ML19344A525

Amended Petition to Intervene Alleging Inability of Soil Conditions to Support Plant Structures.Alleges Falsification,Evasiveness & Reluctance in FSAR Statements Re Fill Soils & Seismic Characteristics

ML19344A525
Person / Time
Site:	Midland
Issue date:	08/18/1980
From:	Stamiris B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OM, NUDOCS 8008210067
Download: ML19344A525 (3)

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U.S. NUCI. EAR REGULATO'ff COMMISSION 2

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CONSUMER POWER CO.

Docket No.50-22S.8E P Midland Plant Units 1 & 2 56-53030M' AMENDED PETITION TO INTERVENE (2714 m)

Barbara Stamiris petitions to intervene in support of the Order of Modification of Construction Permits in order that continued work.on and unsatisfactory resolution of soil settlement problen:s do not thrraten her health sud safety intrests.

3UPPTNEWT TO PETITION TO INTERVENE (2714 b)

Barbara Stamiris is representing herself with the following list of contentions:

1. Thatthe soil conditions of the Midland reactor site, their potential for subsidense identified in t' s 1970 S.E.R., and their inability to support plent structures without the use of fill soils and compaction proceedures represent inadequate attention to health and safety requirements (10 CFR-10C).

2t That.C.P.Co. statements ~ and responses to the N.R.C. have been at tines a) false - in FSAR statements regarding fill soils under the doisel generator building (table 2.5-14) b) evasive - regarding geologic classification and seissio characteristics of the region as separate from the Central Stable Region (Responses to questions 361-362) c) and reveal an overall pattern of reluctanco in compliance with N.R.C.

questions and testing procedures regarding e, oil settlement problems (response to Requests 5, 35, and 37 and to the Army Corp of Engineers Report and Request Aug. 4,1980)

+ hew which show that C.P. Co. can't be trusted to divulge and attend to' important safety issues.

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3. That C.P. Co. is placing their own financial and time schedule interests above their concern for safety issues involved with the soil settlement.

(Economics are mentioned only in so far as they directly sffect safety issues) is demonstrated bys a) The new completion scheduld, and pressure on the NRC to accept it, as a result of the Dow Steam Contract deadline.

b) The pressure of the ERC to reschedule the priority of their operators license '

because of " enormous resources already invested by NRC and C.P. Co." as outlined at the July 29, 1980 meeting in Midland.

c) The continuation of work on deisel generatur building while unresolved safety issues ezisted.

d) C.P. Company's appeal"against further testing requirements of the NRC (Aug. 4, 1980)

4. That C.P. Co. has not implemented its Guality Assurarce Program in compliance with Consni.saion Regulations ( 10 CFR Part 50 Appendix B) throughout the construction process as was reasonably assured to occur in the conclusions of the 1973 Show Cause hearings on past Q.A. deficiencies. Design and construction specifications were not followed in a) the use of random fill soils under safety related structures b) in the compaction of these soils c) in the inspection of a and b above and these repeated breakdowns of quality assurance threaten the health and safety of the public.

5. That the performed and proposed remedial action of C.P. Co. regarding the differential soil settlement under safety related structures (set forth in their application for ammendments 72,74,76, 77) f all far short of meeting health and safety requirements.

6. That tha additional information and testing requested of C.P. Co. by the NRC and its consultant the Army Corp of Magineers Au:; 4,1980 is essential for the staff to perform its evaluation of health and saf ety interests and must i

i therefore be responded to fully.

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I 10 erefore petitioner requests that she be perstitted to cortinue to intervene in the proceedings for the order of modification of const uct ion permits.

Respectfully Submitted, Barbara Stamiris

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U.S. Nuclear P.egulatory Consnission 2-Washington DC 20355 Attn Docketing and Service Branch i

Michael I Miller, Esq.

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/ sham, I.incoln, and Beale i

l-One First National Plaza Chicago, Illinois 60690 i

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