ML19323F346

Requests That Outlined Questions & Comments Be Included in Record of 800325 Proceedings as Allowed by Us Court of Appeals

ML19323F346
Person / Time
Site:	Marble Hill
Issue date:	04/02/1980
From:	Mccarthy D AFFILIATION NOT ASSIGNED
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19323F341	List: ML19323F346
References
NUDOCS 8005280806
Download: ML19323F346 (6)

Text

. .

O Deborah H. McCarthy ,

208 Elm -

Eminence, Kentucky ,40019 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 that 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 representatives) stated that you write the regulations (regarding qualifications for employment, inspection procedures, training requirements, etc.) for PSI; so I ask who, specifically, among you writes them and what training and qualifications fspecifically).does that person (s) have to do so? . , .

2. It was noted by Mr. Keppler (1 believe) that it has come to your attention that there are inconsistencies in some instances between your procedure manual and PSI's procedure manuals. With regard to this problem (which should be enough by itself to continue the stop-work order),

you cerely asked PSI to explain. Did you consider that singular question, and PSI's nonspecific reply, adequate j investigation? Why did you not present examples of such I

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 procedures when you know their manual does not conform to your manual? Why whould PSI be allowed to write its own manuals; we know already that we cannot rely on them to police themselves.

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APR 111980

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)? .

'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 WORKED OUT (to the nth degree), isn't such a company PER SE unqualified for a -

license to proceed?. .,-

. ,. 5; ;.After .all, Mr. Stello, 'your inference (in talking about N

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. f r't J ~ quality ' control of subcontractors). was that the only way to V .," ' .

h' !... .~" 5 ~'c~. 'pio'ceed. if 'one,found shoddy' work, was to. be rid of the '- c ; . , .f.

contractor who performed the shoddy work. Does this n'ot '.

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app'ly required many of the times over mind master to theofissue this ,ofplant, what PSI? should .W bed r'../ ~

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6. 'Aren' t you ' . the. NRC, goi5g. .:to., o'~ ' require 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 ,-

accept PSI's self-s,"as '

erving possible?.

statements Dr. do on you thisintendissue?-Y to merely -

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. ..& represe;ntiat1ves

.._ L A of ..the u >NRC,,

.. -allow' PSI ; ..

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representatives.to drone on and on reading page after page of printed material (which said little anyway, since two -

words out of every sehtence'were PSI doubletalk: " quality assurance", " inspectors" or' " quality control managers")?

You gave.~the d!.stinct' impression, all,fosr, of you, while the

• PSI men were readin's 'that you 'we're bored; yo'u all conversed

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with each otlier'. motioned to'your colleague on' the floor, . . -

. _looke'd at"yohr w'atches; 'ete'.; sio .T ask each of "'

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.~. read th'e' mate' rial before the ' meeting? W

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the. mome% nt you.*:.'%A' ~ll. .p.J*

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roperly --d'- -

6@.Q""v.y.,,;why 'then did"younot '. ins'ist that,the time be used to pose ' . r ';.

0~ ',.' questions to the PSI ment Obviously, from the few exchanges

.2

' 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. Veren'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. PSI admitted that the quality control committee, one of the big changes they made, is basically a means of getting i l

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. . . l 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 mot'give

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, ~ the appearance of being in an . adversary. or watchdog' rela ' I tionship with PSI. ,You cannot give me a valid reason'a's to .-

why I don't have the riiht.'to'

'" . f.i r - issue of whether to locate. this ultra ' hazardous plant ..(which .

a lo' cal . referendum fon' the - .  !

4 ' .

l will supply' energy Jto p~roduce,' nuclekr' materials..'.in a, plant ~

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', hundreds of miles away) in my community; but you' can tell me .

why you, by your lack of preparation, lack of hard questions to PSI and apologetic man ~ner 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 , intimidation'of those citizens, why you have made a charade of this one opportunity we as citi-zens have left to protect~

,- ( ...;3 3 ourselve.s? .. ,. c ,

12. What sort of confidence-should we place.in any NRC 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,of thousands of years and, cannot

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conceivably be adequately.,contai ed) when the time comes"?

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13. Do you' intend to allow'c'onstruction'.to proceed w'ithout ~~

requiring any independent dcumentation of changes which are'.

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3 'f? ' . in force at this date?. . ..and if you .do intend .to . require .L .

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.s.3- . independent collaboration;~do#you not' intend to 4- -

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to,,a.b'e privy to 'that'inforuatio' n:... g <..<.y . ..:. p .y . u. q. . .n . +.2 n  ?;/..y...@. allow l

l Whospecifically.trainedallth'e~se;ne'w'employeesPSI

14. .. 1 hired (and all the' old unqualified ones)' ;how'were they ': .

trained so quickly? How can .you thin'k of letting work

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. proceed when it's obvious that the most PS1 has done is to -

hire consultants to write manuals for them (as opposed to 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 . ,3 4

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nomenclature thore 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 dir, integrating while you figure it out at *

, Three Mile Island? . .s i

16. How can you state with any degree of certainty what a dosage of radiation people took at Three Mile Island; isn't. .

dt true that detectors were not in place until three days . .',,

after the first announced leak? So the readings you toss...' i . ._

out are a measure of what was present on the date and in the ,e s .

c- place the reading was taken, nothing more, isn't that'true?i..; 'f .'~

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on to what ' notice days of was the meetini noti'ce lh. of the a,Madiso~,n .n, *in what~ -

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published?

ctual'date of the meeting ,...- -

I saw a publication of notice that the' meeting 4 .1 a 2 .' would be on.one date; then it was

.T ~ . 'I saw no proper notice that the'me.et'ing changed.tohad'been Marchchanged 24, 1980. j '-' '

again to March 25, 1980.'- i .-  % ---* ~ *; ,

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As I understand the law, every proceeding is (should

be) adversary in substance if it may result in an order in ,. 'J-favor of one person as against another and the proceeding is.N 3 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. 565; ~

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? .

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. 20. What factors are' considered in choosing a cite..:

for a

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. nuclear power plant? Is it mere happenstance that they are;.._. .

d..v often located in rural a,reas where the education level of 4-  ;

1. y k..g.[ ff.,paycNeck

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W ;' the s , go,6. . .

mopulace a long wa'y{ is to winlowa and .

person's .

where loyaltythe ., 7 3 jy; opportuni pv' y.7

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21. , If an emergency occurred, t s long wo;uld'you have' to .. ' , ' .J r.

put into effect an evacuation plan? How can you pretend '-

think ANY evacuation plan of a 10 mile /50 mile radius (a.s to you've indicated would be required) would work? '

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 the committee who make the decision will have nothing in front of them other than the material submitted by PSI itself; the people of this country cannot remain calm as it becomes clear that this is what you consider regulatory action.

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22. I understand that after I left 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 p-ablic? .

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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 PSI? -

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! 24. Have you made provisions for a c'omplete security check

[ of all employees and contractors working at Marble Hill? If not, on what basis do you justify the lack? An ill inclined '

_ .J . contractor ~or wor'ker alone could perform shoddy workmanship c . ' m ,1 1, s which,would'have grave consequences later. Terrorism is as >

, ' ; . ' !' , much a real threat as ' earthquakes and tornados; this plant l

in particular might 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 jou will deal with when the time comes?' -

-.~- + ._

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 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 I, 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

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facts or explanations. Further, Mr. Thornburg, Stello and .

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7,b.. p .~...,, Keppler' repeatedly checked their watches and commented .~.5 abou

?  ; w., , i' the opportunity to ask all their questionsi repeatedly

...e . . 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.,

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1. Why should a company who'went so far with no planning (and would have gone further) be alloiTEd to proceed at all? - -

2.

What has PSI done to change?

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3. What has been done to set up controls to be certain everything is done perfectly (because anything. less than perfect is not safe enough)? -

4. What has the NRC done to exercise it's power and duty to assure public safety? , ,

5.; How can you think of building this pla,nt when 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?. '- ..V ' ' .

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Since you ob'viou' sly do thirik its okay to ' proceed without having the answers to those' ultimate questions, how can you, .prete,nd . .

to, be any. sort of watchdog agency?

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Deborah' H. McCarthy cc: Senator Walter D. Huddleston Senator Wendell H. Ford s Senator John Berry f #', 4 i . f

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ijgf2 The SASSAFRAS AUDUBON SOCIETY I

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of LAWRENCE . GREENE MONROE - BROWN .

MORGAN & OWEN COUNTIES 3 y

- :- ,/ INDIANA "

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April 7, 1980 / 4g fi' w R' -

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Mr. Victor Stallo, Jr.

• Director, Office of Inspection and Enforcement hYiOO '

U.S. Nuclear Regulaton Con =ission y&_ M8 g e

i Washington, D.C. 20555 Lear Mr. Stello Sassafras PSI, Audubon April 11, 1980 received notice today of the forthco=ing meeting of the NIC with for krble Hill. in Bethesda, holand, on PSIts Revised Quality Assurance Progrs=

You at an notIndd Madison, listed anaas a participant in the testing, but since you chaired the meeting on this subject, and will be involved in the recor. mends. tion to the Ce*ssioners as to whether safety-related construction should resu::e at Marble Hill, wc thought it best to address our continuir.g concerns to you.

None of the major questions SAS seeks answers to concerning Marble Hill (see Statement presented to you at Madison, Indiana on March at Madison. 25, 1930) wen answered at the meeting hope that the NRC vd With regard Question I, "Can hrble Mill be repaired sufficientiv?", we support an independent ssr.essment of the quality of constmetic Save-the-Valley.and the degree to which it can be satisfacto:ily repaired, which has bee The question of whether PSI v'"

be required to have N Certification, not just an

" interim latter", prior to resumption of construction at Marble Hill, was made more Shields, Vice-P2vsident, Electric Systens, PSI. confusing at the meeting all responsibility for Marble EdH ? Does PSI still intend to assa:ne over-will not PSI have to be certified? If the ASME Code is law in the State of InMan of the Subcom=ittee Hearings on Construction Pmblems at Marble Hill _:Nu Nuclear Berub-tory Co cission Oversittt, Novenber 27 and 28,1979, states that it in extremely im-portant that all systems and components in that plant be built in accordance with the AME Code and be code stamped in order for PSI to qualify for insurance at Marble Hill This is not the time to accept another premissory note from PSI. .

Sassafras Audubon continues to be disturbed by the fact that substantial prog:ess has been made in the construction of Marble Hill (even though not " safety-related") yet PSI does mt. have a fullt developed and functienal Material Management Progran.This seens inexcusable and a matter of =isplaced prierities.

PSI, when questioned by the NRO at the March 25 meeting as to when PSI personnel would 2splace MAC personnel, replied that they expected it to take one to three years As .

we commented on March 25th, this is far too indefir.ite considering thessfety-related work of stoppage was brought on at least in part by serious understaffing as well as la k nucleaa at present. experience. MAC personnel scarcely seems the answer to the extent plannec d uet 5914'/87

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PSI's analysis and conclusions ngarding their fbad-price contracturr1 agree-nents did not addreas the substantive proble=s associated with thee, in the pt.st ,

and as such are unacceptable. W assure that construction schedules and =ctiers  !

which cause delays in schedules vill be part of the April 11 Agenda on PSI's Revised CA/QC Pmgram. '

After the meetinE of PSI with the h% on April lith, we would appreciate a reply to our questions of March 25th and of this date, as well e.s a su==ary of the answers of PSI to the questions asked by the h% in CA Ouections Conerr.ine the Marbla Hill Docketed DA Prorram.

The ovedriding concern of our Society conti=ces to be the need for Marble F'll?

The evidence indicates it is not needed. To ignore this fact dien many aspects of Marble F'" 8s construction is being questioned cannot be justified.

To -c sincerely, j l

.. o A.  ; , . s1 .

Route 1, Box 375  !

Nashville, DM== 47448 i t

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,'s, y "f) f)D/f) SASSAFRAS Al'Dl'llON SOCIE'lY '

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of LA\V ZENCE . GREENE - MONI(OE IIROWN -

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w y / 7 @$~7 MORGAN & OWEN COUNTIES y,/  %*

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bet ivm s e s~

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TO: Mr. Victor Stello, Jr., Director, Office of m

d[h , Q '. p Inspection and Enforce-4nt Nuclear ?.eg-

- .c_.y uhtory Cominion (h'd. b6 2

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~g h Mr.

( 3 s G. Keppler, Direc, tor, Region III

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Y N .O. Mr. Cordell C. Willia =s, Construction ?mj.

, Ef ect Section Chief, Region III NP2.

Questions and Co=:nonts of the Sassafras Audubon Society presented at a Public Feeting held at Madison, Indiana, March 25, 1980, on the Re-sponse of Public Service Indiana, Inc. (PSI) to the N?a " Order Con-fir =ing Suspension of Construction" at Marble Hill, August 15, 1979

• he para =ount question concerning Marble Hill is not whether safety-rehted construc-tion should be resu=ed, but whether all constzuction should be stopped. Should the public be subjected to the dangers inherent in the operation of a nuclear phnt, in-cluding the storage of the plant's highly toxic wastes .on-site, if its pov-r is not needed? ',-

PSI has an overcapacity of Inore than 50% at peak power de=and with Gibson 5 expected to co=e on li-n in 1933 PSI has over-esti=ated grewth in de=and for electrical en-orgy in its se:vice area for =any years, and is unsilling to recognize :

1) that the expected population growth and Eeneral econo =ic activity in its area is likely to re=ain low, below the Nation's average, and

2) that the increasing cost of electrical energy will spur greater enercr con-servation, with the potential of energy conservation cutting energy use 30-!J$ by the year 2000, and

3) that ine: easing availability of natural gas in the next several decades will co=pete with and reduce dependency on electric power.

' The disastrous economics of nuclear plants adds another dimension to the question of whether Marble Hill should be built. The costs of constructing a nuclear phnt has been increasing annually at = ore than 3X the rate of general inflation, partly because of changes in design and adoption of standards to reduce the level of hazards in plant ope ration.

I PSI should be requi:ed by the NP.C, prior to consideration of resu=ption of constzvetion, to identify and docu:ent all safety-related =aterials and syste=s which will have to be changed, additionally tested placed to comply with post-T L

the DOE study of the Byron Nu should also be applied to Ma erators on-site have co be ze DUPLICATE DOCUMENT PSI has =ade no realistic estimate of v Entire document Previously enter into s stem u er:

but cost estimates of nuclear plants of g lic service co==issions place the cost ANO '

l does not include the costs of decontami

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J'8'1l ll1.' ( l THOMAS M. DATITLO pg l gas ,j ATTCANEY AT LAW G }- / i j l 311 EAST MAIN STREET RfMl ,

fileg Vl MADISON, INDIANA 47250 PwoNE Sl2 2M 4333

• March 26, 1980 -

Mr. Victor Ste119 i

Nuclear Regula' 7 Commission

)

Division of Inst'setion and l

Enforcement Vashington, D.C. 20555 In re the matter of Marble Hill STN Nos. 50-546 & 547

Dear Mr. Stello:

Please find enclosed a copy of Marion Hudgiris' statement presented at your meeting with Public Service Indiana on March 25, 1980 in Madison, Indiana. Also find enclosed a copy of the Professional Vita of Michael A. Cassaro, Ph.D.

This writer apologizes for not having copies available for you at the meeting.

Thank you.

Very truly yours, C

~ /Lw N NAL{

Thomas M. Dattilo TMD/mjb Enclosures

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cc: Mr. James Keppler 5' Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 s

DUPLICATE DOCUMENT Entire document previously entered into system under:

ANO CO O 07 No. of pages:

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FRED HA UCK

• [fEl # ' 1 Environmental Consultants, WI O'j P. O. Box 391, A

or (J \ ' I W # *' Route 3, Tower Heights, Shelbyville, Ky. 40065 t

i March 26, 1980 Mr. Victor Stello, Director Office of Inspection & Enforcement Nuclear Regulatory Commissi.on Washington, DC 20555

' i

Subject:

The March 25th. Marble Hil1 Meeting

Dear Mr. Stello:

I I

I must compliment you on your handling of a very difficult sit- l uation last night. I'm sure that you and the NRC are doing your i level best to properly discharge your duties.

In an effort to abide by'your rules, Save-the-Valley's attorney, l Tom Dattilo, persuaded me to omit the heart (I called it the " gut issues") of the presentation I wanted to make. The complete in-tended presentation is attached. I hope that you, Mr. Keppler, Mr. Strasma and the others will read it carefully in order to help all of you to understand the problems fully.

PSI's tremendous over-capacity, their current an'd impending slow-er and slower demand growth rate, and the unbearably heavy financial load if unneeded Marble Hill is ever completed, are the " gut issues" on which we have put carefully weighed numbers.

I will appreciate your consideration of my complete statement.

Sincerely,

/bf

• Fred Hauck, President l Save-the-Valley P.S. - Sassafras Audubon's written statement, which was handed to me,

, . is also enclosed.

l CopykoMr.Keppler 3 DUPLICATE DOCUMENT Region 3 Entire document previously entered into system under:

ANO h No. of pages:

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