ML20038A925

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Forwards Testimony Re Proposed Remedial Underpinning Work for Auxiliary Bldg.Testimony Provides Adequate Basis for Assurance That Proposed Work Can Be Carried Out W/O Undue Risk to Public Health & Safety
ML20038A925
Person / Time
Site: Midland
Issue date: 11/19/1981
From: Williams F
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To: Bechhoefer C, Cowan F, Decker R
Atomic Safety and Licensing Board Panel
Shared Package
ML20038A926 List:
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8111240459
Download: ML20038A925 (2)


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Charles Bechhoefer, Esq. Dr. Frederick P. Cowan Atomic Safety and Licensing 6152 N. Verde Trail Board Panel Apt. B-125 U.S. Nuclear Regulatory Boca Raton, Florida 33433 Commission Washington, D.C. 20555 Dr. Jerry Harbour Atomic Safety & Licensing Ralph S. Decker Board Panel Administrative Judge U.S. Nuclear Regulatory Route No. 4, Box 190D Commission Cambridge, Maryland 21613 Washington, D.C. 20555

Dear Administrative Judges:

Enclosed is Applicant's testimony with respect to the remedial underpinning work for the Midland Auxiliary Building. This testimony has five authors, who will be pre-sented as a panel in the evidentiary hearings beginning in Midland on December 1. The principal author is T. E. Johnson who is Chief Civil / Structural Engineer for Bechtel, Ann Arbor. Ed Burke and James Gould of Mueser, Rutledge, Johnson

& DeSimone, a firm of consulting engineers which specializes in underpinning work, are respectively responsible for Sections 4 and 8 of the testimony, which discuss how the i

underpinning will be constructed and geotecnnical considera-tions. Finally, Dr. W. Gene Corley and Dr. Mete Sozen, who are experts in structural engineering and in the properties of reinforced ccncrete, address in Appendix A the signi-ficance of the cracks which occur in the Auxiliary Building and all other reinforced concrete structures. The impressive qualifications of these witnesses are described in more detail in the affidavits attached to this testimony.

Applicant will submit the testimony of Dr. Robert Kennedy discussing the seismic model used in the Auxiliary Building (as well as the seismic models for the Service Water Pump Structure and the Borated Water Storage Tanks) on November 30, 1981.

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> .s The information in this testimony relating to the proposed Auxiliary Building underpinning work exceeds that normally available at the construction permit stage in NRC licensing proceedings. This testimony provides an adequate basis for a finding that there is resonable assurance that the proposed underpinning work can be carried out without undue risk to the public health and safety. Definitive operating license type findings must of course await com-pletion of the remedial work and later stages of this pro-ceeding.

Respectfully submitted, Frederick C. Williams ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.

Washington, D.C. 20036

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