ML19305E570

Comments Re Reopening of Facility,Addressing Licensee 800305 Request for Insp of Safety Matls & Licensee Independent Exam of Concrete.Urges Positive Action Re QC Violations & Improperly Placed Concrete

ML19305E570
Person / Time
Site:	Marble Hill
Issue date:	05/07/1980
From:	Dattilo T DATTILO, T.M., SAVE THE VALLEY - SAVE MARBLE HILL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8005200065
Download: ML19305E570 (5)

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BEFORE THE NUCLEAR REGULATORY COMIIISSIONERS MAY 7iM

• Y Office o':'e Secretary DoclW, 4rvico )

IN RE THE PROPOSED MARBLE HILL ) DOCKET NOS. 50-546, 5 ,

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SERVICE INDIANA, LICENSEE )

SAVE THE VALLEY COMMENTS REGARDING THE CONSIDERATION OF THE REOPENING OF MARBLE HILL Save The Valley, a non-profit Kentucky Corporation with offices in Indiana, represents the interest of the populace from Kentucky and Indiana who live adjacent to the proposed Marble-Hill Nuclear Power Plant. Save The Valley has requested of the Commission Secretary, Mr. Samuel J. Chilk, the rigat to present relevant comments for the purpose of aiding the Commissioners in determining whether or not the existing quality control level of expertise and actions of PSI and its sub-contractors are consistent with the NRC regulations initially; and, secondly, whether or not the URC staff, particularly the Office of Investigation and Enforcement, is simply noting non-conformances and taking no positive action to corI ect the flagrant quality control violations that'have come to their attention for the past approximatel;, .

three ( 3 ) ye ars .

Save The Valley wishes to briefly discuss two (2) substantial issues in this paper, namely:

1. The March 5, 1980 request of Licensee to receipt inspection of safety category materials and components, and,

2. The question of an independent examination of concrete by Save The Valley at the Marble-Hill site.

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ISSUE NO. 1: LICENSEE REQUEST TO RECEIPT INSPECTION OF SAFETY CATEGORY MATERIALS AND COMPONENTS.

On March 25, 1980, at a public meeting in Madison called by the NRC, Save The Valley presented one Marion Hudgins as a witness. Mr.

Hudgins worked as a quality control inspector for Cherne Contractor Corporation, a sub-contractor at Hurble-Hill, from November, 1968 to March 30, 1979.

Mr. Hudgins observed improper storage of safety category material and components, including large motorized safety valve s . Mr. Hudgins noted for a period of more than one (1) month improper controlling of temperature readings in a Marble-Hill warehouse set up specifically to store safety category materials and components. .

At no time during his term of employment was Mr. Hudgins able to note that any of his positive suggestions toward proper storage of safety components and materials were ever acted upon either by Cherne or PSI. And at all times the NRC was available supposedly to attempt to correct the situation.

Mr. Hudgins has received copies of non-conformance reports of NRC I & E inspectors from July 20, 1978, to and through March 29, 1980.1 l

The common thread of evidence throughout all of these reports manifests l simply that the NRC can have no confidence that PSI and/or its sub-contractor agents are capable of receiving safety category materials and components at the Marble-Hill site in the near future.

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It is our firm opinion that it is simply not enough for the NRC I&E to note one non-conformance after another regarding millions of dollars of equipment which may become pure salvage due to improper receipting and storage; the NRC must effectively see that proper storage actions are immediately being done.

ISSUE NO. 2: INDEPENDENT EXAMINATION OF COIICRETE.

On Narch 25, 1980, in the aforementioned publ1c meeting, this writer speaking for Save The Valley requested an independent examinatic-of the concrete at Marble-Hill by a qualified Save The Valley representative. This request received a favorable response from Mr.

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Victor Stello, the head of the NRC Inspection & Enforcement Division.

At the same time this writer requested copies of the evaluation reports of concrete at Marble-Hill by PSI representatives and by the NRC.

This writer did not receive copies of the Sargent & .Lundy report dated November 20, 1979 regarding " Evaluation of In-place Concrete at Marble-Hill" in two (2) volumes and also a copy of the NRC Inspection i Report 80-02 concerning same until May 1st. Possibly the Division of ,

1 I&E did not wish for Save The Valley to have sufficient time to adequately comment regarding these reports prior to the meeting of the Commissioners on this matter.

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Due to a forced speed search of the Sargent & Lundy November 20 report and the NRC Inspection Report 80-02 Save The Valley has several relevant comments that should certainly aid the Commissioners in making their determination on the concrete issue.

1. There seems to be no way on the basis of the Sargent & Lundy November 20, 1979 report and on the basis of the liRC Inspection Report 80-02 to determine whether or not the 60 areas chosen by Sargent &

Lundy were proper areas for a study of the existing concrete placement at Marble-Hill;

2. Therc seems to be no way that a competent engineer can determine on the basis of the above-stated studies alone whether or not the explanations given by Newberg personnel regarding damages' concrete and rebar or other obstructions were accurate; were such Newberg observations verified by the PCA study team? For. example, path analysis, Appendics B, PCA Report, November, 1979, Page 11, Tables B-5-6-7-8-9-10-12-13-14-15-16-17-18-19-21 & 23. These Tables indicate inform Ation obtained from Newberg personnel.

3. There seems to be no way a competent engineer on the basis of the above-cited studies can comment coherently whether or not Sargent

& Lundy has adequately tested the inaccessible areas, namely:

underground areas beneath the concrete and the. stated voids in the auxiliary building, l

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4. Were through transmissions er reflected ultra sonic tests performed in cores so that the readings could be compared with IN-SITU test results to determine if cores were representative It should be specifically noted that at least 40% of the areas checked in the Sargent & Lundy report manifested documentary evidence of improperly placed concrete and 1 trther.that all but 13% of these areas were explained away by comments from Newberg and/or PSI representatives.

Regarding the pulse-echo method, several questions may need to be still explained from the report of Sargent & Lundy. However, insufficient time has been given by I&E for Save The Valley to pl aperly and more specifically comment thereon.

It should be noted that Sargent & Lundy has been paid millions of dollars to be PSI's consultant from the inception of this proposed Marble-Hill project. It should be further noted that some questions may arise as to the closeness of that particular relationship; however; Sargent & Lundy on the whole has a fine reputation throughout the country in these areas.

A request for an independent examination of the existing placed concrete at Marble-Hil and an execution of it by Save The Valley can only serve to enhance the reputation of the NRC Commissioners.  !

RESPECTFULLY SUBMITTED, SAVE THE VALLEY BY: Iskew l THOMAS M. DATTILO, ATTORNEY FOR THOMAS M. DATTILO, ATTORNEY SAVE THE VALLEY 311 EAST MAIN STREET MADISON, INDIANA 47250 PHONE: 812-265-6355 Page-5.

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