ML20126H273

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Interrogatories & Request for Production of Documents. Requests Info Re Administration Bldg Settlement & Fall 1979 Cooling Pond Drainage.Ltr to C Bechhoefer Encl
ML20126H273
Person / Time
Site: Midland
Issue date: 03/27/1981
From: Stamiris B
AFFILIATION NOT ASSIGNED
To:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20126H269 List:
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8104080403
Download: ML20126H273 (3)


Text

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UNITED STATES NUC12AR REU1ATORY CottfISSIN l

In the matter of Desket Bes. 60 339 go-g l

C.F.Co. Midland Plant Units 1 & 2 BEFORE TFX ATOKIC SAFETT & LICEREIEG DQ&as 3/27/81INTEITEBORDISCOVERTIEQUEETCPC.P.CO.

(Instructionsanddefinitionsasin12/4/60 request)

DOCUMENT R3 GUESTS:

1.A12/28/78 letter (tab.24 Tel.III,50-54f) was. sent to eensultants Peek and Hendron asking for their sessments, sad requestirg that the " marked up copies be sent back to Mr. Perris. Please provide these " marked up oopies" regarding backfill spesifientions.

2. Provide a copy of C.P.Co. April.17,1980 Answer to Betioe of Bearing.
3. Provide any written statements of censultants Peck er Bendron regarding the settlement problems at the Administration Building.
4. Provide any written statements of censultants Peek er Bendron regarding g beyond these j

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the removal and replacement of fill soils beneath the D.G.B provided in the 50-54f er 50-55e reopenses.

5. Provide the benthly Projoet 4.A. Aetivity Reports te Key Project Personnel for the senths of July 1977 through Nevenber 1977, and for July 1978 through January 1978,in which any mention is made of Wieistration Building ooil settlement er 1978 poil settlement matters.

II*ERROGATORIES:

1. On what basis was the decision made to change the original mat foemde. tion design for the D.G.B. to a anallow spread festing? Mme made this decision, when was it made,and when was the 35: intensedt
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2. Identify fesadation design ekangee to any shr Category I structures femaded on plaat area fill. Om what basis were emeh deeisises madef f

Who made these deeisions,when were they tiede,and when was W ERC informed!

3. Were any sorroetire actions r======adad as a result of the Administraties Building dettlement probleme? If os please deseribe.
4. Enve maqr strees analyses er observatica progromsEtituted S&ase'1977 for h Administraties Building? If se please desoribefand give results of such programs.

t 5.3 ee say settlestat measurements takesit en'resadattear-soitt eefrDeG.B& '

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eenparing'esil'Ittels tus4:6ftar placessat to soil levels just prior te 4

begianing esastrustieaf If so, please provide resalts.

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6. Were any laboratory tests dess to justify bearing espacities at h D.G.B.T if so,briefly identify be and the rationale behind W deeision to take them.
7. My was the eeeling pond drained in the fa611 of 19797 How mueh was it I

drainedt ht informatian was gathered free this motivitri

8. Mees handwritten notations and questions appear en the rough draft of Report en failure of grade beam 0 4 line - Administration Building (file 13440 or 3990)f
9. h were the key people that were intelved in & Administration Building settlement assessment and decisions,ht were ales' involved in Beeisions to begin and sentinue sonstrustien of D.G.3. shortly theres*terf 1320,3410) 8,197810.L from Afiti to Castlebury (oepies to
10. The March metes a searliet er seatusima regarding borings..Flosse esplain this eschange and provide h three referessed I.C.Ls.

Respectfully Suhatitted,

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& d M SECNIEI h March 27,1961 Dc;hsting & W

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Dear Judge Beehheefer and Censussers Fewer Attermeys,

.I will preface my disoevery request with this informal letter of explanation'in the hopes of expediting further objoetiens er motions

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to eenpell,which I anticipate over the timiar; of this request.

Due to ' severe family health problems,I was unable to work en aqr intervention studies during the month of February. In Marsh,I resumed my studies (with the March,2, arrival of C.F.Co. roepenee to my 1/26/81 submittal).

Since then,in studying the doctaments provided and reviewing seer soil settlement documents in preparing my answer to CF.Ce interrogatories I have come up with these discovery reonests. I have tried to. limit these requests to very specific items er dooumonte (as discussed in previous

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compromise eenversations with James Brunner).

Due to these extenuating ciromastances and due to the timing of -

Censumer's roepenses te aqr, requests thio 3/27/81..Dissevery Bequest falls ~.

within the seepe +st.the ruling made at: the '1artyrekoaring senteresse (p.4 ef 2/27/81 Memerandum).te fils such reoneets as soon aa peaeible" a

I have not yet received Censusser's reopense to aqr 1/14/81 requests, but will hereby offer to submit any further and final diesevery reenests within three w+eks of reestving' thkir roepenee 'if relsted quest 19ae are meessaary.

.Simoerely, b

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