ML19344A758

Suppl to Petition to Intervene Alleging Poor Quality of Fill Soil Composition & Inadequacy of Dewatering & Preloading Procedures

ML19344A758
Person / Time
Site:	Midland
Issue date:	08/14/1980
From:	Warren S AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OM, NUDOCS 8008220148
Download: ML19344A758 (2)

Text

snerun A. nesien 636 Hillcrest

' Midland, MI 48640 ,

g ited States Nuclear Regulatory Commission T II ington D.C. 20555

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=cc"ED In the Matter of

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w, esNac 2 Consumers Power Company M AUG 18 580 > ,

( Midland Plant - Unit 1&2)

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g 3 Docket Nos. - -

b Y/ 7 Sucolement tc the Petition to Intervene c3 g In order to meet the requirements of the petition to in intervene required by Section 2.714 and other pertinent sections of the Nuclear Regulatory Commissions Rules of Practice, I wish to make the following statements:

1. The composition of the fill soil used to prepare the site

. of the Midland Plant-Units 1 and 2 is not of sufficient quality to assure that pre-loading techniques have permanently corrected soil settlement problems. The NRC has indicated that random fill dirt was used for backfill. I contend that the components of random fill dirt can include loose rock, broken concrete, sand, silt, ashes, etc. all of which cannot be compacted through pre-loading procedures.

2. The known seepage of water from the cooling pond into the surrounding soil poses a threat to the reliability of the construction integrity of this plant and its safety systems.

We know that the entire Saginaw Valley is built upon centuries of silt deposits--which are highly permeable.

3. Dewatering procedures are inadequate in the event of increased water seepage, flooding, failure of pumping systems, power outages and especially considering the composition cf the soils being dewatered. According to Consumers Power dewatering will keep water levels below 616 feet. I contend that l

under the conditions previously mentioned, they cannot guarantee that these stated levels could be maintained.

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4. I contend that the pre-loading procederes undertaken by l Consumers Power have violated the structural integrity of the l di es el generating building and its plumbing and electrical l components. 1 I reserve the right to ammend thesercontention a t any future date. /'/ )

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.a CC Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael I. Miller, Esz.

Isham, Lincoln and Beale, One First National Plaza Chicago, Illinois 60690 Secretary of the Commission U.S. Nuclear ' Regulatory Commission Washington, D.C. 20555 d

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