ML20126F855

Objects to Util 810119 Discovery Reply.Util Did Not Adequately Respond to Requests for Documents Re Soil Settlement Costs,Addl Borings & Administration Bldg Settlement.Related Correspondence

ML20126F855
Person / Time
Site:	Midland
Issue date:	01/26/1981
From:	Stamiris B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20126F851	List: ML20126F849 ML20126F855 ML20126F858
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8103200567
Download: ML20126F855 (5)

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gy;1TED COMPONDENCE U.g. NUCIE.AR REGUIATORY ' COMMISSION ,

In the matter of Locket No s. 50-329 OM OL C.P.C.. Midland Plant 50-7?O Ok' OL Units 1 & 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD INTERVENOR RESPONSE TO C.P.00 1/19/81 DISCOVERY REPLY FOR NOTICE OF THE BOARD 1/26/81 In the intreet of moving forward with substantive issues,I will hereby set forth my objoetionsite Consumer's reply informally. I have mise included clarifying and fellow up questions to my 12/4/80 request, y

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(Instructions and definitions as stated in 12/4/80 request) 8' DOCKETED

% USNPO PERTAINING TO DOCUMENT REQUESTS -

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1. nesponse is satistantery.

2. Response is incomplete. N ,

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m) What are the most recent estimates for total soil settlement oests (includin6 various completion sehedule paths) assuming current remediation proposals are mooeptablet b) Pleave exp1 min these estimates, breaking them down into their component parts.

c) What are the most resent estimates for total soil settlement costs if Removal and Replacement after Preloadin6 (Option 3) (50-54f#21) were new

! necessary?

d) Will any portion of these soil settlement oosts be ineluded in requests before the Michigan Public Servise Commission as a part of eenstructies oests '* '

& oests to be ultimately included in the ratabasef

• e = G e. 4e e .. w y, 810320056%

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I l .. m e) If the answer to d) is yea,p1' esse desoriBe and explain such anticipated reque sts.

3. Response is ineemplete and doouments provided de not respond to the intent of the request.

I reauested d&4umentation of"all-discussions concerning and leading up to C. P. C#! s deoision to appeal the IRC reauests for additional berings,".. net of the appeal itself, enee the final deeision had been made.

The meeting summaries and note 6 provided did not ?3ver these preliminary analysis as requested.

I would consider any meeting notes or other communications en the subject of additional berings during July and August 1980 to be relevant to my recuest and disoeverable(nocerding to the parenthetical discussion at the an)Order)tappor+

Conferense in end of item 2 page 6 of the Ooteber 24 1980 Frehearin6 3mped $ my 3

eenktmen :.e.

Iwould ask that any objoetiens to produ4ing suah deouments be spesifically stated and explained.

4. Response is ineemplete.

I rerruested deoumentation of any dieeussions or considerations of possible lawsuits b2volving soil settlement matters'.

One dooumont was provided. Please state and explain the trivelege or objection by which further dooumont requests are here refused.

5. Response is entisfactory that no such documents exist.

I requested documentation of "allaeptions ever eensidered (whether formal or informal, tentative er semplete) for eerreetion of the Administration Building settlement". '

a) Why are there ne records er desuments eeneernirs eerrestien efddministratim Building settlement (including the chosen option)7 b) On what basis was the decision to remove and replace the faulty fill under the Administration Building madet I

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1 e) who made this (Sb) decisient d) When was this (6b) decision madet e) Describe and explain any alternative eerrective actions ever considered and j rejected for the Administration Building,1f such sensiderations were made. ,

l FERTAINING TO INTEREDEMRIE8 1

I am acting en the und' erstanding that responses to disoevery requests are to be researehod with the intent of finding answers,1f they exist to questient pesed. I do not consider to be adeouste an individual response  !

l made"to the best of our present knowledge, recollection, and belief" which makes no attempt to review the period in cuestion,or include the responses of persons involved, (

1. Response to la is satisfactory.

heauest Ib asks""Who makes the final decisions en which actions are taken or will be taken.f In sentence 2 define the phrase " depending on its importance" more precisely.similarly define the phrase"in the case of decisions of lessor ir:portance" in the last sentence. What criteria d4iftne "importance" warranting )

l management review in each instaneet '

f e) were any decisions of the Bechtel Project Engineer on soil settlement matters later modified by Bechtel er Censumer's Project Management Review?

l Please describe and explain any such decisions and modifications.

2. Response is incomplete and does not respond to the ouestion asked.

hequest 2a asks "Did your consultants ever differ in their recersnendations on soil settlement matters (including tentative stages)f I am particularly intreated in differing opinions of consultants Peck a'ad in tentative stages or " minor differences ef opinien" to use your Wen'dron words.

F a) Did you communicate with consultants Peek Bendren er Gould asking their input in response to this question as your answer impliest Please provide desumentation of any such requests , giving the date of the 6

request.

b) What is the working relationship of censultants Peak,Hendron,and Gouldt o) Did censultants Peak and Eendron ever differ in recesmondations or

- approaches to actions oeneerning the Electrieal Ducts; Turbine Building., removal,ef-prateady use of gratingst grouting of gaps; the mud mat foundation;er any other e actions eeneerning the effects of the preload'.or other remedial actionst d) If the previous answer is yes,what were these differences,and how were they rc u.. .vt re solvedt (Original request 2a)

3. Response is inoemplete and does met respond to the parenthetical qualifications of the reauest.

Reaue st sa asks "What,1f any, eriginal receamendations of censultants (whether formal er informal, tentative er oemplete) were later changed er not followedt a) In responding,please address,but de not limit your response .te; the feMowing items: 1) Timing of eeeling pond filling in relation to placement of preload 1

2) Breaking up of mud mat l

3) Greuting of gaps between footings and mud mat (D.G. Building)

4) Use of gratings (D.G. Building)

6) Cutting of eendensato line

6) Turbine Building stres ses -

7) Berings in cooling pond dike area b)(as in original request) Explain the reason for such changes or departures e.(exceptin6 ohan6e from greuting to permanent dewatering).

I o) (as in original request) that was thodecision making process for each' of such changes er departures?

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