ML20078N945
| ML20078N945 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/27/1983 |
| From: | Brunner J, Kostielney J, Murray G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Stamiris B STAMIRIS, B. |
| Shared Package | |
| ML20078N940 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8311030081 | |
| Download: ML20078N945 (53) | |
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.N UNITED STATES OF AMERICA
'83 Hay -1 P12:06 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board-FEg[,[, g y';h BRANCH
)
In the Matter of:
)
Docket Nos 50-329 OM
)
50-330 OM CONSUMERS POWER COMPANY
)
Docket Nos 50-329 OL
)
50-330 OL (Midland Plant, Units 1 & 2)
)
)
October 27, 1983 APPLICANT'S RESPONSES TO STAMIRIS INTERROGATORIES OF OCTOBER 11, 1983.
Note:
Questions 1-5 are in the process of being answered and will be sub-eltted at a later date.
QUESTION 6 Describe your understanding of the purpose of the May 20, 1982 meeting between Consumers and the NRC.
RESPONSE 6 Mr Mooney's understanding of the purpose of the May 20, 1982 meeting between Consumers and the NRC, was to advise the NRC Staff was that it "... advised the NRC Staff that the duct bank was deeper than expected and explained the Company's latest plans.
. QUESTION 7 What if any changes do you believe you should make in your prefiled testimony 1
after having read the OI investigative reports.
83110'DOO1 831027 DR ADOCK 05000 RESPONSE 7 Mr Mooney does not believe any changes should be made in his prefiled testi-mony after having read the OI investigative reports.
M11083-5623A-MP03
1 2
QUESTION 8 State your current position regarding whether or not Dr Landman told you at any time that he prohibited excavation below the Q duct bank without prior NRC approval.
RESPONSE 8 Mr Mooney's current position is stated in his prefiled testimony.
QUESTION 9 Explain how the May 25, 1982 Memorandum approves excavation of the deep Q duct bank, as referenced on Page 15 of the Supplemental OI Report.
RESPONSE 9 The above reference appears on Page 14 of the Supplemental 01 Report and is being answered based on that premise.
The letter to Harold R Denton from J W Cook dated May-10, 1982, "ASLB Soils Order" states in part, ".
. Remedial soils work previously approved by the NRC is continuing. Concurrence as to the scope of this work was obtained from Mr Darl Hood, and is as defined below:
. I.c. freeze wall installation, underground utility protection, soil removal cribb'ing and related work in support of the freeze wall installation, freeze wall monitoring and freeze wall activation.
mil 083-5623A-MP03
3 The letter to J W Cook from D G Eisenhut dated May 25, 1982, " Completion of Soils Remedial Activities Review," responding to the May 10. 1982 letter states in Enclosure 4: "... the Staff agrees that prior explicit concur-
- rence for the activities listed by Paragraph I.c. of CP Co's letter, May 10, 1982 had been obtained from the Staff..."
OUESTION 10 Identify all discussions, conversations, meetings or communications which mention, or refer to any way the following:
a.
Dr Landsman had been called to the Midland Site to inspect the deep Q duct bank before activation of the freezewall; b.
A need existed to stop the rater flow beneath the deep Q duct bank; c.
the necessity to excavate to impervious ground beneath the duct bank; d.
QA planning determined the need for " sheeted pit" down to the duct bank; e,
concern with " recharging" the zone.below the deep Q duct bank; f.
changes to the design of the duct bank or method of excavation of the duct bank, for the period March 1, 1982 through September 30, 1982; 1
1g.
deepening or exposing the deep Q duct bank, for the period March 1, 1982 through September 30, 1982.
i RESPONSE 10 a.
Mr Sevo had possession of the following communications regarding NRC inspection before activation of the freezewall:
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4 June 4,1982 letter from Don Horn to Messrs Bird, Marguglio and Dietrich (attachment 6 to Weil Report dated September 12, 1983).
OCR #0159 memorializes a conversation between Mr Sevo and John Fisher; Mr Sevo does not recall how or when he obtained the information conveyed.
(Copy attached)
April 1, 1982 memo from Al Boos refers to audit by I&E of freezewall; Mr Sevo was not present for the meetings which were the subject of this document.
(Copy attached)
Mr Sevo does not recall any other specific conversations, discussiens or meetings concerning this subj ect.
b.
Mr Sevo had possession of the following communications: A document entitled, " Meeting March 12, 1983," refers to the proposed grout curtain which involved stopping the water flow beneath the deep Q duct bank; Mr Sevo does not recall who published the document and does not recall if he was present at that meeting.
(Copy attached)
The April 1, 1982 memo from Al Boos references procedures concerning stopping the water flow.
(Copy attached)
Mr Sevo may have had a number of routine work related conversations which touched upon this subject, however, he has no present recollection as to any such specific conversation, discussion or meetings.
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5 c.
The' April 1,1982 memo from Al Boos may refer to this subject.
Mr Sevo may have had a number of routine work related conversations which included this subject, however, he has no present recollection as to any such specific conversations, discussions or meetings.
d.
Mr Sevo does not recall any discussions, conversations, meetings or communications relating to the statement that "QA planning determined the need for ' sheeted pit' down to the duct bank."
QA was not responsible for
" determining the need" for a sheeted pit; the need was determined by the design group.
Mr Sevo may have become aware of the need for a sheeted pit through routine job site meetings and conversations; however, he does not recall the specifics of any such meetings or conversations, e.
Mr Sevo does not recall any discussions, conversations, meetings or communications relating to the " concern with ' recharging' the zone below the deep Q duct bank."
To Mr Sevo's knowledge, there was not a concern regarding " recharging" the zone below the deep Q duct bank, however, there was a concern regarding preventing the " recharging" of the area inside the freezewall.
Mr Sevo may have become aware of this latter concern from routine job site meetings and conversations, however, he does not recall the specifics of any such meetings or conversations.
f.
Mr Sevo and his group would have become aware of some design changes through their review of drawings and processing of Project Inspection Plans and Reports (PIPR). Mr Sevo does not recall any specific drawings mil 083-5623A-MP03
6 or PIPR's except:
PIPR C-26F, Rev 0; PIPR C-26F, Rev 1; PIPR C-261, Rev 0 (copies attached); and the April 1, 1982 memo from Al Boos. Mr Sevo may have become aware of some changes 'in design through routine job site meetings and conversations, however, he does not recall the specifics of any such meeting or conversation, g.
Mr Sevo does not recall any discussions, conversations, meetings or communications relating to " deepening.
. the deep Q duct bank."
It is Mr Sevo's understanding that the elevation of deep Q duct bank was in-tended to and remained the same.
To the best of Mr Sevo's recollection, the exposure of the deep Q duct bank was part of the work necessary for the activation of the freezewall, therefore, the documents referred to in subsections (a)-(f), above, may refer to this subject.
Mr Sevo may also have become aware of the excava-tion and exposure of the deep Q duct bank through routine job site meetings, conversations or QA planning activities, however, he does not recall the specifics of any such meeting, conversation or planning activity.
QUESTION 11 Explain the factual basis for your " belief that NRC, CPC or BPC had not finalized the plans for the deep Q duct bank at the time of the additional excavation."
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7 RESPONSE 11 Mr Sevo believes that the statement contained in this question is the result of a misunderstanding. Mr Sevo's recollection is that Mr Weil asked him a question.concerning why construction stopped af ter the Phase II excavation below the Deep Q duct bank had been completed.
In response, Mr Sevo believes that he stated his recollection of events at that time to be that the design of the backfill (i.e., what type of material to use) was still in flux due to geotechnical considerations by NRR.
Although neither Mr Sevo nor his group had responsibility for tracking NRC approvals, Mr Sevo's belief that the NRR had not concurred in the design,of the backfili below the deep Q duct bank is based on his general recollection of the Friday job site meetings and other general conversations on site.
Mr Sevo has no specific recollection of the details of any of the meetings and conversations mentioned above.
QUESTION 12 Identify all conversations, communications, discussions or meetings relating to obtaining NRC approval for excavation of the deep Q duct bank or the construction of the freezewall.
a.
between yourself and the NRC; and b.
between yourself and Consumer and Bechtel.
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8 RESPONSE 12 a.
Mr Sevo has no present recollection of any conversation, communication or discussion with the NRC concerning approvals for excavation of the deep Q duct bank or for construction of the freezewall.
Mr Sevo may have attended some NRC exit meetings during the applicable time period, however, he has no re ollection of attending any meeting at which the obtaining of NRC approvals was discussed.
Neither Mr Sevo nor his group had any responsibility for obtaining appro-vals from the NRC during the applicable time period.
b.
Mr Sevo was present for some Friday job site meetings which discussed general NRC approvals and restraints, however, he has no recollection of any meeting where the' obtaining of NRC approvals for excavation of the deep Q duct bank or for construction of the freezewall were specifically discussed.
Mr Sevo had possession of the following communications which may relate to the obtaining of NRC approvals for excavation of the deep Q duct bank or for construction of the-freezewall:
1 OCR #0159 memorializes a conversation between Mr Sevo and John Fisher on April 8, 1982; Mr'Sevo does not recall how or when he obtained the inform-
'ation conveyed.
(Copy' attached) mil 083-5623A-MP03
9 A document entitled, " Meeting March 12, 1982," was sent.to Mr Sevo; lui does not recall who published the document and does not recall if he was present at that meeting.
(Copy attached) '
Mr Sevo was sent a copy of the June 4, 1982 letter from Don Horn to Messrs Bird, Marguglio'and Dietrich which conveyed the minutes of the May 21, 1982 NRC exit meeting.
(See Attachment'6 to the Weil Report dated September 12, 1983.)
. To the best of Mr Sevo's recollection, he may have had routine job site discussions with numerous people during the applicable time period.
He does not specifically recall if any of these conversations dealt with.the obtaining of NRC approvals-for excavation of the deep Q duct bank or for construction of the freezewall..
QUESTION 13 Explain the factual basis-for the statement that the.May 20, 1982 notes meant "the method of accomplishing the impervious zone beneath the deep duct bank l
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'had not been approved, " referred to on Page 21.
RESPONSE 13 LThe statement contained in this question does not appear on Page 21, however,
- it'does appear on Page 23.
The answer.to this question is based on the
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-statement appearing on Page.23.
mil 083-5623A-MP03
10 Mr Sevo's recollection is that as of May 20, 1982, the NRR was reviewing the design for accomplishment of Phase II, which was the creation of an impervious zone below the deep Q duct bank, and had not given its approval at that time (May 20, 1982).
QUESTION 14 Explain the following portions of your typed and handwritten notes for the May 21, 1982 Remedial Soils Meeting:
a.
" target freeze activation on Wednesday, May 26, 1982";
b.
" Pit 4 critical";
c.
" Clear space duct bank.
Brien Palmer";
d.
"have QA.
. look at all pits for any quality concern before Dr Landsman looks at them.
RESPONSE 14 To the best of Mr Sevo's recollection, the following is an explanation of his notes of May 21, 1982, which were made from a QA point of view:
a.
The scheduling goal was to activate the freezewall on Wednesday, May 26, 1982.
b.
Pit 4 was the pit which provided'the interface between the deep Q duct bank and the freezewall.
Pit 4 was " critical" from the standpoint that it' had several outstanding items which had to be completed prior to the NRC inspecting the freezewall and giving its authorization to activate the freezewall.
MI1O83-5623A-MP03
11 c.
This item indicated a notification to Brien Palmer to assure, during the overinspection activities, that the required clear space was present beneath the deep Q duct bank.
The clear space was a designed gap between the bottom of the deep Q duct bank and the existing soil prior to freeze-wall activation.
d.
This item is a notification to the QA overinspection group (Brien Palmer) to conduct a review of all pits to assure accomplishment of all quality inspection, quality overinspections and the completion of all other open quality items before the NRC inspection of the monitoring pits.
NOTE: Mr Scvo's answers to interrogatories numbered 10, 11, 12, 13 and 14 do not include information already provided in the Weil Report, dated September 12, 1983.
QUESTION 15 Explain the Diagram on Page 3 of the attachments to the May 11, 1982 Ronk Memorandum, including but not limited to the meaning of the following:
a.
zone numbers listed; b.
codes used and/or listed; c.
planning schedule caption;
- d. '" sups soils, Consumers Power Company" in third top box from left; and e.
initials "DRF 5/11/82" at bottom left corner of page.
Describe the purpose of this document.
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!?
RESPONSE 15' a.
Zone numbers allow graphically displaying the schedule information in an organized fashion.
The number shown has no intrinsic meaning.
b.
Codes (called activity numbers) are used to organize the information in the computer files.
The numbers are arbitrarily selected'.
c.
The caption " Planning Schedule" is a standard title that is used with the
" PROJECT /2" software program.
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d.
The words "SWPS SOIL CONSUMERS POWER COMPANY" appearing in the third top box from the left are titles that were entered into the program for this network before the network was used for the remedial soils detailed schedule or 90 day revolving schedule.
The network was originally in-tended to model just the Service Water Pump Structure (SWPS) soils activi-ties.
The initials DFR 5/11/82 were placed on the document to indicate that it e.
.was prepared under Mr Ronk's supervision and issued on May 11, 1982.
QUESTION 16 Identify all activities or work listed in your May 11, 1982 memorandum that had been submitted to the NRC for approval prior to May 11, 1982.
' Identify all documents which refer, mention or evidence such prior submission
-of work and activities to NRC for approval prior to May 11, 1982.
RESPONSE 16 Objection.
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13 QUESTION 17 Identify all discussions, conversations, meetings, or communications with Mr Wheeler, Mr Schaub or Mr Mooney in period from March 1, 1982 through September 20, 1982 concerning:
a.
tho deep Q duct bank; and b.
the relocation of the fireline.
RESPONSE 17 Mr Ronk is not able to recall the time, place, participants or nature of any conversation with Mr Wheeler, Mr Schaub, or Mr Mooney between March 1, 1982 cnd September 20, 1982 regarding the Deep Q duct bank and the relocation of the fireline.
QUESTION 18 Identify all meetings, discussions, conversations and communications between Consumers, Bechtel and Mergentine relating to activities and/or items to be covered by the ASLB Order, including but not limited to the May 5, May 6 and May 7, 1982 meetings referred to in May 11, 1982 Schaub Memorandum.
RESPONSE 18 Obj ection.
mil 083-5623A-MP03 7
l 14 OUESTION 19 Identify all activities determined by Consumers or by Bechtel, during the period from April 30, 1982 through September 30, 1982, to be covered by the ASLB Order.
Identify all documents which relate to, mention or refer to in any way the activities listed above.
RESPONSE 19-Objection.
QUESTION 20 For the period March 1, 1982 to September 30, 1982, identify the person or persons responsible for determining (a) whether or not a certain work activity must receive NRC approval, and (b) whether an activity or work is covered by the ASLB Order.
RESPONSE 20 Prior to April 30, 1980 the informal agreement between the Company and the NRC dictated which activities needed approval.
After the April 30, 1980 Order, the Order defined those activities which needed approval. This May 5 confer-ence call further delineated those activities requiring approval.
Mr Ronk's job description did not include keeping track of approvals, therefore, he has no knowledge as to this subject.
mil 083-5623A-MP03
15 OUESTION 21 Explain why the June 23, 1982 and June 30, 1982 Soils Progress Schedule Status Reports include an asterisk indicating NRC review is required for both
" complete deep Q duct bank" and " relocate fire' protection pipeline."
State all reason for removal and/or omission of the asterisk from these two activities from the July 7, July 14, July 21, and July 28, 1982 Soils Progress Schedule Status Reports.
RESPONSE 21 The asterisk associated with " complete deep Q duct bank" was an indication that approval was needed for the permanent-backfill of the excavation.
The asterisk associated with " relocate fire protection pipeline" was an indication that this new item of planned work was not-yet approved.
Mr Ronk and Mr Schaub do not remember exactly why the asterisks were removed.
j QUESTION 22 l
Identify all person (s) responsible for determining:
l a.
which activities in the Status Reports required NRC approval; b.
which activities listed in the Status Reports should be marked with an asterisk; c.
which activities should have asterisk removed; d.
which activities had received prior or required NRC approval.
i mil 083-5623A-MP03 L
16 RESPONSE 22.
J R Schaub was responsible.
QUESTION 23 Explain all reasons for your refusal to or declination to provide a written statement to NRC investigators regarding the Office ot Investigation investi-gations into violation of the ASLB Order.
RESPONSE 23 Mr Schaub did not believe that it was necessary to provide a written statement because he had already been interviewed by the investigators extensively and he felt that a. written statement would be superfluous.
QUESTION 24 Describe the preparation of the Soils Progress Schedule Status Reports,
. including the following:
a.
identification of all persons preparing tha reports; b.
all persons reviewing the reports; c.
all persons who received the reports; and d.
all persons who used the reports in any manner.
.For all such persons listed in subpart (d) above, state the use he/she made of
.the reports.
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17 RESPONSE 24 a.
D F Ronk prepared the report, he was assisted by others within the sched-uling department; b.
The report was reviewed by J R Schaub; c.
R B Landsman and the persons listed as carbon copy recipients are the only people who the report was sent to; d.
R B Landsman was sent the report for purposes of planning his site visits relative to the status of construction.
QUESTION 25 Describe how the Short Term Action Plans were prepared a.
before June 31, 1983; and b.
after June 31, 1982.
t List all reasons for changing their method of preparation.
RESPONSE 25 Since there are only 30 days in June, this answer is based on a reference date l
of June 30, 1982.
The short term action plans were prepared by David Ronk before June 30, 1982.
After June 30, 1982, Dave Ronk and Jerome Kostielney jointly prepared the short term action plans. Mr Kostielney was responsible for finding out the start and finish dates of the proposed work and to prepare the draft of the short term action plans to be approved by John Schaub. The reason for changing the method of preparation was to get Jerome Kostielney involved in the soils work..
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18 OUESTION 26 Explain the method of determining which work activities were asterisked in these reports.
-Identify all persons who participated in any way in the determination or whether or not to asterisk a particular work activity.
RESPONSE 26 Work activities on the short term action plan were first updated and prepared on a drait.
The draft was then reviewed by Dave Ronk and/or John Schaub.
Jerome Kostielney was then directed by John Schaub and/or Dave Ronk to put an asterisk by the appropriate work activities.
Participants involved in putting aeterisks by work activities were John Schaub and Dave.Ronk.
QUESTION 27 Explain your understanding of the following statement when you received the July 8, 1982 Memorandum from Ronk, referenced on Pages 28 and 29 of the Supplemental 01 Investigation:
" Jerry please make sure that appropriate activities get 2n*."
Identify any reason (s) Ronk gave for writing this statement in his memorandum of July 8, 1982.
RESPONSE 27 This statement was just a reminder to make sure that appropriate activities got an asterisk.
mil 083-5623A-MP03
19 QUESTION-28 Explain what you meant when you stated to NRC investigators, "It's on there I assume I got the information," which is referenced on Fage 29 of the Supple-
. mental OI Report.
RESPONSE'28 Mr Kostielney does not recall making a statement "it's on there I assume I got the information." This statement means to him that if an asterisk was placed by a work activity, he would assume he got the information from John Schaub and/or Dave Ronk to put it on the report.
QUESTION 29 Describe your duties or responsibilities related to determining what activi-ties require NRC approval.
Describe your duties and responsibilities with respect to determine whether any activity listed in the Soils Project Schedule Status Reports or the Short Term Action Plans a.
require prior NRC approval; and b.
should be asterisked.
RESPONSE 29 Mr Kostielney assumes that this question refers to his responsibilities at the time he was involved in preparing the short term action plans. His responsi-mil 083-5623A-MP03
20 bility was to place an asterisk by an activity under the direction of Jchn Schaub and/or Dave Ronk.
QUESTION 30 Describe your understanding of " minor excavation" as Mr Wheeler used it in
-describing the agreement between himself and Dr Landsman referenced on Page 31 of the OI Supplemental Report.
RESPONSE 30 Because Mr Wieland was not working directly with excavation permits or work permits at the time of the incident which is the subject of alleged Board Order violation, he was aware only in general terms of an arrangement between Dr Landsman and SMO personnel whereby some excavations were informally re-viewed after work had begun. Mr Wieland did not have a precise understanding of the details of the arrangement at that time, however, since that time, this subject has been the topic of discussions. Mr Wieland's present understanding is that major excavations were work activities such as underpinning the auxiliary building and service water building; minor excavations were items of lesser magnitude than the examples noted above, t
l QUESTION 31 Identify all documents you read or reviewed prior to approving the excavation
-permits for the fireline relocation and deep Q bank excavation.
mil 083-5623A-NP03 L
21 i s m
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identify what portion of these documents indicate"the NRC gave prior approval for the activity and/or that prior NRC approval was no: required for the
,A activity.
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RESPONSE 31 s
w Mr Murray signed the excavation permit for the deep Q duct bank only; he signed the work permit for the fixaline relocation.
As to the fireline relocation, Mr Murray recalls that'enere was no documenta-tion which specifically dealt with the relocation.
Since the activity covered under the Board order was the excavation in Q soils, it was Mr Murray's understanding that this activity was minor and 'therefore covered in the Wheeler-Landsman agreement. Mr Murray also recalls that prior to signing the work permit, he telephoned John Schaub to confirm the above reasoning.
Mr Murray does not specifically recall signing the excavation permit for the deep Q duct bank nor does he recall any specific document which he reviewed.
s QUESTION 32 Describe all changes in the plans for the deep Q duct bank, including the following:
.,- ~.
s a.
person suggesting the change; b.
person authorizing the change; time when change adopted;7and c.
d.
the reason / rationale for the hange.
\\;'. ' '
5 mil 083-5623A-HT03
s-
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22 di a.,
Idsntify all documents constituting, mentioning, referring to or relating in
.cny way to the above mentioned changes.
h RESPONSE 32 Mr Murray has no knowledge of the rationale for, who suggested, or.who
.cuchored, the changes in the deep Q duct bank design.
This information is outside the scope of his job description.
t I
s QUESTION 33 Idsntify sll Consumers or Bechtsl investigations into the alleged violation of l
{. th2 Board Order or the manner in which'the Office of Investigations' investi-gstions were conducted.
Idtntify all reports or other dccuments related to such Consumers or Bechtel invastigations.
t.
RESPONSE 33
' ' Consumers Power Company attorneys, J E Brunner and V P Provenzano, were
'_present, either jointly or individually, for most of the interviews conducted
't
/
by 3r Weil as part of his supplemental investigation.
Mr Brunner,
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Mr Provenzano and F C Williams (Consumers' attorney from Isham, Lincoln and B:cle) conducted a number of follod-up interviews.
s
\\
Mr Brunner was also present~during the interviews conducted.by Mr Weil for the
. initial investigation; he also conducted follow-up interviews.
mil 083-5623A-MP03
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OCR #0159 PROJECTS. ENGtNEIRiNO j
cA, AND CCt STRUOTIOtt -
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- S*T N Of EL ORAL COMMUNICATIONS RECORD
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.f c:x. :w -:a J Fisher - Remedial Soils Panager 4:00 PM e m re rt(s)
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b'
/A" w o n rr NRC for oermissio'n "to activate the freeze wall. M]
r,:,ct:-s ce/cm sx:=s ::tsm Discussion with the i
CPCo and Bechtel persennel had made a request to the NRC to allow partial
.x 2.c:.y c~.m:::r ar ivation of the freeze wall leaving windows (unfrozen zones) at intersecticns with the c-h:ried utilities.
W.e NRC denied this request and stated that approval will not be granted until the pits I;
a-eu.nd the Q utilities had been ecmpleted and inspection by Dr R Landsman of the !!RC.
Ter:.issien to activate the freeze wall vill be considered af ter these conditions have been r e ?..
Ib pa-tial activation will be considered.
CC ' All Civil QAEs (M?QAD)
KiGarc, P14 -41o A A.iE os Eochtel-AA I
MADict. rich, Sechtel-Pddland d'
."* i 5 5 e. Fechsel-Midland
! c S Fd r k e: ', Bechtel-Midland
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.: AMceney, F14-ll5 A JU. hr:5. F13-309A (C4SS.16 File)
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- MEMO, FROM-AL BOOS -
cc,:.AA To:
Remedial Soils Group JRs Phases I and II Open Items t)M 6 to Supoort construction
,gg A two-day work session was held on AM Tuesday, March 30, and 'n'ednesday, gg March 31, 1982, to develop a list of all open ite=s required to be T
co=pleted for Phase I work, and
,$32 to support Phase II work.
py Attached is a listing of ite=s NS discussed.
This list vill be dkM
..a u e discussed further at the, weekly E7 remedial soils schedule review meeting on Friday, April 2, 1982.
$II AJB/ket MorE:
"PD -
DES 4/1/82 h BE b6c 0555D qg Max u mem ac, 6h '>
Attachment qw-em RS MUurM nnygg,
ECEllEt bs M'
APR OG 1982 R&D QUAUTY ASSURANC M!DLAi!D, hitcyjggy e
. - SD
1_
Listed belov are the z.ain topicc reviewed for preparation of the list:
I.
NRC items A.
NRC staff B.
I&E II.
Engineering design releases (drawings, specifications, and consultant interface)
III.
Material procurement IV.
Procedure development V.
Inspection plans VI.
Construction e
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b e
e 9
4 4
w O
- M e
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Phase I Scope - Free evall, gqoundwater control.
TIV? jacking, access shaft to 609 feet, partial instrunentation installation.
I.
NRC ite=s A.
Freezcvall - Utility protection audit by I & E (Can we partial free e? Flash B.
Groundwater control - No open items freeze utility windows?)
C.
FIVP jacking - No open items D.
Access shaft to 609 feet - No open items E.
Partial instrumentation installations l.
Supply copy of C-1493 to NRC 2.
Details of strain monitoring syste= for concrete and steel framing bea= at 6f9 II.
Engineering design releases A.
Freezevall - DCNs to C-1315 and 1316 for shallow and deep utility protection 3.
Groundwater control 1.
Release of hold on dug C-(ej ectors south.of turbine building) 2.
Supply of well data by Bechtel project engineer to Mergenti=e C.
FIVP jacking 1.
Release cf dug C-14 94 2.
Revise spec C-198 to allov vork to proceed on crack
=apping?
IFC only for instrunent installation 3.
Engineering approval of jack locations D.
Access sbaft to 609 feet - No open ite=s E.
Partial instrumentation 1.
Issue dvg' C-1493 for construction 2.
Issue dug C-1490 and 1491 for cddition of ninth DSTM 3.
Issue dug C-vith strcin c ducring det ils (concrete strain and s:cel bea: at 659 ft and 614 ft) 4.
WJE design details for raccvay, vire pulling, and ter=inations to re=ove canagenent stop work
III.
Material procure =ent A.
Free:cvall - Utility protection material by MergentS=e B.
Groundwater control ' No open items C.
FIVP jacking 1.
Delivery of jacks (Mergentire) 2.
Letter fro: MPQAD on acceptance o,f, jack =anufacturers '
calibration program D.
Access shaft to 609 feet - No ope = itens E.
Partial instrumentation 1.
WJE procure =ent of strain =enitoring hardware 2.
Ther=occuple a d vire (who buys?)
IV.
Procedure development A.,
Free:evall Procedures for shallew utility protection installation Soldier piles Eze and lagging Surcharging Rebar & concrete-1.
Procedures for deep utility protection i=stallation a.
driving _sbeet pile b.
instl of vales c.
excavation 1.
around utility 11.
= ass execvation d.
contingency procedure for closure at top of clay under duct e.
concrete place =ent B.
Groundwater control (ejectors) - Resubmit and approve procedure for ejector installation using integrated inspection concept C.
FIVP jacking - Isst:nce of precedure OP42 for crcck n:.pping and : cnitcring vi'1 bzve to b2 in the in:tcratcd fo n t D.
Act-rs shaft to 609 feet - No open itens
i 4-I E.
Partial instru=entation 1.
Resub=ittal of L'I. procedures OP38 and 39 in integrated work plan 2.
Sub=1ttal and approval of procedures OP40 (data processing) and OP41 (e=ergency plan) 3.
Sub_ittr.1 and approval of procedure for strain
=onitoring hardware installation (integrated format)
V.
Inspection plans A.
Freezewall - For utility protection installation B.
Groundwater control - No open ite=s C.
}'IVP j acking Need overinspection plan for crack napping 1.
2.
Need inspection plan for jacking D.
Access shaft to 609 feet - No open ite=s E.
Partial instru=entation 1.
Field inspection plan for racevay installation 2.
Field inspection plan for cable pulling 3.
Field inspection plan for ter=dnations 4
Revisions.to PQCI-6.0 for instru=ent installation 4
inspection 5.
Inspection plan for strain =enitoring hardware VI.
Construction status A.
Should be included in ab6ve
.et e
-r,
,g___
.,r
- 3.-
r?,c itens fer Phcre
't
'" cnd 3 I.
Phase ZA 1.
Plan for pier load test during Phase 2A or plate load test in adjacent area prior to Phase li (not a restraint to construction)
B.
Plans for local groundwater control - restraint to 2A C.
CPCo letter to NRC on QA philosophy, 3/,30/82 (hand carried)
D.
Basis for total settlements since 1977 piping connection' E.
Criteria for connecting 2-inch % steam gener tor drain lines F.
Provide results of 70 vs 30 kcf study for structural effects on existing building (2Q3)
II.
Phase 3 A.
Construction sequence B.
Develop tolerances for building novement based on 70 kcf C.
Provide acceptance criteria for strain nonitoring D.
Provide acceptance criteria for DMD 11,12, and 13 at el. 705 i
E.
Provide increased reading frequency for instrunentation for critical construction stages during Phase 3 (includes def of what the critical stages are)
F.
Provide results of loss of support study under EPA during long :urbine building drif t inst:11ctica III.
Phase 2A and B A.
Engineering design releases - Unless stated otherwise, dugs are issued for construction.- If necessary, holds for construction vill be shown on Phase 2B verk, where Phase 2A and B vork are shown on the sa=e dwg.
Forecast I.
Ircu= icgic du;s 142P and l'.1S-1 3!31/82 F C.
Issue dwgs C-1422 4/16/82 C-1423 4/16/82 C-1424 4/23/82
- ~
C-1430 - lagging details fer kc p'1ers 4/23/82 (3/31/82 C-1445 4/23/82
IorecaGt C-1445-1 4/23/82 C-1445-2 4/23/82 C-1417 4/09/82 C-1417-1 4/09/82 C-1427 1, 2, and 3 (for fab 3/31) 3/31/82 IFF opposite hand 1436 --
C-1434 4/23/82 IFC D.
Issue spec C-195, C-200Q, G-33 (couplers, grouts, sliding plates, ethafoa=-grout for piers-), C-208 (incorporating C-195)
IV.
Material procure =ent A.
Steel sets B.
Sliding plates C.
Ethafoa=
D.
Metal lagging for kt piers E.
Jacks for kc piers F.
Delivery of jacks G.
Crout H.
Pier instru=entation hardware (teltales, tubes, centering devices, gauges, etc.)
I.
Subecatract for ground stabilization J.
GEH subcontract for rebar detailing,' fabrication and installation
-V.
Procedures A.
Priority - required S=nediately Procedure Descriorien Procedure develop =ent (Q) 41 Welding procedure (Q) 15 Eandling and storage of caterials (Q) 14
^utliry training pret.rtn (Q) 1 Docu=ent control (Q) 3.
Priority - required for drifts and pier shafts
?rocc0ure Decert= tion 12 Field fabrication of structural steel (Q)
Note:
47 Centingency plan for ground loss (Q)
Is this includa Devatering of local pockets (Q) in spec C-200?-
Construe:1on of access pits and drifts and pier shaf ts (Q)
Ori.' lint :nd inst-lling rcch enci crs and ccptnsion anche:s (Q) 17 Renoval S3 structural and lean concrete (Q) w w
e*w
r~
C.
Priority - required for pier construction Procedure.
Description 40 Placing and field bending rebar (Q) i 32 Mechanical splicing of rebar- (Fcx Eculet and Cadwelds) (Q)
Placing =iscellaneous i= bedded steel (Q)
Placenent of pier concrete (Q) 11-1 Sandblasting _ (Q)
Installation of jacking p,lates and stands (Q)
Load transfer for piers (excluding control tower) (Q)
Fab'rication and threading of rebar '(Q) 21 Repair of concrete (Q)
D.
Priority - other Procedure Descrintion 45 Concrete core drilling (Q) 9 Constructica of ac, cess shaft below el. 609 (Q) 30 Drypacking (Q) 28 Grouting O
G 9
O e
=9 e
e'
'n-r
Meeting 3/12/82 QA Action Items:
(1 )
MPQA focal point for any more non-Q activities to be submitted to the NRC.
(2 )
Q-plan for Spec. C-195 needs to be redone due to Wednesday meeting with NRC.
(3)
Q-plan for Spec. C-194 also. needs to be revised per NRC meeting.
=%.
(4 )
NRR, Joe Cain, wants details on grout curtain proposed for area of freeze wall with deep duct bank.
(5 ) G&H subcontract to f abricatef rebar will be non-Q.
QC will inspect f abrication activities.
Jagdish--thepressuregroutingofthebNstcrackswillbe (6 )
a "Q" order and "Q" procedure / drawings required per J. Morrey.
(7)
Call to NRC -- Don Horn to proof notes and distribute.
(8 )
The NRC has some restrictions (see attached sheet) prior to start of Phase 2 activities.
Items attached to this QA list (to DEH only).
(1 ) Rough notes l
(2 )
Previous notes and action list (3) Non-Q list (a)
Phase 2 (t )
Completed activities (4 )
Spec. and drawing register remedials (5)
Detailed schedule marked up 7k (6 ) Activities listing required to start Phase 2 (7)
Schedule review meeting (8)
NRR commitments prior to start of Phase 2
.,n
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PROJECT INSPECTION PLAN T!E'isWM'is"?
ouAuTY AssuaAt;;r :n Anweg; pg
. c=m AND REPORT PA:Elcq CAI.5-1
- JECT 12:5?ECT105 F2007.0 50:
PROJICI IKSPECTICS T'x! NO:
71~~.1:
C-26F Installa:ica Inspection of Sheet Piles PIv: 0 for Deep Q - Duct-San'-
./.:7/:
PKCJECI:
PR1;PALD Bi/0;.TE:
Ecyrp ;/pA;I:
E' YM* N N/A Midland Units 1 & 2 jMN 4/i+lT4 IJ y//s/f 7__ l
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- CPI:
l
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INIT A / ATI CEARA ER CHAF.ACTIRISTIC DISCKIPTIOS CR 1.0 PREREOUISITES
.1.1 Prior to installation of sheet piles f or 195-53-1 dee;i Q-duct bank all supervisory staff or 5.1,3.3,3.5 his designee shall be trained.
All trainir<;
sessica,s shall be docu=ented V/R - F.P
.100 Verif y the acceptance of the subsequen*/
C195-53-1 1.2 revisions to shop drawing F7220-C-195 28(1) 4.4
-1 are reviewed by M?QAD/QC prior to i=ple=entation V /R - EP - 100 2.0 INSTA1.1ATION OF SEEET PILES Vnile threading the adjacenthet piles C195-53-1 2.1 7.4 every other sheet shall be ;du= bed in accordance with the ref cGed drawings Shop Drawing and tack-welded to the
- late.
F7220-C195 -
58(1)
V/R - IP - S
.2 Pile driving shall be stopped at l'-- 6" f r o:
Shop drawing l
F7220-C195-top of Q Dadt-bank.
5S(1)
References:
Shoa ravint:
77220 - C-195 - 58(1) mus:
Pr_cedure:
F7220 - C-195 1 N,,f g.
I'_191 A ((O c o,.
1
.ek 1
/
/
/
I===
.!! A r?::STS:
...1/: l i '. :
A F N..".
. 7;t;E0 EY/; ATE:
PROJECTS. ENOINE tRING
' "c=
PRO'JFCT 'INSPFGTlnM.
PLA.N c u a n "u"su u N a e m "a m e,a
^
" 5" * '
.g : n.,= 5 e
t= m R [.
OR I rytict AND.
l' cu,_,
rEoJte: 1xstt: Tics Pixi so:
.:m]. 1ssrt: tes tt=7.s no:
C-26F uv O usacTtt trrtrzx:t '
Rtv #5 cnAracTrus:1c ttscatrilox InTp s/Dnt
. yo-cu tuA
/
2.3-verif y thar_ the piles are driven 5' to 20' C195-53-1 at a time and to approxi=ately the same 7.6
.l.ev..el..
V7R C IP - S 2.4
,Verif y that the piles are driven to the C195-53-1 design. depth as shown in the referenced 7.6 drawings, utilizing " Double acting bemer."
/
V/R - IP - S 2.5 Verif y that if obstructions prevent driving C195-53-1 of' sh'eet piles,. the piles surrounding 7.6
~
duct-bank are driven to the desired eleva-tions as detcrnined by the subcontractor,
[s'upervision.
V/R - IP - S
/
1 3.0 QUALI'~i-CONTROL INSPECTION & RECORDS
/
\\ /
3.1 Reviev QC inspection records including. >
Bechtel QC accu FIR-MPC-34 sdich' to verif y they are co=plete,j --
^ -
l
' rate and up-to-date.
R-IP/PP - S 3.2 Reviev quality centrol training records PSP G-8.1 th'aE' QC personnel perf orming these inspec-Para 9.3 tions are' trained.
~
R - IP /PP - S Verif y the QCE perf ormance e/ nspection i
Bech:el QC
- 3. 3-._
ac tivities FIR-t?C-34 V
IP /PP - S D
.e
A c==.m PROJECT INSPECTION PLAN "iff E'is M E it"?
cuAu n Assuu~tt m m xt g3-AND REPORT Pact _i_or,_2_
y in.
er cAcs-1 ra Jr= :xstrenex 7.Ax sa:
n::.t:
ptn :::srt=:cs F.t:07.D ::o:
C-26F Installatica inspectics of Sheet Piles rn: 1 f or Deep Q - Duct-Bank y/;A;;; M O PKoJtcI:
TFIPAht.i sy/ ATE:
poor.o.rp M
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']F[g}CE 1xz7$$x;g
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l 1.0 PREREQUISITES 1 ".1 Prior to installation of sheeti piles f or C195-53-1 deep Q-duct bank all supervisory staf f or-5.1,3.3,3.5
' his designee shall be trained.
All trainint; sessions
- shall be documented V/R - HP - 100 1.2 Verif y the acceptance of the subsequent.
C195-53-1 revisions to shcp drawing F7220-C-195-58(1) 4.4
-1 are reviewed by MPQAD/QC prior to i=plementarien V/R - HP - 100 2.0 INSTALLATION OF SEEET PII.ES 2.1 k'hile threading the adjacent sheet piles C195-53-1 every other sheet shall be plu= bed in 7.4 accordance with the referenced drawings Shop Drawing and tack-welded to the te= plate.
77220-C195 -
58(1)
V/R - IP - S 2.2 Pile driving 'shall be stopped at l'-6" frcza Shop drawing top cf Q Duct-banr..
r7220-C195-58(1)
References:
Shoo Drawine:
F7:20 - C-195 - SS(1) ynJ.s :
Procedure:
F7220 - C-195 1 to,.k.
1
- n. 3. 4. e..
E 1 '41 A (M od1 e
N rXs.W5:
PRt.: :Ts. tNc:NttR:NO
@3 :=o==
P ROJ E.CT 'lN. S P. F C.Tl n M..
PL A.M, c=um'""= m'Nu x' - m
"" * = "-
v,7jn
',==;m AND.
R I.
OR I F
u.2 2 cr 2 twtc mrt=es t'.As m C-26F
- .Jt:7 issrt ::cs r.tt:r.3 no:
I nv.
m.w u.
ttnz 3tt RneArr.s m-.a,an csAtAcnt:s :c ttser.irnos n
2.3 Verify that driving of sheets will be such C195-53-1 that the adjacent tips shall not exceed a 7.6 dif f erential of 20' nor any pile shall not' FCS #2040 be driven more chan 20' at a ti=e to main-tain verticality.
V/R - IP - S 2.4 Verify that the piles are driven to the C195-53-1 design depth as shown in' the ref erenced 7.6 drawings, utilizing "i= pact ha=ner."
FCN 61985 N/R IP - S 2.5 Verif y that if obstructions prevent driving C195-53-1 of sheet piles, the piles surounding 7.6 duct-bank are driven to the desired eleva-tions as deter =ined by the subcontractor,
' supervision.
~
V/R - IP - S 3.0 QUALITY CONTROL INSPECTION & RICOFOS 3.1 Review QC inspection records including Bechtel QC sketch to verif y they are conplete, accu-FIR-MPC-34 rate and up-to-date.
R - IP/PP - S 3.2 Review quality control training records PSP G-8.1 that QC personnel performing these inspec-Para 9.3 tiens are trained.
R - IP/PP - S 3.3 verify the QCE performance of inspection Bechtel QC FIR-MPC-34 ac tivities.
V - IP/PP - S D
S
% :=.m PROJECT INSPECTION PLAN
,,.jsysjMys,,,,
O EE AND REPORT c;,t. E.1
- c7 n
- snt:Ics rz:cr.n ::o:
rR JE;T I::SFICTICS Pl>3 :;o-
-r-C-261 Installation Inspection of Access FIV:
O Pit for Deco O Duct Bank
.m FWoJECI:
PFIWJID BY/0/.7E:
/SFrevED 1 1 Id 4 r e z.su-w N/A Midland Units 1 & 2 JagTish C. Shah 4/24/82{
4 j
'rI:
E A uCTtR CHATJ.O!tRISTIC DISCRIPTION
.INIIIALS/DAII
~
);0 CRITERIA 1.0 PREP 20UISITES l'.1 Prior to installation of access pit for C195-59 Ddep Q. Dact Bank, all supervisory staff or 5.1
~~
his designee shall be trained.
All training sessions shall be documented.
V - IP - H 1.2 A,ll welders shall be qualified and certified C195-59 by Bechtel, prior to velding.
5.2 V - IP - H 1.3 Verif y that a,cceptance of the susequent C195-59 revisions to the ref erenced shop drawing 4.3 M2, Rev 1 are reviewed by MPQAD and Quality Control prior to i=plementation.
V - IP - H 2.0 EXCAVATION 2.1 Verify that, if any perched water pockets C195-59 are net, the dewatering shall be i=ple=ented 7.1 prier to further excavatien.
C195-64 V/R - IP/PP - S F7220-C195-53-1 ya;f3:
REFEFISCES :
Mercentine Corporation procedures:
7220-C195-59-1 Shoo Drawine:
M-2 Rev 1 Sechtel Drawint:
C1316 (0) nev 1 Bechtel Snec:
C231 (0) Rev 21
- .-P.rs s:
. E NGIN E E RIN G j
PRO 'ECTs. ENOtHEER:N AND cCNSTRUOTION -
IIEUtrloN -
l A ] [ b"~~! '
D p f' ~ 3 v.lgl, D
.h lO,
OUAtlTY ALOURANCE OEPARTMEt TJiOI CEFA8: MEN I
I i
v w
C.f bl PACI 2 CT 3 JAct 3 cr 3 j
incJs= wsit=: s r:x so:
us:
C-261 0
rm PJ.s RIhA?J.s unnDirt s/cAn nInA:s/:An caAv.=II:s :: :tsOx:rno::
cy;3u
.at outlined procedures f or excava-C195 -
f ollowed as specified and the 8.1, 8.2
.s of excavation are controlled as 9.2, 9.4 and concurred by the contracror, Soils Group field engineer af ter
.icn with resident geo-technical
-S IION OF k'A1.ES 6 LACGING t
=
i sequence of installing vales 6' C195-59 l
atis f ollowed as specified.
8.1, 8.2 l
-S C195-59 Bat lagging 6 backpacking below is acco=plished as specified.
10.3 4
-S 2 alternate E - beams are used, C195-59 l
ar'if y that steel channels are 13.1 - 13.3 nstalled as lagging and backpacking
.s acconplished in accordance with lpproved procedure.
(alternate)
,_s
. ?LACEMENT.
~
i hhat bef ore cencrete is placed, the C195-59 L.shall be approved by the onsite -
11.1 Icch Engineer.
rS l hat nudnat or concrete is placed in C195-59 taco with project specification.
11.1, 11.2 Bechtel Spec.
C231 (Q) 5.6. 11.00
'-s CONTE 01. INSPECTION 6 FICORDS QC inspection records to verif y they Applicable Sechtel QC.
plcre, accurate and up-to-date.
TIR/PQCI
-S e
= g D:LHETE' uw?
COTIFICATE OF SEVICE
'83 h'0V -1 R2:07 I hereby certify that copies of the attached responses of Consumers Power CFFi Cc=pany to Discovery Questions of Intervenor Barbara Stamiris veye) nyibyg.,
ym U S Mail, first class, postage prepaid, to the attached service list t:ii' '
s 27th' day of October, except-for Lynne-Bernabei, William Paton and Chairman 3echhoefer, who were served by Federal Express.
)
t eu W. w }/
Catherine M Gleeson
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"%F C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 NOV -1 N s ATOMIC SAFETY AND LICENSING BOARD
' FF F.: D sm:.
DocketNbdIhh['051
'T In the: Matter of -
CONSUMERS POWER COMPANY 50-330 OM (Midland Plant., Units 1 and 2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF JAMES E BRUhTER My name is James E Brunner.
I am primarily responsible for providing a response to the interrogatory numbered 33 submitted by Barbara Stamiris on October 11, 1983.
To the best of my knowledge and belief, the response to the above-mentioned interrogatory is true and correct.
Sworn and Subscribed Before me This M y of 1983 h b(
0 W
Notary Public Jackson County, Michigan My Commission Expires [/3
/j[i[b afl083-0645b100
I
~T:~n:: :f:::
- ',fEji*
UNITED STATES OF A* ERICA NUCLEAR REGULATORY COMMISSION
'33 gy 1 R2:M ATOMIC SAFETY AND LICENSING BOARD CF?
DockN*f4 ';;k929 OM No5,i.g,j 5
In the Matter of;
~b-T30 OM 5
CONSU'ERS POWER COMPANY
.(Midland Plant, Units 1 and.2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF JEROME E KOSTIEUEY
.My name is Jerome E Kosticiney.
I am primarily responsible for providing responses to the interrogatories numbered 25, 26, 27, 28 and 29 submitted by Barbara Stamiris on October 11, 1983.
To the best of my knowledge and belief, the responses to the'above-mentioned interrogatories are true and correct.
9
~
Sworn and Subscribed Before me Thisp$[ Day of h 1983
.nH<Al
--11 iv Notary Public 1-
_Mi@emd-County, Michigan
- kthf My Commission Expires,) f ns.r' U }??$
af1083-0640a100
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UNITED STATES OF AMERICA
'83 liDV -1 P12:06 NUCLEAR REGULATORY COMMISSION
" " ~
ATOMIC SAFETY AND LICENSING BOARD k.E 4, _ int,[.[. (a% 5,,
M E?ANCh Docket No 50-329 OM In the Matter of 50-330 OM CONSU'IERS PO'n'ER COMPANY Docket No 50-329 OL (Midland Plant, Units I and 2) 50-330 OL AFFIDAVIT OF GLENN MURRAY
-My name is Glenn Murray.
I am primarily responsible for providing responses to interrogatories 31 and 32 submitted by Barbara Stamiris on October-11, 1983. To the best.of my knowledge and belief, the responses to-the above-mentioned interrogatories are true and correct.
k
/;
i
)
Sworn and Subscribed Before me This M Day of d r 1983 n1E~ N d) it H
-y i
Notary Public Midland County, Michigan M
MyCommissionElpires go me/ d / 9 f[a rMGM-@l%29a 100
1 CC' XETEC n;.;~_~ -
USNRC UNITED STATES OF AMERICA
~
NUCLEAR REGULATORY COMMISSION
.g3 g, q ATOMIC SAFETY AND LICENSING BOARD CF Docket'jyjj:Sn.-z.
In the Matter of No'"5f.52'9E6N CONSUMERS Port.R COMPAhT 562350 OM (Midland Plant, Units 1 and 2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF DAVID F R0hT My name is David F Ronk.
I am primarily responsible for providing responses to the interrogatories numbered 15 and 17 and jointly responsibic for providing responses to interrogatories numbered 20, 21 and 22 submitted by Barbara Stamiris on October 11, 1983. To the best of my knowledge and belief, the responses to the above-mentioned interrogatories are true and correct.
f f
r I
- t. AC4 Sworn and Subscribed Before me This %
Day of M [.1983 a.uk
. ~ - - -
v-Notary Public 11id2:nd County, Michigan any My Commission Expires MdA.c
/9[3 afl083-0642a100
a '.
1
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us m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 NDP - I Pl2:06 ATOMIC SAFETY AND LICENSING BOARD CFFitr.;r sb.- :,
In the Matter of DFrxetNNd 50?329 OM CONSUMERS POKER COMPANY E?ANC50-330 OM (Midland Plant, Units 1 and 2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF JOHN R SCHAUB My name is John R Schaub.
I am jointly responsible for providing responses to interrogatories numbered 20, 21 and 22 and primarily responsible for providing responses to interrogatories numbered 23 and 24 submitted by Barbara Stamiris on October 11, 1983.
To the best of my knowledge and belief, the responses to the above-mentioned interrogatories are true and correct.
't t. - [
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Sworn and Subscribed Before me This2. U Day of [ l [1983
~)
'kii 0 " ididS/
n Notary Public 11idland County, Michigan r3 u
.My Commission Ex ires V)%,o d / G.[4 af1083-0643a100 l
./-,
3 i _ ;.
_., _ __ i i-y,{; g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 gy -1 P12 :06 ATOMIC SAFETY AND LICENSING BOARD UFU Or 5tc..
In the Matter of Dockhkifikfd0hifU.0M CONSUMERS P0kIR COMPANY
~$dS~530 OM (Midland Plant, Units 1 and 2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF JAMES A MOONEY My name is James A Mooney.
I am primarily responsible for providing responses to the interrogatories numberea 6, 7, 8 and 9 submitted by Barbara Stamiris on October 11, 1983. To the best of my knowledge and belief, the responses to the above-mentioned interrogatories are true and correct.
bibo' s
Sworn and Subscribed Before me This M D y of b b 983
/1our /. J?obuuwO 1
Notary Public Jackson County, Michigan My Commission' Expires
[/7 J-b d,
/7[b 6
af1083-0644a100
1
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~ ~ ~ ~
UNITED STATES OF AMERICA
~
NUCLEAR REGULATORY COMMISSION
'83 NOV -1 Pi2 :06 ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
329 OM CONSUMERS POWER COMPANY 50-330 OM (Midland Plant, Units 1 and 2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF ROBERT SEVO My name is Robert Sevo.
I am primarily responsible for providing responses to i
the interrogatories numbered 10, 11, 12, 13 & 14 submitted by Barbara Stamiris on October 11, 1983.
To the best of my knowledge and belief, the responses to the.above-mentioned interrogatories are true and correct.
b Affirmed and Subscribed Before me This,Q/
Day of M1983
.i }/ /N U
n 8[
Notary Public Midland County, Michigan
, ')'J ftA4.M
/7b My Commission Expires
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4 af1083-0641a100
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 NOV -1 P12 :06 ATOMIC SAFETY AND LICENSING BOARD CFF".1 2: 5i...
In the Matter of Docks $Cf[o]S0)2[b5 7
CONSUMERS POWER COMPANY 50-330 OM (Midland Plant, Units 1 and 2)
Docket No 50-329 OL 50-330 OL AFFIDAVIT OF RODNEY H WIELAND My name is Rodney H Wieland.
I am primarily responsible for providing a response to Interrogatory 30 submitted by Barbara Stamiris on October 11, 1983. To the best of my knowledge and belief, the response to the above-mentioned interrogatory is true and correct.
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/AA uf AffirmedandSubscribedBeforemeThis.S/.4~ Day of(;'/ 1983 Y* o 7T/ O L I_f t
/.t i c's Notary Public Midland County, Michigan sa. ;
My Commission Expires J)? r u
// / Y.fS af1083-0638a100-12