ML19347D584

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Answers to NRC 801126 Interrogatories Re Fill Areas & Remedial Actions.Certificate of Svc & Affidavits Encl
ML19347D584
Person / Time
Site: Midland
Issue date: 03/11/1981
From: Dhar B, Paris W, Swanberg N
BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8103260737
Download: ML19347D584 (22)


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BEFORE THE ATOMIC SAFE *"Y AND LICE'iSING 3OARD $ h

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In the Matter of )

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CONSUMERS Pnk'ER COMPANY ) 33 M 3

(Midland Plant, Units 1 and 2) f09 2 3ll l $I CONSUMERS P0b'ER COMPANY'S (APPLICANT'S)

ANSk'ER TO NRC STAFF INTERROGATORIES DATED 11/26/80 Interrogatorv 1 As a result of settlament and inadequate compaction in the fill area, you have proposed remedial actions and you have agreed to re-analyze the seismic /

structural analyses of the Category 1 structures located in this area.

1(a) Have you verified and evaluated any changes in the design safety margins available for any Category I structures by performing structural re-analysis?

Response

For the diesel generator building, a seismic re-analysis using FSAR seismic design criteria and a structural re-analysis have been completed. For the service water pump structure, the auxiliary building, and the borated water storage tanks, seis=ic/

structural analyses are in progress.

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1(b) If the answer to (a) is yes, please provide documents related to any

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structural re-analysis performed. -

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Response

Documents pertaining to re-analyses of tha diesel generator D building referred to in part 1(a) will be provided for inspection at Bechtel Associates Professional Corporation in Ann Arbor in the , ,

near future. Documents respecting design analy[es$.of other structures ~- -

identified in part 1(a) will be provided when such Wely:c.s mre comicter*_

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_2-1(c) If the answer to (a) is no, please state the reasons for not perforn'.ng that re-analysis.

Response

Not applicable.

1(d) If the answer to (a) is no, but you plan to make such re-analysis, please state when you plan to do so.

Responsa The schedule for structural re-analysis of pertinent structures is as follows:

6/15/81 Service water pump structure - detailed design, including structural and seismic c'onsiderations sufficient to let contracts to facilitate construction.

6/15/81 Auxiliary building - updated conceptual design for under-pinnings, including structural and seismic consideration sufficient to let con:racts to facilitate constructien.

5/1/81 Borated water storage tanks - detailed design including structure and seismic considerations sufficient to allow initiation of renedial neasures on or before this date.

It is anticipated that conceptual designs, based upon preliminary structural and seismic analyses, will be complete by 4/15/81 for the "

service water pump structure and borated water storage tank fixes.

Further, an update of the conceptual design for the auxiliary building underpinnings will be completed by 4/15/81, based upon preliminary structural and saismic considerations. (The above seismic analyses are being performed according to the method spelled out in the response to 1(e)).

I 1(e) Have you factored into any re-analysis information contained in, or resulting from, a letter from Robert Tedesco to Vice President J. Cook dated October 14, 1980, concerning seismological input data acceptable to the Staff?

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Response

Applicant objects on the ground that this question goes beyond the limited jurisdiction conferred by the December 6,1979 Order, that the seismic re-analysis requested by Mr. Tedesco in the October 14, 1980 letter should be reserved for the operating license hear!.ng, and, hence, that'it is irrelevant to these proceedings. Subject to that objection, Applicant answers as follows: The pending seismic re-analy-sis requested in the October 14, 1980 Tedesco letter haa been considered in arriving at the following approach towards designing and analyzing the remedial fixes for the auxiliary build'ing electrical penetration area, the service water pump structure, and the borated water storage tanit ring foundation: Seismic forces obtained by application of FSAR input criteria (i.e. modified Housner spectra and maximum accelera-tion anchored at .12 g) will be multiplied by a factor of 1.5. Forces thus determined will be combined with other loads in accordance with applicable load combinations in arriving at design (cont'd) ,

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- 4-parameters for the remedial measures.,' In addition, with respect to the Diesel Generator Building, Bech'tel is attempting to evaluate the total margin which actually exists in excess of TSAR seismic design criteria.

When dis ussions with the NRC Staff respecting possible redefinition of seismic criteria applicable to the entire Midland site are completed, Applicant will evaluate the necessity for seismic re-analyses of any or all Category I Structures, including those founded partly or entirely on plant fill. .

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1(f) If the answer to (a) is yes, plaasa provide copies of all documents relating to that re-analysis.

Response

The documents pertaining to the design analyses of the remedial fixes for the service water pump structure, the auxiliary building, and the I barated water storage tank ring foundation (using the 1.5 design margin factor) as stated in the response to part 1(b) will be provided. Applicant ,

objects to providing documents relating to the analysis of total margin in excess of TSAR seismic design criteria for the Diesel Generator Building, for the reasons stated in the first sentence of Applicant's response to part 1(e). For the same reason, Applicant objects to providing in this proceeding future seismic re-analyses of Midland structures as requested l

( by the October 14, 1980 Tedesco letter.

1(g) If the answer to (e) is no, please state if you plan to make an analysis incorporating that data, which structures you plan to re-analysis, and when you plan to do so.

Response

See the response to 1(e).

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1(h) If you believe re-analysis is not required for any such category I structure, please state for each structure why such re-analysis is not required.

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Response

See the response to 1(e). .

1(1) Was the floor response spectra for the diesel generator building generated on the assumption that the shear wave velocity would not be lower than 500 feet por second?

Response

Yes.

1(j) If the answer to Question (1) is negative, please state the assunption used with respect to shear wave velocity.

Response

Not applicable 1(k) How have you assured yourself that the soil shear wave velocity v111 not be less than 500 feet per second for the life of the plant?

Response

See the Response to 10 CFR 50.54f Question 24 (a) regarding -lant fill.

Interrogatory 2 The fill material under the northern wing of the service water pump structure has been found to provide inadequate support. While the portion of the structure over the fill material is being supported by the main structure founded on natural material, through cantilever action, it is stated in Management Corrective Action Report No. 24, Interim Report 6, issued September 7, 1978, that the total design loads cannot be supported by the main structure. Your proposed remedial action will utiliza corbels attached to the side of the r structural wall by bolts. The corbels are to be supported by pilings plac'ed l

l underneath them.

2(a) What alternative corrective actions did you consider. for supporting the cantilevered portion of the S m ice Water Pump Structuret n .

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Response

The present design propopi for the service water pump structure makes use of a continuous vall footing which penetrates to the till level.

In the past the following alternatives were considered: (1) removal and replacement of fill, (2) jack pilas, (3) caissons and (4) piles connected to the structure with corbels.

2(b) Was one of the alternatives considered to provide a stable solid foundation support of the cantilever portion of the structure down

! to the glacial till rather than the concentrated support design eventually chosen?

Response

Both the present proposal (vall footings) and the previous proposal (piles) would provide a stable foundation for the structure.

2(c) What structural analyses for each of these alternatives did you perform? ,

l Response A structural analysis, together with a design analysis, is-being performed for the design based upon vall footings. Prior to the recent design change for the service water pump structure, Applicant had undertaken an analysis

of the design which utilized a pile-corbel underpinning approach. This analysis was not fully complete at the time Applicant decided to adopt a different design proposal.

l 2(d) Please provide copies of documents relating to any analysis described in 2(c) above.

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Response

Documents pertaining to the analysis of the wall footings will be provided when the analysis is completed. Documents pertaining to analyses of any other design approach are not relevant to this matter.

2(e) Did you factor into any analysis identified in 2(c) above the infor: nation contained in a letter from Robert Tedesco to Vice President J. Cook, dated October 14, 1980, concerning seismological input data acceptable to the Staff. ,

Response

See the answer to 1(a).

2(f) Explain why each of the alternatives identified in 2(a) above was rejected or accepted. -

Response

Alternative (1) (removal and replacement of fill) was rejected for two reasons, i.e. cost and difficulty of dewatering during construction.

Alternatives 2 and 3 were rejected because the continuous footings approach would provide a design which is believed to be more acceptable to the NRC Staff, although either approach would provide an adequate solution. Alternative 4 was rejected because other designs would provide larger margins for seismic forces. , ,

2(g) For those alternatives that were rejected, but for which no analysis was l identified in 2(c) above, give the reasons for not considering those alternatives.

Response

l See 2(f).

2(h) What analyses have you done to assure yourselves that the long longitudinal bolts which will be ur , in the remedial action vill withstand the force produced in the bending mode?

2(1) Please provide copies of documents relating to any analysis identified in 2(h).

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8-2(j) If no such analysis has been performed do you plan to do an analysis and if so when?

2(k) Do ycu have a plan for pre-service and in-service inspection of the integrity of the bolts during the life of the plant?

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2(1) If the answer to 2(k) is yes, provide a copy or descr1ption of that plant.

2(m) If the answer to 2(k) is no, state the reasons that such a plan is not necessary.

2(n) What type of bracing (if any) will be provided to assure that the vertical piling will resist horizontal forces?

2(o) What analysis have you done to as.sure the adequacy of any horizontal braces identified in 2(n).

2(p) Please provide a copy of any analysis identified in 2(o).

Response

Applicant objects to these questions, as they pertain to a design option

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which is.no longer being proposed.

2(q) What analyses have you done to assure yourselves that the piling under the service water pump structure will provide adequate vertical support w after the occurrence of a postulated egethquake (OBE)?

Response

l Applicant is presently in the process of analyzing the latest design proposal for adequacy under OBE and SEE stresses. Applicant will respond to this question when such analysis is completed. Obviously, the adequacy of the pile-corbel design is no longer relevant to these proceedings.

2(r) What analyses have you done to assure yourselves that the piling under the service water pump structure will provide adequate vertical support after the occurrence of a postulated earthquake (SSE)?

Response

See 2(q) .

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9 2(s) Please provide a copy of any analy' sis identified in 2(q) and 2(r).

Response

See the response to Question 1(a).

2(t) Did you factor into any analysis identified in 2(r) above the information ,

contained in a letter from Robert Tedesco to Vice President J. Cook dated l October 14, 1980, concerning seismological input data acceptable to the Staff?

Response

See Applicant's Response to 1(e).

Interrogatorv 3 The following questions refer to the remedial actions at the service water pump structure.

3(a) Is the corbel design such that it depends upon a friction-fit with the service water pump strucute's north vall resulting from the pre-tensioning of the long longitudinal bolts.

3(b) How have you assured yourselves that this friction-fit will be maintained under all the design loads for the building?

3(c) If the answer to 3(b) is based on tests or other analysis please identify and provide copies of the analysis or test results.

3(d) How have you assured yourselves that the concrete at the interface between the corbel and the Service Water Pump Structure can adequately resist l bearing pressures developed as a result of pre-te.asioning of the bolts.

f 3(e) If the answer to 3(d) is based on tests or other analysis please identify '

and provide copies of the analysis or test results.

Response  ;

i l See the Response to Interrogatories 2(h) - 2(p).

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Interrogatorv 4 ,

In the response to Question 15 of the NRC request, regarding plant fill, it is stated that, " differential settlement primarily induces additional strain, which is a self-limiting effect and does not affect the ultimate strength of the structural members." Additional clarification of this statement is needed.

4(a) Why do you classify the resulting strains as self-limiting in nature?

4(b) How do you reconcile your statement quoted above wit'h your statement concerning the Service Water Pump Structure in the Management Corrective Action Report No. 24, Interim Report 6, issued September 7, 1978 that the total design loads cannot be supported by the main structure.

Response

Applicant will provide a response to this Interrogatory prior to the prehearing conference scheduled April 2, 1981.

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Interrogatorv 5 Your response to Questions 14, 28 and 29.cf'the NRC request regarding the causes of cracks due to settlement,- the significance of the extent of cracks, and the consequences of cracking, addressed only the existing condition of the Category I structures.

5(a) Have you performed analyses which provide tension field data under design load combinations at any crack locations for each Category I structure.

. Response There is a possibility that future differential settlement could cause larger rebar stresses and new or larger cracks. In such an instance, the larger cracks may be indicative of increased rebar stresses. However, since the design analysis of the structure assumes zero tensile strength for concrete, the existence of any crack would not be significant except as an indicator of rebar stresses (and except for corrosion effects).

To account for the possibility of increased rebar stresses due to future differential settlement, Applicant has conservatively analyzcd maxd-"'

rebar s*.resses which would be produced by future differential settlement.

The method directly predicts future rebar stresses without predicting future crack sizes.

With regard to the auxiliary building and the service water pt- p structure, since neither building is expected to undergo appreciable differential settlement in the future, the problem of " crack propagation", which evidences rebar stresses pre,duced by such settlement, does not exist.

With respect to the barated water storage tank, Applicant will determine the necessity of further crack evaluation following its decision on remedial actions to be undertaken.

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. l 5(b) Provide documents relating to data or analysis described in Part(a).

Ret,ponse Applicant will provide such documents as a part of its structural re-analysis package described in the answer to Question 1(b).

5(c) If the answer to (a) is no, state why it is not necessary to perform that analysis.

Response

See Response 5(a).

5(d) Have you performed any analyses .to show the limiting tension field conditions in which a crack will not propagate.

Response

No.

5(e) Pr6vida documents relating to data or analysis described in Part(d).

Response

Not applicable.

5(f) If the answer to (d) is no, state why you do not believe it is necessary to perform that analysis.

Response

The problem of crack propagation is accounted for in Applicant's present analysis by the approach taken in the response to Question 5(a), supra.

In Applicant's opinion, that analysis is equivalent to a " limiting tension field analysis", since the important result of such an analysis would be a predicted rebar stress.

5(g) What analyses have you performed prior to loading or surcharging of any structures or tanks to assure that existing cracks will not further propagate?

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Response

None.

'Interrogatorv 6 Since the fill was replaced by other material, such as lean concrete, in the vicinity of the auxiliary building and of the feedwater valve pits, the soil properties of the foundation material have been changed.

6(a) Have you performed new seismic / structural analyses that utilizes the new soil properties, (e.g. damping valves and shear nodules).

Response -

Such an analysis is presently in process.

6(b) If the answer to (a) is yes, please provide documents relating to such seismic / structural analysis.

Response

Documents relevant to such analysis will be provided along with the structural re-analysis package specified in the response to Question 1(b).

. 6(c) If the answer to (a) is no, please state the reasons for not perforning such new seismic-structural analysis.

Response

. Not: applicable.

6(d) If the answer to (a) is no, please state your basis for concluding that j these structures will comply with current NRC criteria.

Response

Not applicable.

6(e) If the answer to (a) is yes, have you performed a new soils structural

interaction analysis for the =tv411ary building and the feedwater isolation

( valve pits.

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Response

The seismic / structural analyses trently in progress considers the effects of soils structural interaction.

6(f) If the answer to (a) is yes, please provide documents relating to that analysis.

l Response' Refer to the response to Part (b) of this Interrogatory.

Interrogatorv 7 Your replies to date indicate that the effectiveness of the proposed ground water well system has not yet been established. These wells will be needed to control the ground water level and present soil-liquefaction.

7(a) Will the permanent devatering system be designed to withstand the safe shutdown earhquake (SSE)?

Response

No. See the response to 10 CFR 50.54 f, Question 24(c).

l 7(b) If no, will the permanent devatering system be designed to withstand any lasser ground vibratory motion?

Response

No.

7(c) If the answer to (a) is no, have you evaluated the impact of soil liquefaction on any soil supported Category I structures.

I Response No.

! 7(d) If no, why not?

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Response

As discussed in the response to NRC' Question 24 and 47, the permanent site dewatering system will be designed to maintain groundwater at a sufficiently low level to preclude the possibility of soil liquefaction.

7(e) If the answer to (b) is yes, what hound vibratory motion has been considered?

Response

Not applicable.

7(f) If the answer to (a) is yes, have you performed any analysis based upon information contained in or resulting from a letter from Robart Tedesco to Vice President J. Cook dated October 14, 1930 concerning seismological input data acceptable to the Staff?

Response

Not applicable.

7(g) If the answer to (f) is yes, what changes in the dewatering system design and ground water drawdown levels were determined to be needed.

Response

Not Applicable.

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Interrogatorv 8 In connectim with your seismic analysis of the service water pump structure and the diesel generator building have you developed: (1) Lump mass models (2) Stiffness value for each member (3) Mass at each nodes point (4) Spring t  ?

constants used in the analysis (K,, Co , K,, C,, K7, C7 ) and (5) Seismic inputs of the modified Taft N21E 1952 record used in this analysis. As to any affirmative answer, please provide copies.

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Response

For the seismic analysis of the diesel generator building, values I

have been developed for the following: l

1. Lump mass models
2. Stiffness value for each member
3. Mass at each node point
4. Spring constants
5. Seismic inputs for the modified Taft N21E 1952 record For the diesel building, the values will be provided along with the documents pertaining to the structural reanalysis referred to in the response to question 1(b). For the service water pump structure, this informatica vill be supplied when the analysis has been developed.

l Interrogatorv 9 With respect to the seismic Category I valve pits located in the fill adjacent of the east and west side of the diesel generator building:

9(a) What changes, if any, occurred to these pits during the diesel generator surcharge program?

Response

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! As expected, the valve pits have experienced settlement as a result of the surcharge program. The east pit has settled 0.52 inches and the l

west pic 1,49 inches.

9(b) Do any cracks exist in these pits?

Response

l No cracks exceeding 5 mils have been identified in these pits.

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9 (c) What changes, if any, occurred in the rattle space for the piping during r

the diesel generator building surcharge program?

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Reponse The initial readings were taken of service water piping on 11/13/78 prior to isolating the D.G. building footings from the duct banks. Thr. final readings were taken on 5/2/80 after removal of the surcharge.

D.G. BLDG. VERTICAL EORIZONTAL PEN. # LINE i MOVEMENT MIN. CAP MOVEMENT MIN. GAP.

I lHBC-81 + 1/8 1 1/4 + 1/4 1 1/4 2 1HBC-82 + 1/8 1 1/4 + 3/8 1 1/4 5 2HBC-311 - 1/2 1/4 0 1 1/4 6 2HBC-310 - 3/4 7/8 0 1 3/8 8 1HBC-310 - 1/2 5/8 0 1 1/2 9 lHBC-311 - 5/8 3/4 0 1 1/4 11 2HBC-81 - 1/4 3/4 - 1/8 1 3/8 12 2HBC-82 0 1 - 1/8 ' 1 3/8 Directions: Vertical + pipe moves up relative to penetration pipe moves down relative to penetration Horizontal + pipe moves east / north relative to penetration pipe moves west / south relative to penetration e

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~ MAR 161981 > 0' g g g gg.y ((

NUCLEAR REGULATORY COMMISSION s D M ?'*5"M* '

BEFORE THE ATOMIC SAFETT AND LICENSING BOARD E

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  • In the Matter of )

) Docket Nos. 50-329-0M CONSUMERS PCWER COMPANY ) 50-330-CM

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

)

l CERTIFICATE OF SERVICE I hereby certify that copies of " Consumers Power Company's (Applicant's) Answer to NRC Staff Interrogatories dated November 26, 1980, and attached affidavits were served upon the following persons by depositing copies thereof in the United Stated = ail, first class postage prepaid on this lich day of March, 1981.

Frank J. Kelley, Esq. Dr. Frederick P. Cowan Attorney General of the 6152 N. Verde Trail State of Michigan Apt. B-125 Stewart H. Freeman, Esq. Boca Raton, Florida 33433 Assistant Attorney General ,

Gregory T. Taylor, Esq. Michael Miller, Esq.

. Assistant Attorney General Isham, Lincoln & Beale Environmental Protection Div. One First National Plaza 720 Law Building Suite 4200 Lansing, Michigan 48913 Chicago, Illinois 60603 Myron M. Cherry, Esq. Mr. Steve Gadler One IBM Plaza 2120 Carter Avenue Suite 4501 St. Paul, Minnesota 55108 Chicago, Illinois 60611 E. F. Judd, Sr. Project Manager Mr. Wendell H. Marshall Babcock & Wilcox 1 RFD 10 P. O. Box 1260 j Midland, Michigan 48640 Lynchburg, Virginia 24505 1

Charles Bechhoefer, Esq. Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Conum. Washington, D. C. 20555 Washington, D. C. 20555 Mr. C. R. Stephens, Chief

( Gustave Linenbarger Docketing & Service Section

! Atomic Safety & Licensing Board Office of the. Secretary U. S. Nuclear Regulatory Coma U. S. Nuclear Regulatory Commission Washington, D. C.'20555 Washington, D. C. 20555 s

a O Ms. Mary Sinclair 5711 Summerset Street Midland, Michigan 48640 i William D. Paton, Esq.

Counsel for the NRC Staff U. S. Nuclear Regulatory Connaission Washington, D. C. 20555 Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Connaission Washington, D. C. 20555 Barbara Stamiris 5715 North River Road Route 3 Freeland, Michigan 48623 Lester Kornblith, Jr.

Atomic Safety & Licensing Board U. S. Nuclear Regulatory Comma.

Washington, D. C. 20555 t'8A James E. Brunner Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 e

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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) DOCKET NOS. 50-329-0:1 CONSUMERS POWER COMPANY ) 50-330-0M

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

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l COUNTY OF WASHTENAW)

)ss STATE OF MICHICAN )

AFFIDAVIT OF BI.wJG, DHAR Bimal Dhar, being duly sworn, deposes and says that he is employed by Bechtel Associates Professional Corporation, as an Engineering Supervisor; that he is responsible for providing answers to NRC Staff Interrogatories to Consumers Power Company Numbers 5, 9a and 9b, and that to the best of his knowledge and belief the above infor: nation and the ansvers to the above inter-rogatories are true and correct. ,

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Bisag Dhar Subscribed and sworn to before me this [ day of To < < d 1981.

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. *N' L.cc uI, k Y ."%3 Notary Public, Washtenaw' County, Michigan My Commission Expires:!E~ f -

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) DOCKET NOS. 50-329-0M CONSUMERS POWER COMPANY ) 50-330-0M

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

)

) -

COUNTY OF WASHTENAW)

)ss STATE OF MICHIGAN )

AFFIDAVIT OF NEAL SWANBERG Neal Swanberg, being duly sworn, deposes and says that he is employed by Bechtel Associates Professional Corporation, as an Assistant Project Engineer; that he is responsible for providing answers to NRC Staff Interrogatories to Consumers Power Company Numbers 1, 2, 6, 7 (jointly with W. Paris), 8, and 9c, and that to the best of his knowledge and belief the above information and the answers to the above interroga- ,

tories are true and correct.

Neal Swanberg F Suoscribed and sworn to before me this b day of h774.,,I 1981.

Au .&, & /L n Notary Public, Washten,sw._QQunpyu..

_.2.... 2 Michigan My Commission Expires:r4 b!!c . . Iis3iv$$6f1hh)

O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) DOCKET NOS. 50-329-0M CONSUMERS POWER COMPANY ) 50-330-0M

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

)

)

COUNTY OF WASHTENAW)

)ss STATE OF MICHIGAN )

AFFIDAVIT OF WILLIAM C. PARIS,- JR.

William C. Paris, Jr. , being duly sworn, deposes and says that ha is employed by Bechtel Associates Professional Corporation, as an Engineering Supervisor; that he is jointly responsible with Neal Swanberg i

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for providing answers to NRC Staff Inrerrogatories to Consumers Power Company Number 7, and that to the best of his knowledge and belief the above infor-mation and the answers to the above interrogatories are true and correct. ,

i M William C. Paris, Jr. /

Subscribed and sworn to before me this d day of  % o M/ 1981.

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Notary Public, Washtenaw County,17.333 E_77.?J.7 A. Michigan

0:nT TJr.,IC, vi . .21/1 cc.,M:c :

My Commission Expires: x7 cc:c.:ssIox Imrcs :;37.30,1982 s .

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