ML20052C622
| ML20052C622 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/03/1982 |
| From: | Voigt H DETROIT EDISON CO., LEBOEUF, LAMB, LEIBY & MACRAE |
| To: | |
| References | |
| NUDOCS 8205050299 | |
| Download: ML20052C622 (47) | |
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UNITED STATES OF AMERICA yfl( -3 p 3 3R NUCLEAR REGULATORY COMMISSION
.g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD [b
(
In the Matter of
)
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4
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Y
,f,y -
THE DETROIT EDISON COMPANY,
)
Docket No. 5 2341 J-
.y 4
et al. (Enrico Fermi Atomic
)
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' f2f Power Plant, Unit No. 2)
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g x;;h 44
/
APPLICANTS' PROPOSED FINDINGS OF FACT 4
AND CONCLUSIONS OF LAW IN THE FORM OF A PROPOSED INITIAL DECISION 1.
The Detroit Edison Conpany (" Edison") filed an Amended and Substituted Application for Licenses with the Atomic Energy Commission on October 22, 1974, pursuant to Section 103 of the Atomic Energy Act, as amended ("the Act").
An Environmental Report, Operating License Stage
("ER") accompanied the Application.
Subsequently, Edison filed five supplements to the ER and 41 amendments to its Application.
One of those amendments ad,ded Northern Michigan Electric Cooperative, Inc. and Wolverine Electric Cooperative, Inc. (collectively referred to with Edison as 3
g,0 3
" Applicants"), as co-applicants for licenses.
Applicants seek authority to possess, use and I
I operate a boiling water nuclear reactor designed for a steady-state power level of 3292 megawatts thermal, to l
be known as Enrico Fermi Atomic Power Plant, Unit No. 2 i
(" Fermi 2").
Fermi 2 is located on a site owned by Applicants immediately west of Lake Erie in Frenchtown Township, 8205050299 820503 PDR ADOCK 05000341 0
l Monroe County, Michigan.
The Commission issued Edison a construction permit for Fermi 2 on September 26, 1972.
2.
The Application was reviewed by the Regulatory Staff (" Staff") of the Commission and the Advisory Committee on Reactor Safeguards ("ACRS").
Both the Staff and the ACRS have concluded that there is reasonable assurance that Fermi Uni t No. 2 can be operated at the Frenchtown site without undue risk to the health and safety of the public, subj ect to certain specified conditions.
NRC Staff Safety Evaluation Report ("SER") (July 1981); SER Supp. 1 (September 1981) and 2 (February 1982); ACRS letter of August 11, 1981.
3.
In accordance with the requirements of the Act, a notice of hearing was published in the Federal Register on September 11, 1978.
43 Fed. Reg. 40327 (1978).
In response to that notice, several parties petitioned to intervene in this proceeding.
One such party, Citizens for Employment and Energy ("CEE"), was admitted as intervenor in this proceeding by the Board's Order of January 2, 1979.
The other petitioning parties withdrew their requests to l
. intervene.
4.
Two special prehearing conferences, pursuant to 10 C.F.R. S 2.751, were held in Detroit, Michigan on December 18, 1978 and July 22, 1981.
A final prehearing conference, pursuant to 10 C.F.R. S 2.752, was also held in l
o s
Monroe, Michigan on March 31, 1982, immediately prior to the evidentiary hearings.
5.
In an Order dated March 21, 1979, the Board adopted as the issues in this proceeding a Stipulation of Contentions signed by all parties and transmitted to the Board by the Staf f by letter dated March 5, 1979.
6.
At the July 22, 1981 special prehearing conference, the Board granted CEE's request to withdraw several of the contentions previously adopted as issues in the proceeding.
Tr. 191-96.
As a result, there remained for disposition three Contentions, Contentions 4, 5, and 8, previously approved by the Board.
At the July 22, 1981 special prehearing conference, the Board also adopted the parties' agreement that Contention 8 involved solely the feasibility of the evacuation route for the populated area near the Fermi 2 site known as Stony Point, and that Contention 8 did not put into controversy the validity of Edison's emergency plan.
Tr. 207-208.
t' 7.
On November 16, 1981, the Staff filed a motion for summary disposition of Contention 5, which alleged that the Fermi 2 radiation monitoring system would not conform with the Commission's regulations and would not be adequate to implement the off-site protective actions set forth in Edison's emergency plan.
Applicants responded in support 3
of the motion on December 11, 1981.
CEE did not respond to the motion.
In an Order dated January 27, 1982, the Board granted the motion and dismissed Contention 5.
I 8.
Evidentiary hearings on the two remaining contentions were held in Monroe, Michigan on March 31 and April 1-2, 1982.
At the evidentiary hearings, CEE cross-examined the witnesses of Edison and the Staff and presented a witness in support of their positions on the contested issues.
Tr. 280-538.
Edison and Staff cross-examined each other's witnesses.
Edison cross-examined the witness of CEE with respect to Contention 4.
9.
Requests for limited appearances were made by a number of persons, many of whom either appeared at the hearings and made oral statements or submitted statements in writing for the record.
Tr. 221-244; 356-366; 515-518.
All of those making limited appearances either expressed their opposition to the operation of the plant or explained their concerns about various environmental and safety issues.
Most of those making limited appearances raised issues outside the scope of the admitted contentions and thus outside the jurisdiction of the Board.
Other persons raised issues outside the jurisdiction of the Commission.
One person, however, raised an issue appropriate for the Board's review within the scope of Contention 8 concerning the adequacy of the evacuation route for the Stony Point area.
Tr. 231-235.
i r
Findings on Contention 4 10.
Contention 4, as stipulated by the parties and approved by the Board, reads as follows:
The fo'llowing contentions and their factual bases are supported by the direct and indirect knowledge of at least one member of CEE, who is and has been personally involved in the construction of Fermi 2 since work was begun.
(a)
There has been an appalling lack of physical security at the con-struction site since the inception of construction.
Given the need for extremely close quality control in the erection of a nuclear plant, this failing could well lead to flaws in the structure, through deliberate sabotage or unintentional inj ury to components.
(b)
The Applicant's Quality Assurance Inspection Program has not been executed in conformance with criterion X of Appendix B to 10 CFR Part 50.
Recent reinspections of various materials and workmanship indicate that quality control was inadequate during construction prior to the 1974 shutdown of construction activities at the site.
Specifically, CEE identifies:
(1) large and small bore pipe hangers, and (2) welds of safety related component s.
(c)
The Applicant has not maintained sufficient quality assurance records to fur-nish evidence of activities af fecting quality to comply with Criterion XVII of Appendix B to 10 CPR Part 50 in that records have been de-stroyed or lost during the course of construc-tion. - _ _ _ _ _
)
(d)
Detroit Edison twice replaced the team of supervisors from the first general contractor, Ralph M. Parsons Co.,
then terminated its contract with Parsons and hired a second firm, because Parsons' employees refused to sacrifice quality control in order to expedite the con-struction schedule.
(e)
Specific flaws in construction can be identified, among them:
(1)
Excessive water in the reactor hole which caused the concrete base to crack severely, a problem purportedly remedied by patchings.
(2)
Hairline cracks in structural steel surrounding the dry well.
11.
Edison's testimony on Contention 4(a) was presented by Stuart H. Leach, Senior Administrator for Security for Edison.
Leach Test., f f. Tr. 256.
Mr. Leach was accompanied to the witness stand by Donald Bluhm, Director of the Security Department for Edison.
Edison's testimony on Contentions 4(b), (c) and (e) was presented by Tullio A. Alessi, Director, Project Quality Assurance for the Fermi 2 Project for Edison.
Alessi Test., ff. Tr. 260.
Mr. Alessi was accompanied to the witness stand by Walter M. Street, Supervising Engineer-Civil for the Fermi 2 Project for Edison.
Edison's testimony on contention 4(d) i was presented by William J.
Fahrner, Manager for the Fermi 2 l
Project for Edison.
Fahrner Test., ff. Tr. 334.
Mr.
Fahrner was accompanied to the witness stand by Wayne H. Jens, Vice President-Nuclear Operations for Edison.
12.
The Staff's testimony on Contention 4 was presented by Paul A.
Barrett, a reactor inspector with the Engineering Inspection Branch of Region III of the Commis-sion's Office of Enforcement and Inspection ("I&E"); Bruce Little, the Senior Resident Inspector for Fermi 2, from I&E Region III; Harvey M.
Wescott, a project inspector from I&E Region III; Harry Shannon Phillips, Chief Equipment Qualifi-cations Section of I&E Region IV; and F. C. Hawkins, a reactor inspector from I&E Region III.
Barrett, Little, Wescott, Phillips, and Hawkins Test., f f. Tr. 270.
13.
TestinoAy on behalf of CEE on Contention 4 was presented by Fr.qx Euron, an ironworker who formerly worked on ths
,v.r,.recion of Fermi 2.
Kuron Test., ff.
Tr. 367, at 1-9.
Security During Construction 14.
Contention 4(a) statss:
There has been an appalling lack of physical security at the construction site since th(
inception of construction.
Given the need for extremely close quality control in the erection of a nuclear plant, this fail _'a could well lead to flaws in the structure, tr. _ ugh l
l deliberate sabotage or unintentional injury to l
components.
i
! i
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15.
Edison's witness Leach testified in detail as to the security measures that were in ef fect during various phases of construction.
Leach Test. at 2-7.
Security has been continually upgraded to match the plant construction progress.
When construction began at the Fermi 2 site in 1969, security personnel from the adjacent Fermi 1 facility controlled access to the Fermi 2 site by l
guarding site gates and patrolling the site.
Id,. at 3; Tr.
282.
In 1976 when the turbine generator and other sophis-ticated components were received on site, security was increased.
Perimeter fencing was erected, area lighting was improved, strict personnel identification was required, and patrol checkpoint stations were equipped with more durable and sophisticated registering devices.
A new communication system was also installed to give the security personnel a dedicated radio frequency rather than sharing one with construction personnel.
The site perimeter was posted with "No Trespassing" signs approximately every 75 feet.
Leach Test. at 3-4.
16.
Edison's witness Leach testified that certain areas within the building that have been designated as needing high security, such as the torus, turbine floor, control room, and clean room, have been manned with security officers with the specific responsibility of controlling _
- -... =..
I ingress and egress and allowing only authorized persons to enter.
Leach Test. at 5.
17.
Witness Leach testified that while Fermi 2 has been under construction, Edison has had both contract guards and Edison security of ficers providing site protec-tion.
Applicants for security positions are interviewed and background investigations are made on them by super-i visors of the Edison Security Department prior to being assigned to work on any security task.
Fingerprint clearances are obtained through the Michigan State Police to help ensure they have satisfactory backgrounds.
Leach Test. at 2.
18.
Staff witness Little testified that Edison has had a security program in effect at the Fermi 2 facility since the start of construction and that this program provides access and egress control of authorized personnel and materials, as well as fire and security patrols, on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis.
Little Test. at 15.
Staff witness Little also testified that no specific security precautions are required by the Commission for reactor construction sites because there is no perceived threat to the public health and safety before fuel is loaded.
Little Test. at 14.
l 19.
Some thefts of hand tools and minor vanda-lism, such as broken windows, padlocks, and street lamps,
_9_
have been experienced during the Fermi 2 construction.
Leach Test. at 6; Tr. 283-84.
However, there has been no evidence of major destruction or sabotage of property on the site by construction workers or Edison employees.
- See, e.g., Little Test. at 15.
20.
CEE witness Kuron alleged that a release of several hundred gallons of fuel oil on the site occurred sometime during construction.
Kuron Test. at 3.
- However, no evidence was offered to show that the incident actually occurred, or that the incident, even if it occurred, was the result of sabotage or other deliberate action.
CEE witness Kuron did not allege any other specific incidents tending to show a lack of security or damage to any part of the facility.
Mr. Kuron did not refute any testimony by Edison or Staff as to the security measures employed at Fermi 2 during construction.
See Id.; Tr. 283-284.
21.
Trespassing onto the Fermi 2 site has occurred occasionally during construction.
Leach Test. at 7; Tr. 284.
It appears that such incidents number less than 50 during the course of construction.
Id.
Edison's witness Leach testified that most trespassers have been rock collectors, bird watchers, hunters, fishermen or the like who wandered onto the site, apparently without criminal intent.
Some were forced to seek haven on the site from a.
storm, fog, or ice on Lake Erie.
Mr. Leach testified that on occasions when trespassers ignored the security officers or presented a potential hazard to site security, Edison requested assistance from local law enforcement authorities.
Trespassers either have been counseled and released by Edison or, if the situation warranted, referred to the criminal justice system.
Leach Test. at 7.
22.
The Board finds that there is no evidence of any serious intrusion onto the Fermi 2 site which would suggest that sabotage or injury of the plant or components may have occurred.
- See, e.g., Little Test. at 15.
23.
Staff witness Little testified that a comprehensive pre-operation test program will be conducted by Edison prior to start'1p of the facility.
Leach Test. at 7.
This test program will demonstrate that the performance of all components and systems important to safety will meet design requirements.
During the pre-operation tests, the Staff will perform in-depth inspections of selected safety systems.
Little Test. at 15-16.
These inspections will independently verify Edison's test program is adequate and that management controls and quality assurance programs have been implemented before the Staff recommends startup of the facility.
This test and inspection program assures that any safety-significant discrepancies resulting from vandalism or sabotage will be detected.. _.
24.
In summary, the Board concludes that Edison has maintained a progressively more sophisticated security program which has been adequate for each stage of construc-tion of the Fermi 2 plant, that there is no evidence of any significant sabotage of or damage to components or equipment within the facility, and that the pre-operation test program to be performed by Edison and inspected by the Staff will assure that any damage to safety related equipment will be detected before operation of the facility.
Contention 4(a) is dismissed.
Quality Assurance Inspection Program 25.
Contention 4(b) states:
The Applicant's Quality Assurance Inspection Program has not been executed in conformance with Criterion X of Appendix B to 10 CFR Part 50.
Recent reinspections of various materials and workmanship indicate that quality control was inadequate during con-struction prior to the 1974 shutdown of construction activities at the site.
Speci-fically, CEE identifies:
(1) large and small bore pipe hangers, and (2) welds of safety related components.
26.
In response to this contention, Edison's witness Alessi testified in detail as to the inspection requirements imposed upon Edison employees and all contrac-tors, and the reinspection and reporting procedures that are required by the Detroit Edison Quality Assurance Manual when a decificiency is found in a safety-related component.
See Alessi Test. at 1-4.
He also pointed out that CEE's impression that quality assurance ("QA") was inadequate prior to the 1974 halt in construction may have resulted from its misinterpretation of the relatively high rate of component reinspection that took place following resumption of construction in 1976 as a result of redesign of systems. Id.
27.
Staff witness Little testified that I&E conducts inspections during the construction of each reactor.
He testified that these inspections include the following:
(1) a review of the applicant's OA performance, including audits of the applicant's QA records and documen-tation; (2) a witnessing of the construction practices and an inspection of the facility at various stages of con-struction; and (3) a review of the qualifications and training of the construction personnel as well as those of the quality assurance and quality control ("QA/QC") personnel.
Little Test, at 9.
28.
This inspection activity involves checking whether actual work activities are in accordance with procedures, license requirements, technical specifications, plans, and code requirements.
I&E inspectors question craftsmen and operators to determine if they understand, and are adhering to, applicable limits and requirements.
The inspectors observe operating instruments and recorder charts to determine that operations are being conducted within regulatory requirements.
They observe instruments being calibrated.
Observations are made as equipment is started up, shutdown, or otherwise changed in operating mode.
These observations and individual discussions with, and questioning of, people actually doing the work provide a basis for determining how well the licensee is actually implementing its quality assurance program.
Little Test.
at 9-10.
29.
Reports are made of the inspection findings and include items of non-compliance, deviations, and unresolved items.
These items are entered in I&E's tracking system and remain open until appropriately resolved.
Id.
at 9.
30.
Staff witness Little further testified that I&E inspections at the Fermi 2 site, while they had identi-fled some items of non-compliance, and the existence of QA/QC weaknesses in some specific construction tasks, found that Edison adequately developed and implemented a QA/QC program.
In June 1981, I&E performed an "In-Depth QA/QC Inspection" of one of Fermi's safety systems, the core spray system.
This inspection found only one item of non-compliance l
l.--
(configuration control of forms).
The inspection found that required quality control documents existed and that the overall QA/QC program was being performed in a satis-factory manner.
Little Test. at 10-11.
31.
Staff witness Wescott testified that in February 1979 I&E inspectors met twice with CEE witness Kuron regarding statements that he had made at the December 18, 1978 prehearing conference concerning alleged con-struction deficiencies.
Wescott Test. at 17.
These meetings with Mr. Kuron were extensive, the second alone covering nearly two days.
Tr. 387-388.
The second meeting included a walking tour of the Fermi 2 facility without an Edison escort, during which Mr. Kuron was given an opportunity to identify any alleged construction s'eficien-cies.
Id.
Tr. 368-369.
On cross-examination, Mr. Kuron agreed that on this walking tour he was given Lccess to every area of the plant that he desired.
Tr. 369; see also Tr. 388.
32.
Staff witness Wescott testified that the results of this investigation are documented in I&E Report No. 50-341/79-04.
Wescott Test. at 18.
According to Mr.
Wescott, all allegations made by Mr. Kuron either were found to be unsubstantiated (see Wescott Test., Appendix A) or were matters reinspected during subsequent inspections by I&E inspectors and found to be adequately resolved by Edison.
Wescott Test. at 19.
On cross-examination, Mr.
Kuron admitted that his direct testimony in this proceeding did not allege any matter that he had not already presented to the I&E inspectors in February 1979.
Tr. 368-370.
33.
Staff witness Wescott testified that there was some basis for the allegation of improper original installation of large and small bore pipe hangers.
Wescott Test. at 19.
However, this problem had been identified by I&E nearly one year before the February 1979 meetings with Mr. Kuron, and a reinspection and reinstallation program was already under way.
The only improperly installed hanger identified by Mr. Kuron was in the turbine building and not part of a safety-related system.
Wescott Test.,
Appendix A at 15-16.
Mr. Wescott testified that an I&E inspection of pipe hangers subsequent to Mr. Kuron's I
allegations did not reveal any discrepancies that had not been previously identified.
Wescott Test. at 19.
34.
When construction at Fermi 2 was resumed in 1976, Edison set up a shop'to refurbish pipe hangers installed before the 1974 construction halt that had shown signs of deterioration.
These hangers were sandblasted, inspected, l
repainted and reassembled.
Tr. 291.
Hangers that had i _
developed rusting in excess of acceptable standards were replaced.
However, most other pipe hangers installed before the construction halt subsequently have been replaced by pipe hangers of a new design.
Tr. 303-304.
35.
CEE witness Kuron alleged several instances of improper welding of (1) nozzles on the main condenser in the turbine building, (2) the steam inlet to the main steam isolation valve, (3) the chemical cleaning and flushing system, and (4) certain pipe whip restraints.
Kuron Test.
at 4-5.
However, on cross-examination Mr. Kuron admitted that he had brought each of these allegations to the attention of the Staff previously in his February 1979 meetings with I&E inspectors.
Tr. 368-70.
Staff witness Wescott testified that the investigation of Mr. Kuron's allegations of defective welds did not reveal any non-compliance or deviations.
Wescott Test, at 19, Appendix A at 16, 17, 18-21.
Edison witness Alessi testified that all welds are tested for proper geometry and metallurgy by non-destructive techniques.
Tr. 301-302.
l l
36.
Mr. Kuron also expressed concern with alleged void areas in the concrete sacrificial shield wall.
Kuron Test. at 6-7.
This item also was a subject of the February 1979 meetings between Mr. Kuron and I&E inspectors.
Wescott Test., Appendix A at 22-24.
An I&E investigation on February _. _
28, 1979 identified two void areas in sacrificial shield wall compartments.
Id. at 23.
Edison witness Alessi testified that these void areas were not detected in the initial inspection following the grout placement because the responsible inspector had failed to examine two weep holes in the shield wall that were difficult to reach.
Tr. 333.
37.
As a result of the discovery of the void areas, Edison made a commitment to the Staff to reinspect the outer surface of the sacrifical shield wall to verify that all shield wall compartments were completely filled with grouting material.
Wescott Test., Appendix A at 24.
Edison's witness Street testified that the entire sacrifical shield had been reinspected, that the two void areas were filled with grouting material, and that a determination had been made that there were no more void areas in the sacri-ficial shield wall.
Tr. 333.
38.
CEE witness Kuron also expressed concern with the reliability of certain concrete anchors which he-referred to as " redhead" anchors.
Kuron Test. at 6.
Mr.
Kuron displayed to the Board a sample of the type of concrete anchor to which his allegation related.
Tr. 376.
Mr. Kuron alleged that such concrete anchors, which are widely used in the Fermi 2 plant (Tr. 391), were improperly -..
designed and manufactured, and that.t.ey would not hold a load.
Tr. 376, 377.
39.
The Board inquired of Staff whether it would be a matter of concern if the concrete anchors to which Mr.
Kuron referred were to fail in large numbers, and whether a high rate of failure had been experienced.
Witness Hawkins confirmed that a large failure rate would be a macter of concern, but Staff was not able to state what failure rate had been experienced during testing and inspection.
Tr.
391-393.
40.
Edison witness Street testified that the type of concrete anchor displayed to the Board was a self-drilling shell anchor.
Edison commonly used in the plant a brand of this type of anchor named Phillips Redhead.
Tr. 507-508.
In response to I&E Bulletin 79-02, Udison conducted a reinspection of all Class 1 pipe hangers in the plant that were held by that type anchor.
The i
failure rate during the reinspection was low.
Tr. 509-510.
t More importantly, when failure occurred it was because of improper installation, not because of a defect in the shell anchor.
Id.
The results of the reinspection were reported to I&E.
Tr. 507-509.
41.
Edison participated in an electric utility industry program in 1979 to demonstrate the capability of __
different anchor types, including the Phillips self-drilling shell anchor, under various loading conditions.
The program demonstrated the capability of the anchors to withstand cyclic loads without vibrating loose.
It also demonstrated that the anchors actually have a higher load capacity for dynamic loading than for static loading.
Id.
42.
In summary, the Board finds and concludes that Edison's Quality Assurance Inspection Program complies with Criterion X of Appendix B to 10 C.F.R. Part 50, that Edison's inspection program and the I&E inspection program provide adequate assurance that safety-related system conform to design standards, and that the alleged specific construction deficiencies described above either were unsubstantiated or have been investigated and adequately corrected.
Contention 4(b) is dismissed.
Maintenance of Quality Assurance Records 43.
Contention 4(c) states:
The Applicant has not maintained sufficient quality assurance records to furnish evidence of activities affecting quality to comply with Criterion XVII of Appendix B to 10 CFR Part 50 in that records have been destroyed or lost during the course of construction.
44.
In direct testimony, CEE alleged two incidents l
l in which it was contended quality assurance documents were l
I l i
?
\\
I
destroyed:
(1) an Edison official ordered the destruction of "two trailer loads" of quality records; and (2) a fire in Building 45A on December 16, 1978 was more extensive than was reported to the Commission and quality assurance documents were destroyed in such fire.
Kuron Test. at 3-4.
45.
Staff witness Phillips testified that both of these allegations were brought to the attention of I&E inspectors during their February 1979 meetings with Mr.
Kuron, and that the allegations were investigated at that time.
Phillips Test, at 20-22.
46.
In connection with the alleged destruction of documents in the two trailers, Edison witness Alessi testified that when the Ralph M. Parsons Company left the site when construction was suspended in 1974, personal records, working drawings and specifications, and milestone charts (schedules) were purposely burned, but none of these were quality assurance records which are required to be retained.
Original copies of all relevant documents were i
retained in Edison's Document Control Center.
Alessi Test.
at 7.
l 47.
I&E inspectors independently interviewed l
numerous project personnel, including persons who worked in the project record center at the time that records were burned and persons who were working at the record __
t center at the time of the investigation.
I&E inspectors also randomly sampled quality records for the relevant periods for completness and retrievability.
Approximately fif ty Commission inspection reports dating back to 1972 were also reviewed.
I&E concluded that only personal records and other non-permanent records were destroyed.
According to I&E inspectors, no permanent quality assurance records were destroyed and quality assurance record control at the project is adequate.
Phillips Test. at 20-21, Appendix A at 10-12.
48.
Edison reported the fire in Building 45A to the Commission on the same day that it occurred.
Phillips Test., Appendix A at 13.
There is no evidence that the fire was more extensive than reported by Edison.
I&E inspectors interviewed several persons who witnessed the immediate aftermath of the fire.
Their statements and description of the fire were consistent with the original report by Edison.
Phillips Test, at 22.
49.
The fire was caused by a faulty gas heater in the office of the piping contractor, Wismer and Becker.
Id.; Alessi Test. at 7.
Most of the records in Building 45A were in a fireproof file cabinet and were protected.
However, some Wismer and Becker welding process sheets and non-destructive weld examination reports, which were left on
. i
top of desks and in "In Baskets" over the weekend, were burned.
Records near the center of stacks were salvageable and many of those lost could be reconstructed by persons who had originally reviewed 'or signed those records.
Two records of non-destructive weld examinations could not be saved or reconstructed.
The welds involved therefore were re-examined to assure they were acceptable.
Phillips Test.
at 22; Alessi Test. at 7; Tr. 390-391.
50.
The Board finds and concludes that there is no evidence that required permanent quality assurance records have been destroyed by fire or otherwise.
Contention 4(c) is dismissed.
Replacement of Ralph M.
Parsons Company 51.
Contention 4(d) states:
Detroit Edison twice replaced the team of supervisors from the first general contractor, Ralph M. Parsons Co., then terminated its contract with Parsons and hired a second firm, because Parsons' employees refused to sacrifice quality control in order to expedite the construction schedule.
CEE's testimony did not provide any additional 52.
information to substantiate this contention.
See Kuron i
Test. at 22.
53.
Edison witness Fahrner testified that during the period that Ralph M. Parsons Company (" Parsons") was l
' 1
t the General contractor for the Fermi 2 project, Edison did request that two Project Managers for Parsons be replaced.
Mr. O. M. Hockensmith was replaced in April, 1972, at Edison's request because of his poor attendance at the Fermi 2 site.
In October, 1973, Edison requested that Mr. C.
B.
Antill be replaced because of his inability to maintain labor harmony at the Fermi 2 site.
Both requests were accepted by Parsons and both project managers were replaced.
Fahrner Test. at 3.
In neither case is there any evidence that the replacements were requested because Edison felt that these individuals were over-zoalous in the area of quality assurance.
Phillips Test. at 23-25; Appendix A at 9.
54.
In addition, there is no evidence that the replacement of Parsons as general contractor was motivated by quality assurance considerations.
From the beginning of the project until 1974, Parsons had general contractor responsibilities, and in addition, furnished personnel for quality assurance and quality control activity on the site.
Parsons was also the mechanical contractor for piping installation.
The suspension of construction in 1974 allowed Edison an opportunity to review its method of I
l contracting work on the project.
It was decided that a l
l !
l
i construction manager, not involved directly in performing construction, would produce better cost, iule, and quality control than the existing general contractor arrangement.
Based on a review of a number of contractors, Daniel Construction Company was selected to become the construction manager, and the general contract with Parsons was terminated.
Fahrner Test, at 1-2.
Parsons was nonethe-less invited to bid competively under the new system as a piping contractor, but declined to do so.
Id. at 2.
55.
Staff testified that I&E inspectors had reviewed the Parsons termination, but did not uncover any evidence that Parsons was ever requested by Edison to sacrifice quality control.
In the absence of any evidence that replacement of the contractor was so motivated, Staff concluded that Edison's decision to change contractors was not safety-related.
Phillips Test. at 23-25.
56.
The Board finds and concludes that there is no basis for the allegations that Parsons or its employees were replaced because they refused to sacrifice quality control in order to expedite the construction schedule.
Contention 4(d) is dismissed. l
Specific Construction Flaws 57.
Contention 4(e) states:
(e)
Specific flaws in construction can be identified, among them:
(1)
Excessive water in the reactor hole which caused the concrete base to crack severely, a problem purportedly remedied by patchings.
(2)
Hairline cracks in structural steel surrounding the dry well.
58.
These alleged construction deficiencies were investigated by the I&E investigation team which met with Mr. Kuron in February, 1979.
Phillips Test. at 26.
59.
With respect to the alleged water damage to the concrete reactor base, the record shows that in April, 1972, some months after the 4-foot thick concrete base slab for the Reactor Building floor had been poured, radial and circumferential hairline cracks were observed by Edison inspectors on the surf ace and it was also observed that small amounts of ground water was seeping onto the reactor basement floor.
Core samples revealed that the cracks extended anywhere from 6 inches to 3 feet in depth.
Alessi Test. at 9.
60.
An engineering evaluation of the problem indicated that the cracking may have been due to a com-bination of shrinkage strains during the curing of the l
l :
concrete and seasonal temperature fluctuations on a restrained slab.
However, the slab had not been subjected to significant hydraulic forces from the presence of ground water.
Id.
61.
Sargent and Lundy, the structural designers for the reactor building, performed a thorough analysis and concluded that the observed cracks did not impair the structural strength of the base slab.
Phillips Test. at 27.
62.
Edison undertook a program of drilling, pressure testing and repairing with grouting material all cracks in the base slab.
Phillips Test, at 28; Tr. 323.
The repairs were made with grout applied under high pressure.
Alessi Test. at 10.
The repairs were'not merely " patching."
63.
The cracks were carefully monitored for a period of three months (Tr. 322), and it was established that the situation had stabilized and no new cracks appeared.
Alessi Test, at 9.
I&E inspectors concluded that the monitoring program was adequate.
Tr. 394.-
64.
Even without repair of the cracks, if a pipe ruptured in the reactor building, there would be no outward leakage of radioactive water through the cracks in the floor of the building unless the basement became flooded so that the head of water inside was equal to or higher than..
that of the ground water outside.
Under normal plant operating conditions, this would require flooding in the basement to a depth of approximately 30 feet.
If flooding of this potential magnitude began to occur, the reactor would be shutdown and the water contained within the building would be processed through the radwaste system.
Even this potential leakage out of the building is possible only if the cracks were not repaired.
Phillips Test.
at 27.
65.
The Board finds that Edison has adequately repaired the concrete cracking in the Reactor Building base slab, that the repaired cracks do not impair the structural strength of the base slab or pose any danger to public health or safety, and that the evidence shows that no significant additional cracking is likely to occur.
Contention 4(e)(1) is dismissed.
66.
The record establishes that the hairline cracks in structural steel referred to in Contention 4(e)(2) were in clip angles which were welded to the ends of the girders in the slab-over-torus substructure of the reactor building and to the embedded plates in the inner and outer walls of the reactor building concrete structure to which the girders are attached.
Phillips Test. at 28-29.
67.
During routine quality assurance inspections Edison discovered that certain clip angles had developed fine cracks.
Id.
The problem was discussed with Staff as required by S50.55(e) of the Commission's regulations.
How-ever, Staff determined that the matter was a normal construction problem and not reportable under the Commission's regulations.
Alessi Test. at 10.
68.
Sargent and Lundy, the designer of the Reactor Building, re-evaluated the design of the welded connections of the clip anglcs to the steel girders and confirmed that the design was adequate.
Phillips Test. at 29.
They concluded that the hairline cracks were a result of excessive welding used in attaching the clip angles and defects in the clip angle steel.
Alessi Test. at 11.
69.
All welded clip angles which were not embedded in concrete were tested by liquid penetrant for cracks and were replaced or repaired.
Id.; Phillips Test.
at 29.
Excessive weld metal, where found on clip angles, was removed by arc-air gouging and chipping to assure compliance with design drawings.
Id.
Where the concrete slab had been poured and thus the clip angles were not accessible, steel beam seats were installed at each clip angle location.
These beam seats assure that the load would L
be safely carried even if the clip angles failed.
Alessi Test. at 11 and Figure 2.
The beam seats were welded to the exposed portion of the embedded wall plates without any
.rpairment or damage to the concrete slab.
Tr. 303.
70.
Staff stated that the repairs and modifica-tions made by Edison satisfactorily resolved this problem.
Phillips Test. at 30.
71.
The Board finds and concludes that the clip angle cracking in the dry well has been satisfactorily repaired.
Contention 4(e)(2) is dismissed.
Findings on Contention 8 72.
Contention 8, as stipulated by the parties and approved by the licensing board, reads as follows:
CEE is concerned over whether there is a feasible escape route for the residents of the Stony Point Area which is adjacent to the Fermi-2 site.
The only road leading to and from the area, Pointe Aux Peaux Road, lies very close to the reactor site.
In case of an accident, the resi-dents would ' have to travel towards the accident before they could move away from it.
73.
Applicant's testimony on Contention 8 was presented by Evelyn F.
Madsen.
Madsen Test., ff. Tr. 406.
Ms. Madsen was accompanied to the witness stand by Herbert Eugene Hungerford, Professor of Nuclear Engineering at
Purdue University, a consultant on radiation shielding and health physics; Andrew C.
Kanen, a Vice President of PRC Voorhees, a consultant on transportation and emergency planning; and Roger A. Nelson, a professional meteorologist.
Professor Hungerford co-sponscred Ms. Madsen's testimony on radiological dose evaluation (Tr. 406), and Mr. Kanen co-sponsored Ms. Madsen's testimony on evacuation time estimates (Tr. 405-06).
74.
The Staff's testi. mony on Contention 8 was presented by Rick J. Anthony, an Emergency Management Specialist with the Federal Emergency Management Agency; Thomas Urbanik, II, a transportation engineer with the Texas Transportation Institute at Texas A&M University; and Falk Kantor, an Emergency Preparedness Analyst with the Commission's Office of Inspection and Enforcement.
- Kantor, Urbanik, and Anthony Test., ff. Tr. 533.
75.
Testimony on behalf of CEE on Contention 8 was presented by witness Kuron, who is a resident of the Stony Point area.
Kuron Test., ff. Tr. 367, at 9-10.
76.
The Stony Point area referred to in Contention 8 is an unincorporated community located in Monroe County, Michigan south of the Enrico Fermi 2 site.
See Madsen Test., Figs.
1-3.
The area is bounded on the north by the _
plant site and on the east and south by Lake Erie.
The southern end of the area is a narrow peninsula extending into the Lake.
At the west, the area is bounded by marsh and wetlands, from which it is separated by a series of dikes.
See id., Fig. 7.
The principal north-south streets in the Stony Point area are Lake Shore Drive and Dewey Drive.
Lake Shore Drive begins at the end of the Stony Point peninsula and connects with Dewey Drive.
Dewey Drive in turn connects with Pointe Aux Peaux Road ("the Road").
See id., Fig.
2.
To the west of Dewey Drive, there are two separate residential areas, one bounded on the north by Shady Lane, and a second bounded by the south by South Street.
Dewey Drive is the only street connecting those two areas.
See id.
77.
The Road begins near the shore of Lake Erie and proceeds westerly for approximately 2.5 miles to an intersection with North Dixie Highway (M-50).
Kantor Test.
at 2.
For a distance of about one mile west from the intersection with Dewey Drive, the road parallels the south boundary of the Fermi 2 site.
See Madsen Test. Fig. 2.
The Road is the only connection for vehicular traffic to and from the Stony Point area.
See id. at 4 and Fig. 6; Kuron Test. at 9.
78.
The eastern end of the Road is about 1.25 miles away from the Fermi 2 plant.
Tr. 555-59.
Staff estimated that the Road is.9 miles from the plant at its closest point.
Tr. 557, 559.
Edison's testimony indicates that the Road is about 1.1 miles away from the plant's stack gas release point at its closest point.
See Madsen Test., Fig. 7.
79.
The current population of the Stony Point community was estimated by Staff to be 1,368 people based upon information from the Monroe County Radiological Emergency Response Plan ("the County Plan").
Anthony Test.
at 3.
Edison estimated the current population to be 1,400 people, based upon advance 1980 Census data, a count of electrical meters, and house counts.
Madsen Test. at 2; Tr. 412.
Edison also estimated the population residing in various segments of the Stony Point area, based upon site visits and examination of detailed maps of the area.
Madsen Test. at 2.
The area segment population figures are shown in Figure 4 appended to witness Madsen's prepared testimony.
80.
Staf f estimated the number of dwelling units based on 1973 data at 750.
Urbanik Test. at 2.
Staff i
l indicated that the number of houses in the area has declined i
since 1973.
Id.
! i 1
l
, = - -
L 81.
Based upon the assumption that there are 750
[
dwelling units and that 1.5 vehicles per household would be required for evacuation, Staf f estimated that 1,125 cars would be required to leave Stony Point in the event of an evacuation.
Urbanik Test. at 2-3, as corrected at Tr.
1125.
Edison estimated that about 600 cars would be used in the event of an evacuation.
Madsen Test. at 3 and Fig. 5.
Staff witness Urbanik agreed that Edison's esti-mate is based upon better data and is more likely to be accurate.
Tr. 566-67.
He testified that from 600 to 1000 cars might be used during an evacuation.
Id.
82.
Within the Stony Point area, the residence furthest from the Road is about one mile away.
Tr. 557-58; see Madsen Test., Fig. 7.
Over 80% of the area population lives within.75 miles of the Road (see id., Fig. 4), and over 80% of tha vehicles predicted by Edison to be used for evacuation would leave from points within.75 miles of the Road.
See id., Fig. 8.
Over one-third of the population would drive to the Road from points closer to the Road than the intersection of Shady Lane and Dewey Drive.
See id.,
Fig. 4.
83.
The carrying capacity of the Road and the principal streets in Stony Point connecting to it were analyzed by Edison and by Staf f.
Based upon the County,
~
I
Plan, Staf f estimated that the Road has an hourly carrying capacity of 1,200 vehicles.
Anthony Test. at 3.
Edison estimated that the carrying capacity of the Road is 1,200 vehicles per hour and that the carrying capacity of the streets within Stony Point is 900 vehicles per hour.
Madsen Test. at 5-7.
Those estimates are based upon average operating speeds of 15-20 miles per hour on the Road and 10 miles per hour within Stony Point.
Id. at 5.
84.
Edison provided a detailed analysis of anticipated traffic flow during an evacuation of the Stony Point area on a weekday and a weekend day.
Madsen Test. at 5-6.
On a weekday, the maximum traffic concentration is expected to be 180 cars arriving at the intersection of Dewey Drive and the Road during a 15 minute period.
Id.
On a weekend day, the anticipated maximum c0ncentration is 252 cars arriving within a 15 minute period.
Id. at 6.
Both maximum concentrations are well within the Road's carrying capacity of 300 vehicles per quarter hour.
Id.
The maximum weekend day concentration exceeds the 15-minute carrying capacity of Dewey Drive.
However, not all exiting traf fic would be on Dewey Drive; alternate routes to the Road are available beyond the intersection of Dewey Drive and Shady Lane, and over one-third of the area populatinn can drive to the Road without using Dewey Drive.
See id.,._
Figs. 2 and 4; Tr. 568.
Edison's conclusion that the entire population can be evacuated from the Stony Point area "[w]ithout any significant traffic delays" (Madsen Test. at 6) is therefore reasonable.
85.
Based upon anticipated traffic flow and the carrying capacities of the Road and the local streets within Stony Point, Edison and Staff provided estimates of the time that would be required to evacuate the entire population of the area in the event of an emergency.
Edison's estimate of travel time for the entire population is 1-1/4 hours.
See Madsen Test., Tables 1 and 2.
Staff's estimate of travel time is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with traffic control and 1-1/4 hours without traf fic control.
See Urbanik Test. at 4.
Staf f's estimate included consideration of other traffic moving on Dixie Highway.
Tr. 537.
86.
Staff stated that in the event workers at Enrico Fermi 2 were evacuated at the same time as Stony Point area residents, the travel time for both groups could be as much as 2-1/4 hours.
Staff witness Urbanik described this situation as a " worst case".
Tr. 539-40.
Staff's
" worst case" assumed that there would be no traf fic control at the intersection of the Road and Dixie Highway.
Urbanik Test, at 3.
Mr. Urbanik testified that, with traffic control at that point, "there would be no problem at all." f
~
Tr. 566.
Edison's witness Kanen pointed out that the intersection of the Road and Dixie Highway is a designated traffic control point under the County Plan.
Tr. 442, 87.
In addition, Staff's " worst case" assumes that plant workers and area residents would all commence evacuation at the same time.
This assumption does not appear to be reasonable.
It is likely that plant workers would in fact be notified to evacuate in advance of area residents (Tr. 442, 444-45), and would pass the inter-section of Enrico Fermi Drive (the exit route for plant workers--Tr. 479) and Dixie Highway and be out of the area prior to the arcival of Stony Point residents (Tr. 441).
88.
Accordingly, the Board finds that the entire population of the Stony Point area could be evacuated, using local streets and the Road, with a travel time of 1 to 1-1/4 hours.
89.
The foregoing assumes normal travel conditions.
Both Edison and the Staff addressed the effect of adverse weather conditions.
90.
Edison's analysis indicated that in adverse weather, traffic speed would not be significantly reduced, but headway ( the spacing between vehicles) would increase.
This would reduce the carrying capacity of local streets and the Road.
Madsen Test. at 6-7.
The number of cars traveling per minute would also decrease, but not as much.
Id. at 7-8.
Edison calculated that bad weather would produce an approximate 50% increase in travel times for individual vehicles, delays of up to 15 minutes at key intersections, but no increase in the overall time required for evacuation.
Id. at 8.
91.
Staff's estimates of travel time indicate that adverse weather would not increase overall travel time for traffic from Stony Point only, assuming travel control.
Urbanik Test. at 4.
Staff's other travel time estimates were increased by 15 minues to account for adverse weather.
Id.
92.
Concern was expressed over the possible adverse ef fect of heavy snow.
Heavy snow coincident with an evacuation would increase travel times by the amount of time required to clear the roads.
Urbanik Test. at 3.
Staff witness Kantor testified that he had driven in the Stony Point area during a period of heavy snowf all and had observed that the roads were open and well maintained and that there was no significant effect on driving times.
Tr.
569.
93.
Concern was also expressed about the possible impact of flooding.
It is undisputed that local flooding -
has occurred, and may occur again, in the Stony Point area.
See Tr. 481.
However, the Road would not be af fected by flooding, even in a 100-year flood.
Tr. 476.
The lowest point on the Road is above the 100-year flood level and 7.9 feet above the average level of Lake Erie.
Tr. 499-500.
94.
The Board finds that adverse weather would produce an increase in total time for an evacuation of no more than 15 minutes.
95.
Predetermined protective actions to be taken in the event of an en.ergency will be included in the Edison (onsite) and Michigan and Monroe County (offsite) emergency plans.
Kantor Test. at 3.
Protective actions for the Stony Point area include sheltering.(staying indoors),
precautionary evacuation before a significant release of radiation occurs, and sheltering during a release followed by relocation after the radioactive release plume has passed over the area.
Id. at 3-4.
Evacuation during a release would not normally be recommended.
Id.
96.
It is undisputed that, in order'to leave the area, Stony Point residents are required to drive toward the plant for a short distance.
In the unlikely event that an evacuation were in progress during a plume release of radiation over Stony Point, area residents would thus have to drive toward the radiation source.
The amount of time required to drive from the furthest residence in Stony Point to the Road is about six minutes.
Tr. 557, 563, 568.
The amount of time consumed in driving toward the plant would not cause a significant increase in total radiation dose.
Tr. 567.
No matter what the source, the incremental increase in dose would be relatively slight, less than 10 per cent.
Tr. 570.
The juxtaposition of the Road and the plant is not a limiting factor in the use of the Road as an evacuation route.
Tr. 554.
97.
Accordingly, the Board finds that driving toward the plant on local streets to get on the Road and on the Road for a short distance thereaf ter would not interfere with the use of the Road as an evacuation route.
98.
During the hearing, the Board expressed its concern about the impact at a delay in notification on the feasibility of using the Road as an evacuation route.
See Tr. 554-56.
Witness Madsen informed the Board that Edison assumed that, in the event of an emergency situation at the plant involving the possibility of a significant release of radiation off-site, the plant operator would notify the Governor of Michigan within 15 minutes and the Governor (the only person under Michigan law who can do so--Madsen Test. at 9) would promptly authorize an evacuation.
Tr. _.
451.
However, during the first full-scale exercise of the emergency p'lans for the plant, the Governor's office took 45 minutes to decide upon an evacuation.
Tr. 445.
Witness Hungerford acknowledged that a delay in notification could increase the total radiation dose that would be received during an evacuation.
Tr. 461-62.
99.
The Board therefore inquired of Staff whether a delay in notification would affect the adequacy of the Road as an escape route.
Witness Kantor responded that the adequacy of the Road is independent of the notifi-cation time.
Tr. 554.
The Road would be a viable evacuation route regardless of when the decision to evacuate were made.
Tr. 556.
100.
As part of its Contention 8 testimony, Edison presented an evaluation of the radiation exposure that residents of the Stony Point area would receive in the event of a hypothetical accident.
Madsen Test. at 11-14.
The Board expressed reservations concerning the acceptability of the Edison study.
Tr. 524.
Witness Kantor testified that Staff had not independently done a similar analysis.
Tr. 545.
Having reviewed the Edison analysis, with knowledge of the assumptiens used concerning source terms and meteorology, he saw no reason to disagree with the results.
Id.
~
101.
Staff testified that it does not make specific dose calculations for particular areas within the 10-mile emergency planning zone.
Tr. 546.
Emergency planning criteria are developed generically based upon a broad spectrum of possible accidents, including accidents far more severe than the hypothetical accident used as a basis for the Edison study.
Tr. 551.
Dose evaluations are important in deciding whether or not to order an evacuation.
Tr. 546-47.
If it were determined that the Stony Point i
area should be evacuated, the Road would be used; the feasibility of its use would not be affected by thc dose calculation.
Tr. 548, 554, 556.
102.
Both the Applicants and the Staf f take the position that a dose evaluation study is irrelevant to a determination of the feasibility of the Road as an escape route.
Tr. 526, 573-75.
Applicants' attorney explained that the dose evaluation study was included in Edison's testimony to address the possibility that the Board would find that the Road is not a feasible escape route and that construction of an alternate route for evacuation sSould be considered.
Tr. 573-74.
CEE asserts that a dose evaluation is necessary to determine whether requiring residents of the Stony Point area to drive toward the plant during an evacuation makes the Road unfeasible as an escape route.
Tr. 575-76.
103.
The Board agrees with the Applicants and the Staff that, in the circumstances of this case, further consideration of Edison's dose evaluation study is not required.
104.
In summary, the board finds and concludes that the use of local streets and the Road will provide a feasible escape route for the residents of the Stony Point area, that the proximity of part of the Road to the plant site is not a limiting factor, and that the fact that area residents would be required to drive a short distance toward the plant before moving away from it would not interfere with the use of the Road as an evacuation route.
Contention 8 is dismissed.
Ultimate Findings And Conclusions 105.
The Board finds and concludes that no issues have been raised in this proceeding that demonstrate that the possession, use, and operation of the Enrico Fermi Atomic Power Plant, Unit No. 2 by Applicants would present undue risks to the health and safety of the public.
106.
The Board concludes that, based on its review of the entire record of the proceeding and on the foregoing findings of fact, the Application and the proceeding to date comply with the requirements of the Atomic Energy Act of 1954, as amended, and the Commission's Rules and Regulations.
The Board, in issuing this Initial Decision, has limited itself to those issues admitted as contentions in this proceeding.
Order WHEREFORE, IT IS ORDERED that the Director of Nuclear Reactor Regulation is hereby authorized to issue to Applicants a license to possess, use, and operate the Enrico Fermi Atomic Power Plant, Unit No. 2 pursuant to Section 103 of the Atomic Energy Act, subject to the provisions of 10 C.F.R.
S2.764(f)(1)(i).
IT IS FURTHER ORDERED that in accordance with 10 C.F.R.
SS2.760, 2.762, and 2.764 this Initial Decision shall be effective immediately and shall constitute the final action of the Commission thirty (30) days after the date of issuance hereof, subject to any review required or permitted by 10 C.F.R. Part 2.
Exceptions to this Initial Decision may be filed by any party within ten (10) days after service of this Initial Decision.
A brief in support of the exceptions must be filed within thirty (30) days thereafter, forty (40) days in the case of the Staff.
a Within thirty (30) days after service of the brief of appellant (forty (40) days in the case of the Staf f), any other party may file a brief in support of, or in opposition to, the exceptions.
Respectfully submitted, LeBOEUF, LAMB, LEIBY & MacRAE By QAfu(
19 (
c a
Of Counsel:
1333 New Hampshire Avenue, N.W.
Suite 1100 L. Charles Landgraf Washington, D.C.
20036 (202) 457-7500 Peter A. Marquardt Attorneys for Applicants Bruce R.
Maters The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 May 3, 1982
+
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
THE DETROIT EDISION COMPANY,
)
Docket No. 50-341 et al.
)
(Operating License)
(Enrico Fermi Atomic Power
)
Plant, Unit No. 2)
)
CERTIFICATE OF SERVICE I hereby certify that I have this 3rd day of May, 1982, served the foregoing document, entitled " Applicants' Proposed Findings of Fact and Conclusions of Law in the Form of a Proposed Initial Decision" by mailing copies thereof, first class mail, postage prepaid, and properly addressed, to the following persons:
Gary L. Milhollin, Esq.,
Dr. Peter A. Morris, Chairman Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board 1815 Jefferson Street U.S. Nuclear Regulatory Madison, WI 53711 Commission Washington, DC 20555 Dr. David R.
Schink Administrative Judge Chairman, Atomic Safety and Department of Oceanography Licensing Board Panel Texas A & M University U.S. Nuclear Regulatory College Station, TX 77840 Commission Washington, DC 20555
e Chairman, Atomic Safety and Monroe County Library System Licensing Appeal Board Panel Reference Department U.S. Nuclear Regulatory 3700 South Custer Road Commission Monroe, Michigan 48161 Washington, DC 20555 David E.
Howell, Esq.
Stuart A.
Treby, Esq.
3239 Woodward Avenue Office of the Executive Berkley, Michigan 48072 Legal Director U.S.
Nuclear Regulatory Commission Washington, DC 20555 Colleen Woodhead, Esq.
Office of the Executive Legal Director U.S.
Nuclear Regulatory Mr. Robert J.
Norwood Commission Supervisor Washington, DC 20555 Frenchtown Charter Township 2744 Vivian Road Monroe, Michigan 48161 Secretary Nuclear Regulatory Commission Washington, DC 20555 Attn:
Docket and Service Section (orig plus 20)
Y L. Charles Landgraf
/p r LeBOEUF, LAMB, LEIBY & MacRAE Attorneys for Applicants l
_J