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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20078N9451983-10-27027 October 1983 Responses to 831011 Interrogatories.Questions 1-5 Will Be Answered at Later Date.Certificate of Svc Encl.Related Correspondence ML20078M1581983-10-20020 October 1983 Objections to 831011 Interrogatories & Document Production Requests.Certificate of Svc Encl ML20078K3221983-10-13013 October 1983 Errata to Instructions for Interrogatories & Requests for Production Filed on 831011.Related Correspondence ML20080R1771983-10-11011 October 1983 Request for Production of Documents.Certificate of Svc Encl ML20080R1591983-10-11011 October 1983 Interrogatories Re Ofc of Investigations Rept.Certificate of Svc Encl ML20080R4041983-10-11011 October 1983 Request for Production of Documents.Certificate of Svc Encl ML20078J3491983-10-11011 October 1983 Interrogatories Directed to Util.Certificate of Svc Encl ML20073R7191983-04-28028 April 1983 Renewed Amended Objections to Interrogatories Directed to Util on Zack Issues & Renewed Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20073P9991983-04-22022 April 1983 Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20073B7051983-04-0808 April 1983 Second Set of Interrogatories.Certificate of Svc Encl ML20073B8011983-04-0808 April 1983 Third Set of Interrogatories.Certificate of Svc Encl ML20072T4811983-04-0707 April 1983 Request for Production of Documents,Per ASLB 830406 Order. Certificate of Svc Encl ML20064C7481982-12-29029 December 1982 Responses to 821126 Discovery on Stamiris Cost/Benefit Contention.Certificate of Svc Encl ML20067C5061982-12-0202 December 1982 Interrogatories Re Nonfuel Operation & Maint Cost Considerations.Related Correspondence ML20067A8601982-11-26026 November 1982 Interrogatories & Request for Production of Documents on Stamiris Cost/Benefit Contention,Per ASLB 821029 Memorandum & Order.Related Correspondence ML20067A8551982-11-26026 November 1982 Interrogatories & Request for Production of Documents on Stamiris Cost/Benefit Contention,Per ASLB 821029 Memorandum & Order.Related Correspondence ML20063N7561982-10-0606 October 1982 Response to Request for Production of Documents ML20065C0981982-09-22022 September 1982 Interrogatories on Contentions 6,8 & 16.Related Correspondence ML20065C1331982-09-20020 September 1982 Interrogatories on Zack Issues Re Sinclair Contentions 6,8 & 16.Certificate of Svc Encl.Related Correspondence ML20065C1401982-09-20020 September 1982 Response to 820830 Second Set of Interrogatories.Related Correspondence ML20065C1081982-09-20020 September 1982 Response to 820830 Interrogatories.Certificate of Svc Encl. Related Correspondence ML20071M5451982-09-18018 September 1982 Response to 820830 Interrogatories & Document Requests. Related Correspondence ML20071M5561982-09-18018 September 1982 Response to 820831 Interrogatories.Related Correspondence ML20071M8641982-09-17017 September 1982 Objections to 820913 Second Set of Interrogatories Based on New Info.Interrogatories Do Not Pertain to Any Admitted Contention & Are Untimely.Certificate of Svc Encl ML20063N1941982-09-14014 September 1982 Response to Requests for Admission of Truth of Relevant Matters of Fact.Related Correspondence ML20069D5531982-09-13013 September 1982 Responses to 820814 Discovery Questions Based on New Contentions Accepted by ASLB Order.Certificate of Svc Encl ML20027B2621982-09-13013 September 1982 Discovery Based on New Info in Fes.Related Correspondence ML20027B2531982-09-13013 September 1982 Second Set of Interrogatories Based on New Info.Related Correspondence ML20063J3611982-08-30030 August 1982 First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20063J3521982-08-30030 August 1982 Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20063M2781982-08-30030 August 1982 Interrogatories & Document Requests Re Contentions on Cost/Benefit,Qa,Effects of Dewatering & Independent Design Audit.Related Correspondence ML20063J3381982-08-30030 August 1982 Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20063J2431982-08-30030 August 1982 Second Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20065H7161982-08-30030 August 1982 Request for Admission of Truth of Relevant Matters of Fact Re Contention 5.Certificate of Svc Encl ML20063J7441982-08-25025 August 1982 Discovery Questions on New Contentions Accepted by ASLB 820814 Order.Related Correspondence ML20063N1961982-08-14014 August 1982 Objections to Certain B Stamiris 820830 Interrogatories & Document Requests.Certificate of Svc Encl.Related Correspondence ML20058E5741982-07-28028 July 1982 Partial Responses to 820618 Interrogatories.Certificate of Svc Encl ML20063G6781982-07-28028 July 1982 Reply to First Set of Interrogatories.Certificate of Svc Encl ML20054L5221982-07-0202 July 1982 Response to CPC First Interrogatories.Related Correspondence ML20054H5841982-06-18018 June 1982 Discovery Questions Pursuant to ASLB 790226 Special Prehearing Conference Order.Proof of Svc Encl.Related Correspondence ML20054G4661982-06-16016 June 1982 First Set of Interrogatories.Certificate of Svc Encl ML20054G4531982-06-16016 June 1982 First Set of Interrogatories.Certificate of Svc Encl ML20078K1951982-05-12012 May 1982 Response to Interrogatory IV Re Contention 8 on Independent Design Audit ML20005C1751981-11-11011 November 1981 Request for Admission of Genuineness & Authenticity of Encl Audit Repts.Related Correspondence ML20009B6331981-07-10010 July 1981 Correction to Interrogatory Response to B Stamiris 810114 Discovery Request 9.Certificate of Svc Encl.Related Correspondence ML20005B4121981-06-30030 June 1981 Reply to B Stamiris Answers to Util Interrogatories Re Contention 2 on Soil Settlement Issues.Certificate of Svc & Affidavit Encl ML19350E2701981-06-10010 June 1981 Supplemental Responses to NRC 801126 Interrogatories Re Extent of Design Safety Margins,Wall Footing Design, Structural Analyses & Diesel Generator Bldg Analysis. Affidavit & Certificate of Svc Encl.Related Correspondence ML20004E5081981-06-0303 June 1981 Request for RO Documents Directed to Applicant ML19346A2271981-05-27027 May 1981 Responses to B Stamiris Discovery Requests Re Bldg Const,Per ASLB 810508 Order.Affidavits & Certificate of Svc Encl. Related Correspondence ML19347D8851981-03-30030 March 1981 Response to Intervenor B Stamiris 810114 Interrogatories. Provides Info Re IE Insp Repts 50-329/78-12 & 50-330/78-12, Audits Re Soil Settlement & Administration Bldg.A Boos & N Swanberg Affidavits Encl.Related Correspondence 1983-04-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20070E4671991-02-26026 February 1991 Comment Opposing Petition for Rulemaking PRM-73-9 Re Upgrading Design Basis Threat for Radiological Sabotage of Nuclear Reactors.Recommends That NRC Deny Petition to Increase Design Basis Threat for Security ML20207C1331986-12-18018 December 1986 Order Terminating CPPR-81 & CPPR-82,per Util 860711 Motion to Withdraw Applications for OLs ML20215E7301986-12-17017 December 1986 Memorandum & Order Authorizing Withdrawal of OL Application & Dismissing OL Proceeding,Per Applicant 860711 Motion. Served on 861218 ML20211L6181986-12-11011 December 1986 Response to Board 861203 Questions Re Util Request to Terminate OL Proceeding ML20211L6391986-12-11011 December 1986 Affidavit of Gb Staley Re Preparation of Answers to Board 861203 Questions on Termination of OL Proceeding. Certificate of Svc Encl ML20215B2071986-12-11011 December 1986 Responds to Questions Posed in ASLBP 861203 Memorandum & Order Re Conversion to gas-fired Facility.Imposition of Conditions on Withdrawal of OL Application Unnecessary. Certificate of Svc & Svc List Encl ML20214Q4431986-12-0303 December 1986 Memorandum & Order Granting Motion to Expedite Completion of Withdrawal Proceedings & Posing Questions to Parties.Served on 861204 ML20214G7941986-11-24024 November 1986 Motion to Expedite Completion of Withdrawal of Licensee OL Application & Terminate Pending OL & CP Mod Proceedings. Certificate of Svc Encl ML20214T7361986-09-26026 September 1986 Memorandum & Order Dismissing OM Proceeding as Moot & Deferring Action on Applicant Motion for Authorization to Withdraw OL Application Pending NRC Preparation of Environ Assessment.Served on 860929 ML20212M7661986-08-25025 August 1986 Response to Util 860711 Motion for Authorization to Withdraw OL Application & for Dismissal of OL & Order of Mod Proceedings.Board Should Hold Motion in Abeyance Pending NRC Review of Stabilization Plan.Certificate of Svc Encl ML20206M8171986-08-15015 August 1986 Response to ASLB 860716 Order Requesting Responses Re Termination of OM Proceeding.Termination of OL Proceeding & Withdrawal of OL Application Requested.Om Proceeding Should Be Considered Moot.Certificate of Svc Encl ML20212B0311986-08-0101 August 1986 Memorandum & Order Withdrawing Retention of Jurisdiction Over Radon Issue Presented in Facility CP Proceeding & Vacating ASLB Partial Initial Decision on Remedial Soils in Consolidated CP Mod & OL Proceeding.Served on 860801 ML20212B0521986-07-31031 July 1986 Order Extending Time Until 860815 for Util & Other Parties to Respond to Questions Posed by 860716 ASLB Order.Time Extended Until 860825 for NRC Response to ASLB Questions & Util Motion.Served on 860801 ML20203F8791986-07-28028 July 1986 Response Supporting Util 860711 Motion for Termination of Appeal Board Jurisdiction Over Proceeding.Certificate of Svc Encl ML20207H6871986-07-22022 July 1986 Motion for Extension Until 860815 to File Responses to Four Questions Re Util Motion to Dismiss OL & OM Proceedings. Certificate of Svc Encl ML20207E2851986-07-16016 July 1986 Order Presenting Questions in Response to Util 860711 Motion to Dismiss OL Proceeding & to Terminate Order of Mod Proceeding.Served on 860717 ML20202G1621986-07-11011 July 1986 Notice of Change of Address for Washington Ofc of Isham, Lincoln & Beale,Attys for Util.Certificate of Svc Encl ML20202G1201986-07-11011 July 1986 Motion for Termination of Aslab Jurisdiction to Facilitate Termination of Cps,Withdrawal of OL Application & Dismissal of Consolidated OM-OL Proceeding ML20202G0121986-07-11011 July 1986 Motion for Authorization to Withdraw OL Application & Dismissal of OL & Order of Mod Proceedings ML20202G0491986-07-10010 July 1986 Affidavit of JW Cook Re Conversion of Plant Into combined- cycle,gas-fired Power Plant.Plant Never Operable as Nuclear facility.Nuclear-related Equipment Will Be Sold ML20202G0281986-07-0808 July 1986 Affidavit of Ta Mcnish Re True & Correct Extracts of 860408 & 0618 Minutes of Meetings.Resolutions Recited Therein in Full Force & Effect ML20198J4651986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechhoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20198J3861986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20137E0041985-11-21021 November 1985 Notice of Appearance in Proceeding ML20137D9651985-11-21021 November 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133F6421985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N3771985-08-30030 August 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl DD-84-17, Order Affirming 840724 Director'S Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 8506241985-06-24024 June 1985 Order Affirming 840724 Director'S Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 850624 ML20127N7591985-06-20020 June 1985 Transcript of Commission 850620 Affirmation/Discussion & Vote in Washington,Dc Concerning Denial of 2.206 Petition for Midland plant,SECY-85-60 Concerning Pressurized Thermal Shock Rule & Shoreham Order.Pp 1-4 ML20133D9481985-05-13013 May 1985 Response to Aslab 850423 Order.Aslab Should Cancel OL Application & CPs Because Compliance W/Nrc Basic Requirements Not Met ML20116G5181985-04-29029 April 1985 Response to Memorandum of City & County of Midland,Mi Re ASLB 850405 & 0313 Orders on CP Mod Proceedings.Bechtel Should Not Be Granted Admission to Proceedings ML20115J4351985-04-19019 April 1985 Motion for Leave to Participate as Amicus Curiae,Per Aslab 850313 & 0405 Memoranda & Orders Requesting Response to Questions Re Proceeding ML20115J4751985-04-19019 April 1985 Memorandum in Response to Aslab 850405 Order Re Dismissal of OL Application.Application Neither Abandoned Nor Delayed in Dilutory Manner.Certificate of Svc Encl ML20115J5421985-04-19019 April 1985 City & County of Midland,State of Mi Motion for Leave to Participate as Amicus Curiae in Aslab Request for Responses to Questions Presented in 850313 & 0405 Memoranda Orders. Proof of Svc Encl ML20115J5461985-04-19019 April 1985 Motion to Participate Amici Curiae in Resolution of Issue of Involuntary Dismissal of License Application as Identified in Aslab 850405 Memorandum & Order ML20116G5321985-04-19019 April 1985 Motion to Participate as Amicus Curiae in Resolution of Issue to Involuntary Dismissal of License Application,Per Aslab 850405 Memorandum & Order.Granted for Aslab on 850422. Served on 850429 ML20115J5551985-04-19019 April 1985 City & County of Midland,State of Mi Response to Aslab 850313 Order to File Memoranda Re Whether Aslab Should Vacate ASLB Decision Re Certain Mods to CP Due to Mootness. Proof of Svc Encl ML20115J5501985-04-19019 April 1985 Response Opposing Aslab 850405 Memorandum & Order Re Dismissal of OL Applications.Urges Board to Permit OL Applications to Continue in Suspension Until Applicant Affirmatively Resolves Disposition ML20112J5281985-04-0101 April 1985 Memorandum in Response to Aslab 850313 Order LBP-85-2. Decision Should Not Be Vacated.Ol Should Be Dismissed.Based on Listed Changes,New OL Review Required ML20112J6301985-04-0101 April 1985 Memorandum Requesting Aslab Not Take Any Action to Vacate LBP-85-2 or Dismiss OL Applications,Per 850313 Order,Based on Current Intent to Hold CPs & Attempt to Sell Plant. Certificate of Svc Encl ML20112H0981985-03-27027 March 1985 Response to Aslab 840313 Order Re Whether ASLB Decision to Review Issues in Soils Hearing Appropriate Use of Public Resources.Concurs W/Decision to Remand OL W/Instructions to Dismiss OL Application for Failure to Pursue Soils Issue ML20106F6531985-02-0808 February 1985 Response Opposing Intervenor B Stamiris 841224 Motion for Evidentiary Hearings Re Litigation Between Applicant & Dow Chemical Co.Supporting Documentation & Certificate of Svc Encl ML20106D6631985-02-0808 February 1985 Response Opposing B Stamiris 841224 Pleading Requesting Evidentiary Hearing on Matter Raised in applicant-Dow Chemical Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20101S9421985-02-0101 February 1985 Motion for Extension Until 850306 to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Granted by Aslab on 850201 ML20101S9111985-02-0101 February 1985 Motion for Extension of Time within Which to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Certificate of Svc Encl ML20101F3191984-12-24024 December 1984 Request for Evidentiary Hearings on Matter Raised in CPC-Dow Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20107K8011984-11-0101 November 1984 Affidavit of Jd Selby Re Plans Concerning Facilities.Const Will Be Resumed Only If Proposed by Appropriate Governmental Agencies & Officials & If Funds from Some Other Source Become Available.Related Correspondence ML20106F5241984-10-24024 October 1984 Motion to Request ASLB to Cancel Const License & Application for OL ML20092J0361984-06-22022 June 1984 Reply to NRC Further Supplemental Findings of Fact & Conclusions of Law Re QA ML20092J0241984-06-22022 June 1984 Reply to B Stamiris Second Supplemental Proposed Findings of Fact & Conclusions of Law on QA & Mgt Attitude Issues. Certificate of Svc Encl 1991-02-26
[Table view] |
Text
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p BEFOP.E THE ATOMIC SAFETY AND LICENSING FOAR"
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,g \' ' ) 4 \ Docket Nos. 50-329-0M PL*ER COMPANT ) 50-330-OL
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f ?s" APR0 AMENDED AND ADDITIONiL RT.SPONSES TO h u.s, % 8 0 I b bII CERTAIN NRC STAFF INTERROCATORIES DATED 11/26/80 9( codd@% N Interrogatorv 4 k
d' y /
In the respouse to Question 15 of the NRC request, regarding plant fill, it is stated that, " differential settlement primarily induces additional strain, which p is a self-limiting effect and does not affect the ultimate strength of the structural m__.bers." Additional clarification of this statement is needed.
4(a) 'n'hy do you classify the resulting strains as self-li=1 ting in nature?
l l
Resnons e The term "self-limiting" is a shorthand expression for the behavior of a structure under strain-induced loads such as settlement in the absence of a bearing capacity failura.
Based on the charai:teristics of supporting soils and the imposed load from a l
structure, the predicted settlement of the scheture can be calculated over its its lifetime. To evaluate the effect of settlement on the structure, the settlement can be divided into the following:
(1) Uniform settlement (rigid body translationi m
(2) Dif ferential settlement (a) Tilting (rigid body rotation)
~
(b) Curvature 9 Sof 6'I
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l Rigid body notion of the structure, both translation and rotation, does act cause any strain in the structure. Therefore, it is of no concern in the evaluation of structural adequacy.
i In contrast, curvature in the structure due to settlement vill cause additional strain in the structure.
Therefore, the effects of curvature induced due to settlenent need to be
- investigated.
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Curvature and Stress -
When a structural element is subjected to curvature (6), tensile strain is induced in the convex side and cc=pressive strain in the concave side of the element (Figure 1) . For a concrete structural element, the
~
theoretical relationship between curvature and =cment can be established based on the stress-strain relationship of concrete and reinforcing steel.
An idealired moment-curvature plot of an under-reinforced concrete section similar to those used in the Midland Diesel Generator Building is shcun l in Figure 2. As can be seen frem Figure 2, the curvature increases linearly as the moment is increased, up to the moment My, corresponding to the poinc ,
j of yielding for' thedensile steell ~ Beyond that point, any increase in t
l curvature would not increase the moment in the structural element. The
\
mari== curvature that can be induced in the element' is Ou, corresponding to an ultimate concrete strain of.003.
Behavior of Structures sue $ected to Loads l
The loads applied on a structure can be divided into two categories:
(1) Externally applied forces i '
(2)' Externally applied strains l
l
L l
When structures are subjected to externally applied forces, internal forces and sc=ents =ust be induced in the structure to re.:. core static equilibrium between external and internal forces. An increase in curvature beyond 9y* is not useful in resisting such external forces, I
as no additional internal moment is mobilized due to the additional curvature.
When an externally applied strain due to settlement is applied to a l
l structure, the structure must be capable of accommodating additional l
strain imposed on it without failure. Since no net external forces are applied by that process, the induc,ed strain need not cause internal forces in the I
structure.
Therefore, even if a structure has already reached 6 7due to an externally applied force, the structure can still resist externally I More-l applied strain so long as the resultant curvature is less than 9u.
l l
over, the behavior of the structure vould be the same regardless of which influence- the settlement strain or the external force -is applied first.
' For example, let "Mg" be the moment induced in the structure due to ,
- external forces and A9 be the additional curvature induced due to settlement. In the elastic range, let AM be the increase in moment due to 6 8. If-(M 4 + 0M) is less than My, the additional curvature due to curvature settlement will cause the additional moment corresponding to t (A6). (risure 3)
On the other hand if (M
+ A X) is greater than My as in (Figure 4), the i
structure will see a moment equal to My with an increase in curvature equal ;
I to 0 9. The increase in moment due to curvature in this instance (i.e.
1 1
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Figure 4) is less than it would be were the yield =cuent high
,enough such that M +A M < My. If M = My, there is no increase in menent. Since A M is not required to restore static balance, the structure vill be stable even iffM = 0, as long as the additional curvature A0 does not result in a curvature of the structure greater than Ou.
Conclusion The stress induced in a structure due to settlenent can vary from raro to a maximum of a proportionality constant
- multiplied by the induced curvature. The actual stress is assigned by the structure itself depe:x!1ng on its capacity to resist stress af ter allowing for any stress
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requirements due to external forces.
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5-4(b) How do you reconcile your statenent quoted above with your statement concerning the Service Water Pump Structure in the . Management Corrective Action Report No. 24, Interim Report 6, issued September 7, 1978 that the total design loads cannot be supported'by the =ain structure.
Response
For purposes of the underpinning design of the foundations of the service water pump structure, no credit was taken for any bearing capacity in the fill material. Under these circumstances the self-limiting analysis described in the Response to Interrogatory 4(a) does not apply, since the mechadism for producing possible strains in the structure is not limited to settlement.
3 I
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Interrogator r 1(e) and 1(f) (Amended Resoonses) 1(e) Have you factored into any re-analysis infor=atic n cer.tained in, or resulting from, a letter frem Robert Tedesco to Vice President J. Cook dated October 14, 1980, concerning seismological input data acceptable to the Staff?- ,
Response
Applicant objects on the ground that this questien goes beycud the limited jurisdiction conferred by the December 6,1979 Order, that the seismic re-analysis requested by Mr. Tedesco in the October 14, 1980 letter should be reserved for the operating license hearing, and, hence, that it is irrevelant to these proceedings. Subject to that-objection, Applicant answers as follows: The pending seismic re-analy-sis requested in the October 14, 1980 Tedesco letter has been considered in arriving at the folleving approach towards designing and analyting the remedial fixes for the auxiliary building electrical penetration area, the service water pump structure, and the berated water storage tank ring foundation: Seismic forces obtained by application of FSAR input criteria (i.e. modified Housner spectra and maximum acceleration "
, anchored at .12 g) vill be increased by a reasonable margin. Forces
, thus determined will be combined with other loads in accordance with-applicable lead combinations in arriving at design parameters for the remedial measures. In addition, with respect to the Diesel Generator Building, Bechtel is attempting to evaluate the total margin which actually exists in excess of FSAR seismic design criteria.
When discussions with the NRC Staff respecting possible redefinition of seismic criteria applicable to the entire Midland site are completed, Applicant vill evaluate the necessity for seismic re-analyses of any or all Category I Structures, including those founded partly or entirely on plant fill.
. .~ .,
1(f) If the answer (e) is yes, please provide copies of all docu=ents relating to that re-analysis.
~
Response -
The decu=ents pertaining to the design analyses of the renedial fixes for the service water pu=p structure, the auxiliary building and the borated water storage tank ring foundatica (using the apprcach spelled out in the respense to 1(e)) vill be provided, as stated in the respense to questien (b). Applicant objects to providing documents relating to the analysis of total =argin in excess of FSAR seis=ic design criteria fer the Diesel Generater 3u11 ding, for the reasons ' stated in 'the first sentence of Applicant's respcase to questics 1(e). For the sane reason, Applicant objects to providing in this proceeding future seismic re-analyses of
. . Midland structures as requested by the October 1!.. 1980 Tedesco letter.
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(
- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g
. BEFORE THE ATOMIC SAFETY AND LICENSING 30ARD j
. ~- f' In the Matter of )
CONSUMERS POWER COMPANY ) . Docket Nos. 50-329-0M
) 50-330-0M j 50-329-OL ;
(Midland, Units 1 and 2) )
50-329-OL ;
)
COUNTY OF WASHTENAW)
)ss STATE OF MICHICAN )
AFFIDAVIT OF BIMAL LEAR :
1 Bimal Dhar, being duly sworn, deposes and says that he is e= ployed by Bechtel Associates Professional Corporation,'as an Engineering Supervisor; that he is responsible for providing an answer to Censumers Power Company's Answer to E C Staff Inter ogatery No. 4 dated 11/2e/e0, and that to the ,
best of his knowledge and belief the above infornation and the answer to l
the above Interrogatory is true and correct.
pimalDhar Subscribed and sworn to before me this / .3 day of March, 1981.
et J. ' 6 /L.w Notary Public Washtenaw County, Michigan My Co= mission Expires: N.A I+vU_ 4/[(
12rJ.!T 1. 200t3 30 0AM ?~IL*C , '41.e.. .di to . , :!03
- XI Ctr.' CSS *03 II2*- i 50V.30s 1562
UNITED STATES OF AMERICA NUCLEAR REGtH ATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) DOCFIT NOS. 50-329-0M CONSUMERS POWER COMPANY ) 50-330-0M
) 50-329-OL (Midland, Units 1 and 2) ) 50-329-OL
)
)
COUNTT OF WASHTENAW)
)ss STATE OF MICHIGAN )
AFFIDAVIT OF NEAL SWANBERG Neal Swanberg, being duly sworn, deposes and says that he is enployed by Bechtel Associates Professional Corporation, as an Assistant Project Engineer; that he is responsible for providing amended responses to NRC Staff Interrogatories to Consumers Power Company Numbers 1(e) and (f) and that to the best of his knowledge and belief the above infor-mation and the answers to the above interrogatories are true and correct. ,
l i
l = /
l Neal Swanberg' /
l Subscribed and sworn to before me this / day of M _ri I , 1981.
._, . h.. LA u Notary Public, Washtenaw County, Michigan My Commission Expires: %%e, _ it.f.2/ / ///4 2I 2-~.? A. 5 00~ i
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MI COPE.25;;;; 7S ~-' 0'.~.30,1352 1
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UNITED STATES OF AMERICA
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- .7 ny . g 4 j g g j p ,1-NUCLEAR REGULATORY COMMISSION Ci".ca of tM Set ets' 0;;... 9; & Seni:t ,
i, % E /
In the Matter of ) % ,
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) Docket Nos. ~
CONSUMERS POWER COMPANY )
3 0 (Midland Plants, Units 1 and 2 2
)
3
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CERTIFICATE OF SERVICE I hereby certify that copies of Amended and Additional Respenses to Certain NRC Staff Interrogatories Dated 11/25/80, with attached affidavits, were served upon the following persons by depositing copies thereof in the United States Mail, first class postage on this 20th day of March, 1981.
Frank J. Kelley, Esq. Michael Miller, Esq.
Attorney General of the Isham, Lincoln & Beale State of Michigan One First National Plaza Stewart H. Freeman, Esq. Suite 4200 Assistant Attorney General Chicago, Illinois 60603 ,
l Gregory T. Taylor, Esq.
Assistant Attorney General Mr. Steve Gadler 720 Law Building 2120 Carter Avenue Lansing, Michigan 48913 St. Paul, Minnesota 55108 Myron M. Cherry, Esq. D. F. Judd, Sr. Proj ect Manager One IBM Plaza Babcock & Wilcox Suite 4501 P. O. Box 1260 Chicago, Illinois 60611 Lynchburg, Virginia 24505 Mr. Wendell H. Marshall Atomic Safety & Licensing Appeal Board RFD 10 U. S. Nuclear Regulatory Comission i
Midland, Michigan 48640 Washington, D. C. 20555 i
Charles Bechhoefer, Esq. Mr. C. R. Stephens, Chief Atomic Safety & Licensing Board Panel Docketing & Service Section l U.S. Nuclear Regulatory Comm. Office of the Secretary i
U. S. Nuclear Regulatory Commission Dr. Frederick P. Cowan Washington, D. C. 20555 6152 NJ Verde Trail Apt..B-125 Boca Raton, Florida 33433
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Lester Kornblith, Jr.
Atomic Safety & Licensing Board '
U. S. Nuclear Regulatory Comissica . ,
Washington, D. C. 20555 Ralph S. Decker, Esq.
Route 4 Box 1900 Cambridge, Maryland 21613 Ms. Mary Sinclair 5711 Summerset Street Midland, Michigan 48640 William D. Paton, Esq.
Counsel for the NRC Staff U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Atomic Safety & Licensing Board Panel-U. S. Nuclear Regulatory Comission Washington, D. C. 20555 Barbara Stamiris 5795 North River Road Route 3 Freeland, Michigan 48623 .
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James E. Brunner Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 ,
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