ML20024B093

Ack Receipt of Response Re Independent Audit of Facility. Truly Independent Audit Should Include Full Scope Overview of Completed Const Done by Third Party Rather than Util

ML20024B093
Person / Time
Site:	Midland
Issue date:	05/31/1983
From:	Romo L LONE TREE COUNCIL
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20024B092	List: ML20024B091 ML20024B093
References
NUDOCS 8307050188
Download: ML20024B093 (3)

Text

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LONE TREE COUNCIL k

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• F ATHER JOHN GUSSENB AUER PROFESSOR OF BIOLOGY Sv5C V

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& lf 3ames Keppler dWk U.S. Nuclear Regulatory Commission kgo Region III Eg gy g 799 Roosevelt Road

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Dear Mr. Keppler,

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l FILE] z} s Thank you for the prompt reply regarding an independent audit of the planned Midland Nuclear Power Plant.

Unfortunately, we are disturbed by your ending paragraph in which you imply that letting Consumers Power Company reinspect its own work does not make a mockery of the N RC 's commitment to ensuring safe construction.

You add, "particularly in view of third party inspections and other actions being taken under the Construction Completion Plan."

Let us look at these " third party" inspections and the CCP.

As we understand it, an audit is an examination for the purpose of verification--in this case a safely constructed nuclear plant.

Our understanding, and please correct us if we are wrong, is that Consumers Power selects what TERA Corporation will inspect (with NRC approval).

To use an analogy, if we are audited by the Internal Revenue Service we get to choose those parts of our finances we would like disclosed.

Of course, this is ludicrous.

Yet Consumers seemingly has that power.

In addition, it has selected, and the NRC has approved, the Auxiliary Feedwater System, which has been reviewed and approved recently.

An audit is usually thought to be complete and very thorough.

While it is reassuring that the heating, ventilation, and air conditioning system, and the emergency power system might be reviewed, it appears that TERA will be focusing mainly on the design of these systems rather th.an the construction--a very distinct difference.

Concerning the CCP, your letter disguises the fact that there would probably be no CCP had it not been forcibly suggested by the NRC.

The plan was not a result of the utility's initiative.

This does not create a feeling of confidence in the l

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utility's commitment to do the job properly.

In a related matter, Consumers Power announced that, unless told otherwise by the NRC, they would begin their Construction Implementation Overview (CIO) on April 18, 1983.

Publicly, the NRC has remained silent.

Regarding the selection of outside firms as third party inspectors and citizen input, you have previously stated that the public will not have a vote in this since you " don't believe in the shared process of decision making." (Midland Daily News, May 4,

1983)

We find it ironic that the licensee has chosen the areas for re-inspection as well as the inspectors, and obviously is able to share in this process, yet citizens are denied it.

In summary, there are several questions that are raised:

1.

What new light will be shed by a re-evaluation of the Auxiliary Feedwater System?

2.

Would you explain the extent to which TERA Corporation will examine construction as well as design?

3.

Regarding the CIO--

a.

Did it begin April 18, 1983, as announced by Consumers?

b.

If so, have you approved of the plan?

c.

Has Stone and Webster, therefore, been approved?

d.

If so, will it include a 100% review as promised by Consumers in December, 1982?

We have dif f erent ideas on what a third party audit should encompass.

It does not seem unreasonable that a truly independent audit should:

1.

Include a full scope overview of completed construction done by the third party rather that the utility.

2.

Consist of a thorough inspection of as-is construction, as well as the design of the plant.

3.

Be selected solely by the NRC (or allow the public

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the same voice as the utility)

It would seem that this approach would totally assure our community that the plant has been constructed safely.

Would you explain why this method is not possible?

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l Mr. Keppler, we know that the Midland plants have become an albatross f or you.

You have indicated several times that your l

role is that of regulator, not builder.

We understand your I

position, but one cannot ignore the many quality assurance breakdowns and poor construction record of Consumers Power.

To use your own words, "You wonder after so many screw-ups whether i

l the utility is capable of doing the job right." (Interview, WXYZ-TV, F;;1,19 82) 2

We hope our comments are seriously considered.

Again, thank you for the quick response.

Further detailed information, especially regarding the CIO, would be most welcomed.

Sincerely dg M7 Leo R. Romo Corresponding Secretary cc:

V. Stello, EDO H. Denton, IE R. DeYoung, NRR D.

Eisenhut, NRR DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Galder (P.E.)

Howard Levin, TERA Billie P. Garde, Government Accountability Proj ec.t 1

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