlement surveys for all Category I structures and facilities founded partially or totally on fill J

4.0 REMEDIAL WORK IN PROGRESS OR PLANNED (Q4, 12, 27, 31, 33 & 35)

S. Afifi 4.1-Diesel Generator Structures 4.2 Service Water Pump Structures l

4.3 Tank Farm 4.4 Diesel' Oil Tanks 4.5 Underground Facilities 4.6 Auxiliary Building and FW Isolation Valve Pits 4.7 Liquefaction Potential 5.0: EVALUATION OF PIPING (Q16, 17, 18, 19 & 20) N ' ^ ^ ~'* /

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6.0 DEWATERING (Q24)

B'. Paris

.7.0 ANALYTICAL-INVESTICATION B. Dhar 1

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[ g g go 7.1 Structural Investigation (Q14, 26, 28, 29,30 & 34) 7.2 Seismic Analysis (Q25) ( c.kv it M Co, JD b

7.3 Structural-Adequacy with Respect to PSAR, FSAR, etc.

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.0 CONSULTANTS SU} DIARY Peck /Elendron/

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  • 10.0 DISCUSSION All Ij

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-l Consumers Power Bechtel Consultants

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G. S. Keeley Harris Burke R. B. Peck T.' C. Cooke Sherif Afifi A.-J. Hendron, Jr.

T..Thiruvengadam Don Riat C.

H.~ Could 3,

Bimal Dhar M. T. Davisson I

Bill Paris Jdlius Rotc Jim Wanzeck I

Karl Wiedner John Rutgers Lynn Curtis Al Boos Chuck McConnel NRC US Corp Of Engineers E-TEC L. Heller N. Gehring P. Chen

-R. Jackson J. Grundstrom J. Brammer J.;Kane B. Otto

- T.'Cappucci W. Lawhead F. Rinaldi P. Hadala R. Gonzalis F. Schauer D. Ilood G. Callagher R. Cook

- US Navy Weapons Center P. Huany J.-Matra i

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asesamca os onica svanot wanct NCEED-T Ceotechnical Engineering Assistance to NRC-Trip Report Site Investigation Midland Nuclear Facility 14 November 1979 C"Y '

NRC File N

Kubinski 4 Feb 80 KUBINSKI/ww/66786 1.

'Ihe purpose of this trip was of orientation in nature to familiarize NCE personnel with site conditions at the Midland Nuclear Facility.

2.

The meeting took place on 14 November 1979 at ths Midland Nuclear Facility, Midland, Michigan.

1.

'Ihe trip consisted of two phases: a meeting at the Bechtel offices on the site and a walk through the entire site as well as in the completed structures.

The meeting was intended to bring NCE staff up to date as far as area of concern and proposed solutions to questions raised by NRC.

The site visit was made to familiarize NCE staff with foundation conditions, the buildings in the state of completion in which they exist, and general site conditions.

4.

A list of people in attendance at the meeting as well as making the site visit is attached to this report. The following individuals are considered of significant nature in reading trip report:

T. C. Cooke (CPCo-Project Superintendent)

Darl Hood (NRC-Overall Project Manager)

Ray Gonzales (NRC-Hydrology)

Cene Callagher (NRC 'tegion III, I&E)

Al Boos (Bechtel-Project Engineer)

Various other Bechtel and CPCo staff as indicated on sign in sheet.

5.

"Ihe following is a list of significant items which were discussed at the meeting or during the inspection:

T. C. Cooke made an introduction and from then on,Darl Hood chaired the a.

meeting. The introduction hinged around discussions concerning the quality control program with respect to problems which were initially observed in the settlement of the diesel generator building.

At this point Bechtel personnel

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gave a presentation concerning the facility.

I b.

Bechtel Corporation was responsible for the construction of the facili ty.

Canonie was responsible for the placemen't of the fill and any excavation at the facility. At the present time all foundations are in place and the actual civil / structural work is 90% complete.

All the foundations and slabs are in place at the present time.

The following discussion concerns the diesel generator building. The c.

diesel generator building is placed on shallow strip footings with the il generators on the inside,placed on pedestals. A number of sketches are available.See the correspondence. The generator building is in the main construction area of the~ facility.

The reactor towers,which are near the j

generator building.are placed on till material,whereas the generator building was placed on fill material. The type of material this building is placed on DA &n".a 2496

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SUBJECT:

Geotechnical Engineering Assistance to NRC-Trip Report Site

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Investigation Midland Nuclear Facility 14 November 1979 consist of sands, clays [ some lean concrete. A control survey first detected the problem and from then on settlement has been monitored.

Doctors Hendronand Peck have nbeen retained as consultants to Bechtel and CPCo and according to those present at the meeting,they recommended pre-consolidation which would limit the amount of settlement in the future. He foundation was placed in 4 >

October of 1977 and monitoring did not begin until May of 1978. It is assumed by the Bechtel staff that.the foundations are sound and that they had settled with 'the building," going along for the ride" so to speak. The sands under the a

building are of major concern because of1 improper density and liquefaction potential. At one point in time the entire building was supported by a vertical 4

duct bank at one corner. The foundation as well as the pedestals supporting the diesel generators were in some cases placed on a lean concrete mud mat which is

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placed for ease of construction. The excessive loading due to the weight of the i

pedestals caused a" bow"which causedminor cavitation underneath:the spread footings. This is detailed in a report by Dan Gillen,available in the District i

file. The building was thought to have undergone ridged body rotation which caused the differential settlement.' After the building was preloaded with approximately 20 feet of sand both.inside and around it, a rebound of j

approximately 3/8 of an inch was observed. Not more than 1-1/4 inches of settlement is anticipated in the next 40 years according to Bechtel Geotechnical staff. Refer to the questions and answers raised by NRC staff and responded to by CPCo concerning these issues. They should be analyzed and studied ausd de determinen if the responses are adequate.

[

d.

The service water pump structure JA the associated cracks were also discussed. Please refer to Dan Gillen's report to the NRC file.

-l e.

The diesel oil storage tanks, also Category I structures, were filled with water to hold the structures to a safety factor of approximately ohe and exhibited no problems in settlement. There ware a lot of questions concerning H

the reliability of loading to a safety factor of one to determine no future 3

problems with settlement. The service water valve pits were subjected tg

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preload during the preload placed on the diesel generator building.

Thefe were j;

moving with the soil as the diesel generator building was moving.

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The Mulrided water storage tanks are thin shelled tanks placed on ring i p footings with sand in the center.

It is proposed that these tanks be filled with water and. monitor the settlement af ter filling.

Questions were raised P

concerning the applicability once again of loading the structure with a dead j

load safety factor of one and extrapolating future settlements due to the load.

t' Borings indicate good material under the tanks, but as exhibited in other areas ij

. nature of the fill material seems to vary significantly in short distances.

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Lines to tanks and valve pits are now also considered to be of l!

Category I nature, and no system of proof loads has yet been developed to d

ascertain that they will not settle beyond anticipated amounts. @ gee load teste j

were performed in the vicinity which yielded satisfactory results locally.

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SUBJECT:

.Ceotechnical Engineering Assistance to NRC Trip Report Site j

Investigation Midland Nuclear Facility 14 November 1979 Cracks were observed in the valve water pits between 20 and 30 millimeters but no. reported settlement has been observed. This is, however, inconclusive since settlement was not monitored during construction and immediately af terwards.

h.

The proposed fixes to the auxillary building were described and discussed by Bechtel staff. Once again see Gillen's summary of conditions at the site.

i. Liquefaction potential of sand at the site was discussed. The preposed solution is to permanently dewate the site.

1 J.

The following remedial actions are being considered at,the site.

(1) At the service water intake structure, closed-in,14 inch diameter piles will*placed adjacent to the cantilever portion, and then permanently fixed to the building. These piles will be driven to the till matarial and support the building by the till material.

i l

(2) The wing walls of the auxillary building will be underpinned using

,g placed down to the till material, and then dowelleJto the building itself.

Apparently, Professor Could of U of M has been brought in to consult concerning this matter.

(3) The entire site is intended to be dewatered to eliminate any possibility of liquefaction potential within sand areas.

According to Bechtel staff, no settlement is anticipated due to an increase in unit weight of the soil. The dewatering system is not yet finalized and there is still a possibility of installation of cut off wells coupled with permanently dewatering the area.

l k.

Various minor discussions were held concerning specific issues between Darl Hood and Bechtel staff, which were of a nature which did not concern NCE at this time.

<s 6.

The site visit was extremely helpful in recognizing relative magnitude of problems as they exist in the correspondence. It was.also beneficial to view how Bechtel and CPCo staff aredte:'pting to analyze and address these problems.

At this time no conclusions can be made concerning the issues, but it is imperative that all the transmitted correspondence be*gone through*to find a proper history of occurrence at the site, as well as familarize NCE personnel with current resolution of problems as proposed by Bechtel and CPCo.

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JOSEPH KUBINSKI Concurrence:

R. Erickson (NCE) s' l1 Darl Hood (NRC-Overall Project Manager) l!4 Ik 3

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