Text

Testimony of Gs Keeley Providing Sequential History of Events & Activities Re Soils Settlement Issues.List of Important Const Dates for Facility,Selected Soils Placement Activity & Affidavit Encl.Related Correspondence
	ML20004E850
Person / Time
Site:	Midland
Issue date:	06/04/1981
From:	Keeley G; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	;
Shared Package
ML20004E851	List: ML20004E850; ML20004E852;
References
	ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8106150390
	Download: ML20004E850 (21)
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                            ' ' y.;g=.2 This is th                      IkGilbertSKeeley.       I have been employed by Consumers Power Company since 1961.             I am currently Midland Project Manager. My present I            duties include workina on the Midland Soils hearing, reviewing the ' technical l

l aspects of the proposed remedial fixes and providing guidance to the licensing l l group on soils-rel.4 ed matters.

                                         -              In addition, I provide direction to Mid managers in the areas of design production, construction, testing andM                             ,. r i

administration of contracts. I report directly to James W Cook,

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l Vice-t-resident of Projects, Engineering and Construction. A t From July 1971 to March 1980, the date of the appointment of a Vice-P sg / %i g &s

         - for Midland, my Midland Project duties also included overall responsibility for licensing, design, construction, testing, cost analysis, scheduling and the administration of contracts between Consumers Power and its principal suppliers and of the contract between Consumers and Dow Chemical.

From November 1972 to July 1975 I was Director of Quality Assurance Services for nuclear and cunventional power plants' design and construction. In that capacity I was responsible for structuring and implementing the Consumers Fower Quality Assurance Program. From 1970 to November 1972 I was director of Electric Plant Projects Engineering. My duties included supervising a staff in various engineering disciplines involved in the design of nuclear and fossil power plants. This j staff also developed the technical basis for specifications issued by Consumers Power for the procurement of major equipment. 1 I also have held the following positions in the Consumers organization: From 1968 to 1970 I was a Supervising Nuclear Engineer with responsibility ,over a f ' staff of engineers engaged in writing specification's for the procurement of ts0681-0379a112 Sd 810615o @<

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       .   .                                                                                   2 nuclear fuel; from 1963 to 1970 I as a Nuclear Engineer; and from 1961 to 1963 I was the Startup Engineer at Consumers Power Big Rock Point Nuclear Plant.

From 1955 to 1961 I was employed in the Atomic Power Division of Westinghouse Electric Corporation as an engineer. From 1949 to 1955 I was an engineer at Pacific Gas and Electric Company, and from 1948 to 1949 I was a test engineer with General Electric. In 1948 I graduated from the University of Missouri with a BS in Electrical Engineering. I have taken postgraduate courses at the University of Idaho and the University of Michigan. I have held various positions La engineering societies and committees relating t l to my work. During the years 1964 to 1970 I was a member of the IEEE Nuclear Standards Group; from 1970 to 1975 I was a member of the ASME N45.2 Standards i Committee, which wrote QA' standards to supplement Appendix B to 10 CFR 50; and l from 1972 to 19 s Chairman of the ASME N45.3.13 work group, which wrote the QA standard on Control of Procurement. l I I an a Registered Engineer in the State of Michigan and a member of Tau Beta . Pi, the National Engineering Honorary Fraternity, and of the Michigan Society i of Professional Engineers. In this testimony I will provide a sequential history of events and activities relating to the soils settlement issues at the Midland Site. My overview will , I cover important events and activities in various areas, including quality assurance, communications and meetings between Consumers and the NRC Staff,

1. .

f construction activities and events at the site, design activities, and managerial decisions. In addition, I will address certain specific ts0681-0379a112

                      -                                                          -.-_-L-..--.--

l' , contentions of Barbara Stamiris, including example 8 with asspect to Stamiris Contention 2, set forth in Stamiris' Response to Applicant's Interrogatories, dealing with " failure to excavate loose sands as committed to in the PSAR,"

          .,                  .and example 9, alleging that " installation of preload instrumentation was fgr p :-

subject to time pressure assoc. (sic) with f ;ost protection considerations." A chronology of some of the important dates regarding the construction of the a, liidland Nuclear Power Plant is set forth in the attached Keeley Exhibit 1.

   .o As set forth in the attached Keeley Exhibit 2, the placeser.t of the soils M

underlying the Diesel Generator Building ~begn in October 1975 and concluded in October 1977. From the start of the soils placements activities to Julf

          "             ~~

1978, when the soils settlement was observed, NRC Inspection and Enforcement

      .C M                         Region III made periodic inspections of site construction activities,

'f On Ifarch 26,1973 'Ae !!idland Atomic Safety & Licensing Appeal Board (ALAB) l .M . issued mencrandum and order ALAB-106. The requir-Inents of ALAS-106 were, . lB " Ne among other things, L .. '

     ,.                        1.      On the first day of each calendar quarter, reports be submitted to the lj                                      regulatory staff on constr9etion work to be performed during that quarter, containing names of QA Supervisers and engineers of both applicant and the architect-engineer wh2 will be on-site during the period covered by the J.'.porti
      .                        2.      A statemenc of QA qualifications of each individual named be supplied;

3. On a monthly basis, nonconfonnance reports covering previous month's work be forwarded to the staff, with enough detail so that the reasons for the discrepancies, if any, will be apparent. .

   ,,,                         ts0681-0379a112

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The Board requested that copies of all reports be forwarded to it by the Staff on a timely basis, together with any comments that the Staff may have. The Board further stated that it, expected that the Staff would closely monitor the activities of the applicant and architect-engineer. The reporting requirements of AI.AB-106 were in effect during the entire time of the soils placement activities.

 'I} ]lj Consumers Power has complied with all the requirements of ALAB-106 since its

9' In fact, all of the Consumers Power nonconformances (QF's) and.

issuance.

 -:i,;;f Bechtel nonconformances (NRC's) mentioned in the Soils IE Investis'ation Reports No. 50-329/78-20 and 50-330/78-20 had been provided to the Staff and Region III the month following their issuance. However, prior to the release
            .a: '-
          ; ,Q, ,                               on March 22, 1979 of the results of the NRC's soils investigation, (i.e.
  .wW.

G, Investigation Reports No. 50-329/78-20 and 50-330/78-20), neither the Staff Mjd.). _l. = nor Region III had made any comment or suggestion whatsoever to Consumers i'M . Power or Bechtel thati adequate corrective action had not been taken taith n ,'<,1

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respect to soils nonconformances.

    '15                                                ..

In August, 1977, Consumers Power became aware of settlement of a grade beam for the Administration Building, a non-safety related structure. 1 Investigation indicced that in the affected area the fill had been compacted

          '                                      to a value lower than that required by the specification. It ns determined
               *             -                -  that- the testing contractor, U S Testing, had selected lower maximum i'                  a                             laboratory dry Jensity standards than were appropriate, which resulted in an I

indication that the soils underlying the grade beam had been compacted to s greater than 95% of optimum. In actuality, such soils were compacted in a

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range of 83.1% to 90.5% of optimum. ,. - Y ts0681-0379a112 _.m._ _ . . .-._. m ., - - _ . ,._ _ . _ _ , _ . , ,_ _

                                                                    .                                                                                                   5 i
        %s The fill in this area had been placed and compacted with large equipment, after which it had been partially excavated to permit placement of concrete for the steam tunnel and Administration Building. Of a total of seven grade
   .a-CT.

M beams in the area, only one exhibited settlement. The inadequately compacted soil under the columns supporting the failed beam was removed and replaced

  '           ;                               'with lean concrete.

m . s.

g. ,7 To determine the extent of the poorly compacted fill, the two adjacent grade

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beams were load tested, with no indication of problems. In addition, from

$$k'.                                           September 27, 1977 through September 30, 1977 two borings were taken in the
        -M area of the grade beams, one boring in the diesel generator building area, and
                            ~~

one boring near the evaporator building area. The latter two borings

   ' n.V                                         1ndicated no problems in those two areas. Based upon the results of this ggf;;

t- investigation, the nature of the failure and the information available at the

   -                                             time, it was concluded that the grade beam failure was localized.
 .j%['                                           Shortly after that determination, construction of the Diesel Generstor

! ...' Building began with the sump concrete pour in October 1977. l : ?- . E As stated in FSAR Section 2.5.4.10.4, structural settlement measurements were i

   * .;.[.y V-to be monitored to provide a history of time-movement in order to verify v.

b,_'* e settlement predicted by analysis. The details of the survey frequency are n-

 '                                                                                                                They basically consisted cf survey
                             .                    describ_ed

_. . . in FEAR Section 2.5.4.13.2. E .: measurements for Seismic Category I and II structures every 60 days during construct. ion and every 90 days during the first year of operation, with an

1. . +c-e evaluation to determine frequency fer subsequent years. For Seismic Category M I and II tanks, survey measurements are called for after the tanks are ww.P/4 .-

installed anI prior to hydrostatic te. sting, during hydrostatic testing, aft'er h- hydrostatic testing with the tanka empty, and after filling of tank for

A;;.c.; . . h% ts0681-0379a112 L... s.:. . ' * ?j ' ,

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 ~-                                                                                                       6 7
  ',-                      operation, with an evaluation of previous data to determine frequency during subsequent years.

In July 1978, during routina monitoring of structures for settlement, it was ym. 4:.,

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found that settlement of the Diesel Generator Build 2ng was in excess of that which would have been expected. Accordingly, on August 21, 1978 a 4 Nonconformance Report was issued; on August 22, 1978 the NRC Region III u . ..- Resident Inspector was notified of this potentially reportable condition; and v;. on August 23, 1978 construction on the building was placed on hold. . ,.? ([ As of August 23, 1978 55% of the concrete for the Diesel Generator Building had been placed, with the walls in place to an elevation of 30 feet above

  ..,                      grade, the generator pedestals poured, the mud sat poured inside the building,

.. s m g the e,lectrical duct banks placed under the building with horizontal and m vertical runs completed, the underground piping in the area under and adjacent 7]) 7 s (T23 to the building installed, and all backfill placed to grade level. .w d;h. On September 7, 1978 the NRC Region III Resident Inspector was notified that .:.. r Consumers Power had determined that the condition with respect to the Diesel ,.- Generator Building soils was reportable per 10 CFR 50.55(e). This was based on the fact that analysis o: soil borings started on 8/25/78 showed that compatcion of soil was significantly less than was measured during initial placement of the fill. Commf.ttaents were made to provide a formal report by

   },-                     October 7, 1978.

-{ On September 29, 1978 ine first 50.55(e) report was issued with the following recommended actions: 5- ts0681-0379a112

           ~.
               ,-                                                                                                           7 I

1. Determine the amount of settlement of the diesel generator building and increase the frequency of foundation survey measurements to. find if the settlement is or will be excessive.

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2. Determine the cause of settlement.

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3. If the settlement is or will be excessive, determine what actions are required to correct the condition and preclude' recurrence.

e These recosamended actions were implemented. In addition, a boring exploration a' and testi'ng program wh:tch had been initiated on 8/25/78 to provide better definition of the fill couditions under the building and to obtain soil

samples for laboratory tests, was continued.

.g                     .

subsequent to the issuance of the initial 50.55(e) report on September 29, 1978, there were additional 50.35(e) reports transmitted on Novesi,er 7, 1978, December 21, 1978, January 5, 1979, February 23, 1979, April 30, 1979, A [ June 25, 1979, August 10, 1979 and September 5, 1979. These reports were

[ provided to inform Region 3 and the NPJL Staff of conditions relative to the settlement, investigative actions, remedial actions proposed or implemented, and mate. rial presented to the Staff in a meeting of July 18, 1979 which con- , sisted of conceptual designs for the remedial activities. Following discovery of the settlement problems, initiation of the exploration and testing program, and issuance of 50.55(e) reports on September 29, 1978 and November 7, 1978, the NRC Inspection & Enforcement Branch conducted an investigation in December, 1978 and January, 1979 and held meet.ings with 7 Cousumers Power Management in February and March 1979. Also shortly after,the settlement problem was discovered, a Task Force made up of Consumers Power,and Bechtel personnel was formed to resolve the technical I .~ t 0681-0379a112

           *-    - *'     .-_._-__,.J-"7.,_,..,.,.;._...,,..J...*.._,_,.*._*"'"**._____,_._____.

 ..s...                     ,

8 I I issues rc',ating to foundation soils. In September 1978, Des. Ralph Peck and Alfred Hendron were retained as consultants to assist in the evaluation of data and feasibility of corrective actions. On September 28, 1978, a site H *d $a visit was made by Dr. Feck to acquaint him with general site conditions, settlement observations and preliminary findings of the exploration and testing program. In October 1978 Dr. Woods of the University of Michigan was i

             -                     retained as a consultant for interpretation of dutch cone penetration tests                                      !

and Mr. Dunnicliff was retained to assist in developing a soils monitoring

,4

' . i. J program. The first major issue facing the task force was to determine what was to be r ' done about the diesel generator building settlement problem. After a careful

consideration of alternatives, the task force, upoa tie unanimous reconsenda-6M tion of the consultants, decided upon the " pre-load" or " surcharge" approach.

ir.-,. This involved placing a layer of sand over and around the soils under the

 ]   ..

4 diesel building foundation. The additional weight of this sand would

 ~.**".2 l
           ;                       accelerate the consolidation of the soils belcw the building foundation. The 1 vs.

technical basis for the proposal will be fully described in the testimony of ? :;

         .i
        ,--                        Dr Ralph Peck.

The task force's recommendation w s adopted by Consumers Power management. The task force also advised that construction work on the diesel generator

'~

building could resume, since the additional structural weight thereby produced would enhance the effectiveness of the pre-load. Management concurred, and con- wetion of the diesel generator building resumed. f'" While the various remedial options were being considered, a field engineer recommended, and the task force decided, that certain instrumentatic,n associated with the proposed surcharge be installed prior to the placement of ts0681-0379a112 _____ __ - - . _ , _ . _ _ .-. __,- ._ ~ . -- _ _ . _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . _ . _ - - _ . _ . _

t i 9 frost protection. The so-called " frost protection" consists of the placement of a thin layer of fill over existing grade to protect lower layers from freezing, a necessary first step in the preload process. Because some of the a instrumentation to be installed in connection with the proposed surcharge required excavation or sub-surface installation, it was advantageous to install such instrumentation prior to placement of the frost protection layer. While some of this instrumentation was installed prior to the final decision in favor of the surcharge option, the instrumentation involved only minimal , . . Y.

   ^                                                       cost and had no effect on the choice for remedial action. This responds to example 9 in Stamiris' answers to Applicant's interrogatories.

The monitoring program recommended by consultants was implemented by site )Y- surveyors and included measurements of 29 settlement markers on the Diesel Generator structure and pedestals. Twenty-nine soil borings and 13 dutch cone

    @                                                      penetrations were taken in the area of the Diesel Generator Building. Soil 5
  .d                                                       borings were also tak n in other plant fill areas.         ,

Several meetings were held with the Staff and, later, with their N .sultants to inform them with regard to planned remedial actions. In addition to the

      -                                                    meetings with the Region III IE personnel previously referenced, there was a j

meeting on-site December 3 and 4,1978, attended by Dr I.yman Heller, the NRC's chief geotechnical reviewer, Darl Hood, NRC Project Manager, other NRC p2rsonnel including representatives from Region III, Bechtel Engineers and Consultants and Consumers personnel. At that meeting, the history of the soils problem was reviewed, the site exploration program was described and

    .y                                                      various aspects of the recommended pre load-option were described and l

discussed. i ts0681-0379a112 h

10 Instrumentation installed at the site prior to the placement of the surcharge included piezometers, strain gauges for. crack width measurement, borros anchors, and settlement markers. In addition, profiling of underground piping A :t was carried out both before and after the surcharge placement. T~h On January 26, 1979 application of the surcharge to the Diesel Generator Building was commenced. Application of thu first ten feet of fill material was concluded in approximately 25 days. On the advice of Dr Peck, placement was then stopped for a period of approximately two wesks in order to observe -

   .s instrumentation. Application of the surcharge then recommenced and continued for approximately 25 additional days, at which point the surcharge height nached its maximum level of 20 feet. The surcharge remained in place at its Ini                            maximum level from April 6 to August 15. During that period inste                                         station Qif -                           (piezometers) and settlement markers were observed to determine the j.

'i effectiveness of the surcharge. Based upon a review of data by Drs Peck and Hendron, the surcharge had carried out its purpose by August 15, when removal J.] 2 I was started. The removal operation was completed by August 30. ! ' f. The settlement data for the Diesel Generator Building and pedestals as well as plots of borros anchors, settlement platforms data, preload intensity data, piezometer readings and cooling pond level readings was provided to the NRC in 50.55(e) reports. This information was alt.o provided, in part, in answers to

               '                          ~

50.f4'(f) questions, and in meetings with the NRC. I In January 1979, settlement data, including that of the new monitoring program l observed to that'date, indicated that with the exception of the Diesel ! Generator Building and the pedestal (which had total settlements of 3-3/4" and 4-1/4" maximum, respectively), other structures had minor settlements. This was based on a foundation data survey program that had been expanded from that ts0681-0379a112

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

t 81 committed to in the FSAR to provide an increase in foundation settlement points from 69 to 180 with the additional points being for structures located

  .,                                          on plant fill. The measured intervals were decreased to 7 days on the Diesel

= .. -.

'~

Generator Building and 14 days on other structures on plant fill. The 60 d2y period remained in effect for other structures. In the spring of 1979, additional borings were taken at the Midland Site. 3g; Based upon the results and analysis of borings, which were provided to the NRC r :.i.; via 50.55(e) reports, 50.54(f) responses, and meetings, it was decided tha't

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remedial action thould be taken for the overhang portion of the Service Water Pump Structure, the Auxiliary Building Electrical Penetration Areas, and the

   ,o                   .--

Feedwater Isolation Valve Pits. Initially it was proposed that such remedial

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   'f'                                        action would consist of chemical grouting to stabilize medium dense sand areas as discussed in the 50.55(e) report dated June 25, 1979, as well as the use of
  .a

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piling for support of the overhang portion of the Service Water Pump byjj - Structure. Seismic Category I tanks located on fill were to be filled with "3. water and monitored for settlement, although the' boring program indicated x

adequate compaction af the soils under the Borated Water Storage Tank ("BWST")

  ;-i ugw                                     and Emergency Diesel Fuel Oil Storage Tanks.
 $.o On March 21, 1979, the NRC Staff issued an initial 10 CFR 50.54(f) request for information.        Subsequent requests were issued on November 19, 1979; June 30, 1980; August ',+ 1980 and August 27, 1960.                                                          Consumers Power has responded to these questions during a period from April 24, 1979 through the present.                                                             On February 7,1980 Region III was notified that due to the fact that 50.54(f) yy                                          questions had been submitted and since an Order modifying the Construction G<

Permits was sent to the Company on December 6, 1979, there would be no further

 . .                                         50.55(e) reports. Further information would be provided via responses to

' ' 'i.~ . 50.54(f) questions.

 =14 ts0681-0379a112 1

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u. ee+w~-y. .-,y-p,--y.-- - , -+m#y#--,,,-g,9%p w , gw_

12 At a meeting on June 18 and 19, 1979, Censumers Power Consultants, including Peck & Hendron, cecommended that the site be permanently dewatered, since it

;               was recognized that there f.ere potential difficulties in assuring that grouting would reach all sand pockets.

On July 18, 1979 a meeting was held with the Staff during which they were informed of the following: ,1

1. Options considered to correct the various soils issues.

1

2. Results of the investigative program.

3. Settlement monitoring program including effects of surcharge.

4. Decision to implement site dewatering.

5. Remedial Work in Progresa or Planned f (a) Diesel Generator Structure -

i (b) Service Water Pump Structure . (c) Tank Farm

(d) Diesel Oil Tanks (e) Underground Utilites (f) Auxiliary Building and Feedwater Isolation Valve Pits (g) Liquefaction Potential (h) Dewatering

           ._    __~ _ . _       _.

6. Analytical investigations (structural, seismic, soils) ,

7. Statement by Dr. Peck on adequacy of remedial action.

8. Schedule for remedial activities.

9. Cause investigation. ,

10. QA/QC corrective actions, ts0681-0379a112

13 I . The information presented to the Staff was then formally transmitted in the 50.55(e) report dated August 10, 1979. g On July 31, 1979 the NRC Project Manager, Darl Hood, stated to Consumers Power that the positive aspects of the July 18, 1979 meeting were the proposed

  "-~                 design fixes. It was the consensus of opinion of Consumers Power and its Consulu nts that the NRC Staff had accepted the conceptual designs proposed
 . i.
  ;7 and discussed to that date, and that there were no major problem areas.

On October 16, 1979 Consumers Power Company was informed that the US Armv Corps of Engineers was to assist the NRC Staff in their review. On February 26, 1980 Consumers Power was notified that the Navy Weapons Center would also

r. be' assisting the NRC Staff, and on February 29, 1980 Consumers Power was ll;'.

fy informed that ETEC would be assisting the NRC Staff, as well. After engaging consultant assistance,'the NRC aske,d Consumers Power to advise - M . the Consultants of the history of the problem, activities accomplished and planned remedial actions. Meetings for those purposes were held on November

..e .

        .             14, 1979; January 16, 1980; February 27, 1980; arid Tabruary 28,'1980.                                  In the
, .I, latter two meetings, Consumers informed the Staff that it had elected not

' I-l proceed with further remedial actions until NRC Staff approval was secured. This was done voluntarily and was not mandated by the Order issued by the NRC _ , _ Staff on December 6, 1979. Included in some of the documentation and in some of the meetings listed above was the subject of the cause of the excessive settlement. The causes and corrective actions are described in detail in the answers to 50.54(f), r- ) Questions 1 and 23. Corrective actions taken on these causes as well as other ' quality issues are discussed in detail.in the testimony of B W Marguglio. e e 9 bI ts0681-0379a112

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

                           ,                                                                                     a     14 l

l A meeting was held on 9/27/79 between Consumers Power and NRC Management to discuss upgrading of the plant to incorporate the results of TMI-2 and general 4 r .. . licensing critical path areas. Consumers Power was then informed that there M.. . b., _. were problems with NRC resources and that NRC Project Management had been

urging the NRC Technical Staff to take a position with regard to the status of technical review in the soils area, but had so far been unsuccessful.

i- A 50.55(e) report dated September 5,1979 indicated that the preload had been successfully completed. There had been essentially no settlement during the' j: previous six weeks, as shown on figures attached to the report. Sufficient data had been obtained to allow prediction of long term settlement by extrapolation, and preliminary calculations indicated that residual settlement

  ,       /

due to secondary compression of clay would be less than one inch over 40 years. In a 50.55(e) report dated November 2,1979, it.was indicated that the settlement monitoring of the Diesel Generator Building and pedestals would be

        .~
  %Q                              changed from once a week to once a month until January 30, 1980, after which I

[ monitoring would be carried out in accordance with the regular foundation data survey program as described in the FSAR. w

              -                   On November 19, 1979 the Staff sent 50.54(f) Questions 24-35 which concerned dewatering, site specific seismic spectra, structural analysis, settlement of the Diesel Generator Building, crack analysis load testing of the borated water storage tank and additional exploration, sampling, and testing to

( , determine soil properties resulting from the preload program. These questions were received on November 26, 1979. On December 6,1979, prior to the time l

               .                  for response to the latest 50.54(f) Questions, an order was issued modifying l~                                 tue Midland constructica permits.           In part the order claimed that, "Several of the Staff's requests are directed to the determination and justiflcation of acceptance criteria to be applied to various remedial measures tak'en and ts0681-0379a112

15

I proposed by the licensee. Such criteria, coupled with the details of the remedial action, are necessary for the Staff to evaluate the technical adequacy and proper implementation of the proposed action. The information c:a 7J. provided by the licensee fails to provide such criteria. Therefore, based on a review of the information provided by the Licensee in response to Staff questions, the Staff cannot conclude at this time that the safety issues associated with remedial action taken or planned to be taken by the Licensee to correct the soil deficiencies will be resolved." It had been assumed by Consumers Power that answers to 50.54(f) questions, as well as the information provided in 50.55(e) reports, were adequately responsive to the information the staff required for technical adequacy. On December 26, 1979 Consumers

 , [,                                            requested a hearing. Since requesting the hearing, additional 50.54(f) 2.s questions were issued by the Staff on June 30, 1980, August 4, 1980 and 33 August 27, 1980 and additional answers and information have been provided by i.

fy. , Consumers Power. Substantial information has also been provided to the Staff

in subsequent meetings and via various discovery in connection with the

>y.p hearing.,

A letter ou October 14, 1980, from R C Tedesco of the NRC Staff advised I g. , Consumers Power of a changed Staff position with respect to the criteria to be l: ,{

t. sed for the seismic review of the Midland Site. Since that time Consumers Power and the Staff have conducted several meetings in which Consumer's Power has presented its proposal to meet the Staff criteria. The development of that proposal, the so called site specific response spectra (SSRS), has been described in detail in Consumers Power Motion to Defer Consideration of Ypj Seismic Issues. At the prehearing conference on April 27, 1981, the Staff and c.g Applicant agreed upon, and the Board approved, a method.for considering the seismic aspects of the proposed remedial action. Information on this subject N ts0681-0379all2

       ..-..                          .- .               7......
                                                                   . . . - .    . . . - - - . . . . - . .   .. -          , . .                  m           .

                                                                                                                                                                                                             ~              ~

16 4 has been provided to the Staff, and meetings on the subject have been, and will continue to be, held. hI Another area of discussion between Consumers Power and the Staff concerned Staff on June 30, 1980. a request for additional borings, submitted by th.: Consumers This subject is discussed at length in James Cook's testimony. Power is presently in the process of taking the borings requested by ths C Staff, results of wLich should be available in July,1981. 15Af . I will now address an " additional example" in connection with Stamiris' .s -- - Contention 2, which alleges that " financial and *ime pressures have directly and. adyersely af fected resolution of oils settlement issues." I h.:GJ The " example" provided by Stamiris in her response to Applicant's s g.

-. ?g l.9       -A                                                            Interrogatory Number 2a, was "the failure to excavate loose sands as
'                                                                      committed i;o in the PSAR."                                                                    I disagree with this allegation, for the "1

7.N -

following reasons:

 .s                                                                                                                                                                                         ,

On2[24/7,8theNRCissuedanFSARquestion,#362.2,relatingtoaPSAR l, y, commitment to remove naturally occurring loose sand, if any, from beneath A review of relevant Class I and certain non-Class I structures. documentation fa2. led to show that the commitment had been met in all areas

                                   ~ ' ~
                                                                      %Y a fesult,                    Consumers Power took steps, including an analysis of borings, to insure that loose sands were not present; and documented its results
  .                                                                                                                                                                                                   It was concluded, for the NRC in the response to FSAR Question 362.2.

based upon analysis,'that the naturally occurring sands at the site met

 ,s. (                 .
         ~I                                                               density requirements except in a few isolated lenses of no significance to Category 1, Structures.                                                                  The mat.cer was discussed with the NRC Geotechnical Section on April 10, 1979, and was considered a closed issue.

.T~. es0681-0379all2_. _ _ _ _ _ _ _ . _ _ .. v -y .

                         ,---g.w--         ~ ,c-w%,,,,m,.,www-.--g--g               v--e.--g.sv,.e-y,wyr-+,-cw--n---y---tewwyr -ywwp.wnwy,e--e-e,-g,,y-yw,i-w-y-t,.-g                         -e-wes-   9e.g-w.gway y 9ece,wq--nym a pes       c- y   ---g*g+ wwwe

17 l The above information demonstrates that the resolution of the loose sands question had no relationship whatsoever to " financial and time pressures" On the contrary, Consumers Power took the necessary steps and incurred the necessary expense,'both in money and time, to insure that a satisfactory technical solution was acheived.

      -l:                           Conclusion                                                                                                                              -
';O5:

d -- The above rendition of events and activities at the Midland site demonstratcs , hd5 the tremendous expenditure of time and effort on the part of Consumers

         .--                        and Bechtel to satisfactorily resolve soils issues. This overviews while
    .                  . . . .      it does not . cover every meeting, event or canssunication, does cover the
            .4         .            highlights, and does provide a basis for putting the issues dealt with

~+

f,f in other testimony in proper perspective.

52. -

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  .w;s                       .

1 F ;- ' l ,~. l t p. (. , ' q ,~ es0681-0379a112

Keeley Exhibit I s.L The following are some important dates regar m s the construction of the

 ?                     Midland Nuclear Power P1'a'at:

Event Date PtaR transmitted to AEC-DRL for early review October 31, 1968 A Application for construction permit filed with Januarv 13, 1969 l} Atomic Energy Cc mission \ n .' 1 Construction permit hearing begins December 1, 1970 .

MIDLAND PROJECT ) ,, Selected Soils Placement Activity

y- -

Starting Completion Date Date ;[. Q-List Soils Placement Lit #5 Structure ' L's ~ Auxiliary Building electrical penetration area December 1974 November 1976 Tank Fars Area *- - (Borated Water Storage Ta=ks) September 1975 August 1976 i4, Service Water Structure L,4.. Cantilever Section November 1976 June 1977

T*

J Diesel Generator Building October 1975 October 1977 gf w.*$ ! .:? Non-Q-List Soils Placement 19 ' July 1969 October 1975 T. Dike - ~ 2 June 1977 Administration Building May 1977 , 'n i 6- 1 "Q-list soils placement" shown is soils placement for' support of the structure only. 2 Based upon an attachment from a letter, J F Newgen to M D Edley, dated - February 1, 1978.

=.

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ML20004E850

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