ML19339A606: Difference between revisions
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\ t s ss e q q =*m es es | \ t s ss e q q =*m es es | ||
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; ' F0r13f mm | ; ' F0r13f mm | ||
(!, | (!, | ||
%ce President, stsJland i+vject Generea Of..cos: 1945 West Parnall Road, Jackson, Mechegan 49201 e (517) 788-0640 October 31, 1980 Mr J G Keppler, Regional Director Office of Inspection & Enforcemer.t US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEA'4 PLANT UNITS 1 AND 2, DOCKET NOS 50-329, 50-330 SWAY STRUT RCD ENDS DEFICIEICY FILE: 0.h.9.h2 UFI: 73*10*01, 152h0(E) SERIAL: 978h This letter confirms the 50.55(e) item cencerning Sway strut Rod Ends Deficiencies reported by telephcne call to R Sutphin, USNRC Region III, Glen Ellyn, IL, on September 2h,1980. . | |||
%ce President, stsJland i+vject | |||
Generea Of..cos: 1945 West Parnall Road, Jackson, Mechegan 49201 e (517) 788-0640 October 31, 1980 Mr J G Keppler, Regional Director Office of Inspection & Enforcemer.t US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEA'4 PLANT UNITS 1 AND 2, DOCKET NOS 50-329, 50-330 SWAY STRUT RCD ENDS DEFICIEICY FILE: 0.h.9.h2 UFI: 73*10*01, 152h0(E) SERIAL: 978h This letter confirms the 50.55(e) item cencerning Sway strut Rod Ends Deficiencies reported by telephcne call to R Sutphin, USNRC Region III, Glen Ellyn, IL, on September 2h,1980. . | |||
The attachments to this letter describe the conditions and actions taken concerning this item. | The attachments to this letter describe the conditions and actions taken concerning this item. | ||
Another report, either interim or final, vill be sent on or before December 19, 1980. | Another report, either interim or final, vill be sent on or before December 19, 1980. | ||
&h , wf-WRB/lr Attachments: 1) Management Corrective Action Report (MCAR-1), Report :Io h2, dated September 24, 1980 | |||
&h , wf- | |||
WRB/lr Attachments: 1) Management Corrective Action Report (MCAR-1), Report :Io h2, dated September 24, 1980 | |||
: 2) MCAR h2, Interim Report 1, Loose Hanger Standard Parts Bushings, dated October 21,19S0 CC: Director of Office of Inspectica & Enforcement Att Mr Victor Stello, USI;RC (15) | : 2) MCAR h2, Interim Report 1, Loose Hanger Standard Parts Bushings, dated October 21,19S0 CC: Director of Office of Inspectica & Enforcement Att Mr Victor Stello, USI;RC (15) | ||
Director, Office of Management Sol 1 s | Director, Office of Management Sol 1 s | ||
Information & ProCra . Control, US:!RC (1) | Information & ProCra . Control, US:!RC (1) | ||
R Cook, USNRC Resident Inspector j Midland Nuclear Plant (1) ' | R Cook, USNRC Resident Inspector j Midland Nuclear Plant (1) ' | ||
801104o @ 5 . s | 801104o @ 5 . s | ||
1] | 1] | ||
2 Serial 978h CC: CBechhoefer, MLB Panel GALinenber;;er, ASLS Panel FPCowan, ASL3 Panel AS&L Appeal Panel. | |||
2 Serial 978h | |||
CC: CBechhoefer, MLB Panel GALinenber;;er, ASLS Panel FPCowan, ASL3 Panel | |||
AS&L Appeal Panel. | |||
MMCherry, Esq MSinclair CRStephens, US!!RC | MMCherry, Esq MSinclair CRStephens, US!!RC | ||
'4DPaton, Esq, USNEC | '4DPaton, Esq, USNEC FJKelly,'Esq, Attorney _ General SHFreenan, Esq, Asst Attorney General GTTaylor, Esq, Asst Attorney General. | ||
'4FJ4arshall GJMerritt, Esq, TNK&J Great Lakes QA-Managers 0 | |||
FJKelly,'Esq, Attorney _ General SHFreenan, Esq, Asst Attorney General GTTaylor, Esq, Asst Attorney General. | 9 0 | ||
'4FJ4arshall GJMerritt, Esq, TNK&J Great Lakes QA-Managers | e 39 | ||
0 | |||
39 | |||
I | I | ||
Line 66: | Line 45: | ||
.'*..- REPORT NO. | .'*..- REPORT NO. | ||
* 1 O | * 1 O | ||
September 24, 19pjj | September 24, 19pjj JOB NO. O NO. DATE 1 | ||
JOB NO. O NO. DATE 1 | |||
* DESCRIPTION finefu fing referencesh Standard parts (sway struts, unubbers, and shock suppit'nors) purchased from III Grinnell, NPS Industries, Pac'ific Scientific Industries, and Corner /r Luca ' | * DESCRIPTION finefu fing referencesh Standard parts (sway struts, unubbers, and shock suppit'nors) purchased from III Grinnell, NPS Industries, Pac'ific Scientific Industries, and Corner /r Luca ' | ||
have been found to contain partially or totally disengaged self-aligning rod end bushings. | have been found to contain partially or totally disengaged self-aligning rod end bushings. | ||
Ref.: Bechtel NCR's 3108, 3109, 3110, 3130, 3131. (This attribute is not a specific inspection point). Project Engineering has concluded that this condition, if not corrected, could cause the piping and/or piping welds to become overstressed. ' | Ref.: Bechtel NCR's 3108, 3109, 3110, 3130, 3131. (This attribute is not a specific inspection point). Project Engineering has concluded that this condition, if not corrected, could cause the piping and/or piping welds to become overstressed. ' | ||
' RECOMMENDED ACTION (Optional) . | ' RECOMMENDED ACTION (Optional) . | ||
: 1. Project Engineering provide criteria for determining acceptability of rod end bushin'g installation in purchased components. . | : 1. Project Engineering provide criteria for determining acceptability of rod end bushin'g installation in purchased components. . | ||
Line 81: | Line 57: | ||
P cate W R.D fr ject t *-oAOEngin)er-i c c s u 9 "2.( - CO / 0 11 REPORTABLE DEFICIENCY 8 l | P cate W R.D fr ject t *-oAOEngin)er-i c c s u 9 "2.( - CO / 0 11 REPORTABLE DEFICIENCY 8 l | ||
NOTIFIE LIE JT W3 ahu ed G M / 2 u*~ | NOTIFIE LIE JT W3 ahu ed G M / 2 u*~ | ||
cate O No i l Eves _ | cate O No i l Eves _ | ||
rt tt.tanagerf | rt tt.tanagerf | ||
--)W/ t, ate | --)W/ t, ate 111 CAUSE CORRECTIVE .a.CT;0N TAKEN | ||
111 CAUSE CORRECTIVE .a.CT;0N TAKEN | |||
:D g m A 3'T~ | :D g m A 3'T~ | ||
V | V | ||
% e Jlu n a AUTHORIZED BY | % e Jlu n a AUTHORIZED BY oste ttsa m :tes ttv. cs w.,..,,, FORMAL REPORT TO CLIENT Pgr. et q uiro P t y. Frecer..cng Pgr. (If section II Applies) Date Fee),et *a..ger. | ||
oste ttsa m :tes ttv. cs w.,..,,, FORMAL REPORT TO CLIENT Pgr. et q uiro P t y. Frecer..cng Pgr. (If section II Applies) Date Fee),et *a..ger. | |||
: c. ......s , ,....., | : c. ......s , ,....., | ||
$,#i 3,''/" | $,#i 3,''/" | ||
Line 101: | Line 71: | ||
euni .n..,,,,,..u,.,.,,.....,..,,,,,,.,,,,,oo,.... Project GA Engineer Dat iM f4 C | euni .n..,,,,,..u,.,.,,.....,..,,,,,,.,,,,,oo,.... Project GA Engineer Dat iM f4 C | ||
Attachr.ent 2 Serial 976h Bechtel Associates Professional Corporation 0i4358 | Attachr.ent 2 Serial 976h Bechtel Associates Professional Corporation 0i4358 | ||
==SUBJECT:== | ==SUBJECT:== | ||
MCAR 42 (issued 9/24/80) | MCAR 42 (issued 9/24/80) | ||
Loose Hanger Standard Parts Bushings INTERIM REPORT 1 DATE: 10/21/80 PROJECT: Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 | Loose Hanger Standard Parts Bushings INTERIM REPORT 1 DATE: 10/21/80 PROJECT: Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Introduction Description of Deficiency Sway struts, snubbers, and shock suppressors purchased from ITT Crin-nell, NPS Industries, Pacific Scientific Industries, and Corner & Lada, Inc have been identified in Nonconformance Reports (NCRs) 3108, 3109, and 3110 dated September 8,1980, and 3130 and 3131 dated September 23, 1980, to have loose or totally disengaged rod end bushings. | ||
Introduction | |||
Description of Deficiency Sway struts, snubbers, and shock suppressors purchased from ITT Crin-nell, NPS Industries, Pacific Scientific Industries, and Corner & Lada, Inc have been identified in Nonconformance Reports (NCRs) 3108, 3109, and 3110 dated September 8,1980, and 3130 and 3131 dated September 23, 1980, to have loose or totally disengaged rod end bushings. | |||
Potential Safety Implication A potential safety problem would exist if the cap assembly became par-tially or totally disengaged from the bushing causing a binding or gap between the bushing and the intersurface of the cla=p or rear bracket. | Potential Safety Implication A potential safety problem would exist if the cap assembly became par-tially or totally disengaged from the bushing causing a binding or gap between the bushing and the intersurface of the cla=p or rear bracket. | ||
Existence of this gap or binding during a seismic event could result in overstressing of piping and/or piping welds due to movement of the piping system. This overstressed condition could result in a signif-icant safe".y hazard due to possible failure of the pressure boundary because of unanalyzed forces and movements. | Existence of this gap or binding during a seismic event could result in overstressing of piping and/or piping welds due to movement of the piping system. This overstressed condition could result in a signif-icant safe".y hazard due to possible failure of the pressure boundary because of unanalyzed forces and movements. | ||
Investigation Loose bushings were identified on pipe support sway struts supplied by Corner & Lada, Inc to Union Electric Calloway Unit 1 and Kansas Cas and Electric Wolf Creek Generating Station. The deficiencies in the sway struts for Wolf Creek Generating Station were reported to Nuclear Regu-latory Commission (NRC) Inspection and Enforcement (I&E) Region IV in accordance with 10 CFR 50.55(e). Subsequently, these deficiencies were reported by Bechtel to NRC I6" Region I in accordance with 10 CFR 21 (see attached report dated July 24, 1980). | Investigation Loose bushings were identified on pipe support sway struts supplied by Corner & Lada, Inc to Union Electric Calloway Unit 1 and Kansas Cas and Electric Wolf Creek Generating Station. The deficiencies in the sway struts for Wolf Creek Generating Station were reported to Nuclear Regu-latory Commission (NRC) Inspection and Enforcement (I&E) Region IV in accordance with 10 CFR 50.55(e). Subsequently, these deficiencies were reported by Bechtel to NRC I6" Region I in accordance with 10 CFR 21 (see attached report dated July 24, 1980). | ||
Based on this information, engineering requested an investigation be performed at Midland plant Units 1 and 2. Deficiencies in sway struts ; | Based on this information, engineering requested an investigation be performed at Midland plant Units 1 and 2. Deficiencies in sway struts ; | ||
manufactured by ITT Crinnell, Pacific Scientific Industries, and NPS l Industries, as well as those manufactured by Corner & Lada, Inc w e identified in the above NCRs. | manufactured by ITT Crinnell, Pacific Scientific Industries, and NPS l Industries, as well as those manufactured by Corner & Lada, Inc w e identified in the above NCRs. | ||
Line 122: | Line 84: | ||
1 | 1 | ||
I Bechtel Associates Professional Corporation l MCAR 42 q.4353 Interim Report 1 October 21, 1980 Page 2 | |||
I Bechtel Associates Professional Corporation l MCAR 42 q.4353 Interim Report 1 | |||
October 21, 1980 Page 2 | |||
: 1. Identify and locate all sway struts furnished to the Midland plant by Corner & Lada, Inc, ITT Crinnell, Pacific Scientific, and NPS. | : 1. Identify and locate all sway struts furnished to the Midland plant by Corner & Lada, Inc, ITT Crinnell, Pacific Scientific, and NPS. | ||
: 2. Inspect all bushings to determine if they are loose or improperly installed. | : 2. Inspect all bushings to determine if they are loose or improperly installed. | ||
: 3. Obtain the manufacturer's recommended procedures for resolving di 41ciencies without precluding warranty, and repair or re Mace the b..hings. | : 3. Obtain the manufacturer's recommended procedures for resolving di 41ciencies without precluding warranty, and repair or re Mace the b..hings. | ||
: 4. Review jobsite receipt inspection procedures on all sway struts furnished to the Midland jobsite for possible modification. | : 4. Review jobsite receipt inspection procedures on all sway struts furnished to the Midland jobsite for possible modification. | ||
Reportability Based on the potential safety concerns and numerous , vendors involved, this ites is considered reportable. This deficiency was reported by telephone on August 24, 1980, to Mr. R. Sutphin, Office cf Inspection and Enforcement, Region III, U.S. Nuclear Regulatory Commission, by Consumers Power Co=pany as a reportable deficiency for Midland Units 1 ' | |||
and 2 in accordance with 10 CFR 50.55(e). | and 2 in accordance with 10 CFR 50.55(e). | ||
Based on identification of similar deficiencies at the Palisades plant, this deficiency was reported, both verbally and by letter, by Bechtel on October 8, 1980, in accordance with 10 CFR 21. | Based on identification of similar deficiencies at the Palisades plant, this deficiency was reported, both verbally and by letter, by Bechtel on October 8, 1980, in accordance with 10 CFR 21. | ||
Line 143: | Line 100: | ||
/ | / | ||
./ | ./ | ||
J h 1 10CTR50.55(e) REPORT o= | J h 1 10CTR50.55(e) REPORT o= | ||
Di4122 Loose 3dshings In Pipe Supperc :.vay Struts s Supplied By Corner & 1.ada Co., Inc. | Di4122 Loose 3dshings In Pipe Supperc :.vay Struts s Supplied By Corner & 1.ada Co., Inc. | ||
For Callavay Unit No. 1 (Union Electric) | For Callavay Unit No. 1 (Union Electric) | ||
And | And | ||
. Wolf Creek (Kansas Cas and Ilectric Co.) | . Wolf Creek (Kansas Cas and Ilectric Co.) | ||
uI f.L' SW4LrT cwtv A"a C bJatf""Dw . | uI f.L' SW4LrT cwtv A"a C bJatf""Dw . | ||
4NC E ~E CE se | 4NC E ~E CE se | ||
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Bechtel Power Corper Caithersburg, Ma DUPLICATE DOCUMENT July 24.198 Entire document previously entered into system under: | Bechtel Power Corper Caithersburg, Ma DUPLICATE DOCUMENT July 24.198 Entire document previously entered into system under: | ||
ANO M\%d19 b | ANO M\%d19 b No. of pages: 1 | ||
No. of pages: 1 | |||
. . . . . . . - . . - . . . . . - _ . _ . . _ _ ,}} | . . . . . . . - . . - . . . . . - _ . _ . . _ _ ,}} |
Revision as of 11:31, 31 January 2020
ML19339A606 | |
Person / Time | |
---|---|
Site: | Midland |
Issue date: | 10/31/1980 |
From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
References | |
10CFR-050.55E, 10CFR-50.55E, 9784, MCAR-42, NUDOCS 8011040405 | |
Download: ML19339A606 (12) | |
Text
\
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%ce President, stsJland i+vject Generea Of..cos: 1945 West Parnall Road, Jackson, Mechegan 49201 e (517) 788-0640 October 31, 1980 Mr J G Keppler, Regional Director Office of Inspection & Enforcemer.t US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEA'4 PLANT UNITS 1 AND 2, DOCKET NOS 50-329, 50-330 SWAY STRUT RCD ENDS DEFICIEICY FILE: 0.h.9.h2 UFI: 73*10*01, 152h0(E) SERIAL: 978h This letter confirms the 50.55(e) item cencerning Sway strut Rod Ends Deficiencies reported by telephcne call to R Sutphin, USNRC Region III, Glen Ellyn, IL, on September 2h,1980. .
The attachments to this letter describe the conditions and actions taken concerning this item.
Another report, either interim or final, vill be sent on or before December 19, 1980.
&h , wf-WRB/lr Attachments: 1) Management Corrective Action Report (MCAR-1), Report :Io h2, dated September 24, 1980
- 2) MCAR h2, Interim Report 1, Loose Hanger Standard Parts Bushings, dated October 21,19S0 CC: Director of Office of Inspectica & Enforcement Att Mr Victor Stello, USI;RC (15)
Director, Office of Management Sol 1 s
Information & ProCra . Control, US:!RC (1)
R Cook, USNRC Resident Inspector j Midland Nuclear Plant (1) '
801104o @ 5 . s
1]
2 Serial 978h CC: CBechhoefer, MLB Panel GALinenber;;er, ASLS Panel FPCowan, ASL3 Panel AS&L Appeal Panel.
MMCherry, Esq MSinclair CRStephens, US!!RC
'4DPaton, Esq, USNEC FJKelly,'Esq, Attorney _ General SHFreenan, Esq, Asst Attorney General GTTaylor, Esq, Asst Attorney General.
'4FJ4arshall GJMerritt, Esq, TNK&J Great Lakes QA-Managers 0
9 0
e 39
I
.8 MANAGEMENT CORRECTIVE ACTION MPORT Attach ent 1 ;l phfl{1D
~~ L/ MCAR 1 b 7 UfM "'"
.'*..- REPORT NO.
- 1 O
September 24, 19pjj JOB NO. O NO. DATE 1
- DESCRIPTION finefu fing referencesh Standard parts (sway struts, unubbers, and shock suppit'nors) purchased from III Grinnell, NPS Industries, Pac'ific Scientific Industries, and Corner /r Luca '
have been found to contain partially or totally disengaged self-aligning rod end bushings.
Ref.: Bechtel NCR's 3108, 3109, 3110, 3130, 3131. (This attribute is not a specific inspection point). Project Engineering has concluded that this condition, if not corrected, could cause the piping and/or piping welds to become overstressed. '
' RECOMMENDED ACTION (Optional) .
- 1. Project Engineering provide criteria for determining acceptability of rod end bushin'g installation in purchased components. .
- 2. Project Engineering incorporate (1) above into appropriate specification so that all pipe supports will be checked. If practical, provice " standard repair" instructions to cover rework of unit. (Consider the different suppli9rs).
- 3. Quality Control take appropriate action to ensure pipe supports are inspected to the re-quirements as specified in (2) above.
- 4. Project Engineering evaluate for reportability under Part 21 of 10CFR.
REFERRED TO y ENGINEERING s CONSTRUCTION OA MANAGEMENT .O OeROCuReMeNT .i ssueo av MD >15 bcd 9 - **
P cate W R.D fr ject t *-oAOEngin)er-i c c s u 9 "2.( - CO / 0 11 REPORTABLE DEFICIENCY 8 l
NOTIFIE LIE JT W3 ahu ed G M / 2 u*~
cate O No i l Eves _
rt tt.tanagerf
--)W/ t, ate 111 CAUSE CORRECTIVE .a.CT;0N TAKEN
- D g m A 3'T~
V
% e Jlu n a AUTHORIZED BY oste ttsa m :tes ttv. cs w.,..,,, FORMAL REPORT TO CLIENT Pgr. et q uiro P t y. Frecer..cng Pgr. (If section II Applies) Date Fee),et *a..ger.
- c. ......s , ,.....,
$,#i 3,/"
f,N Fes).f '".I t /Fre!. Carit.V4r. .
CORRECTIVE ACTION IMPLEMENTED f eej.Pe ecse e est rge.
O.t . t cr e. . .rse , t e g,,, ,, ,, g g g,p,,,, ,,, ,,
frStieretrat Sep t t er (6 33:7 q,, 3,g es>. : rris.r b.tary rir. VERIFIED BY cs so. r' 8 "'
euni .n..,,,,,..u,.,.,,.....,..,,,,,,.,,,,,oo,.... Project GA Engineer Dat iM f4 C
Attachr.ent 2 Serial 976h Bechtel Associates Professional Corporation 0i4358
SUBJECT:
MCAR 42 (issued 9/24/80)
Loose Hanger Standard Parts Bushings INTERIM REPORT 1 DATE: 10/21/80 PROJECT: Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Introduction Description of Deficiency Sway struts, snubbers, and shock suppressors purchased from ITT Crin-nell, NPS Industries, Pacific Scientific Industries, and Corner & Lada, Inc have been identified in Nonconformance Reports (NCRs) 3108, 3109, and 3110 dated September 8,1980, and 3130 and 3131 dated September 23, 1980, to have loose or totally disengaged rod end bushings.
Potential Safety Implication A potential safety problem would exist if the cap assembly became par-tially or totally disengaged from the bushing causing a binding or gap between the bushing and the intersurface of the cla=p or rear bracket.
Existence of this gap or binding during a seismic event could result in overstressing of piping and/or piping welds due to movement of the piping system. This overstressed condition could result in a signif-icant safe".y hazard due to possible failure of the pressure boundary because of unanalyzed forces and movements.
Investigation Loose bushings were identified on pipe support sway struts supplied by Corner & Lada, Inc to Union Electric Calloway Unit 1 and Kansas Cas and Electric Wolf Creek Generating Station. The deficiencies in the sway struts for Wolf Creek Generating Station were reported to Nuclear Regu-latory Commission (NRC) Inspection and Enforcement (I&E) Region IV in accordance with 10 CFR 50.55(e). Subsequently, these deficiencies were reported by Bechtel to NRC I6" Region I in accordance with 10 CFR 21 (see attached report dated July 24, 1980).
Based on this information, engineering requested an investigation be performed at Midland plant Units 1 and 2. Deficiencies in sway struts ;
manufactured by ITT Crinnell, Pacific Scientific Industries, and NPS l Industries, as well as those manufactured by Corner & Lada, Inc w e identified in the above NCRs.
Co rrective Action The following actions vill be initiated.
1
I Bechtel Associates Professional Corporation l MCAR 42 q.4353 Interim Report 1 October 21, 1980 Page 2
- 1. Identify and locate all sway struts furnished to the Midland plant by Corner & Lada, Inc, ITT Crinnell, Pacific Scientific, and NPS.
- 2. Inspect all bushings to determine if they are loose or improperly installed.
- 3. Obtain the manufacturer's recommended procedures for resolving di 41ciencies without precluding warranty, and repair or re Mace the b..hings.
- 4. Review jobsite receipt inspection procedures on all sway struts furnished to the Midland jobsite for possible modification.
Reportability Based on the potential safety concerns and numerous , vendors involved, this ites is considered reportable. This deficiency was reported by telephone on August 24, 1980, to Mr. R. Sutphin, Office cf Inspection and Enforcement, Region III, U.S. Nuclear Regulatory Commission, by Consumers Power Co=pany as a reportable deficiency for Midland Units 1 '
and 2 in accordance with 10 CFR 50.55(e).
Based on identification of similar deficiencies at the Palisades plant, this deficiency was reported, both verbally and by letter, by Bechtel on October 8, 1980, in accordance with 10 CFR 21.
This completes Action Item 4 of the subject MCAR.
Forecast Data for Investigation and Corrective Action The next interim report is scheduled for December 5,1980.
Submitted by: ,e 'm2 l'
Approved by: .\ < d b(2.D 5 4
s ll pe
' Concurrence by: u h
/
./
J h 1 10CTR50.55(e) REPORT o=
Di4122 Loose 3dshings In Pipe Supperc :.vay Struts s Supplied By Corner & 1.ada Co., Inc.
For Callavay Unit No. 1 (Union Electric)
And
. Wolf Creek (Kansas Cas and Ilectric Co.)
uI f.L' SW4LrT cwtv A"a C bJatf""Dw .
4NC E ~E CE se
- 0 8*8'h
~ ICE .e
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Bechtel Power Corper Caithersburg, Ma DUPLICATE DOCUMENT July 24.198 Entire document previously entered into system under:
ANO M\%d19 b No. of pages: 1
. . . . . . . - . . - . . . . . - _ . _ . . _ _ ,