ML19331A844

Affidavit Re Const Status,Costs & Prerequisites for Full Resumption of Const.Stresses Adverse Effects of Delay. Certificate of Svc Encl

ML19331A844
Person / Time
Site:	Midland
Issue date:	01/02/1973
From:	Kessler W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML19331A781	List: ML19331A780 ML19331A844
References
NUDOCS 8007230877
Download: ML19331A844 (5)

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UNITED STATES OF AMERICA

. ATOMIC ENERGY COMMISSION In the Matter of )

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CCNSUMERS POWER COMPANY ) Docket Nos. 50-329 50-330 (Midland Plant, Units 1 and 2)

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AFFIDAVIT Willia :t E. Kessler of Jackson, Michigan, being first duly svom, deposes and states upon information and belief as follows: ,

I am employed by Consumers Power Company as Project Manager 1.

in chcrge of its Midland Project Department, which has overall responsi-bility for the licensing, design, construction, costs, scheduling and _

startup of the Midland nuclear units. I have been associated with the -

project since Decenber 1967, first as Project Engineer and then as .

Project Manager.

2. In November 1970, in anticipation of a lengthy ASLB hear-ing in this proceeding, Consumers Power Company suspended all procure-ment, engineering and construction work on the Midland units, except I

such engineering support as was required for licensing.

3 Since receipt of the construction pe:mits for the Midland

! units on December 15, 1972, the Company and its principal contractors, Bechtel Corporation and the Babcock & Wilcox Company, have been performing only the following types of work related to the Midland project:

a. Identification of Consumers Power Co=pany personnel to be assigned or reassigned to the project, and interviews of job applicants.

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b. Identification and notification of Bechtel engineering personnel to be assigned or re-assigned to the project, some of whom have already moved to Bechtel's new office at Ann Arbor, Michigan. Also, preliminary identification of Bechtel construction per-sonnel to be assigned.

c. Preliminary engineering by Bechtel consisting of review of applicable codes, standards and safety guides, and investigation of alterna-tive reboiler designs.

16 Design vork, as such, has not been resumed. At present the

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Babcock & Wilcox Company is providing licensing support, as it Es done

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for the past two year's, plus some review of Bechtel work described in 3c above. .

5 Following expiration of the period for filing exceptions in the proceeding, Consumers Power Company vill evaluate the advisability of proceeding with remobilization of contractor personnel and resumption of design work. I estimate that identification, orientation and reloca-tion of contractor engineering personnel vill take from three to six months from the date of issuance of the construction permits, assuming no change in the time for filing exceptions to the ASLB's Initial Decision.

6. Construction activities at the Midland site can be resumed only after a minimum staff of about 25 to !+0 construction management

' engineers has been identified and the engineers have been relocated to the plant site. These engineers are presently engaged on other projects

, 3 all over the country, and this identification and relocation process alone vill take about one. month. Delay in the deaaH ne for filing exceptions to the ASLB decision vill cause a postponement of such identification and relocation, with a resultant delay in commencement of construction.

7 At the earliest, actual site work could probably not begin until April 1973 The first site work vill consist of removing protec-tive coverings that were applied when the project was suspended in 1970, placing forms for additional concrete, and grading. B&W is also scheduled to resume fabrication work on the nuclear steam supply system . .

and other plant equipment in early April 1973 .

8. Ifexceptionsarefiled,ConsumersPowerdompanyintends to delay identification and relocation of construction management engi-

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neers and resumption of fabrication and site cor.struction work at least -

until after the ASLAB has issued its decision. If an extension of time for filing exceptions to the ASLB's Initial Decision is granted, it vill delay remobilization and the resumption of design work, with consequent delay in fabrication and construction. If such an extension results in delaying the date of the ASLAB's decision beyond the end of February 1973, identification and relocation of construction management engineers and resumption of construction and fabrication activities vill also be de-layed. Although the Company could choose to resume such efforts without regard to the review process, absent a stay order, the possibility that work on the project might again have to be suspended as it was in 1970, at great expense, indicates that postponement of resumption of the work is the more prudent econcctic choice.

4 9 Delay in resunption of construction and fabrication work on the project vill result in increased project costs at the rate of at least $3,100,000 per month, or about $100,000 per day. Of the $31 million, $19 million would be attributable to escalation at $ en labor and materials costs (based on Bechtel's analysis of cost trends and contract obligations), $0.6 million would be attributable to suspension

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of B&W fabrication (based on our costs for such suspension to date),

$0 3 million vould consist of additional vendor charges for delay in ship =ent of the turbine-generator, and $0 3 million would be interest during construction on the capital invested in the project to this date.

Further deponent says not. k Di William E.'Kessler

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STATE OF MICHIGAN - -

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COUNI'? 0F JACKSON)

On this 2nd day of January,1973, before me, a Notary Public in and for said County personally appeared William E. Kessler, to me known to be the same person described in and who executed the within instrunent, who acknowledged the same to be his free act and deed.

Phyllfji Bogart ' g Notafy Public, Jackson County, Michigan My Co=nission Expires April 20, 1974

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UNITED STATES OF AMERICA  ;

ATOMIC ENERGY COMMISSION l l

In the Matter of ) l

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

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(Midland Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the attached " Opposition of Applicant to Saginaw Intervenors' Motion for Extension of Time in Which to File Exceptions"., dated January 4,1973,- and of the accompanying Affidavit of William E. Kessler, dated January 2,1973, have been served on the following in person or by deposit .in the United States mail, first

• class, this 4th day of January, 1973.

• Alan S. Pn enthal, Esq., Chairman David E. Kartalia, Esq. l Atomic Sakby and Licensing U. S. Atomic Energy Cozmaission Appeal Board . Washington, D. C. 20545 U. S. Atomic Energy Commission I Washington, D. C. 20545 Milton R. Wessel, Esq. ._

Kaye, Scholer, Fierman, Hays ' ~

and Handler

• Dr. John H.. Buck, Member ' "

Atomic Safety and Licensing ,425 Park -Avenue Appeal Board New York, New York 10022 U. S. Atomic Energy Commission '.~

Washington, D. C. 20545 James N. O'Connor, Esq.' -

The Dow Chemical Company '. . ' '-

• William C. Parler, Esq. , Member 2030 Dow Centur Atomic Safety and Licensing Midland, Michigan 48640 Appeal Board U. S. Atomic Energy Commission Myron M. Cherry, Esq. (2) .

Washington, D. C. 20545 135 South Lasalle *

- 33rd Floor .

William J. Ginster,.Esq. Chicago, Illinois 60603 Suite 4, Merrill Building '

Saginaw, Michigan 48602 Irving Like, Esq. ,

Reilly, Like.and Schneider l Mr. Frank W. Karas (20) 200 West Main l

Chief, Public Proceedings Branch Babylon, New York 11702 Office of the Secretary of the Commission Hon. William H. Ward U. S. Atomic Energy Commission Assistant Attorney General Washington, D. C. 20545 State of Kansas James A. Kendall, Esq.

135 N. Saginaw Road Midland,, Michigan 48640 b(Y Harold F. Re2.s

• / By person and by mail.

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