ML19323D163
| ML19323D163 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 04/07/1980 |
| From: | Eyed J SASSAFRAS AUDUBON SOCIETY |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19323D130 | List: |
| References | |
| NUDOCS 8005210187 | |
| Download: ML19323D163 (2) | |
Text
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.. .e , . vg The SASSAFRAS AUDUBON SOCIETY h j i#[cQ of 1.AWRENCE . GREENE . MONROE . BROWN -
MORGAN & OWEN COUNTIES ) INDIANA f . g
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g April 7, 1983 .,-
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, J ( h Mr. Victor Stello, Jr.
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D.. rector, Office of Insp-ction and Inforce:ent U.S. Nuclear EcEulatory Coe=ission y Washington, D.C. 20555 Lear Mr. Stello: Sassafras PSI, Audubon April 11, 1980 received notico today of the forthco=ing meeting of the NEC vith for Marble Hil.1. in Bethesda, Ma:jland, on PSI ts P.svised Quality Assurance Progran YouMadieon, at an not listed In* nas a participant in the meeting, but since you c; mired the meeting on this subject, and will be involved in the recoc:enia. tion to tre Cc _ issionero as to whether safety-related constmetion should rect =m at Marble Hill, vc thought it best to addmsa our continuir.g concerns to you. None of the major questions SAS seeks answers to concer.ing Marble Hill (see State ent presented to you at Madison, Indiana on March at Madison. 25, 1980) were ansvend at the meeting With 2ege.nl Question I, "Can Marble Hill be repaired sufficient 1v?", se hope that the NP.C will support an independent asness:nent of the quality of constn::ti. and the degree to which it can be satisfactorily repaired, which has been sought by Save-the-Valley. The question of whether PSI will be required to have N Certification, not just an "interic latter": prior to resu=ption of construction at Marble Hill, was made mo:e confuswg at the coeting on March 25, Madison, Indiana by the co=ments of Mr. S.V. Shields, Vice-President, Elactric Systems, PSI. all recponsibility for Marble EC'? Does PSI still intend to assu::e over-vill not PSI have to be certified? If the ASME Code is law in the State of Indian of the Subcom=ittee Hearings on Constmetion Problets at Me bin Hill:Nutech's assess Rdeer Re rula-ter r Co : .ission 0*.ersitht, November 27 and 28,1979, states that it is extre:ely in-portant that all systems and co=ponents in that plant be built in accordance with the ASME Code and be code stamped in order for PSI to qualify for insurance at Msicle F.ill. This is not the tire to accept another promissory note from PSI. Sassafras Audubon continues to be disturbed by the fact that substantial progress has been =ade in the construction of Marb2c FD' (even tho'.y;h not "ssfety-related") yet PSI does not. have a fully developed and functional Material Management Progrt.n. This seems i cxcusabic a2d a matter of =isplaced prioritics. PSI, when questioned by the NRO at the March 25 meeting as to when PSI personnel would replace MAC personnel, replied that they expected it to take one to three years. As we co=nented on McMh 25th, this is far too indefinite considering thatsefety-related work of stoppage nuclear at pzseent. experience.was brought on atscarcely MAC personnel least insee=a part the by serious ansg;;cesunderstaffir~%as trd xtent plannec. we l s oos29 If
l l 1 PSI's analysis and conclusions regarding their fixed-price centracturt.1 agree-r.cnts did not addztss the substr.ntive problens associated with then in the pr.st , and as such are unacceptable. th assu:e that constructicn schedules and =r.tters ! which cause dehys in schedule vill be part of the April H Agenda on PSI's , Revised Ca/QC Progra=. After the meetinE of PSI with the NRC on April 11th, we would appreciate a reply to our questions of March 25th and of this date, as well as a su==ary of the answers of PSI to the questions asked by the IE in CA Cuectier= Conmine the Merth Hill Docheted CA Prorra=. The intr-ridinc concern of our Society continues to be the reed for Marble Hill? The evidence ir.dicates it is not needed. To igncre this fact dien many aspects of Marbh FW 's conctruction is being questioned cannot be justified. To s sincerely, l e
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s1 . a, . heute 1, Box 375 ' Nashville, InM == 47448 i e e 9 e l l l '
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- l DUPLICATE DOCUMENT
[ , Deborah H. McCarthy g Entire document previously 208 Elm . entered into system under: Eminence, Kentucky ,40019 O0314 CX306 ANo N o. of pages: (h April 2, 1980 Mr. James G. Keppler , Nuclear Regulatory Commission Director, Region 111 611 Ryan Plaza Drive - Suite 1000 Arlington, Texas 76012
Dear Mr. Keppler,
I attended the meeting at Madison on March 25, 1980, regarding the issue of whether or not to lift the stop-work order at Marble Hill; I ask t.iat the following questions and comments be included in the record of that proceeding as allowed by the U.S.C.A.. (Mr. Stello stated there would be a transcript of the meeting, as required, although our local papers reported that the NRC had refused to make such a . record.)
- 1. You (NRC re7 esentatives) statsd that you write the l
regulations (r.gscding qualifications for employment, inspection prot e'~ s, training requirements, etc.) for PSI; l so I ask who, spc ically, among you writes them and what training and qualifications Ispecifically) does that person (s) ; have to do so? , .
- 2. It was noted by Mr. Keppler (I believe) that it has come to your attention that there are inconsistencies in some instances between your procedure manual and PSI's With regard to this problem (which procedure manuals.should be enough by itself to continue the stop-work order),
you merely asked PSI to explain. Did you consider that singular question, and PSI's nonspecific reply, adequate investigation? Why did you not present examples of such inconsistencies and ask them, specifically, to explain the problem and how and when it arose and will be corrected? How can you be at all certain they are following adequate
]t procedures when you know their manual does not conform to your manual? Why whould PSI be allowed to write its own j manuals; we know already that we cannot rely on them to police themselves.
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APR 111980
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, 3. What has PSI done since the issuance of the stop-work order, other than write and rewrite procedures and move all personnel on sight so that the long distance telephone need not be used? Tell me specifically what you heard them say they had done (other than those two things)? ? . I *
'4. Isn't a company who would' enter into constructicn of an ultra hazardous facility (i.e. , nuclear power plant) without having such rules, regulations, procedures, training pro- '
' grams and trained personnel ALREADY VORKED OUT (to the nth degree), isn't such a company PER SE unqualified for a -
license to proceed?, .. .,
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5.. After .all, Mr. Stello, your inference (in talking about . ' r. -
. t r't ' quality ' control of subcontractors). was that the only way to. i .,' ' - .
' i .". ~ t . ..' ~ pro'ceed. if'one found shoddy wor'k, was to be rid of the C , .J Y .."c-- . contractor who p,erformed the' shoddy work. Does this n'ot ;-
' apply many times over to the issue of what should be r./ .
. required of the master mind of this , plant, PSI? . G;'1'- - -- .- '~
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- 6. 'Aren't you' the NRCIgoing'~td r'equire production of some of these contracts so you can verify whether or not.they do, by virtue of,their' terms, include an ' incentive to complete the job as quickly as possible? Or, do you intend to merely accept PSI's self-3erving statements on this issue? e
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7 .~ .. r.~- :.- : w ..?.cWhy did ~you/'repre'se;ntativ,es of the NRC,, ?. allow PSI ; representatives.to drene on and on reading.page after page of printed material (which said little an pay, since two - words out of every r sentance' vere PS1 doubletalk:- " quality . assurance", " inspectors" or' " quality control managers")? You gaveithe distinct imprassion., all.four,o.f you, while the - PSI men were readin'g 'that yev were' bored; you all conversed motioned' to your colleague on the floor, -
.'.' _looke'd
. with each..otherat~at yo6r w c ,,
hes ~ 'ete'. ;'mee' ting? ; so I ask each of you, had you - N'W , read th'e' mate ' J it < . s y..x w. e..e +. . .' rial n. before~ the
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Assuming.for..s..w;..s..
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n.s. ,.~.4.e moment you were all p.w -r o p5'e r l y..~ ii . ' I.?" 'N . . .. . . .why'then did you*not insist that.the time be used to pose ~
"C. '
, .'questioni to the PSI ment Obviously, from the few exchanges between Mr. Stello and Mr. Norris, you were not getting any information that was helpful in making a decision; why if
. .you are a regulatory body, was that allowed?
'9. Weren't you curious as to why there are enough "non-conformances" that PSI is able to detail them and develop trends from them? Anyone who is familiar with statistics knows that it would take many "nonconformances" before any generalizations, or trends could be developed; should you not question why there are so many nonconformances if there is proper quality control assurance?
- 10. PS1 ndaitted that the quality control committee, one of the big changes they made, is basically a means of getting
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information about problems and progress to the various administrative people; it is not and cannot be a watchdog committee since it is composed of PSI people; so how is that a "significant change" that has been made to correct the ' ' problems discovered in June? . .- .
- 11. This rule making process is the.only chance we citizens have to " participate" in the decision' as to whether or' not to allow this company (who has shown bad faith through complete lack of planning and expertise) to proceed with>
building this public nuisance in our community; as Mr.., Wendell Berry stated in his remarks.to you, you do not give the appearance of being in an . adversary. or watchdog' rela ~ ."
. tionship with PSI. .You cannot give me a valid reason as to .-
~.- why I don' t have the riiht . td a' lo' cal . referendum .'on the - .. .
..i r # will' issue of whether supply' energyto'to locate.this produce nuclekr' ultra tazardous materials' plant in . a ..(which
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,pl. ant hundreds of miles away) in my community; but yo'u can tell me ~
why you, by your lack of preparation, ' lack of hard questions to PSI and apologetic ma~nner towards.them, by your failure to require independent collaberation of issues, by your i initially derisive attitude towards the' citizens who came before you and by' your eintimidation'of those citizens, why you have made a charade of this one opportunity we as citi-zens have left to pr.ot,ect.ourselve.s.?
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- 12. What sort o'f' confidence.should we place.in any NRC
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official who sits and tells us we'should " trust him" to protect our interest b'ecause he's the" man who believes proper planning and safety controls means " deciding what to do with the waste and cont'aminated materials (many of which have a half life of tens,o'f thousands of years and. cannot
. conceivably be adequately conta1 ed) when the time comes"?
, . . A . N . . ,9.- ..
Do y'uo 1ntend to allow"c'onstruction'to proceed w'ithout
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13. requiring any independent d'~cumentation of changes;which are'.
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,' in force at this date?.~. .and~ if you ah> intend to . require .1 p. . .
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C '- independent collaboration,' do'you not intend to allow the" ' - si
' ..7.M.. ' public 'to b'e privy to 'that'information?,,s/..f,. .; y_).M ?; : s. f. l[Ij9 .' ~ ~ $ ..
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- 14. Who specifically'. trained all tEese ne,w employees PSI
- 7. .
hired (and all ~the' old unqualified ones); how"were 'they . . .- trained so quickly? How can.you think of letting work
, proceed when it's obvious that the most PSI has done is to -
hire consultants to write. manuals for them (as opposed to
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having completed adequate training of its employers)?-
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- 15. You (being NRC represent'atives and Public Service Indiana representatives) said the meeting'was to be based on the " truth"; how can you make a tongue in check comment like that? Does your " truth" include the assertion that with all the nuclear power plants now in operation "we've only had one Three Mile Island"? After all, any well read person knows of many " accidents" and " shutdowns" - what is your 3 . f-
'w.v'i.
nomenclature those incidents? And is it your opinion that Three Mile Island is over? You said you would figure out what to do with the waste and contaminated structures "when the time comes"; well, what have you decided to do to. keep those pipes from disintegrating while you figure it out at
- Three Mile Island?
- 16. How can you state with any degree of certainty what .
dosage of radiation people took at Three Mile Island; isn't . it true that detectors were not in place until three days . , ,, after the first announced leak? So the readings you toss . .'. out are a measure of what was present on the date and in the , s i. place the reading was taken, nothing more, isn.'t that true? . . ' . ' . '. _ ~
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O'.' 17 ',' As to notice of the' meetinp' ih, Madison', in wh'at' papers .' [c ' ...[ -
. '. s and on what days was noti *ce of the actual'date of the. meeting'. , . .
published? I saw a publication of notice that the'me'eting
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- ' . would be on.one date; then it war. changed..to March 2.4, 1980. . ' -M I saw no proper notice that the mee' ting had' been changed
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again to March 25, 1980'.~ *
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- 18. As I understand the, law, every proceeding is (shod 1d .
be) adversary in substance if it may result in an order in , favor of one person as against another and the proceeding is. . ' none the less an adversary one simply because the primary purpose of the agency is to protect the public interest . (U.S. v. Abilene & S.R. Company, 265 U.S. 274, 44 S.Ct. S65; in light of that, how can you (looking to the transcript of ' that March 25, 1980 meeting) justify your behavior? Your lack of questioning? Your failure to require independent verification? Your failure to take control of the situa-tion? Your willingness to let PSI proceed based on their
- own self serving promises? ~ , , .' l
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- 20. What factors are' considered in choosing a cite for a ~
nuclear power plant? Is it mere happenstance that they are ( . f'-
'often located in rural a'reas where the education level of %-
a-
- .". the populace is low and where the opportunity.for'a ' ^ f .i '.
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.,.] .paychech goes a long wa' l to win a ' person's loyalt$.'regularg...
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- 21. , If an emergency occurred, how long would you have to' .
put into effect an evacuation plan? How can you pretend.to '.. i think ANY evacuation plan of a 10 mile /50 mile radius (as j you've indicated would be required) would work? ' i
- 21. Since you who attended the meeting on behalf of the NRC were not the ones who will make the ultimate decision here, !
did you not have an even higher duty to search out answers ! to these and other obvious questions? The members of th3 committee who make the decision will have nothing in front of them other than the material submitted by PS1 itself; the people of this country cannot remain calm as it becomes clear that thi.= is what you consider regulatory action.
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- 22. I understand that af ter I lef t you (Mr. Stello) agreed it might be a good idea to get some independent agent to inspect the " corrected" faults in the concrete; did it take a chance suggestion from a member of the public to make you think of that? And you are the watchdog for the pbblic? .
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- 23. Might I suggest 'that'the independent agent shbuld be allowed to test whereever he wants and not where directed by
' IS1? .
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- 24. Have you made provisions for a complete security check of all employees and contractors working at Marble Hill? If 8 e not, on what basis do you justify the lack? An ill inclined
_e . contractor 'or wor'ker alone could perform shoddy workmanship
. n .'? ( ..; which, would 'have ~ grave consequences later. Terrorism is as N., ..!'. , ' much a real threat as earthquakes and tornados; this plant in particular 1might be more susceptable' to such an act
. considering who is to be the recipient of its power. Have you considered this'or.is this,another' problem you will deal with when the time comes?' s - 2- -
Senator Townsend of Indiana has acknowledged that the Public Service ~ Commission in Indiana is a source of real problem to the people; i.e. , that it is interested in excess profits regardless of the effect on the people. Obviously, since
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the power produced by Marble Hill is to be shipped out of the state, this plant is not for the people, but for the profits. Since you must know even more about this than 1, and yet you continue to rely on the " good faith" of those same individuals, it can only be said that you are indeed acting in collusion with the Commission members and PSI - officials. I want the record to reflect my feeling that NRC repre-sentatives were generally unprepared for the March 25th
,,,- meeting..or, they were unwilling to press PSI for any hard . .. . . . y c . ' facts or explanations. Further, Mr. Thornburg, Stello and .
- ~. . . ,,, . .Keppler' repeatedly checked their watches and commented about .
'l ."c N.t h the time.'. Mr:~ Stello,' while telling people they would have J
~ the opportunity'to ask all their questions, repeatedly
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s . badgered "How many 'more questions do you have" and "There is a long line of people waiting" and he failed to control the floor for those who were asking questions; and, in more than one instance, joined in the derisive attitude of the pro-Marble Hill people in the crowd (construction people, equipment operators and engineers primarily). This meeting did not serve the purpose of getting any hard data from PSI as to what specifically they have done,to correct their'heneous planning, construction, training, and quality control practices. NRC officials ontinue to fail to deal with many of the issues which are of concern to the citizens, i.e., l l - 5 l - . i .H .
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- 1. Wy should a company who ~went so far with no planning (and would have gone further) be alloiTed to proceed at all? - -
- 2. Wat has PSI done to' change? ' '
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- 3. Wat has been done to set up controls to"be certain everything is done perfectly (because anything less than perfect is not safe enough)?
- 4. Wat has the NRC done to exercise it's power and duty to assure public safety? . .
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5.- How can you think of building this plant when
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you admit that you'll have to figure out what to do
, . to keep us from being contaminated by waste, spills -
and/or shut downs ~, when the time "comes?. *-
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- 6. _Since you obviously do thirik its okay to ' proceed without having the answers to those' ultimate questions, how can you p, ret.e,nd to, be any .sor.t. of watchdog agency?
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Sincerely, .
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J Deborah' H. McCarthy cc: Senator Walter D. Huddleston Senator Vendell H. Ford ,. Senator John Berry , ; , . .
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