ML20077H640

Affidavit of P Shunmugavel Re Use of Ethafoam at Jobsite. Certificate of Svc Encl

ML20077H640
Person / Time
Site:	Midland
Issue date:	08/02/1983
From:	Shunmugavel D BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20077H638	List: ML20077H637 ML20077H640
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8308110171
Download: ML20077H640 (28)

Text

o August 2, 1983 3

STATE OF MICHIGAN )

) SS.

COUNTY OF WASHTENAW )

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM

) 50-329-OL (Midland Plant, Units 1 ) 50-330-OL and 2) )

Affidavit of Dr. Palanichamy Shunmugavel My name is Dr. Palanichamy Shunmugavel. I have previously been a witness in this proceeding and my pro-fessional qualifications are in the record. I swear that the statements made in the attached Affidavit are true and correct.

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' a'o t ,.scl.s. , i !, . .,  !,

Palanichamy Shunnugavel Signed and sworn to before me this 2nd day of August, 1983 x D>& b*

Nefa'r~y Public LINcA 10U151 cott Atary M' c, Wu'.ie .a s re .y. Ec 4p:.

s IAy Commissio.i Expkas /.sg65 16, 1925 8308110171 830000 PDRADOCK05000g G

AFFIDAVIT OF DR. PALANICHAMY SHUNMUGAVEL ON ETHAFOAM I. INTRODUCTION My name is Palanichamy Shunmugavel. I am an Engi-neering Specialist in the civil / structural department of Bechtel Power Corporation in Ann Arbor, Michigan. My resums has been introduced earlier in these proceedings.

In connection with my role as an Engineering Special-ist, on February 17, 1983, I appeared before the Licensing Board to sponsor testimony on behalf of the Applicant regard-ing Seismic Category I duct banks at the Midland site. During the course of oral examination on this testimony, the Licens-ing Board inquired about the use of Ethafoamlbrand polyeth-ylene foam to isolate the duct banks. Specifically, the Board asked (1) the purpose of the use of Ethafoam; (2) whether 1

there is any assurance that Ethafoam will retain its physical or structural integrity while buried in the soil over the 40-year life of the plant; and (3) whether there are any stan-dards, tests or qualifications that document the ability of Ethafoam to withstand the conditions that it will encounter while buried in the soil.2 This affidavit is provided in response to these inquiries.

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1 Ethafoam is a trademark of the Dow Chemical Company. l 2 Tr. 12025-12027

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II. GENERAL DESCRIPTION OF ETHAFOAM Ethafoam is a flexible, closed-cell expanded polyeth-ylene (plastic) foam produced by the Dow Chemical Company. It ,

is a physically stable material that resists shattering, 1

breakage or crumbling when flexed, cut or struck. Ethafoam also displays excellent chemical stability, and it is excep-tionally resistant to most solvents and other chemicals at room temperatures.

Stability of the material is dependent upon the load imposed on the foam, exposure time and the temperature involv-ed; therefore, no specific maximum use temperature is given by Dow for Ethafoam products. In applications where Ethafoam is not subjected to load stress, such as the uses described below in Section III, Ethafoam products can be used successfully while exposed to intermittent temperatures of up to 165'F.

Over an extended period of exposure, ultraviolet rays in sun-light can cause some degradation of Ethafoam.

Dow Chemical Company has evaluated typical properties of Ethafoam under the methods adopted by the American Societf' i 3 " Designing Packages to Survive Shipping and Source:

Handling with Ethafoam Brand Polyethylene Foam," Form No.

172-221-80, Dow Chemical U.S.A. This document is a 29 page promotional brochure which principally describes shipping and packaging uses for Ethafoam. Therefore, the brochure has not been attached as an exhibit.- Unless otherwise indicated, all discussions herein refer to the product known as Ethafoam

( 220.

.__ . _ _ . . , _ . ~ . . , , - _ _

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for Testing Materials (ASTM). As can be seen from Exhibit 1 attached hereto, Dow has analyzed Ethafoam using ASTM Test 4 Dow has also analyzed Method D-790, D-3575 and D-3576 .

Ethafoam using ASTM Test Method D-1596.5 III. APPROPRIATENESS OF ETHAFOAM FOR MIDLAND SITE APPLICAT_ONS I As a result of the Licensing Board's inquiries about l

Ethafoam, on March 3, 1983, N.W. Swanberg of Bechtel prepared and mailed a letter to Dow asking for specific information l regarding this product. I reviewed the letter before it was mailed, and verified that items 1, 2 and 3 of the letter accurately characterize the conditions of Ethafoam use with respect to duct banks and piping at the Midland site. A copy On June 9, of this letter is attached hereto as Exhibit 2.

1983, Dow Chemical responded to Mr. Swanberg's letter. This 4 Exhibit 1 cautions that the typical properties listed are not to be considered specification values. As described below, with respect to Ethafoam 220, Applicant does not rely on the properties listed in Exhibit 1, and therefore does not require verification of these properties in its procurement documents. However, pursuant to Applicant's agreement with the NRC Staff relating to remedial soils work, all Ethafoam is purchased as "Q", which provides proper documentation esta-blishing that the material being supplied is in fact Etha-foam. Additional quality assurance requirements with respect to material testing and specifications apply to the purchase of Ethafoam 120 for the use described in Section III(H), below.

5 Source: " Designing Packages to Survive Shipping and Handling with Ethafoam Brand Polyethylene Foams," Form No.

172-221-80, Dow Chemical U.S.A.

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response is attached hereto as Exhibit 3. Dow's response highlights some Ethafoam cha'racteristics which are important to its use at the Midland site:

-- Dow has no performance history covering Ethafoam use for 40 years.6

-- While Dow has no specific performance history covering Ethatoam buried in the ground, Dow notes that the product has good resistance to acids, bases and salts. Long term contact with hydro-carbons, however, is not advisable.

Oxidation of Ethafoam can occur at ele-vated temperatures over long periods of time. Thus, while no oxidation would be anticipated in Ethafoam maintained at soil temperature of about 60*F for 40 years, the onset of oxidation might

- occur as early as one to three years in Ethafoam maintained continuously at -

165'F. Fully oxidized Ethafoam dis-integrates into a powdery form.

-- Ultraviolet rays from the sun will gradually deteriorate the surface of Ethafoam. However, no such deteriora-tion would occur in buried Ethafoam.

The following sections outline the specific soils-related uses to which Ethafoam has been or will be applied.

As will be seen, in most applications, the Ethafoam will not be exposed to elevated temperatures and will therefore not be subject to temperature-related oxidation. Moreover, in all soils-related applications, the Ethafoam will be buried and therefore free from ultraviolet light degradation. Further, i

6 Polyethylene plastic did not exist 40 years ago; this plastic has only been in wide-spread use for approximately 20 years or less.

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- the Ethafoam is not expected to be exposed to hydrocarbons.

In the soils-related uses described below (except for the use described in Section III(H), below), Ethafoam is used merely as a forming piece to create the equivalent of an air gap; the resiliency and cushioning properties of the Ethafoam are not relied upon.O Thus, potential temperature-related oxidation is of no consequence.9 7 There are several locations at the Midland site where large quantities of hydrocarbons can be found. However, in all except one of these locations, no Ethafoam is involved in a soils-related use. In the one instance, Ethafoam was used '

to wrap a diesel fuel line penetrating concrete. As is de-scribed in Section III(E), below, the Ethafoam was used to create a gap around the line during the placing of the con-crete, not for any structural purpose. The gap-would still remain if the Ethafoam were to degrade; thus, contact of this Ethafoam with hydrocarbons is of no concern.

8 During the course of oral examination on my testimony regarding Seismic Category I duct banks, I agreed with Judge Harbour that the purpose of Ethafoam was to " provide a crush-able material so that the duct banks would not be subjected to shear." Tr. 12025. This statement may be misleading without explanation. While I was being questioned, I was aware that Ethafoam is not relied upon in soils-related appi? cations to provide support. In my answer, I intended to convey that the purpose of the Ethafoam is to provide a zone of low resistance through which the duct bank could move before contacting an object in a manner that might create strain. I did not intend to suggest that the Ethafoam is used as a cushion.

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9 Applicant's investigation of these Licensing Board questions has uncovered an Ethafoam application unrelated to soils matters, where the plastic may have been relied upon to l provide support in an elevated temperature environment. Spe-cifically, two "O" spent fuel. pool pipelines which may operate at above ambient temperatures have been found to be wrapped in Ethafoam and encased in thick concrete shielding. These lines are currently being evaluated to determine the effect -- if any -- of oxidation of the Ethafoam. The situation will be reported under 10 CFR {50.55(e) if appropriate. -

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l A. Application: Between Building Foundation Wall and Fly Ash Concrete Backfill A 2-inch thick layer of Ethafoam has been or will be placed between the foundation of the service water pump struc-ture and circulating water intake structure and the low strength fly ash concrete backfill that is being placed in the excavation area to the north of these t'wo structures. The purpose of this application is to provide both a pouring mold

("formwork") for the liquid concrete and a space between the structure foundations and the concrete so as to allow for seismic movement. For this use, an air gap could serve the same purpose, so long as the gap were sealed to prevent the accumulation of foreign materials in the gap. The Ethafoam will be completely buried, and will be exposed only to normal soil temperatures (about 60*F); thus, no ultraviolet or tem-perature-related oxidation will occur.

B. Application: Surrounding Duct Banks Encased in Fly Ash Concrete Backfill A 6-inch thick layer of Ethafoam has been or will be used to surround portions of duct banks around which the fly ash concrete backfill is placed. This Ethafoam blanket stops where the duct bank gnters compacted soil backfill.11 The 10 See figure attached hereto as Exhibit 4.

11 See figure attached hereto as Exhibit 5. ,

1 purpose of this application is to provide a space between the duct bank and the concrete backfill at the point where the duct bank enters compacted soil backfill, thus creating a transition that will eliminate concentrated shear strain to the duct bank caused by differential settlement. The Ethafoam is not used to support the duct bank; a 6-inch air gap between the duct bank and the concrete backfill would serve the same purpose. Calculations have established that, in almost every instance, these duct banks can span the Ethafoam created gap without undue deflection or unacceptable strain; the concrete backfill supports the duct banks at one end while compacted soil backfill supports the duct banks at the other end. In the few instances where additional support was deemed neces-sary, supports were added at the interface between the duct banks and the structures which the duct banks penetrated.

The maximum anticipated soil settlement at the Mid-land site is 3 inches. Thus, the 6-inch Ethafoam gap will provide sufficient space to allow for the maximum predicted settlement at interfaces. In addition, the Midland site set-tlement monitoring stations will keep site personnel informed as to any settlement at these duct bank transition locations.

See, e.g., SSER #2, {2.5.4.4.5, Figure 2.11.

The Ethafoam will be buried and exposed only to nor-mal soil temperatures. Thus, no ultraviolet or temperature-related oxidation will occur.

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l C. Application: Surrounding Duct Banks Encased in Concrete Backfill at Building Penetrations l

l This application is a combination of the previous two. Here, the Ethafoam is used both to prevent contact be-tween the duct bank and the concrete backfill, and to provide a space between the building foundation and the concrete backfill 1 The discussions presanted with respect to the previous two applications are equally applicable here.

D. Application: Surrounding 26-Inch Service Water Piping Encased in Concrete Backfill A 6-inch thick layer of Ethafoam has been or will be used to surround portions of 26-inch service water system lines around which the concrete backfill is placed. This Ethafoam blanket stops where the piping enters compacted soil backfill.1 As with the duct banks, the purpose of the Ethafoam is to provide a space between the piping and the con-crete backfill at the point where the piping enters compacted soil backfill, thus creating a transition that will eliminate l concentrated shear strain to the piping caused by differential settlement.

This Ethafoam application is fully underground, so ultraviolet oxidation will not occur. However, the pipelines 12 See figure attached hereto as Exhibit 6.

13 See figure attached hereto as Exhibit 7.

are expected to reach temperatures of up to 109'F during nor-mal system operation, with temporary excursions to much higher temperatures in emergency conditions. It is anticipated that normal operating temperatures could lead to gradual oxidation of the Ethafoam within the 40-year life of the plant. How-ever, such oxidation is of no consequence, because the Etha-foam is not relied upon for support. Calculations have estab-lished that this piping is capable of spanning the longest Ethafoam-created gap without undue deflection or unacceptable strain; the concrete backfill supports the pipe at one end while compacted soil backfill supports the pipe at the other end. Pipe deflection is not expected under any postulated circumstance (including soil settlement and earthquakes) to exceed that available within the 6-inch gap between the pipe and the concrete backfill. Disintegration of the Ethafoam would leave a void between the piping and the concrete back-fill, and this void would serve the same spacing purpose as the Ethafoam. Moreover, the Midland site monitoring stations will keep site personnel informed as to any settlement at these service water piping transition locations. See, e.g., -

SSER2, {2.5.4.4.5, Figure 2.11.

E. Application: As a Form for Penetrations Through Concrete Block or Poured Concrete Walls-A layer of Ethafoam is placed around various Category I and non-Category I items that penetrate Category I.and non-

Category I interior walls, foundations or footings.14 The purpose of the Ethafoam is to provide a form around which concrete can be placed or concrete blocks can be cemented in place. When the concrete dries or the concrete block instal-lation is complete, a gap is formed around the penetrating ob-ject, thus preventing structural interactions betweens the penetrating object and the wall, footing or foundation. The Ethafoam is not used for support.

Some of the penetrating objects (pipelines, for example) are expected to reach elevated temperatures during normal system operation. It is anticipated that these temperatures could lead to oxidation of the Ethafoam within the 40-year lif e of the plant. Such oxidation, however, would be of no consequence. Disintegration of the Ethafoam would leave a void around the penetrating object, and the creation of this void is the very reason Ethafoam is used.

F. Application: Between Two Structures A 2-inch thick layer of Ethafoam is often placed be-low final grade between two adjacent structures.15 The pur-14 See figure attached hereto as Exhibit 8. This exhi-bit shows a concrete block wall, but this type of penetration is also made through placed concrete walls.

15 See figure attached hereto as Exhibit 9.

pose of this application is to provide a space below final grade between the structures so as to allow for seismic movement. (Above final grade level, Ethafoam is not used, and the space between the structures is usually greater than two inches.) For this use, an air gap could serve the same purpose, so long as the gap were sealed to prevent the accumulation of foreign materials in the gap. Because the Ethafoam is completely buried and exposed only to normal soil temperatures, no ultraviolet or temperature-related oxidation will occur.

G. Application: Between Soil and Lagging during Excavation i

Excavation work is currently taking place at the Mid-land site. As soil is removed during excavation, wooden planks, stamped steel sheets or steel tubing, commonly re-ferred to as " lagging," are placed against the unexcavated soil to prevent soil collapse into the pit. For the auxiliary building underpinning, Ethafoam 120 is placed between the cor-rugations of the stamped steel lagging and the soil so as to prevent soil movement after the lagging is installed.16 Thus, this is the one soils-related use for which Ethafoam is relied upon to provide support in any way. This is a tem-16 See figure attached herto as Exhibit 10.

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porary use, during which oxidation of the Ethafoam will not occur. After the work requiring the excavation is completed, the excavation will be filled with concrete or backfill with the lagging and Ethafoam still in place, thus preventing sur-rounding soil from collapsing into the pit. The buried Etha-foam will not degrade during the 40-year life of the plant, and would cause no undesirable effects even if it were to degrade.

Application: Spacing Between Certain i

H.

Buried Non "O" Utilities There are several locations at the Midland site where buried non "Q" utilities cross each other closely enough to make it difficult to properly compact backfill between the utilities. One such location is to the north of the circulat-ing water pump structure and ti service water pump struc-ture. At this location, the buried piping and utilities are being encased in the concrete backfill, which will prevent contact between the utilities. Ethafoam is not used to pre-vent contact between buries utilities at this location.

At other locations at the site, non "Q" utilities such as sewer pipes and pipes carrying water for fire protec-tion purposes are in close proximity where they intersect.  ;

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Here, blocks of Ethafoam are placed between the utilities to allow for proper soil compaction around the intersection.

(Ethafoam is not used in this manner for spacing between two "O" utilities or a "Q" and a non "0" utility. ) In each instance, the utilities in question are buried and operate at near normal soil temperature, so no ultrviolet or temperature-related oxidation of the Ethaform is expected over the lift of ,

4 the plant.

IV. CONCLUSION The above discussion has described the soils-related puposes for which Ethafoam has been used, and has demonstrated that Ethafoam is appropriate for these uses. No adverse ef-fects are anticipnted during the 40-year life of the plant from the uses that have been dencribed herein.

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TABLE 1-Typical Properties

• of ETHAFOAM Products ETHAFOAM ETHAFOAM ETHAFOAM ETHAFOAM ETHAFOAM ETHAFOAM 220 400 000 900 TYPICAL TEST 221 222 PLANK PLANK PLANK PROPERTIES PROCEDURE SHEET SHEET PLANK ,

bens h f.k D 5 kh swa a m y wa.c,..,, nmp li2,

.e a rg..g g 11 V f Con Size (MM) ........: s ASTM D 357s ..N.t!.L E d.di[/5 _' I #..) L Dow Modified .,g '_,;W W-23

%*=2.4 m!

Q= W=L; t2 Q.gf L

13 g  !

!{_se'4~'_s' * - cia *r* [m; 18 r

L .> _

i n wq. .. ,1 mgg.7~1 Compress.

, w.= g nreStrength 3

gy,e.y.m .s .q: -

~

' ;r .y n

gpig .4 m n~m,.;s.x?]-

g ,* , . ;-g.9.,3 p-e-J ,

g j (PSI) . . .. . . . . .....4

. ASTM D 3575 Test B - - j . W: h*

0 -.-"q g.3. p- . - -9A g .%.

'?" $3

% n t

? 15*4

.57 lr %-J e

1  ; et 5% *C - N 23 # 1 35 w W

!. ". 44 ~

' '. et 10% ).htbdh.'5 N k 8.5 17 48

• M^.E * '

'?

~*i a .'4

~4 ' at 25 % .'.7.'.W.'. . "'.D *3 i

• ,. M O k8M. 3 N' f 5

'8'. h 12f..7 - . ^* e-

- I~~,20"Nf  !' . 54, d]g

- 333 C 75 h1 i

. .. 15 wJ 6 15 h.3

.D',. ". E5..; 21 - J..c

.. - _ . . i - et 50 % . J7.*.D. . . . . ._ *j . ..

• ~. .b.

Compressive Creep

(% Deflection) . . . . . . . .~ ASTM D 3575 Test BB i

I, .'

f 7[J

' ~1 T. -)'

Loaded @ specified PSI f* . 3* .h <. Q .}' 3 static loed for 1000 hrs. t 4

<5 @ 3 PSI , <5 @ 4 PSt , <4 @20 PSI 757 ..... - -

} <5 <5@l.5

@.25PSI 160*F . .... .... ... -

PSI' <8 @ 1 PSI . <5 @ 2 PSI , <747 PSI '

. f, ' - l- ' I

- tr.h. Lt_50...: ',+-7 -*.-"' . N) ,I 30 " * .:l, Tensile Strength (PSI) . . .. ASTM D 3575 Test E . . . . . . . 80 e

. 100

. b.

...s..,.

85

..--..q.

. .J . '. 130 30 SG j 70 70 l 100 Tensile Elongation (%) ..... ASTM D 3575 Test E . . . . . 80 ' * - "

Tsar Strength (ib./In.) . . . . ., ASTM D 3575 Test 0 . . . . . . .,

30 s

l' 15

. 3. . . . 25 d.a30 ' .. , . .. .

50

, 3 I. - 300 500 ,,j 700 2 , 1100 .

Flexural Modulus (PSI) . ... ASTM D.790 .... ......

J, -

5540 5540 5560 53 58 5455 I Buoyancy (PCF) . . .. ... ASTM D 3575 Test AA ..... 5HiO t

Thermal Conductivity (BTU-in./hr.fL T)at 8  %*=03

~

0.4 0.4 0.4 75T meen temperature .. ASTM D 3575 Test EE . . . . .'. W-0.4 W-03 0.4 '

Method B  %'=0.4  %'=0.4 - l Thermal Stability

(% Shrinkage) . . ... . ASTM D 3575 Test F '

I Conditioned @ specified temp. with no load:

-1 A @1657 24 hrs . . . . . . . . ...... - -1 A @ 1857 -10 @ l65'F - 10 @ l651 -1 A @l65*F

-2.4 @ 165T -15 @l651 -1A @1657 -1A @ l65T 48 hrs . . . . . . . . . . . . . - - 1.5 @ 185 1 Source: "Ethafoam Brand Polyethylene Foam,"

Form No. 172-125-80, p. 7, Dow Chemical U.S.A. 7 SNNE as f

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. Bechtel Associates ProfessionalCorporation 777 East Eisenhower Parkway Ann Arbor, Michigan iQ7019 t u ,' amens P O Boa 1000. Ann Ardor.M Chiga,48106 March 3,1983 Dow Chemical Technical Service and Development Research Center P.O. Box 515 Cranville, Ohio 43020 Attention: Mr. Gary Miller

Subject:

Midland Plant Units 1 and 2 Consu=ers Power Company Bechtel Job 7220-101 ETHAFOAM DATA In reference to our telephone conversation on February 17, 1983, our client, Consumers Power Company, requires additional information

• regarding the behavior of your products Ethafoan #220 and #120 as follows:

1. All information shall be related to the plant life of 40 years.

2. The ethaform will be buried 6 feet deep at all times. Is there any chemical reaction during the period of the time encasing 30"$, 26"9 pipe and electrical duct bank?

3. Te=perature dif ference between 165F and 45F for pipe only.

Temperature around duct bank would be normal ground temperature (60F + 5F).

4. Hardening and disintegrating possibility of ethafoam during 40 year duration (underground).

5. Elasticity behavior (40 year duration) a) compressibility b) resiliency c) rigidity d) cushioning a) flexibility

6. Light stability (40 years duration).

7. Related test procedures, if any.

We will appreciate your cooperation in answering the above items to our client's satisfaction. We would like to have, if possible, the answers in 3 weeks.

t Bechtel Associates ProfessionalCorporation Letter to Dow Chemical Page 2 i070iS l If you have any related questions, please call Steve Hartstern at 813-994-7802 or Julian Berezanski at 813-996-3466.

Very truly yours,

/3 N.W. Swanberg Project Engineer - Soils hNS/JB/cs(SD) 03010402

/

cc: R.C. Bauman bec: L.A. Boccer ,

- J. Bere:ans,ki 'a.

B. Dhar S.C. Hartstern D. Lewis P. Shuns.ugavel N.W. Swanberg Written Response Requested: Yes Com Use: NA SMME Exhibit 2 -

(cont'd.)

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< =mev DOW CHEMICAL U.S.A.

June 9, 1983 cRANvut RESEARCH CENTER P.O. BOX 515 GRANVuE. Ohio 43023 Mr. N.W. Swanberg Bechtel Associates Professional Corp.

777 East Eisenhower Parkway P.O. Box 1000 Ann Arbor, MI 48106 RE: MIDLAND PLANT CONSUMERS POWER COMPANY You have inquired about the performance of our polyethylene foam products, ETHAFOAM* 220 and ETHAFOAM HS 120 over a 40 year period while incasing pipes buried six feet in the o earth You indicate a pipe temperatgre ranging from 165 F to 45 6F and ground temperature of 60 F (+ 5 F) . Specifically, you are interested in chemical reaction from the earth and physical property change. We do not have performance history under your conditions or for that length of time and cannot determine appropriateness of ETHAFOAM for your end-use.

However, to help you make that determination, we will comment on several points you have raised.

1) Chemical Reaction - The base plastic in ETHAFOAM is polyethylene which has good resistance to most chemi-cals such as acids, bases, and salts. However, long term contact with hydrocarbons is not advisable as property deterioration would result.

2) Oxidation - Oxidation of ETHAFOAM can occur at elevated temperatures for long periods of time. Onget of oxida-tion of ETHAFOAM adjacent to a pipe at 165 F continuously might occur as early as one to three years, gNo oxida-tion of ETHAFOAM adjacent to the earth at 60 F would be anticipated in 40 years. If significant oxidation of foam does occur, the material will gradually lose strength such as compression and tensile. Also, its resiliency will fall off - that is its ability to recover frog compression or flexing. Eventually, the foam at 165 F will disintegrate to a powdery form.

• Trademark of The Dow Chemical Company.

BMMM Exhibit 3 AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY

N.W. Swanberg j

June 9, 1983 '

Page Two I

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3) Light Stability - Ultraviolet rays from the sun will  ;

gradually deteriorate the surface of ETHAFOAM* in much i the same way oxidation affects it. However, no effect l would be anticipated in the buried condition. l We trust this helps in your consideration of our ETHAFOAM products.

Very truly yours,

~ 0' f' Gary M' ler Indus ial Foams TS&D jm cc: Julian Berezanski, Bechtel Steve Harlstern, Bechtel Jeff Lee, Dow, Detroit Sales l

SNME f - Exhibit 3 -

l (cont'd.)

4 1

Go CASE 1 - GENE RA _ CON 3 -~ ON l

BLDG ,

g . .

j o -FLY ASH -

CONCRETE COMPACTED SOIL

@ g 2"ETHAFOAM 220 g .. BACKFILL .. BACKFILL o

TO CREATE A E

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SPACE TO E

' M ABSORB SEISMIC 3 . .

MOVEMENT- l& .

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Exhibit 4

CA S E 2, - E _ EC-~ R CA _ JUC-~ BA N X

, -6" ETHAFOAM 220 I ( I COMPACTED 5 OIL

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.= .. BACKFILL 4 M M h 0 W NJ [ l [ )l 1

1. ELEC. DUCT BANK N j i

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[I Al}I N NdC[ll ,

M

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, .  : .. . FL ASH * * '

j [. CONCRETE.

., BACKFILLp o _

- 20 F T. -

- j_

o 6 e- .

e. e-b I

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me ammmmmmmmmmmma

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Exhibit 5

l

. l CAS E 3 - E_EC TCA_ JUC-~ BA N <

pFINAL GRADE

( ) I BLDG # COMPACTED SOIL BACKFILL % / f g g. .

- . o .. . .

,j e

, .N

~

T - -

2"ETHAFOAM /T[Jf jff] []o o.. /

220 TELEC. DUCT BANKu l

N[N5fl j_Ul l  ;

F'Li' ASH' CONCRETE .

BACKFILL .

. e,

- 16 F T. =

=

6" ETHAFOAM 220 l

BM M ~

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Exhibit 6

i CASE 4 - 26' O - 3C-15r'6, '9.-20.-53. -54, 41 ~~

f FINISH GRADE -55 &-56,,

.,. - COMPACTED SOIL BACKFILL-r

' FLY ASH .

a ,-[, oCONCRETE EMCKFILL .' ' .'D? -

• tE3fBlNEMMtlMROINlmlfJME i /

% -26"p PIPE

f. ; : .TM9ffWNX MRMRM25RMifd '

q., . - - .-

F.....:

. ..  : y ;..: ,

i: .s . . ... .

i 6' ETHAFOAM 4 O'- 0" m r muuumummmmmmmmmmmmmmmmmmmmma

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Exhibit 7

CAS E 5 - WA _L DE\ E' RATION (BLOCK OR CONC. WALL) l J /

/ (

T T

) /

f \

N I Y ETHAFOAM

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Exhibit 8

CASE 6 - BETWEE N TWO STRUC- UR ES FINAL GRADE S STRUCTURE STRUCTURE ps r

L i

s 1

a 2" ETHAFOAM 220 1

MM '

S

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Exhibit 9

t .

4 CASE 7 -

3E. N J

._ A G G N G b

SOIL -

Mg2 '"

MM sr I

. LAGGING ETH AFOAM 120

=* = SOIL LAGGING

l m mm

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Exhibit 10

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM

) 50-329-OL (Midland Plant, Units 1 ) 50-330-OL and 2) )

CERTIFICATE OF SERVICE I, Brian R. Gilomen, one of the attorneys for Consumers Power Company, hereby certify that a copy of the Affidavit of Dr. Palanichamy Shunmugavel on Ethafoam was served upon all persons shown on the attached service list by deposit in the United States mail, first class, this 8th day of August, 1983.

Brian R. Gilomen

O

- Frank J. Kelley, Esq. Ms. Mary Sinclair Attorney General of the 5711 Summerset Street State of Michigan Midland, Michigan 48640 Carole-Steinberg, Esq.

Assistant Attorney General William D. Paton, Esq.

. Environmental Protecti on Div. Counsel for the NRC Staff 720 Law Building U.S. Nuclear Regulatory Lansing, Michigan 48913 Commission Washington,'D.C. 20555 Myron M. Cherry, Esq.

Cherry-& Flynn Atomic Safety & Licensing Suite 3700 Board Panel 3 First National Plaza U.S. Nuclear Regulatory Chicago,-Illinois 60602 Commission Washington, D.C. 20555 Mr. Wendell H. Marshall 4625 S. Saginaw Rd. Barbara Stamiris Midland, Michigan 48640 5795 North River Road Route 3 Charles Bechhoefer, Esq. Freeland, Michigan 48623 Atomic Safety & Licensing Board Panel Dr. Jerry Harbour U.S. Nuclear Regulatory Comm. Atomic Safety & Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Commission Dr. Frederick P. Cowan Washington, D.C. 20555 6152 N. Verde Trail Apt. B-125 'Lynne Bernabei Boca Raton, Florida 33433 Thomas Devine Louis Clark j Mr. D. F. Judd Government Accountability Project Babcock & WilcoX of The Institute For P.O. Box 1260 Policy Studies Lynchburg, Virginia 24505 1901 Q Street N.W.

Washington, D.C. 20009 James E. Brunner, Esq.

Consumers Power Company- Mr. James G. Keppler 212 West Michigan Avenue Director j Jackson, Michigan 49201 Nuclear Regulatory Commission' Region III Steve Gadler 799 Roosevelt Road 2120 Carter Avenue .

Glen Ellyn, IL 60137 St. Paul, Minnesota 55108 Atomic Safety & Licensing

~ Appeal Panel U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 L

Mr. Scott'W. Stucky

! Chief, Docketing & Services U.S. Nuclear Regulatory Comm.

Office of the Secretary Washington, D.C. 20555

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