ML19332B114
| ML19332B114 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/09/1980 |
| From: | Stamiris B, Warren S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19332B115 | List: |
| References | |
| ISSUANCES-OM, NUDOCS 8009260001 | |
| Download: ML19332B114 (8) | |
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UNITED STATES OF AMERICA NUCLEAR REGUIXIORY COPHISSION Before the Atemic Safety and Licensing Board
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In the Matter of
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CONSUMERS POWER COMPANY
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50-330-OM (Midland Plant, Units 1 and 2)
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SUPPLEMENT TO WARREN PETITION 'IU INTERVENE AMENDED SUPPLEMEPTT TO PETITION 'IO INTERVENE OF BARBARA ST?.MIRIS e
8 00926000l Dated, 9I 9 I 80
Sharon K. Warren 636 Hillcrest Midland, MI 48640 In the Matter of Consumers Power Company (Midland Plant - Units 1&2)
Docket Nos. 50-329-OM 50-330-OM Supplement to the Warren Petition to Intervene In order to meet the requirements of the petition to interv..e required by Section 2.714 and other pertinent sections of the Nuclear Regulatory Commissir ns Rules of Practice, I wish to make the following s ta tements :
1.
The composition of the fill soil used to prepare the site of the o
Midland Plant - Units 1 and 2 is not of sufficient quality to assure that pre-loading techniques have permanently corrected soil settlement problems.
The NRC has indicated that random fill dirt was used for backtill.
I contend that the components of random fill can include loose rock, broken concrete, sand, silt, ashes, etc. all of which cannot be compacted through pre-loading procedures.
2.
Because of the known seepage of water from the cooling pond into the fill soils in the power block area, I contend that permanent dewatering procedures being proposed by Consumers Power Company are inadequate, particularly in the event of increased water seepage, flooding, failure of pumping systems and power outages. Under these conditions Consumers cannot provide reasonable assurance that stated maximum levels can be maintained.
Considering, also, that the Saginaw Valley is built upon centuries of silt deposits, I further contend that these highly permeable soils which underlie, in part, the diesel generator building and other class I structures may be adversly affected by increased water levels producin3 liquifaction of these soils. The following will also be affected:
- 1) bosated water tanks,
- 2) diesel fuel oil tanks.
3.
I contend that pre-loading procedures undertaken by 8'a9sumers Power have induced stresses on the diesel generating building.,*eneture and have reduced the ability of this structure to perform its essentia'l ' unctions f
under that stress.
I, furthermore, state that those remedial actions that have been taken have produced uneven settlement and caused inordinate stress on the structure and Circulating water lines, fuel oil lines, & electrical co.n? ui t.
Sharon K. Warren
Amended Petition to Intervene Barbara Stamiris petitions to intervene in support of the Order of Modi-fication of Construction Permits in order that continued work on, and unsatis-factory resolution of soil settlement problems do not threaten her health and safety.
Amended Supolement to Petition to Lntervene Barbara Stamiris is representing herself with the following list of con-tentions:
1.
Consumers Power Company statements and responses to NRC regarding soil f
settlement issues reflect a less than complete and candid dedication to providing information relevant to health and safety standards, as seen in:
a) the material false statements in the FSAR (Order of "odification, Appendix B) b) the failure to provide information resolving geologie.:lassification of the site which is pertinent to the seismic desig.
..at on soil settlement issues (Responses to FSAR Questions 361.4.'
.rd 5, 361.7 and 362.9) c) the appeil against providing further information and testing requested in June 30, 1980 and August 4, 1980 letters d) the failure to provide adequate acceptance criteria for remedial ac-tions in response to 50.54f requests (as set forth in p&rt II of the Order of Modification) and this managerial attitude necessitates stricter than usual regul'*ory supervision (ALAB 106)
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2.
Consumers Power Company's finan'.ial and time schedule pressures have di-rectly and adversely affected res.lution of soil settlement issues, which
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t constitutes a compromise of applicable health and safety regulations as deronstrated by:
a) the admission (in response to 50.54f question il requesting identifi-cation of deficiencies which contributed to soil settlement problems) that the FSAR was submitted early due to forecasted 0.L. intervention, before some of the material required to be included was available b) the choice of remedial actions being based in part on expediency as noted in Consumers Power Company consultant R. B. Peck's statement 8-10-79.
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c) the practice of substituting materials for those orig 41 ally specified for " commercial reasons" (NCR QF203) or expediency,. -in the use of
.:oncrete in electrical duct banks (p. 23 Keppler Repot.)
- d) continued work on diesel gen rator building while unresolved safety issues existed, which precluded thorough consideration of Option 2 -
Removal and Replacement Plan a
e) the failure to freely comply with NRC testing requests to further evalu-ate soil settlements remediation as such programs are not allowed time for in the new completion schedule presented July 29, 1980 3.
Consumers Power Company has not implemented its Quality Assurance Program regarding soil settlement issues according to CFR Appendix B regula-tions, and this represents a repeated pattern of quality as urance defici-ency reflecting a managerial attitude inconsistant with irblementation of Quality Assurance Regulations since reasonable assurance vas given in past (ALAB 100, ALAB 106 and LBP 74-71) that proper quality assurance would cases ensue and it has not.
- March 22, 1979 Keppler Investigation Report conducted by Region III Dec 78-Jan 79
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Examples of Quality Assurance deficiencies regarding soil settlement include:
a) 10CFR 50 - Appendix B, Criteria III, V, X and XVI as set forth in the Order of Modification b) 10CFR 50 - Appendix B, additional criteria denoted by Roman Numerals below I.
The applicant has failed to assume responsibility for execution of the CA program through his failure to verify and review FSAR statements (pp. 6-8 and p. 21 Keppler Report) and through his reliance on final test results not in accordance with specified a
requirements (p.16 Keppler Report).
II.
The QA program was not carried out according to written policies, procedures and instructions 1.: that oral directions were relied i
upon and repeated deviations from policies een,a1 regarding com-paction procedures (p. 9-14 Keppler Report)
E-VII.
Control of purchased material has not been :;
.svaed in that C
examination and testing of backfill material.S l'd h.wt occur in accordance with regulations (NCR QF29, NCR QFi.c'...
IX.
Control of non-destructive testing was not ec.
aF.i.e d by quali-fled personnel using qualified procedures reg. lixp.
a) moisture control (Keppler Report p. 14-16, QA.' o,uest SD40, NCR QFS52, 172, 174 and 199) b) compaction procedures (Keppler Report p. 9 - NCR OFS 68,120 and 130) c) plant fill wor). (p. 24 and 25 Keppler Report)
XI.
Test programs did not incorporate requirements and acceptance limits adequately in the areas referenced in a, b and e above),
and do not meet these requirements regarding soil settlement remedial actions
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XIII. Measures were not adequately established to prevent damage or detereoration of material regarding frost effects on co:apacted fill (p.16 ar.d 17 Keppler Report).
c) the settlement of the Administration in 1977 should have served as a quality indicator, preventing the same inadequate procedures from oc-curing i.n the 1978 construction of tne diesul generator building causing its eventual settlement 4.
Consumers Power Company performed and proposed remedial actions regarding soils settlement are inadequate as presented because A.
Preloading of diesel generator building
- 1) does not change the composition of the improper 3 ils to meet the original PSAR Specifications
- 2) does not preclude an unacceptable degree of ft:;' < differential settlement of diesel generator building
- 3) dges not allow proper evaluation of compaction.. edures because of unknown locations of cohesionless soil pockett
- 4) may adversely affect underlying piping, conduits e. nearby structures
- 5) effects of the preload were not scientifically is cated from the ef-fects of a rise in cooling water and therefore na$- taeasured properly B.
Slope stability of cooling pond dikes is not assured *.acause they were built with the same improper soils and procedures (NCP QF172)
C.
Contention 4.C. to be revised and submitted on or befoce September 24, 1980.
D.
Permanent Dewatering
- 1) would change the water table, soil and seismic characteristics of the dewatered site from their originally apptoved PSAR characteristics -
w characteristics on which the safety and integrity of the plant were based, thereby necessitating a reevaluation of these characteristics for affected Category I structures
- 2) may cause an unacceptable degree of further settlement in safety re-lated structures due to the anticipated drawdown effect
- 3) failure or degradation of permanent dewatering would allow inadequate time in which to initiate shutdown, thereby necessitating reassess-ment of these times Therefore, unless all the issues set forth in this contention are adequately resolved, the licensee actions in question should not n.'.unsidered an ac-ceptable remediation of soil settlement problems.
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'he additional information and testing requested of
,osumers Power Company, by the NRC and its consultant, the Army Corps. of G.jneers, in June 30, 1980 and August 4, 1980 is essential to the st;[,I '. evaluation of Consumers Power Company's remedial S.S.* action, and withoc *:l ich staff does not have o
reasonable assurance that the plant can be opera'.c1 without undue risk to the health and safety of the public (part II, p. 3 grder of Modification),
and must therefore be responded to fully and cornp1 ed with totally.
- Soils Settlement j
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