ML19331D313
| ML19331D313 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/25/1980 |
| From: | Stamiris B AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OM, NUDOCS 8008280668 | |
| Download: ML19331D313 (4) | |
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';sY U.S. NUCLEAR REGUIATORY C0'.24ISSION b
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..fo In the matter of Docket No. 50-329 O N *.,I Consu=srs Power Co.
50-330 CE Midland Plant Units 1 and 2 AENDED PETITION TO INTERVENE Barbara Stamiria petitions to intervene in support of the Order of Modification of Construction Permits in order that continued work on,and unsatisfactor r resolution of soil settlement problems do not threaten her health and safety intrests.
AENDED SUPPIMNT TO PETITION TO INTERVENE j
Barbara Stamiris is representing herself with the following list of cententions :
- 1. That the soil conditions of the Midland reactor site, their potential i
for subsidence identified in the 1970 S.E.R., and-their inability to support plant structures without the extensive use of fill soils and compaction proceedures, represent insdequate attention to health and safety requirements in that design specifications have not allowed
- appropriate and adequate l
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compensatory safeguards"(10 CFR-100.10).
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- 2. That C.P. Co. statements and responses to the NRC have been at times l
l a) false - in FSAR statements regarding fill soils (table 2.5-14) l l
b) evasive - regarding geologie classification and seismic characteristics l
of the region as separate from the Central Stable Region (responses to NRC questions 361-362) c) and reveal an overall pattern of reluctance in complisnee with NRC questions and testing proceedures regarding soil settlement problems (responses to NRC 50-54f requests and the August 4,1980 Ar=y Corp of Engineers Report) which show that C.P.Co. isn't fully divulging and attending to these i=portant safety is sues.
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- 3. That C.P.Co. is placing their own financial and ti=e schedule intrests above their ecacern fer safety issues involved with the soil settle =ent
- as de=c=strated by :
a) The new ec=pletion schedule pressure as a result of the Dew stet = centract deadline b) The pressure on NRC to reschedule the priority of their Operator's License review because of "enor:ncus rescurees already invested by the NEC and C.P.
Co. " as outlined at the July 29,19S0 Eidland =ceting.
c) The conti=uation of work on Deisel Generator Building while u= resolved safety issues existed d) The apparant concern for expediency in the choice of re=edial actiens as noted i R.3. Peck's censultart state =ent 6-lC-79s and the rejectice of Option 2 Removal and Replace =ent Plan e) The ad=issien that "the Midland FSAR was sub=itted to the NRC at a= earlier point in the project than would have nor= ally cceured in order to provide additional ti=e for the operati=g license hearings due to the forcasted intervention.*(response to 3-21-79 EC-54f request Q.1)
- 4. That C.P.Co. has not i=ple=ented its Quality Assura:ec Progra= in eceplia ee with 10 CFR-50 Appendix 3 rsgulatic=s as was "rearo2 ably assured" to occur in the conclusions of the 1973 Shew Cause Heari gs on past Q.A. deficie=cies as noted ins a) Oesign and eccstructien deviations and inadequacies in the use of ra dc=
fill under safety related structures b) In the ec=paction of these soils e) In the is i=spection of a and b above d) In the corrective actiens tr. ken (as these deficient proceedures ec=tinued about 15 years beycnd official cotificatics) a=d these repeated breakdow=s in quality assura:ce threaten health and safety of the publie.
4 EecMnks are mw+iened cnly D 50 kr~ as '-ey ditWly 02c-ci 25 ty w'e s.
0 & nSea ;ti des;cn spsa;Aca rms 4r *c:m mu c.'11 maScts '(wm ga,
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- 5. That the perfor=ed and proposed re=edial actions of C.P.Co. regarding soil settle =e=t under safety related structures do not =eet health and safety standards in thats l
Preloading in and around Deisel Generator Building i
a) does not charge the composition of the i= proper soils to meet the original PSAR specifications b) does not preolude all future settle =ent of this or other safety related structures or stability of cooling pond slopes where the sa=e inadequate
=aterials and proceedures were used c) =ay have adversely affected surrou= ding soils 3e per asent dewateri=g system a) would change the water table soil,and seis=ic characteristics of the whole y
plant site fro = their ori inally approvd specifications as set forth in the 6
PSAR and Construction Per=it - specifications on which the safety and
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integrity of the operating p'. ant were based b) could shorten the safe shutdown ti=e c) =ay cause additional settlement
- s. That the additional i=for 4 tion snd testing requested of C.P.Co. by the NRC and its consultant the Ar=y Corp of F.ngineers August 4,1980 is essential for the staff-to perfor= its evaluation of health and safety intrests and
=ust therefore be responded to fully and co= plied with totally.
- 7. That the practice of e= ploying Quality Assurance Staff and cc=struction 3
engineers and workers, frc= t a sa=e co=pany (Sechtel) represents a ec=flict of intrest that has interfered with satisfactory perfor=ance regarding soil settle =ent issues (10 CFR-50 Appendix 3) -as de=enstrated by the pattern of quality control deficiencies regarding fill soils fro = 1974 through 1979 (nonconfor=ance reports-and Q.A. recuests referenced. in Appendix A of the Dec.61979 Order of Modification)
Wherefore petitioner requests that she be permitted to continue to intervene in the preseeding for the Order of Modifiention of Construction Permits.
Dec. 6 1979.
Respectfully Submitted r
Barbara Stamiris 5795 N. River Freeland Mich. 48623 August 25,1980 YLl%W Y f)1.4 m
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