ML20069L963
| ML20069L963 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/15/1982 |
| From: | Bird W, Wheeler R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20028A330 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8211180362 | |
| Download: ML20069L963 (40) | |
Text
> .< ~
11/15/82 D$ ?
UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSIOy;, g 01d eq u -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket Nos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM
) 50-329-OL (Midland Plant, Units 1 ) 50-330-OL and 2) )
TESTIMONY OF W. BIRD AND R. WHEELER CONCERNING NCR #M01-4-2-008 (Rev. 1) (February 25, 1982), NCR #MOl-9-2-038 (March 8, 1982),
NCR #MOl-9-2-051 (April 21, 1982), BECHTEL NCR #4199 (including stop work order FSW-22) ,
and BECHTEL NCR #4245 Q.l. Please state your names and jobs.
A.l. My name is Walt R. Bird. I am Manager, Midland Project Quality Assurance Department ("MPQAD") . My resume is attached.
I have reviewed and am familiar with the nonconformance reports listed above. These nonconformance reports are included as Attachments 7A, 7B, 7C, 7D and 7E to the Testimony of R. J. Cook, R. B. Landsman, R. N. Gardner and W. D.
Shafer with respect to Quality Assurance as filed on October 29, 1982, and therefore they are not included in this testimony.
My name is Robert M. Wheeler. I am Soils Section Head in Consumers Power Company Midland Construction Department.
I am a graduate of Michigan State University with a Bachelors degree in Civil Engineering and have over 8 years experience i ' ~~.
["PDR ADOCK82ii'18'0362820 l 05000329 i PO8 PDR ,
in nuclear power olant construction. My responsibilities include implementation of the NRC-CPCO Work Authorization Procedure dated'Auaust 12, 1982, and I am-involved with the Excavation Permit System, FIC 5.100, described in this testimony.
Q.2. Mr. Bird, can you please explain the purpose of this testimony?
A.2. The purpose of this testimony is to provide additional information on these nonconformance reports as requested by the Licensing Board in its July 7, 1982 Memorandum and Order.
Q.3. Gentlemen, have you read the October 29, 1982 testimony of Dr. Landsman (Question and Answer 5) with respect to these nonconformance reports and do you agree with him?
A.3. We have read it and we agree with Dr. Landsman.
Q. 4. Mr. Bird, can you please describe NCR #MOl-4-2-008 and NCR #MOl-9-2-038.
A. 4. NCR #MOl-4-2-008 (Landsman Attachment 7A) concerns a forty-two inch - forty foot deep hole which was drilled to provide a construction aid to assemble construction equipment. It was Bechtel's construction practice at that time that control of such excavations was by Field Engineering ("FE") and a FE-ad-ministered excavation permit system was in place and used in this case. The FE system involved checking to ensure no underground utilities would be contacted. Moreos.r, the applicable Bechtel specification, C-211, required that backfilling of such ex-cavations meet certain requirements including the involvement
of the On Site Geotechnical Engineer. However, the drilling itself of the hole was not required to be done under the supervision of the on-site Geotechnical Engineer.
NCR #MOl-9-2-038 (Landsman Attachment 7B) concerns drilling of two four inch by forty-eight foot test borings to obtain information on soil conditions in the vicinity of the freezewall. One of these holes was in Q fill, one was not. The method used for drilling and soil stabilization was not specifically covered by instructions, procedures or drawings for the two borings, but was in accordance with current accepted construction practice. While NCR #MOl-9 038 states that "The on-site Geotech was not aware of the drillings or grouting of [the hole in Q Fill)," Bechtel has since provided information indicating that the on-site Geotech was present for the grouting of the hole in Q-fill.
These two nonconformance reports were written because it was my position and MPQAD's position that there should be specific controls pre-established and documented for excavation, including drilling, in Q-fill areas as such activitics (even though not themselves safety-related) could affect the quality l of the fill and could potentially damage Q-listed utilities, j This position has prevailed and is specifically provided for by FIC 5.100 entitled Excavation Permit System. (Attachment i
- 1) The earlier FE-administered system was not included in l
the formal Quality Program and did act include the rigorous requirements presently adopted in Attachment 1.
i I
l l
I l t 1
y.
4_
Q.5. Mr. Bird, can you please describe Bechtel NCR
- 4199 and #4245 (Landsman Att'achments 7E and 7D respectively.)?
A.S. Bechtel nonconformance reports #4199 and #4245 cover damage to a "Q" deep electric duct bank and a void adjacent to the upper portion of the permanent observation well OBS #4.
The duct bank was damaged on April 24, 1982, during drilling of an ejector well for the freeze wall monitoring pit. This happened because the drilling rig was mispositioned by a couple of feet. The root cause of the nonconformance was that the procedural control to not drill closer than two feet to any known buried utility for vertical holes was not adequately implemented. When obstruction was encountered Field Engineering apparently believed that they were hitting a concrete overpour around the duct bank rather than the duct bank itself. They continued drilling until drilling fluid
- was lost. Subsequently the fluid was observed in the auxiliary building and it was ascertained that the drill had hit the edge of the duct bank. Consumers Power Company Site management stopped further addition of drilling fluid on April 28, 1982 as a result of their involvement in the immediate investigating of the drilling fluid found in the auxiliary !
building. The CPCo Site Manager issued a letter on April 28, confirming the verbal stop work directive applicable to j all drilling operations and sheet-piling activities by l
Mergantime Corporation and its subcontractors, in all Q and i non-Q areas. MPQAD management later issued a formal Quality I l Stop Work Order to provide tracking and close-out of the l
corrective action required to lift the stop work. The stop work order was subsequently lifted based on further training and implementation of the excavation permit procedure FIC 5.100 described below.
With respect to NCR #4245, the void associated with observation well f4 appears to be a localized phenomenon near the surface of the well, which was observed on May 11, 1982 during drilling. This void is apparently only indirectly related to another condition associated with OBS #4 observed at approximately the same time, that being the penetration of a twelve inch non "Q" condensate drain line at a depth of 38 ft. The striking of the line and associated vibration may have contributed to the void formation. The remainder of the void is thought to be from material removal resulting from the drilling process. A final Engineering Report on this subject awaits completion of probing to determine the extent of soil disturbance. The specification for well drilling has been revised to restrict the position of the bailer in relation to the bottom of the casing which should limit excess soil removal for any future application of -this drilling technique.
The review prior to drilling for utilities in the vicinity of OBS#4, missed the condensate line because the drawing showing this line was not on the list of drawings requiring review. The new excavation permit system (Attach-ment 1) has attached to it a listing of drawings, by discipline, which represents the most complete information available on all underground utilities at the Midland site.
t Q.6. Mr. Bird, can you please describe what happened
'in NCR #MO1-9-2-051 - (Landsman Attachment 7C) ?
A. 6. During the excavation and/or concrete removal of an existing electrical duct bank adjacent to the southwest-corner of the bcrated water storage tank valve pit, a small void was created beneath the' southwest corner of the Borated Water Storage Tank valve pit. The void created beneath the valve pit corner was approximat'ely two feet (maximum) in depth and '
extended approximately one and a half feet (maximum) horizontally beneath the foundation.
Immediate corrective action was taken, as indicated in block 34 of this NCR, to correct the void created. This NCR also indicated the need to revise the Field Engineering -
administrated excavation permit system to address stricter controls for the protection of structures or utilities encountered within the confines of the excavation or in the proximity of the excavation. This concern was addressed in the preparation of FIC 5.100 (Attachment 1), the new excavation permit procedure. Some examples of revisions in the excavation permit procedure are as follows: The new excavation permit procedure, specifically section.6.5, requires the on Site Geotechnical Engineer to determine the influence of the proposed work on adjacent structures or utilities and whether the proposed action to be taken is adequate. The new excavation permit procedure, specifically 6.7, also requires a signature by MPQAD for excavation permits in Q-listed areas. This
}
sign-off indicated an awareness of the work and that app-ropriate plans to provide QA/QC coverage will be available.
The new excavation permit procedure, specifically 6.9, also more descriptively states the requirements for the monitoring performed by the Onsite Geotechnical Soils Engineer.
Q.7. What specific corrective action has been or will be taken to remedy nonconforming or indeterminate conditions resulting from the incidents described above?
NCR #MO1-4-2-008 (the 42" by 40 ft. deep hole drilled as a construction aid), NCR #MOl-9-2-038 (the test boring in Q. fill), NCR #4199 (the "0" deep electric duct bank), and NCR #4245 (the void associated with observation well OBS #4) all have resulted in disturbed soil conditions which may require further investigation, excavation and backfill. The damage to the "Q" leep electric duct bank must be evaluated and repaired. Plans are now being prepared by Bechtel to carry out such repair work. Such work will, of course, be subject to the NRC-CPC work authorization procedure and the excavation permit procedure FIC-5.100 described in this testimony.
The small void under the BWST valve pit corner has already been corrected.
Q.8. Mr. Wheeler, can you please describe the procedures which have been implemented to correct problems associated with drilling operations to protect existing buried installations?
A.8. Bechtel procedure FIC-5.100 entitled " Excavation
i Permit System" Rev. 1 dated June 24, 1982 (attachment 1) has been issued to provide protection of existing buried installations. The scope of this procedure covers all excavations in "Q" and non-Q soils areas. All anticipated excavations including drilled holes, pile driving and open pit excavations, are subject to the requirements of the procedure and a permit with the proper signatures are ob-tained before commencement of the work. The necessary signatures include the following:
A. Bechtel Field Engineering's signature indicates that there has been a review of existing underground utilities and appropriate action taken to protect them. FE also identifies any structure or utility which will be encountered within the confines of the excavation.
B. Bechtel lead Civil Engineer's signature shows that he has examined the need for additional procedures.
C. Bechtel Onsite Geotechnical Engineer determines the influence of the proposed work on adjacent structures
- or utilities and whether the action to prevent any such damage is adequate.
D. CPCo construction signs off as verification that the work is authorized by NRC.
E. MPQAD sign off (which is required only for work in Q soils) indicates an awareness of the work and that appropriate QA/QC coverage will be available.
F. .. .
1 In addition to the excavation permit system described above, on August 12, 1982 a joint URC Region III and CPCo work authorization procedure was instituted to avoid any misunderstandings as to the work which has been authorized by the NRC. The NRC and CPCo work Authorization Procedure requires that CPCo submit a written list of activities anticipated over the next 60 days to the NRC at the beginning of each month.
NRC authorization for the submitted work activities is provided in writing. Work will not commence on any work activity unless written authorization is received from the NRC Region III.
A copy of this Work Authorization Procedure is included as Attachment H to the testimony of James G. Keppler dated October 29, 1982.
In order to control the ASLB Order work activities with Bechtel, a separate administrative guideline entitled
" Soils Work Permit System" was issued and implemented. This system requires Bechtel to provide notification to affected parties of planned work and to obtain CPCo construction approval of the planned work.
The NRC/CPCo work authorization procedure and the Bechtel/CPCo soils work permit system provide adequate controls to ensure that only NRC authorized work may be implemented.
I am personally responsible for seeing to it that these two work authorization procedures are followed, and I am confident that they will be followed.
c- . .
. . . w Q. 9. Gentlemen, based on the procedures outlined above, do you believe that these are adequate controls to prevent damage to underground utilities?
A. 9. Yes. We believe this is true even though it can be expected that some temporary or non-Q underground utilities may continue to be encountered during drilling or excavation operations. Unfortunately our records for non-Q or temporary utility buried installations are not good enough to.com-pletely eliminate any chance of such occurrences. However, the excavation permit system procedure requires that after encountering a utility concurrence to proceed must be obtained by three organizations including MPQAD. The procedure requires a conscious formal assessment and disposition of any encountered utility.
It also should be noted that any utilities which might unexpectedly be encountered during the Service Water Pump Structure and Auxiliary Building underpinning are addressed and dispositioned via Specification 7220-C-200 (Q) entitled " Technical Specification for Identification and Initiation of Administrative Action and Corrective Measures for Underpinning Activities at the Auxiliary Building, Feedwater, Isolation Valve Pits and Service Water Pump Structure" (App. E. , pp. E-2 and E-3) . A copy of Specification j 7220-C-200 (Q) is included as Attachment 2 to the October 29,
,! 1982 testimony of R. J. Cook, R. B. Landsman, R. N. Gardner,
) and W. D. Shafer. Therefore, we believe we are adequately l
l prepared for this contingency if it arises during the
! underpinning work.
T a: n' '
.- p>, L v%cle-.
f CHANGE SHEET i lk 2* CHHNGE StueI l PROCEDURE: f)[- 5,jgg REV No: /
CON s ROLLED i Field Procedure Eye. perm, r is changed as foiro w s: i
'Anaekmen+ c" ic ius pro cedu e< shall be -u meNAeA a.s .sb own on /he a (d'a } copy. l. .
I l
i i
I i
I t
I ..
t l I
I l b
t i
l f
~" of W. Bird & R. Wheeler 'l;
- - - - - Testimony'
~
,' Attachment 1 11/1.5/82 '
l Scental Power Corporation ~
al:nc Project Unrts 1 & 2 ~pg g/ __.
j Joe 7020 c .3 1 n_
FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities . . _ _
Multi-Di scipline FSK-CY-52, sheet 1 FSK-CY-52, Sheet 2 . _ -
FSK-CY-52, Sheet 3 FSK-CY-52, Sheet 4 FSK-CY-52, Sheet 5 FSK-CY-52, Sheet 6 FSK-CY-250 FSK-CY-251 FSK-CY-252 FSK-CY-253 .
FSK-CY-254 FSK-CY-255 FSK-CY-256 FSK-CY-257 FSK-CY-258 FSK-CY-259 FSK-CY-260 FSK-CY-261 FSK-CY-262 FSK-CY-263 FSK-CY-264 FSK-CY-265 FSK-CY-266 FSK-CY-267 FSK-CY-268 FSK-CY-269 FSK-CY-270 FSK-CY-271 FSK-CY-272 FSK-CY-273
- FSK-CY-274 D-126-11
FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities Civil C-3 C-4 C-5 C-6 C-7 C-8 C-42 C-43 C-46 C-51 C-52 C-57 C-71 C-82 C-91 C-92, Sheet
- C-92, Sheet 2 C-92, Sheet 3 C-93 C-131 C-132 '
C-133 C-134 C-135 C-699 C-987 C-992 C-993, Sheet 1 C-998 C-1190 C-1310 C-1311 C-1312 C-1313 C-1314 C-1315 C-1316 C-2016
- C-2017 C-2018 C-2019 7220-C-195-36 C - 12 7 C - 12 g D-126-11
FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities ,_
Electrical E-500, Sheet 2A E-500, Sheet 2B E-500, Sheet 2C E-500, Sheet 2D E-500, Sheet 2E E-500, Sheet 3A E-500, Sheet 3B E-500, Sheet 3C E-500, Sheet 4A E-500, Sheet 4B E-500, Sheet 4C E-500, Sheet 4D E-500, Sheet 5A E-500, Sheet 5B E-500, Sheet SC E-500, Sheet SD
- E-500, Sheet SE E-500, Sheet 12 E-501, Sheet 1 E-501, Sheet 2 E-502, Sheet 1 E-504, Sheet 1 E-505, Sheet 1 E-506, Sheet 1 __
E-508 l
E-509, Sheet 1 E-510, Sheet 1 E-511 E-512, Sheet 1 E-513, Sheet 1 E-520 E-521, Sheet 1 E-522, Sheet 1A E-522, Sheet IB E-522, Sheet IC l E-522, Sheet ID l E-522, Sheet 2A l E-522, Sheet 2B E-522, Sheet 2C E-522, Sheet 3 1
D-125-11 l
c .
FIC - 5.100 Attachment C P.ev. 1 List of Reference Drawings For Underground Utilities Electrical E-523, Sheet 1 E-523, Sheet 3 E-526, Sheet 1 E-526 Sheet 2 E-526, Sheet 3 E-526, Sheet 4 E-526, Sheet 5 E-526, Sheet 6 E-526, Sheet 7 E-527, Sheet 1 E-527, Sheet 2 E-528, Sneet 3 E-529, Sheet 1 E-529, Sheet 2 E-530, Sheet 1 E-530, Sheet 2 E-531, Sheet IA E-531, Sheet IB E-531, Sheet IC E-531, Sheet 1D E-531, Sheet 2 E-532, Shedt 1 E-543, Sheet 1 E-547, Sheet 1 l
l E-594, Sheet 1 E-595, Sheet 1 E-596, Sheet 1
- E-600, Sheet 1 E-601, Sheet 1 E-698, Sheet 1 E-698, Sheet 2 E-698, Sheet 3
, E-698, Sheet 4 l E-699, Sheet 1 E-699, Sheet 2 FSK-EY-3 FSK-EY-9 l FSK-EY-17 't FSK-EY-38 FSK-EY-45 l F6l(-EY M 5A"i/
l l D-126-11
~^
l 1
1 FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground' Utilities Mechanical 558, -Sheet 1 1 N 58, Sheet 2 M-152 N165 N166 N167 N168 N169 -
M-170, Sheet 1 M-170, Sheet 2 N607, Sheet 16 N 612, Sheet 7 5 612, Sheet 8 N613, Sheet 7 N 613, Sheet 8 N649, Sheet 1 N 649, Sheet 2 5649, Sheet 3 N 665, Sheet 1 ,
FSK-MPY-16, Sheet 1
. FSK-MPY-16, Sneet 2 .
FSK-PFY-18 . . .
FSK-MP Y-24 FSK-MPY-29 -
FSK-MPY-32 FSK-MPY-33 FSK-MPY-45 FSK-MP Y-46 FSK-MP Y-72 FSK-MP Y-98 FSK-MPY-108 FSK-MP Y-165 FSK-MPY-166 FSK-MP Y-167 FSK-MPY-168 FSK-MPT-1-1 FSK-MPT-1-2, Sheet 1 FSK-MPT-1-2, Sheet 2 FSK-MPT-1-2, Sheet 3 FSK-MPT-1-2, Sheet 4 D-126-11
FIC - 5.100 Att' nment C Rf 1 List of Reference Drawings For Underground Utilities Mechanical FSK-MPT-1-35 O J 8 D - 1/ 7 - /
FSK-MPT-2-1 / C C B 4 FSK-MPT-2-2 FSK-MPT-2-4 2CCB 4 FSK-MPT-2-44 Sheet 1
. FSK-MPT-2-44, Sheet 2 FSK-SP-561, Sheet 3 FSK-M-2HBC-4-2 FSK-M-2HBC-4-3 FSK-M-2HBC-497-1 FSK-M-2HBC-497-3 FSK-M-2HBC-498-1 FSK-M-2HBC-498-2 FSK-M-0CCC-1-1
_ r er u._r - +
FSK-M-1HBC-3-2 FSK-M-1HBC-3-3 FSK-M-1HBC-3-4 FSK-M-1HBC-4-2 FSK-M-1HBC-4-3 Fe5 M-1HBC-4-4 FSK-M-1dBC-497-1 FSK-M-1HBC-497-2 FSK-M-1HBC-4 98-1 FSK-M-1HBC-498-2 FSK-M-1HBC-498-6 FSK-M-2HBC-3-2 FSK-M-2HBC-3-3 I HS C 1
( l HBC 5 I HBC -497-3 i HB C - 4T8-3 2 HBC /
2 HB C. 4 2 HB C 1
'I 2H6C ~4-A 2 HSC -49 7-3l 2 HBC -498 -3 D-126-11
l CHANGE SHEET PROCEDURE: Fic 5.100 REV NO: l Field Procedure is changed as follows:
AcAA u 44tc.chrm4 C p'Sc 6 PC S.100
- pgK.-M9Y-17 0 e.
l j
l g % y g M 2 d i a r.d ? cyect U.h : 3
,s ~~v g, 2 {l(- g [QQ
-w s s
.I r - _ . _ - _ . .
.T *l: '
- M a 7/sL l ( ~~
- -- . _ .. _ _ . . ...EV_f..__DATE /E2n p Ac,E i- l er l l,
FIC- 5.100 CONTROLLED w.t 6/24/82 QUAUTY REATED Bechtel Power Corporation Field Instruction FIC - 5.100 Rev. 1 Excavation Permit System T0; All Field Engineers and Construction Superintendents 1.0 Purpose To provide instructions for the proper application, approval, and use of the Excavation Permit. The Permit is intended to prevent disturbance of foundation subgrade for structures, maintain the integrity of compacted backfill, protect existing buried installations, and therefore, the health and safety of personnel, and to provide notification to affected parties of planned work.
2.0 Scope The Excavation Permit as delineated in this Field Instruction is required for all excavations in both "Q" and Non-Q soil areas. Tunneling as required for underpinning of the Auxili-ary Building and excavation and tunneling associated with underpinning of the Service Water Pump Structure (SWPS) and rebedding or replacing the adjacent Service Water Piping, is not included. These excavations are covered by the design documants for these activities.
3.0 References 3.1 Specification 7220-C-211Q - Technical Specification for Bechtel.
D-126-11
FIC-5.10g Rdv. O Page 2 3.2 FIC - 1.000 - Q-Listed Soils Placement Job Responsi-b111 ties Matrix.
3.3 EDPI 2.14.7 - On-Site Geotechnical soils Engineer for Midland Backfill and Laboratory Testing 3.4 Design Drawing C-45 -
Class I Fill Material Areas 4.0 Definitions 4.1 Excavation - as used in this Field Instruction, exca-vation is a general term for removal or displacement of soil by any means, to any final dimensions. Exca-vations covered by tnis Field Instruction can be categorized as one of the following three types.
4.1.1 Drilled holes - any circular excavation ,
vertically or at an angle into the soil by drilling, driving, or jetting methods.
4.1.2 Pile Driving - as used in this Field In:truc-tion is the mechanical insertion of sheetpil-ing or load-bearing piles wnether of timber, concrete, steel, or composite construction.
4.1.3 Open Pit Excavations - all other excavations not covered by section 4.1.1 or 4.1.2. .
Methods of excavation include power shovel,
! draglines, clamshells, hoes, trenching machines, etc.
l 5.0 Responsibility i 5.1 The Project Field Engineer is responsible for the direction and implementation of this Instruction.
5.2 The Lead Civil Field Engineer is responsible for the following:
5.2.1 Mainteining the log and numbering system.
I D-126-11
FIC-5.10%
Rev. 1 Page 3 l 5.2.2 Determining whether additional procedures are required.
5.2.3 Issuing and distributing the pennit applica-tion only when all appropriate signatures have been oDtained.
5.2.4 Maintaining a file of approved permits.
5.2.5 Ensuring that Section 5.3.3 has been adhered A
/'\
to by the originator before signing off the Excavation Permit.
5.3 The originator of the excavation permit is responsible for complying witn this Instruction in regard to the foll owing:
5.3.1 Filling out the excavation Pennit.
5.3.2 Obtaining proper signatures prior to starting the work.
5.3.3 Processing a procedure / instruction change sheet in accordance with FIG-1.120 when under-h ground utilities for which he is filling out an Excavation Permit is shown on a drawing tnat is not listed in Attachment C.
j 6.0 Method of Processing Permit I
6.1 The originator fills in his name, the date, and the j following on the attached form:
6.1.1 "Date Work to be Started" - obtained from Supervision. This is a forecast only and is dependent upon complete sign-off of the Permit prior to start of work.
6.1.2 " Purpose of Excavation" - the reason for the excavation including drawing references, if
, applicable, must be stated here. If the l drawings referenced show underground utilities and are not listed in Attachment C they should be added to Attachment C of this procedure.
D-126-11 l
l
FIC-5.100h Rev. 1 Page 4 T51s is to be accomplished by the originator prt,c-mng a procedure / instruction change sheet in accordance witn FIG-1.120. This requirement includes, but is not limited to all new designs for underground utilities whether issued by Project Engineering or the field.
The work item which is to be placed within the excavation is to be noted on the Excava-tion Permit under this section.
- 6.1.3 " Location and Limits of Excavation" - this description shall give the limits of excava-tion in tems of yard coordinates. Depth shall also be specified. A sketch will be used if a written description cannot be made clear. Any structures or known utilities in the proximity of the proposed excavation snall be noted. Variations in these limits are per section 7.3.
6.1.4 " Method of Excavation" - such as power shovel, dragline, clamshell, hoe, trenching machine, auger drilling, rotary drilling, jetting, etc.
If sheetpiling or any other method of slope control is to be utilized, it should be noted here. -
6.1. 5 "Q-List" - Yes or No. This refers to the soil. Civil design drawing C-45 should be consulted for limits of Q-listed soil. If any portion of the excavation falls within the limits of the Q-listed soil, this will be marked "Yes".
6.1.6 If the excavation is a drilled hole, the back page of of the Permit shall be completed.
6.2 The form is then routed by the originator for signa-tures by Supervision, Field Engineering, and the Onsite Geotecnnical Soils Engineer, as noted on the Permit.
D-126-11
\
l FIC-5.10h Rev. 1 Page 5 1
6.3 As noted on the fom, the signatures by Bechtel Super-and Bechtel Field vision, (i.e. Superintendents)f Engineering signify a review o existing underground installations and appropriate action taken to protect them. Any structures or utilities which will be encountered within the confines of the excavation or in the proximity of the excavation will be noted and initialed under the " Remarks" section and the appro-priate drawing numbers noted therein. Any appropriate
, action to be taken should be noted under the " Remarks" A
/i\
section also (attach additonal sheets if necessary).
The list of drawings in Attachment C shall be utilized by each Discipline Field Engineer in this sign-off process.
6.4 It is the responsibility of tne Lead Civil Field Engineer before he signs to review for the need of procedures. These may be beyond design requirements.
Of particular concern is deep drilled holes by Sub-contractors. Also, the Lead Civil Field Engineer is to ensure that Sections 5.3.3 and 6.1.2 concerning updating Attachment C have been adhered to by the orginator before signing off the Excavation Permit.
6.5 Tne OGSE detemines the influence of the proposed work on adjacent structures or utilities and whether proposed 4
action to be taken is adequate.
, 6.6 The sign-off by CPCo Construction is for verification @
that the excavation and all work associated with the A
/I\
excavation through completion of backfill is within the scope authorized by the NRC.
6.7 When the Q-listed section is checked yes, a signature by MPQAD is required. This sign-off indicates an awareness of work and that appropriate plans to provide QA/QC coverage will be available.
l 6.8 After all signatures have been obtained, copies must be routed as noted by the originator. prior to start l of work.
6.9 All excavations and backfill are monitored by the Onsite Geotecnnical Soils Engineer to verify that work is performed in accordance with the approved permit and References 3.1 through 3.3.
l l
D-126-11
. . _ _ , - , , . - . .,_r . . , . . . . .<_
- - _ . . _ _ - , _ _ , _ , _ _ _ , _ . . . _ _ . , , . _ _ _ _ _ _ _ _ . _ _ _ _- _m-- .
FIC-5.100h Rev. O Page 6 7.0 ' Additional Reauirements 7.1 The Lead Civil Field Engineer or his designee shall maintain a log (see Attachment B), a corresponding permit file, and unique numoering system for all approved excavation permits.
7.2 Structure foundations and exposed utilities shall be protected from the effects of frost while an excava-tion remains open.
7.3 variations in excavation limits and construction methods must be approved by the Onsite Geotechnical Soils Engineer. Sucn approvals are documented by the Onsite Geotechnical Soils Engineer in his daily report.
7.4 The Onsite Geotechnical Soils Engineer, Lead Civil Field Engineer or designee, and MPQAD (Civil Section) will be notified:
7.4.1 If during open-pit excavation, an unidenti-fied (not listed in remarks section on form) permanent utility is encountered.
7.4.2 If during drilling or pile-driving operations any obstruction is encountered.
Concurrence to proceed or other disposition will be documented on a Field Engineer's report form, signed by Onsite Geotechnical Soils Engineer, Lead Civil Field Engine or designee, and MPQAD (Civil Section).
Prepared By: 9 mm Date 4//g/gz Reviewed by:M 4W 72 PFE 1 sg E Date dI/o:4f/'/8 PFQCE s Date d /'t 2- y 2_-
PQAEf fase) Date 2.5/87 MPQAD Date h/L8f [82.-
Approved by:
Consumers Power Compa h#//A/ Date Gh'/!9'Z. -
Site Ma ager Date 2-/. h D-126-11
' FIC - 5.100 Attachment A Page 1 Bechtel Power Corporation JoD 7220 -
Midland Nuclear Power Plant Excavation Permit Pennit #
(To be completed prior to Start of Work)
Originator: Date:
Date Work to De Started:
Purpose of Excavation:
Location and Limits of Excavation:
Metnod of Excavation:
Q-Li st : YES NO NOTE: The back of the excavation permit must be completed for drilled holes only.
Signatures below signify review of existing underground and appropriate action taken to protect existing installation.
Bechtel Supervision Bechtel Field Engineering Civil Mecnanical Electrical Electrical (Security Systems)
Survey Remarks or Special Instructions:
Onsite Geotechnital Soils Engineer Date CPCo Construction Date MPQAD (Q-only)
__ Date cc: Lead Civil QC Engineer (Q-only) CPCo Construction MPQAD Section Head (Q-only) Lead Civil Field Engineer Onsite Geotechnical Soils Engineer D-126-11
_ _ . - . . . _ _ .= - - - ..
,j t Excavation Permit (To be completed prior to start of work)
NOTE: This back page must be completed for drilled holes only. See Page 1 ,
i for general infonnation.
i ,
Metnod of Advancing Hole: ,
I 1
i Metnod of Stabilizing Hole: i n
/
Method of Backfilling ne Hole: <
/
P Time restraints' to backfill (or install equipment) after' drilling is completed.
d Specific steps to be taken if an obstruction is encountered NOTE: If an unaccountaole loss of drilling fluid (water, bentonite slurry, revert, etc.) occurs during drilling, all work on that hole shall stop and the Cnsite Geotechnical Soils Engineer and Project Field Engineer are to be notified immediately.
p[
D-126-11
3 dd 5
ee 6 vv r oi
. e re pc 5m pe h
- c AR a
s o
p r
u P
g o
t t
i m
r r
- o P t a
n n i
o g t
a r v O a
c x
E r
o t
a i
n g
i r
O i
_ f n
oI i
tt ai vm ar 1 ce 1 xP -
E 6 2
1 D
FIC - 5.100 Attachment C Rev. 1 List of Re :erence Drawings For Underground Utilities Multi-Discipline FSK-CY-52, Sheet 1 FSK-CY-52, Sheet 2 FSK-CY-52, Sheet 3 FSK-CY-52, Sheet 4 FSK-CY-52, Sheet 5 FSK-CY-52, Sheet 6 FSK-CY-250 FSK-CY-251 FSK-CY-252 FSK-CY-253 FSK-CY-254 FSK-CY-255 FSK-CY-256 FSK-CV-257 FSK-CY-258 FSK-CY-259 FSK-CY-260 FSK-CY-261 FSK-CY-262 FSK-CY-263 FSK-CV-264 FSK-CY-265 FSK-CY-266 FSK-CY-267 FSK-CY-268 FSK-CY-269 FSK-CY-270 FSK-CY-271 FSK-CY-272 FSK-CY-273 FSK-CY-274 D-126-11
l FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities Civil C-3 C-4 C-5 C-6 C-7 C-8 C-42 C-43 C-46 C-51 C-52 C-57 C-71 C-82 C-91 C-92, Sheet 1 C-92, Sheet 2 C-92, Sheet 3 C-93 C-131 C-132 C-133 C-134 C-135 C-699 C-987 C-992 C-993, Sheet 1 C-998 C-1190 C-1310 C-1311
! " 1312 C-1313 C-1314 C-1315 C-1316
~
, C-2016 C-2017 C-2018 C-2019 7220-C-195-36 l i D-126-11 l
FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities Electrical E-500, Sheet 2A E-500, Sheet 2B E-500, Sheet 2C E-500, Sheet 2D E-500, Sheet 2E E-500 Sheet 3A E-500, Sheet 3B E-P'), Sheet 3C E-500, Sheet 4A E-500, Sheet 4B E-500, Sheet 4C E-500, Sheet 4D E-500, Sheet 5A E-500, Sheet 5B E-500, Sheet SC E-500, Sheet SD E-500, Sheet SE E-500, Sheet 12 E-501, Sheet 1 E-501, Sheet 2 E-502, Sheet 1 E-504, Sheet 1 E-505, Sheet 1 E-506, Sheet 1 E-508 E-509, Sheet 1 .
E-510, Sheet 1 l E-511 !
E-512, Sheet 1 l E-513, Sheet 1 I E-520 E-521, Sneet i l E-522, Sheet 1A ,
E-522, Sheet 1B i
. E-522, Sheet 1C -
1 E-522, Sheet 1D E-522. Sheet 2A E-522, Sheet 2B E-522, Sheet 2C E-522, Sheet 3 D-126-11 l
FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities Electrical E-523, Sheet 1 E-523, Sheet 3 E-526, Sheet 1 E-526, Sheet 2 E-526, Sheet 3 E-526, Sheet 4 E-526 Sheet 5 E-526 Sheet 6 E-526, Sheet 7 E-527, Sheet 1 E-527, Sheet 2 E-528, sneet 3 E-529. Sheet 1 E-529, Sheet 2 E-530, Sheet 1 E-530, Sheet 2 E-531, Sheet 1A E-531, Sheet 1B E-531, Sheet IC E-531, Sheet 10 E-531, Sheet 2 E-532, Sheet 1 E-543, Sheet 1 E-547, Sheet 1 E-594, Sheet 1 E-595, Sheet 1 E-596, Sheet 1 E-600, Sheet 1 E-601, Sheet 1 E-698, Sheet 1 E-698, Sheet 2 E-698, Sheet 3 E-698, Sheet 4 E-699, Sheet 1 E-699, Sheet 2 FSK-EY-3 FSK-EY-9 FSK-EY-17 FSK-EY-38 FSK-EY-4 5 D-126-11 e
FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities Electrical ;
FSK-EY-64 FSK-EY-66 FSK-EY-69, Sheet 1 FSK-EY-69, Sheet 2 FSK-EY-74 FSK-EY-79 FSK-EY-93 FSK-EY-94 FSK-EY-104 FSK-EY-106 FSK-EY-108 FSK-EY-111 FSK-EY-150, Sheet 1 FSK-EY-150, Sheet 2 FSK-EY-151, Sheet 1 FSK-EY-151, Sheet 2 FSK-EY-151, Sheet 3 FSK-EY-151, Sheet 4 FSK-EY-152 FSK-EY-153 FSK-EY-154 FSK-EY-155 FSK-EY-156 FSK-EY-157 FSK-EY-158 FSK-EY-159 FSK-EY-160 FSK-EY-161 FSK-EY-162 FSK-EY-163 FSK-EY-164 FSK-EY-165 FSK-EY-166 FSK-EY-167 FSK-EY-168 FSK-EY-169 FSK-EY-170 FSK-EY-171 FSK-ET-2-4 D-126-11
1
'FIC - 5.100 Attachment C Rev. 1 1
List of Reference Drawings For Underground Utilities Mechanical M-58, Sheet 1 ,
M-58, Sheet 2 M-152 M-165 M-166 M-167 M-168 M-169 M-170, Sheet 1 M-170, Sheet 2 M-607, Sheet 16 M-612, Sheet 7 M-612, Sheet 8 M-613, Sheet 7 M-613, Sheet 8 M-649, Sheet 1 M-649, Sheet 2 M-649, Sheet 3 M-665, Sheet 1 FSK-MPY-16, Sheet 1 FSK-MPY-16, Sheet 2 FSK-MP Y-18 FSK-MPY-24 FSK-MP Y-29 FSK-MPY-32 F SK-MP Y-33 FSK-MPY-45 FSK-MPY-46 FSK-MPY-72 FSK-MP Y-98 FSK-MPY-108 FSK-MPY-165 FSK-MPY-166 F SK-MP Y-167 FSK-MPY-168 FSK-MPT-1-1 FSK-MPT-1-2 Sheet 1 FSK-MPT-1-2, Sheet 2 FSK-MPT-1-2, Sheet 3 FSK-MPT-1-2, Sheet 4 D-126-11
r FIC - 5.100 Attachment C Rev. 1 List of Reference Drawings For Underground Utilities Mechanical FSK-MPT-1-35 FSK-MPT-2-1 -
FSK-MPT-2-2 FSK-MPT-2-4 FSK-MPT-2-44, Sheet 1 FSK-MPT-2-44, Sheet 2 FSK-SP-561, Sheet 3 FSK-M-2HBC-4-2 FSK-M-2HBC-4-3 FSK-M-2HBC-497-1 FSX-M-2HBC-497-3 FSK-M-2HB C-498-1 FSK-M-2HBC-498-2 FSK-M-0CCC-1-1 FSK-M-0DBC-4-1 FSK-M-1HBC-3-2 FSK-M-1HBC-3-3 FSK-N-1HBC-3-4 FSK-M-1HBC-4-2 FSK-M-1HBC-4-3 FSK-M-1HBC-4-4 FSK-M-1HBC-497-1 FSK-M-1HBC-497-2 FSK-M-1HBC-498-1 FSK-M-1HBC-498-2 FSK-M-1HBC-498-6 FSK-M-2HBC-3-2 FSK-M-2HBC-3-3 D-126-11
_ . ___ .__ ~ __ . _ _ _ _ . . _ .
's .
e a June 1982 1
i PROFESSIONAL RESUME OF WALTER R BIRD (PE)
SUMMARY
OF CAPABILITIES Broad engineering experience in operations, design quality assurance, and project management of design and construction of complex energy and research facilities. Skilled in the development and implementation of
, -Quality Management Systems. Functional engineering abilities in materials, manufacturing and joining processes, machine design, facilities design, standards writing, and inspection and test specifications.
Experienced Manager of large multi-disciplined engineering and quality assurance organizations.
PROFESSIONAL POSITIONS April 1980 to Present Midland Project Quality Assurance Department Manager - Midland Nuclear Project, Consumers Power Company, Jackson, Michigan.
Manage the Quality Assurance functions for the Midland Project. The Department consists of both the Architectural Engineer and Constructor's QA Personnel and Consumers Power personnel, and it serves both organizations. The Department has jurisdictional responsibility for design, procurement, construction and preoperational and hot functional testing.
May 1977 to April 1980 -
Quality Engineering Section Head - Midland Nuclear Project, Consumers Power Company, Jackson, Michigan.
t Manage the Quality Engineering Section responsible for all safety-related equipment and construction activities for the 3.2 billion dollar Midland
, Nuclear Project. This Section consisting of Mechanical, Electrical,' Civil and Nondestruerive Examination Engineering Groups establishes the Quality Assurance Program to 10CFR50 and National Standards and assures the architect-engineer, constructors and equipment suppliers maintain equivalent quality programs. Reviews and audits their drawings, calculations, construction procedures, procurement documents and other engineering documents to assure compliance to the QA Program commitments.
In addition, the Section is responsible for inspection planning for Consumers Power Inspection Section and certification of the Department's NDE personnel. -
January 1974 to May 1977 Quality Engineering Branch Manager Idaho National Engineering Laboratory Idaho Falls, Idaho, e
l
- - MIO782-0010A-MP01
Juna 1982 2
l l
Manage the Quality Engineering Branch which consists of three QE Sections and one Nondestructive Examination (NDE) Section. The Branch had total company responsibility for: 1) Design Quality, 2) Quality planning for procurement and installation, and 3) testing and qualification of designs, components and processes. The NDE Section provides training and certification of examination personnel, develops new NDE techniques and procedures and administers several major research projects. These include development of an automated computer controlled ultrasonic system to examine thick stainless steel welds and a feasibility program to apply acoustic emission to reactor systems for real time inservice inspection. A total of 22 Engineers up through PhD level were employed in this Branch.
In 1976 the assignment of LOFT Quality Program Manager (QPM) was assumed.
This additional responsibility added a large section of inspection personnel to the Branch. Specific new responsibilities included establishment of the overall quality policy and program for the facility, operations and experiments, and providing quality' verification of the readiness of the facility to conduct each test.
October 1972 to January 1974 SLSF Design Section Supervisor, Idaho National Engineering Laboratory, Idaho Falls, Idaho.
Administrative and technical supervision of up to 26 Engineers. In this position, I approved design analysis, design documentation and procurement packages for the Sodium Loop Safety Facility (SLSF). This design consisted of a completely self contained helium-cooled sodium system which is located within a pressurized water reactor. I had direct design responsibility for the fill, storage and remelt (FS&R) System. This System was used to purify sodium, heat the test loop, bring the loop to vacuum conditions and fill the loop with sodium. The design included the architectural engineering for radiation shielding, liquid metal fire mitigation, ventilation system and radiation and fire detection systems.
July 1971 to October 1972 Project Engineer, National Reactor Testing Station, Idaho Falls, Idaho.
Engineering Division Project Manager for Power Burst Facility (PBF) modifications. Major modification include providing PBF with the capability of: LOCA testing of both BWR and PWR experiments with top spray and bottom flood emergency cooling water, BWR Power-Coolant Mismatch (PCM) two phase flow testing, and LOCA testing with blowdown. These were major system designs for a nuclear facility that complied with ASME Section III and RDT Standards.
January 1971 to July 1971 l
Mechanical Design, Section Supervisor, National Reactor Testing Station, Idaho Falls, Idaho.
MIO782-0010A-MP01
i Juns 1982 3
Responsible for the mechanical engineering design section at the Test Reactor Area. Section provided plant engineering support for the
" Engineering" and " Advanced Test Reac' tors," and experimental design support for Navy Sponsors and Aerojet Scientific Divisions. Provided system engineering for tasks assigned to the main Engineering Division for detailed design. The work scope is the same as in the following section.
Plant engineering included all phases of support for both reactor primary and secondary systems. Reviewed incident reports for recommendation of engineering action.
March 1970 to January-1971 Project Manager for Experimental Systems, National Reactor Testing Station Idaho Falla. Idaho Prime responsibility was to insure that engineering division work for the '
sponsors (KAPL, BABL, and Battelle Northwest) was completed satisfactorily. In six months, turned around a bad situation to where sponsors had confidence in engineering work and were using division services. Specific job functions included: 1) scoping engineering tasks,
- 2) providing design criteria and cost estimates, 3) giving technical direction to the Engineering Division Branches, 4) review of engineering work, 5) providing sponsors with technical and fiscal status 6) insuring tasks were completed on time within resources. Specific tasks included a variety of experiments for both loop and capsule facilities, design of a large multihole capsule facility for ATR, a new experimental lead pressurizing system for ETR, a major modification to a pneumatic rabbit fccility and an engineering review of a new BABL "large" inpile tube and i
loop design for the Advanced Test Reactor. Engineering services to the sponsors includes thermal and stress analysis, mechanical and electrical design, metallurgical support and drafting.
August 1969 to March 1970 Design Engineer Section Supervisor, National Reactor Testing Station.
Idaho Falls Idaho Responsible for design work of mechanical engineering group. Majority of work was plant engineering support for the test reactors and the design of specialized handling tools to replace the Engineering Test Reactor i
beryllium reflector. Some work was performed in the design of the Semi-scale Test Facility for blowdown tests.
May 1967 to August 1969 I
Design Engineer, National Reactor Testing Station, Idaho Falls, Idaho.
i l Mechanical Design Engineer and Project Engineer for MTR beryllium i changeout. Responsible for designing required handling tools and writing l the detailed procedures required to replace the Material Test Reactor's l beryllium reflector, skirt plates, and miscellaneous internals in i
i preparation for the " Phoenix Core Experiment." Provide training to i
i ? MIO782-0010A-MP01 l
. - .. . . - - - _ - . . _ _ . . =_ - __
-\ <
June 1982 4
operating personnel in the use of the tools and procedure. Coordinated engineering and quality assurance activities during the changeout and provided engineering support to solve problems as they developed.
Responsible for general plant engineering and mechanical design engineering mostly in support of the Advanced Test Reactor. Made procurement trips to expedite delivery of primary system valves. Provided design review and liaison engineering for the ATR Gas Cooled Loop cask and experiment handling systems.
September 1962 to April 1967 r
Naval Officer, United States Navy.
All assignments were shipboard engineering billets including damage control assistant and repair officer aboard two destroyers, and Boiler Officer aboard the attack aircraft carrier Oriskany. Qualified Engineering Officer of the Watch. Navy duty provided broad experience in steam propulsion machinery and auxiliary equipment. Extensive shipyard experience gained as the two destroyers and the carrier underwent FRAM or a major overhaul during assignments.
EDUCATIONAL ACHIEVEMENTS Bachelor of Science - Mechanical Engineering, 1962, University of Idaho Master of Science - Nuclear Engineering, 1972 University of Idaho UTEC Basic Ultrasonics School, 1976 Six Graduate Level credits in Quality Assurance Courses University of Idaho Ten Weeks Damage Control Assistant Course. US Navy, Philadelphia Naval Shipyard PROFESSIONAL REGISTRATION Professional Engineer (Mechanical), State of Idaho, 1975 Certificate No 2803 PERSONAL-DATA ,
Married - Three Children Currently in twentieth year of US Naval Reserve holding rank of Commander. Commanding Officer of a Naval Reserve Research Unit.
Active in Boy Scouts of America.
MIO782-0010A-MP01
t
' i n --
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSI %dED In the Matter of )
) Docket 97 N 5 ')7-3p9-OM Yos.OV 1 :05 CONSUMERS POWER COMPANY ) 50-330-OM
) LFF:Ct :t50-j3P'QL (Midland Plant, Units 1 and 2)) UCCKLIjfMML OL CERTIFICATE OF SERVICE I, Philip P. Steptoe, one of the attorneys for Consumers Power Company, hereby certify thdt copies'of the following testimony were served upon all persons shown in the attached service list by deposit in the United States mail, first class, except where marked with an asterisk, in which case service was by hand, this 15th day of November, 1982.
Testimony of Ralph B. Peck, concerning the Diesel Generator Building Testimony of Karl Wiedner, concerning the Diesel Generator Building Testimony of Dr. Mete Sozen, concerning the effect on structural strength of cracks in the walls of the Diesel Generator Building Testimony of Dr. W. Gene Corley, concerning the Midland concrete crack repair program Testimony of Dr. W. Gene Corley, Appendix B, " Limit Analysis of Service Water Pump Structure", to be attached to Dr. Corley's testimony concerning cracking in the Service Water Pump Structure, filed October 20, 1982.
y 53
i y
- ^
Testimony of W. Bird and R. Wheeler, concerning NCR #MOl-4-2-008 (Rev. 1)
(February 25, 1982), NCR OMOl-9-2-038 (March 8, 1982), NCR #MOl-9-2-051 (April 21, 1982), Bechtel NCR #4199 (including stop work order FSW-22), and Bechtel NCR #4245 A
PhLlip P. ;
ItW /f I I
4
, -, - _ , , -- . - . . . .~. -. -. . - - , . . . . , - . , . - , . . - - - -
o .
SERVICE LIST v
Frank J. Kelley, Esq. Steve Gadler, Attorney General of the 2120 Carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq.
Assistant Attorney General Atomic Safety & Licensing Environmental Protection Div. Appeal Panel 720 Law Building U.S. Nuclear Regulatory Comm.
Lansing, Michigan 48913 Washington, D.C. 20555 Cherry & Flynn Mr. C. R. Stephens Suite 3700 Chief, Docketing & Services 3 First National Plaza U.S. Nuclear Regulatory Comm.
Chicago, Illinois 60602 Office of the Secretary Washington, D.C. 20555
- Mr. Wendell H. Marshall .
4625 S. Saginaw Rd. *Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Street Midland, Michigan 48640
- Charles Bechhoefer, Esq.
~
Atomic Safety & Licensing
- William D. Paton, Esq.
Board Panel Counsel for the NRC Staff U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Washington, D.C. 20555
- Dr. Frederick P. Cowan
- Atomic Safety & Licensing 6152 N. Verde Trail Board Panel Apt. B-125 U.S. Nuclear Regulatory Comm.
Boca Raton, Florida 33433 Washington, D.C. 20555
- Lee L. Bishop
- Barbara Stamiris Harmon & Weiss 5795 North River Road 1725 I Street, NW #506 Route 3 Washington, D.C. 20006 Freeland, Michigan 48623 Mr. D. F. Judd
- Jerry Harbour Babcock & Wilcox Atomic Safety & Licensing P.O. Box 1260 Board Panel Lynchburg, Virginia 24505 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555
- James E. Brunner, Esq.
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 19201