ML19350C798

Affidavit That Const Should Continue Despite Financial Risk. Present Uncertainty Re Seismic Issue Will Be Accounted for by Designing Soils Remedial Work W/Margin for Seismic Loads

ML19350C798
Person / Time
Site:	Midland
Issue date:	03/16/1981
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML19350C792	List: ML19350C791 ML19350C798 ML19350C807
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8104060714
Download: ML19350C798 (4)

Text

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UNITED STATES OF NERICA Q\ /.

NUCLEAR REGUL\ TORY COS0!ISSION

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,d. lT' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the !!atter of o-

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CONSUMERS POWER COMPANY DocketNos.50-3'bOL

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) 50-33 OL (Midland Plant, Units 1 and 2

) 50-330-0M

) 50-330-0M STATE OF MICHICA'; )

)ss COUNTY OF JACKSON )

AFFIDAVIT OF JAMES W. COOK I, James W. Cook, being first duly sworn, do state that I am of lawful age and that the statements in the attached affidavit are true and correct to the best of my knowledge and belief.

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' James TI. ' Cook "

Subscribed and sworn to before me this //o day of % w C 1981.

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Notary Public ,

Jackson County, !!ichigan 3 My Commission expires: dwh t.- ? / 9 f Y' 810.40 607/Yt

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In The Matter Of ) Docket Nos. 50-239 OM

) 50-330 OM CONSUMERS POWER COMPANY )

) Docket Nos. 50-239 OL (Midland Plant, Units 1 and 2)) 50-330 OL AFFIDAVIT OF JAMES W. COOK My'name is James W. Cook. I am employed by Consumers-Power Company as Vice President in charge of Project Engineering & Construction. My responsibilities in this_ job include overseeing all project activities and making scheduling decisions for the Midland Nuclear Power Plant.

My educational background and work experience is as follows: I have a B.S. in Chemical Engineering from Princeton and an M.E. in Nuclear Engineering from Penn State University. I am a licensed professional engineer in the State of New York. From 1962 to 1972 I was employed by

> the American! Electric Power Service Corporation in capacities involving _a variety of' design and-supervisory responsibilities.

From 1972 to 1977 I was employed by Stone-& Webster Engineering Corporation, Boston, Massachusetts,_as an assistant project engineer and, later, a project engineer. My final position in Stone & Webster was that of-project engineer responsible-

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for all design activities in connection with the Millstone Unit 3 project. From 1977 to 1980 I was smployed by Consumers Power Company as the Vice President in charge of Energy Planning. In 1980 I was assigned to my present position with the Consumers' organization.

It is extremely important to Consumers Power Company and to the consumers of electricity in Michigan that the Midland Plant be placed in service as promptly as

-rassible. Consumers Power Company has voluntarily halted soils-related remedial work in deference to the concerns reflected in the NRC Staff's December 6, 1979 Order Modifying

' Construction Permits. However, further delays in resolving ,

the soils-related matters which are the subject of this proceeding could make it impossible for Consumers. Power

. Company to complete construction o# the Midland Plant on schedule. .For this' reason I urge the Licensing Board not

.to take:up seismic issues in this proceeding.

'The present construction schedule calls for the Midland Units 2 and 1 to beLplaced in service by July 1983 and December, 1983,.respectively. This construction schedule cannotL be met unless' the soils issues which are the subject' of this proceeding'are. resolved this year. The total cost

.to Consumers Power Company of delay in bringing these units

-in line is in excess of $30 million per month. In addition.

there Lcould be further adverse impacts if tdut Nidland Plant -

is,not able to supply process steam to the Dow Chemical plant across the Tittibawassee River by December 31, 1984 in accordance with Consumers Power Company's contract with Dow.

Eventually these costs of unnecessary delay will be borne either by the stockholders of the Company or by consumers of electricity in Michigan, who are presently suffering the worst economic conditions in the country.

I am aware of and a party to the ongoing dis-cussions between the NRC Staff and Consumers Power Company concerning the need for a review of the seismic input for

'further analysis of the Midland plant. I am aware that continuing construction in the face of uncertainty concerning additional seismic analysis presents a financial risk, not just with respect to the soils remedial work, but also with respect to the entire Midland plant. But I am also aware that all plants currently completing the operating license process are successfully resolving similar questions by means of protracted discussions with the NRC Staff and by providing detailed additional seismic analyses of the major portions of the completed plant structures and equipment.

Therefore,.due to the overwhelming need to complete the Midland plant on time, due to current' industry experience and based on the expert judgment of Dr. Thiruvengadam and others that all outst'anding seismic questions can be successfully

6 regolved, I have determined that construction should and must continue despite this financial risk.

I have also decided that it is prudent to account for present uncertainty concerning the seismic issue by designing the soils remedial work with a margin for seismic loads as described in the affidavit of Dr. Thiruvengadam.

This design margin has not been used for other plant structures and equipment, which are essentially completed and in place, including structures and equipment supported by the remedial work.

For the Licensing Board to make findings in this proceeding relating to the adequacy of the seismic design margins for the soils remediel work would not meaningfully reduce the overall financial risk to Consumers Power Company resulting from the present uncertainty arising from the Staff's review of seismic design basis of the entire Midland plant. Moreover, I am informed by Dr. Thiruvengadam that the seismic re-review has not progressed far enough to allow the Board to address this issue in the near future. There-fore, taking up seismic issues in this proceeding is incon-sistent with prompt resolution of the soilu-related issues.

Consumers Power urges the Board to defer considera-tion of seismic issues until the operating licensing proceeding, and recognizes that in doing so we are taking'a financial risk. Wenacknowledge that we build at our own risk.

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