ML20064K526

Intervenor B Stamiris Interrogatories & Document Requests to CPC Re Soil & Bldg Settlement.Certificate of Svc & Afifi Affidavit Encl.Related Correspondence

ML20064K526
Person / Time
Site:	Midland
Issue date:	01/14/1981
From:	Stamiris B AFFILIATION NOT ASSIGNED
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20064K524	List: ML20064K520 ML20064K526
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102030369
Download: ML20064K526 (7)

Text

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RELiTED CORRESPONDEhch UNITED STATES OF AMERICA NUCLEAR REGUlATORT COMMISSION Dooket No s.50-329 QM 50-330 OM O In the Matter of Censumers Power Co. -

50-329 OL 50-330 OL Midland Plant Units 1 & 2 BEFORE THE ATOMIC SAFETT AND LICENSING BOARD INTERVEMOR REQUESTS OF CONSUMERS POKER COMPANT 1/14/81 In moeerdance with 10 CFR 2.740b and 2.741, Intervener Barbara Stamiris serves en Censumers Power Co. the fellowing interrogatories and deoument reque st s :

(Instruotions and definitions as stated in 12/4/80 request)

1. NRC Inspection Report 50-329/33078-12 netos "Other Activities to be Planned (1) Possible sere borin6s in eeeling pend dike area te verify integrity of dikes." Provide documents as a basis for this statement and relating to the decision en this matterwas it was first considered.

2. Were any audits eendusted severing soil settlement matters (including If so, provide QA QC aspects) which have not been presented to the NRCf these findings.

3. liew mueh time is alleted in the mest resent eempletism schedule for remediation of soil settlement matters and for respenses to NRC testing and boring requestof begunt What was the means of

4. When was the Administrationit Buildin6 tion Building and when was that

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5. Provide the Bechtel reports as to the cause of the Administration Buildin6 settlement and whether it was an isolated problem,or any other event.

reports reconenending precedural chan6es stemming from this

6. Describe the Established Foundation Data Survey Program for the Diesel Generater Building . When was it established,and by whout

7. Were any settlements noted formally or infer:mally prior to July 1978'

• r the. <he< et gen e rt2 4e,- buildig 7 l

If se provide these observations.

8. When was Dr. Peak or any other soil settlement consultant first told Provide any documents of the settlement of the Administration Buildingt i

recording discussion of the Administration Building with soil settler.ent con sultant s.

settlement of the Administration

9. When wa s the NRC first informed of the Building / Relate the circumstances of this initial disclosure.

10. Arsendment 3 to the PSAR eliminated the original site dewatering plan Provide documents relevsnt to this decision.

Caseload Forecast Panel Veeting in Midland , mention

11. At the July 29,1980 was made of C.P.Co. leane to Beehtel and other subcontracters in the intr of staying en schedule. Deseribe the extent-ef these'. leans and the circum-stances surrounding them.

12. Were there any established requirements regarding groundwater elevations 19787 If so and their effects en plant foundations and structures in provide these documents.

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15. What work has been done sinow A ril 1980 en the Diesel Generater Building? What pereent eemplete is the building newt

14. What precedure er system is fellowed te record er eerrect peer employee performaneetby Beehtel er C.P.'Co.1 Have any employees withbjebs relating to soil settlement matters been fired.or received some type of warnin6 relted to job performanoef If se provide these records.

15. On page 26 ef MRC Inspection Report 50-329/330 78-20,mentien is made of the QC inspector who was primarily reopensible for the plant fill werk who is ne longer employed by Bechtel. Provide the name of this individual, his position gand the daps;;stt his employdent,and forwarding address.

16. Provide the names and addresses of any other QA er QC personnel 1975-1980 who are ne longer with jobs relating to soil settlement from employed by Beehtel er C.P. Co.

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General OMicas: 212 West Michigan Avenue, Jackson, Mkhigen 49201 * (517) 786 4660 January 23, 1981 Ms Barbara Stasiris 5795 North River Road Ecute 3 Freeland, MI h8263

Dear Ms Sta= iris:

i Attached is a ecpy of an Affidavit of Sherif Afifi, which, due to = ailing delays, was not included with the interrogatory answer previcusly submitted.

Very truly yours,

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( is 9 h UNITED STATES OF AMERICA j Ja sp h NUCLEAR REGULATORY COMMISSION y. fgg pl j **1

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD < l,%'::e q

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In the Matter of )

CONSLTERS POWER COMPANY ) DOCKET NOS. 50-329-0M

) 50-330-0M

) 50-329-OL (Midland, Units 1 and 2) ) 50-329-OL

)

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AFFIDAVIT OF SHERIF AFIFI Sherif Afifi, being duly sworn, deposes and says that he is employed by Bechtel Associates Professional Corporation, as an Engineering Supervisor; that he is jointly responsible with Neal Swanburg for providing answers to Barbara Stamiris' Interrogatories to Consu=ers Power Conpany Nunber 2-3; and that to the best of his knowledge and belief the above information and the answers to the above interrogatories are true and correct.

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Sherif Afifi Subscribed and sworn to before ce this ,' / - day of u . . . , _ , 1981.

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Notary Public, Washtenaw Co. Michigan My Consission Expires:  %> <u m ,. .

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CERTIFICATE OF SERVICE e

James E Brunner hereby certifies that he served a copy of the Affidavit of Sherif Afiti pertaining to answers submitted to Barbara Stamiris Interrogatories, by placing a copy of same in the mail, first class postage prepaid, addressed to the following:

Atomic Safety & Licensing Appeal Board US Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety & Licensing Board Panel j ' o:

US Nuclear Regulatory Commission j '. )A,-

Washington, DC 20555

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Charles Bechhoefer, Esq Atomic Safety & Licensing Board Panel  ; M , gf, US Nuclear Regulatory Commission g.pe f.M. g: cep/

Washington, DC 20555 f t-SSi..:.J..;.i. i e

f Myron M Cherry, Esq / g h One IBM Plaza, Suite 4501 Chicago, IL 60611 Dr Frederick P Cowan 6152 N Verde Trail, Apt B-125 Boca Raton, FL 33433 Mr Steve Gadler 2120 Carter Avenue St Paul, MN 55108 D F Judd, Sr, Project Manager Babcock & Wilcox PO Box 1260 Lynchburg, VA 24505 Frank J Kelley, Esq Attorney General of the State of Michigan Stewart H Freeman, Esq Assistant Attorney General Gregory T Taylor, Esq Assistant Attorney General l Environmental Protection Division 720 Law Building l

Lansing, MI 48913 Gustave Linenberger Atomic Safety & Licensing Board Panel US Nuclear Regulatory Commission Washington, DC 20555

2 Mr Wendell H Marshall RFD 10 Midland, MI 48640 4

Michael Miller, Esq Isham, Lincoln & Beale One First National Plaza, Suite 4200 Chicago, IL 60603 William D Paton, Esq Counsel for the NRC Staff US Nuclear Regulatory Commission ,

Washington, DC 20555 Ms Mary Sinclair 5711 Summerset Street Midland, MI 48640 Barbara Stamiris 5795 North River Road Route 3 Freeland, MI 48623 Mr C R Stephens Chief, Docketing & Service Section Office of the Secretary US Nuclear Regulatory Commission Washington, DC 20555 Sharon K Warren 630 Hillcrest Midland, MI 48640

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awe'd  !

Dated: January 23, 1981 ' James E Brunner l

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