ML20054H584

Discovery Questions Pursuant to ASLB 790226 Special Prehearing Conference Order.Proof of Svc Encl.Related Correspondence

ML20054H584
Person / Time
Site:	Midland
Issue date:	06/18/1982
From:	Sinclair M SINCLAIR, M.P.
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8206240226
Download: ML20054H584 (19)

Text

,

Mary P. Sinclair 5711 Summerset Dr.

%~ Midland, MI 48610 Consumers Power Company 1945 West Parnall Itoad Jackson, MI 49201 In the Matter of: )

) Doc. Nos. 50-329 CONSUMERS POWEll COMPANY, ) 50-330

)

(Midland Plant, Units 1 and 2 ) Operating License DISCOVEllY QUESTIONS OF INTER VENOR MAllY P. SINCLAllt June 18,1982 These interrogatories are fibd in accordance with the Special Prehearing Conference Order of February 2G,1979.

Terms are defined as follows:

" Staff"--meane any consultants or expert witnesses retained by the Nuclear Hegulatory Commission (NHC) for any issue discussed as well as the regular NilC. staff.

" Documents"--shall include reports, studies, notes, worksheets, meeting reports and summaries, correspondence, telecons or other communientions.

Documents to be provided and questions are as follows:

1. Provide any document or records that you may have supplied to the NPC staff for the preparation of the draft copy of NUREG-0110, "The NHC Program for the Besolution of General issues Pelated to Nuclear Power Plants" (1978)

2. Contention 6 deals with the poor quality control record of both the Applicant and the architect-engineer both at Palisades and Midland. As the 130ard has requested discovery questions are to be directed to current operation of the Quality Assurance program (including the alleged " doctoring" of welding certificates).

Questions:

a. Provide all the documentation on the " doctoring" of welding certifi-cates at Midland that were made available to the NRC staff at this time.

I 8206240226 820618 PDR ADOCK 05000329 g PDR 3Q C

. \

b. The current status of the QA program has been most recently com-mented on by the ACitS in their letter of June 11, 1982 Will the QA audit recommended by the ACllS be undertaken ?

c. What assurance does the public have that it will be an independent audit ?

d. List the procedures by which the Quality Assurance issues that the ACitS has recommended to be reviewed will be undertaken,

c. Will there be opportunity for third party review of these procedures and the results ?

3. Contention 7 deals with the fact that the Applicant has distorted and suppressed the truth regarding important new information in proceedings before the Commission.

(Exhibits 24, 25, Suspension hearings, Dec. '1,1976). The Applicant has continued to concealirnportant information, such as the failure to advise the NitC about the Administration building settlement, the material false statement listed in the December 6,1979 Order that initiated the OM-OL proceedings, and four other false statements in Appendix A of the December G Order.

Questions:

a. In view ofyour history of concealing the truth, what assurance does the'NIlC staff have that further soils remedial work, as approved by the Construction Permit Amendment #3 and NllC's May 25, 1983 letter to Mr.

Cook, will proceed with due regard for public health and safety ? Provide documentation,

b. The Board's April 30, 1982 Memorandum and Order calling for the Amendment to the Construction Permits expressed " doubt whether, in the absence of Staff review and approval, Consumers would carry out certain remedial soils activities using appropriate QA procedures and principles."

(p 14-15) What events happened between that April 30, 1982 Memorandum and Order and the May 25, 1982 letter to Mr. Cook granting permission to proceed with Phase II remedial work?

+

h' ,

c. Who were all the people involved in making this decision and in drawing up the May 25, 1982 letter to Mr. Cook? Provide documentation that substantiate the validity for coming to the decision that led to the ,

May 25,1982 letter to Mr. Cook.

4. Contentions 20 and 21 on t'he nuclear fuel cycle and the lack of a method to store nuclear waste should now be admitted for discovery since the U.S. District Court of Appeals struck down as invalid the S.3 Table (April 27, 1982) on which the NRC was relying for compliance with NEPA. I am resubmitting these issues in my amended list of contentions.

5. Contention 24 is now the basis for the on-going soil settlement hearings.

]

6. Contention 27 deals with the lack of an adequate emergency evacuation plan at Midland, i

Questions:

a. Who will decide when an emergency evacuation is necessary ?

6

b. The area warning system has frequently malfunctioned. Ilow will people be convinced it is a real emergency?

c. Ilow high would radiation doses have to be before evacuation of a 10 mile zone is ordered?

d. Will the radiation dose limits for evacuation vary for men, women, children, pregnant women and infants ? In what way ?

e. When Dow had a major chlorine leak several years ago, all the communications to the plant were jammed with people calling in or trying i

to call out. Ilow will this be avoided if the Midland nuclear plant has an emergency ?

f. llave parents been consulted about how their children should be taken care of if they are in school during an emergency ?

j

g. During the Dow chlorine leak, people were driving into the cloud to look for their sick relatives, children and pets. Do the emergency plans allow for known human reaction patterns shown in past emergency I

situations ? What are these plans ? Provide documentation.

i

h. Ilow much time does the safe shutdown of all critical processes at -

Dow require?

1. What protection will the workers have who must stay during an I '

emergency to complete the shutdown process ?

j. What special training for an emergency will these workers have ? ,

p k. What guarantees do you have that they will stay as long as needed during an emergency?

r

1. Will uncontaminated food and water supplies be kept available for f

their use for several days in the event of an emergency?

m. What are the host cities to which people in a 10 mile radius will be evacuated? IIave they been notified and prepared for this ?

! n. Ilow will people who do not understand the English language be notified ?

o. Ilow will people in nursing homes be evacuated?

f: .

J p. Ilow will people in hospitals be evacuated?

l (I. Ilow will people who do not own cars be evacuated?

j r. Ilow many beds for treatment of radiation poisoning does the h!!dland -

5 - Ilospital have ? Day City General? Saginaw General?

s. What plans are in place to deal with changes in wind direction after

'l, cvacuation has begun ? Ilow will people be notified of this change ? -

, t. Are there segments of the population for whom no evacuation plans can be made ? Who are they ? Why can't they be evacuated?

u. The NRC says there could be radioactive fallout as far as a 50 mile radius. What protection will there be for residents beyond a 10 mile radius?

llave their officials been included in the emergency planning process ?

v. Ilomeowners insurance policies specitically exclude coverage for loss due to a nuclear accident. Will homeowners be able to recover their losses from some other source, since the area could be uninhabitable for h

decades ?

r 7. Contention 28 deals with the water hammer problem of pressurized water reactors of the 511dland type. This problem is identified as one of the unresolved y

l' safety issues applicable to Alidland I & 2 in the SER, C-4

r V

I  : Questions:

h

a. Would you allow the plants to operate at full power with this defect?

f b. What is the series of events in the reactors that will take place, when and if the water hammer problem manifests itself ?

c. What non-safety related systems can affect or initiate the water hammer problem ? Provide documents that explain this interaction l

between the water hammer problem and non-safety related systems,

d. Provide the most recent summary documents of the Task Force I A-1 that indicate methods for resolving the water hammer problems.

1 Ilow will this unresolved safety problem affect the total power.

e.

output of these nuclear plants ?

. f. Ilas t'.ere been any incident in an operating reactor which raised this as a concern? Describe it and provide documents on the incident or incidents .

g. V'hy is this an unresolved safety problem?

. 8. Contention 29 deals with the failure of the design for the reactors to consider the effect of an asymmetric loading on the reactor vessel supports resulting from a postulated reactor coolant pipe rupture at specific locations. .

Questions:

a. What is the precise way in which you have addressed this problem to meet the special design at Midland ?

b. Provide names and reports of contractors, consultants and docu-ments of staff work for resolving this problem;

}

i 9 Contention 30 deals with the degradation of steam tube integrity. Babcock and Wilcox (B&W) steam generator tube integrity is listed as one of the unresolved safety problems at Midland 1 & 2. (SEH, C-4) l i

i l

i i

Questions: ,

a. Would you allow the plants to operate at full power with this defect?

b. What is the series of events in the reactor that will take place when and if the steam generator tube degradation problem manifests itself?

c. What non-safety related systems can affect or initiate the steam generator tube degradation problem? Provide documents that explain this interaction between the steam generator tube degradation problem and non-safety related systems.

d. Provide the Inost recent summary documents of the Task Force A-3, A-4, and A-5 that indicate possible methods for resolving the steam generator tube degradation problem,

c. Ilow will this unresolved safety problem affect the total power output of these nuclear plants ?

, f. Ilas there been any incident in an operating reactor which raised this as a concern? Describe it and provide documents on the incident or incidents.

K. Why is this an unresolved safety problem?

h. Provide documentation on corrosion problems at other operating, B&W plants,

l. Provide documentation to show how the type of corrosion that has occurred at the TMI-l reactor steam generator while standing idle cannot occur at Midland.

10 '. Contention 31 deals with anticipated transients without scram (ATWS).

Questions:

a. Indicate precise ways in which this problem will be handled for Midland given the unique design of this plant and its interrelationship with The Dow Chemical Co.

b. Provide draft copy of NUREG-0460, Vol. 4, and documents of staff, consultants and contractors dealing with the resolution of this problem. ,

c. Indicate all non-safety related systems that can affect ATWS.

_7_

11 Contention 32 deals with the questions of suitable safety margins for materials used for reactor vessel fabrication. Ileactor vessel Materials Tough-ness is listed as one of the unresolved safety problems in the SEII, of C-4. The questions of reactor embrittlement and the consequences of thermal shock have had increased attention by the NRC.

Questions:

a. Provide documentation on the materials that went into the con-struction of the Midland reactors as well as the dates they were built and the dates they were installed,

b. Provide reasons and documentation why Unit I which was known to be among 0 defective reactors in the country with a high copper content in a major weld was permitted to be installed even though this defect was known for some time,

c. Provide evaluations of pressure vessel integrity at other reactors and how these compare with Midland.

d. Provide any analysis of rapid cool downs and how they compare with Midland,

c. What surveillance requirements are required for pressure vessels of the B&W Midland type?

r; P. ovide documentation to show that'these surveillance requirements l

l are adequate,

g. lias there been any incident in any operating plant which raised a concern on this problem ? Describe it and provide documentation,

h. Provide documents to show why this is an unresolved safety problem.

l 12 Contention 33 addresses the necessity of reassessing the fracture toughness of the steam generator and reactor coolant pump support structure because of the i potential for lamellar tearing and low fracture toughness of these materials. This I has been identified as an unresolved safety problem in the SEit, C-4.

l l ._

1 l

I Ouestions: .

a. Would you allow the plants to operate at full power with this defect ?

b. Given the same premise, would you allow the plants to operate at full power with this defect?

c. What is the series of events in the reactors that will take place when and if the low fracture toughness and lamellar tearing problem manifests itself?

d. What non-safety related systems can affect or initiate this problem?

l Provide documents that explain this interaction between this problem and non-safety related systems, j c. Provide the most recent summary documents of the Task Force A-12 that indicate methods for trying to resolve this problem.

f. Ilow will this unresolved safety problem affect the total power output of these nuclear plants?

g. lias there been any incident in an operating reactor which raised this as a concern ? Describe it and provide documents on the incident or incidents,

h. Why is this an unresolved safety problem ?

13 Contention 34 deals with the actual and potential of snubber malfunction.

Questions:

a. Provide documents on the methodology employed to determine the r

necessity for using snubbers as component supports in the Midland project,

b. Itow does the snubber problem specifically apply to Midland ?

l c. List the specific measures that will be taken to resolve this issue.

i I d. What non-safety related systems can affect or initiate the mal-Ik function of snubbers ? Provide documents that explain this interaction

)

between the snubbers that malfunction and non-safety related systems.

f '

f. Ilow will this unresolved safety problem affect the total power i .

i output of these nuclear plants ?

?

-9

g. Itas there been any incident in an operating reactor which raised -

this as a concern ? Describe it and provide documents on the incident or incidents.

h. Why is this an unresolved safety problem? .

14 . Contention 35 deals with pressure vessel integrity and the "significant uncertainties"in the ability to detect and adequately size flaws to assure continued integrity of the reactor coolant pressure boundary and to assess margin against failure under various plant conditions for the full life of the plant.

Questions:

Consumers Power Co.

a. What is the precise way in which the/ staff has addressed this problem for the Midland design?

. Consumers Power Co.

b. In tho/ staff's opinion, has this been resolved for Midland? Provide documentation,

c. Since the accident at TMI-2, it is known that failure probability of a reactor pressure vessel must be considered as a design basis accident.

What is the course of events that will occur that can lead to such an accident?

d. What is the precise probability for such an event for Midland I & 2?

e. Provide all documents on the ability to detect and adequately size flaws in the pressure vessel.

f. Provide names of contractors, consultants and staff members who are responsible for this PR A.

g. Identify any staff members or consultants who disagree with these views. Provide documents on their views,

h. lias there been any incident in any operating plant which raised this issue asa concern ? Describe it. Provide documents to show how it was resolved.

15 Contention 3G discusses the lack of a systematic process to review dif-ferent nuclear power plant systems to determine their safety-related impact on other parts of the plant. Systems interactions is identified as an unresolved safety problem applicable to Midland I & 2 in the SER, C-4

1 L

)

N Questions:

a. Would you allow the plants to operate at full power with this defect?

I

b. Provide the most recent summary documents of the Task Force A-17 l

that indicate methods for resolving this problem.

c. Ilow will this , unresolved safety problem affect the total power output of these nticlear plants ?

d. Describe and document the incidents in operating B&W reactors where systems interaction was a concern, i e. Why is this an unresolved safety problem?

16 . Contention 37 deals with the absence of adequate design criteria for postula-tion of pipe breaks and protection thercfrom.

Questions:

a. Precisely how does this lack of design criteria for pipe breaks apply i '

to the Midland plant design?

b. Provide names and reports of all contractors and consultants who have worked on this problem. Provide summary documents on their work,

c. Provide documents of staff that worked on this problem.

d. llave any staff members or consultants disagreed with the criteria being used ? Who are they ? Describe the substance of their disagreement and provide documents on this,

e. What non-safety related systems can initiate or aggravate a pipe I

break problem ?

f. Ilow will this interaction be monitored or controlled ?

17. Contemion 38 deals with the inadequate analyses of main steamline break and the concerns regarding the capability of the equipment to survive such a break inside the containment.

3 Y l 1

___._ -_ _ _ . . _ _ . . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ - _ __ _m . _ .

I Questions:

) Ilas a PR A been made for this problem ? What is it? Provide documents.

a.

i

b. Precisely how does this apply to the Midland I & 2 design ? ,

c. Provide names of staff, contractors and consultants who have worked on this problem and their final reports for r'esolving this issue.

d. Ilas any staff member, contractor or consultant disagreed with your final resolution of this issue?

e. If so, what were the reasons for their dissent? Provide documents j on their reasons.

1

18. Contention 30 deals with the inadequacy of Appendix J to set forth clearly

{ the requirements for acceptable containment leak testing programs and for field inspectors to judge the acceptability of a licensees containment leak testing practices.

Questions:

a. What improvements have been made in Appendix J since 1978?

Provide documents that describe them.

b. Ilow does this problem specifically apply to the Midland nuclear plants ?

c. In their first summary letter on Midland, the ACRS stated that B&W reactors have a higher leakage rate than other similar type reactors.

Provide documents on the extent of this higher leakage rate as compared to other reactors,

d. What leak testing programs for the Midland nuclear plants has the staff found acceptable? Do the field inspectors agree that this is an accept-able leak testing p.rogram? Provide documents to demonstrate these facts.

I c. Ilas any staff member, field inspector, contractor or consultant disagreed as to the acceptability of the containment leak testing program?

If so, provide documentation on the nature of their dissent.

f. If no imp'rovements have been made, does Appendix J remain the l

regulatory requirement?

19. Contention 40 deals with the lack of adequate qualitication methods to satisfy the requirements for safety-related equipment established in IEEE standard i

323-1974 for nuclear generating plants. -

I

__. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ ^ _ . _

I

! a. Ilave adequate qualification methods been established to meet the f

IEEE Standard 323-1974 for safety-related equipment at the Midtsud I & 2 7

b. If the answer is yes, provide documents to substantiate your answer.

c. If the answer is no, what criteria for qualification and'what standards are being used for safety-related electrical equipm'ent ? Provide documents to substantiate your answer,

d. Itave any staff members or consultants disagreed on the adequacy of your methods or criteria for qualification of safety-related equipment? ,

Provide documents that indicate the nature of their dissent.

20. Contention 41 deals with the present practices of permitting the connpction of non-safety loads and required safety loads toClass IE power sources. l I l Questions:

a. llave any improvements been made in the manner in which non-safety loads and required safety loads and their connection to Class IE power sources since this contention was written in 1978 7

. b. If the answer is yes, provide documents to explain changes.

c. If the answer is no, explain the sequence of events that can happen i

with these types of connections that could lead to significant releases of radioactivity to the environment in the event of an accident.

d. What could be done, if anything, to intercept this c'ourse of events ?

c. Ilow does this problem specifically apply to Midland?.

f. List the specific measures that will be taken to resolve this issue.

21. Contention 42 deals with the fact that there is no assurance of adequate I overpressure protection at Midland.

Questions:

a. Describe and document all the incidents of pressure transients in k B&W reactors which have exceeded press tre temperature limits of the reactor vessels,

b. Ilow were each of these incidents inititiated ? Ilow were they resolved ?

c. Ilow does this problem specifically apply to Midland?

, d. What specific measures are being taken to solve this problem at .

Midland ?

1

j .

22 Contention 43 deals with the vulnerability of the Midland reactors to I

industrial (or other) sabotage. ,

Questions: .

a. FEMA has already indicated that the Midland area is a military target because of the Dow production and research operations here, some of which have military uses. IInve precautions for security of the plant taken this fact into consideration?

b. To what extent will the civil rights of people working in the nuclear plant, the Dow facilities and the community as a whole be violated as a means of security protection? This includes wire-tapping, surveillance, and other types of invasion df privacyl

- c. lias the public or the employees been advised as to how their civil 1

rights will be affected in order to provide security for the Midland nuclear plant ?

r23 Contention 44 deals with the need to reexamine'Ihe Dow Chemical Co.

• power systems as set forth in NUREG-0305 because of serious safety-related concerns.

Questions:

a. lies this reexamination of Dow Ch mical power systems taken place for Midland? ,-

b. If the answer is no, how do you intend to compensate for this problem at Midland? f,

c. List the speelfic measures that are being taken to solve this problem.

'1 h

24 '. Contention 45 depli with the fact that the offsite power system for the Midland facility falls to meet the requirements of General Design Criterion 17. f Questions

. < e 4 >

a. Document the specific manner in which the offsite power source will l interface with the onsite power systems at Midland.

b. Will any of this interaction depend on electrical equipment that has f been stressed by the soll settlement problem?

I

[.

a .. _ .. . . .

______e____.__._

B 4

c. What are the special testing procedures that will be undertaken prior to operation to solve this problem at Midland given the unique soll settle-

.s ment problems and .their effect of unduly and unevenly stressing underground installations which includes electrical equipment? ,

i25. Contention 4m deals with the absence of acceptable standards and criteria governing the management of heavy loads ne tr spent fuel.

Questions:

a. Ilow does this problem specifically apply to Midland?

[ b. What specific measures have been taken t<> Improve methods for i

handling this problem at' Midland since it was identified in NUREG-04107

c. Describe and document incidents where this has been a problem at 1 other operating reactors.

20. Contention 47 deals with the lack of a radionuclide/ sediment transport model which has been field verified.

! Questions:

i

n. Ilow does this problem specifically apply to Midland?

! b. Document the specific measures.that have been taken to solve this

problem at Midland.

l 27. Contention 4 8 deals with the lack of an adequate analysis by the NRC staff to design basis floods.

'i Questions:

Consumers Power Co.

a. What improvements have been made by the scaff on design liasis i

floods as it applies to Midland since it was identified as a problem by the t

ACRS and in both NUREG-0410 and the Black Fox testimeny?

b. Control of flooding at Midland depends on the integrity of a series of dams on the' Tittabawassee River system. Are there any plans for con-tinued monitoring of these dams to be assured of their integrity?

c. What will be the series of events that will take place at the Midland

nuclear plant if flooding takes place? ,

d. In the event that all the dewatering systems break down, because cf k

power failure during flood conditions, what will be the affect on the operation of the Midland nuclear plant ?

i

. ,~ .- - _ , - . - - - . - , , _ - ..

. ~ . . , _ - -. _--_,.- _

-_m -

28. Contention 49 deals with the fact that there is no assurance that the design and operation of safety-related water supplies will insure adequate operation of the systems in the event of extreme cold weather and ice build-up. .

Questions:

a, llow does this problem specifically apply to Midland ?

b. List the specific measures that are being taken to resolve this issue.

29 Contention 50 deals with the fact that occupational radiation exposure to station and contrr.ctor personnel has been increasing, leading to hiring of transient workers which can increase the risk of operator error, sabotage, etc., as the Staff has recognized in NUREG-0410 and the Black Fox testimony.

Questions:

a. What methods have been taken to reduce occupational exposure at Midland since this problem was identified in NUREG-0410 and the Black Fox testimony ?

b. Ilas any staff member or consultant disagreed with the adequacy of a these measures ?

c. Describe and document the nature of these concerns.

d. Are there plans to use transient workers at Midland at this time?

e. If so, what kinds of criteria for qualifications of these workers will be used ?

30 Contention 51 deals with the fact that there is no assurance that existing geometry can adequately satisfy the functional design criteria for the behavior of fuel element assemblies during accident conditions.

Questions:

a. Ilow does this problem specifically apply to the Midland nuclear plant ?

b. List and document the specific measures that have been taken to resolve this issue.

N.B. Due to a typographical error in the numbering of my contentions, numbers 16 on are incorrect. I have renumbered them correctly for these interrog-  !

4 atories.

4

-w - ,,..~r4 , - ..-.a - - -= - - - - ny , _ , , _ _ ,

-lG-

31. Contention 52 deals with the unreliable performance of diesel generators.

[ Questions:

Describe and' document the incidents of failures in diesel generators a.

at operating reactors.

l

b. Provide documentation on the causes of these failures.

c. Ilow have these problems been resolved ?

d. Will the serious questions raised about the integrity of the diesel generator building itself further exacerbate the problems with the per-formance of the diesel generators ? Provide documentation for the answer.

32. Contention 53 deals with the lack of adequate safety and environmental criteria for replacement of major pieces of equipment and of total decommissioning.

a. What mode is now planned for decommissioning these plants ?

b. If mothballing is the choice of decommission, who will pay for the guards, security, surveillance, monitoring and maintenance that the plants will require?

c. If entombing in concrete is planned, have local and state oIIicials been notified that because of the long half-life of nickel-59, which has a half-life of 80,000 years,means that the structures will remain there until they dis-f.

l integrate and will have to be monitored permanently and with no tax base to i pay for this ?

d. Ilow long can concrete structures aircady stressed by the soil settle-ment problems be expected to last?

e. If dismantling will be done under water, where will the highly radio-active parts be stored?

f. The costs of these options will vary greatly. Ilow have they been I

onsideregl in the cost bencIlt analysis ?In what way[ What are the guidelines Forcost, f g. What environmental and safety criteria have been established for the

,s possible replacement of the steam generators or other major parts has occurred at other nuclear plants ?

p I

i

1

33. Contention 54 deals with the possibility of damage to safety systems due I to turbine missiles.

9 Questions:  ;

a. The ACRS stated that this plant is unusually susceptible to the turbine.

missile problem. What additional safeguards will be provided to avoid this problem ?

b. Describe and document the incidents of turbine missile problems in ,

operating reactors.

34. Contention 55 deals with questions of adequacy of seismic design.

Questions: j

a. Will the most recent seismic criteria be implemented at the Slidiand ,

site for all the buildings when the plant begins operation ? f

b. Which buildings will not be included?

35. 'Codntion 56 deals with the fact that Slidland is not designed to accom-modate a totalloss of AC power.

W

. Questions: i

n. What back-up systems have been provided for loss of AC power? ,

j Provide documentation.

+

b. liow will loss of AC power affect the operation of this plant? .

I

c. Describe and document incidents of the loss of AC power and their effects f at other operating reactors.

36. Contention 57 deals with the fact that the electrical system will not function ,

adequately under accident and/or fire conditions.

)

l Questions:

a. What fire tests have been done since those made in September and .

October,1978 ? Document.  ;

I b. What improvements have been made in electrical wiring equipment since the September, October,1978 fire tests ? [

f

c. Ilow will the environmental qualifications be met for operating under ,

accident conditions for the electrical equipment in the following critical  !

t safety systems: Containment spray, core flood, emergency core cooling, ^~

auxiliary feedwater, nuclear service water, containment isolation,' decay. i heat removal and containment cooling.L

Addendum #1 l

Y Contention 13 deals with the financial qualifications of Consumers Power ,

I Co. to operate the plant. While a recent ruling by the NHC states that reviewing financial qualifications of utilities will no longer be required at licensing procedures, the fact is that consideration of Consumers Power Co.'s financial plight as the result of the construction of these plants taints all of their decisions as well as those of the staff.

For example, Inspector Joseph Kane said that from the standpoint of public safety alone, that removal and replacement would be a better solution to the diesel generator building, but since costs and impact on schedule were important than

- that is not the best option (p 4209-10).

Similarly, the most recent letter to Cook on afay 25, 1982, does away with all i the disclosures that the soil settlement hearings have yet to provide on what are adequate remedial measures for the cracked and sinking buildings. This letter

• surely reflects a total concession to Consumers' financial plight and schedule with-out regard for public safety, f Consumers Power Co. has been placed on Credit Watch by Standard and Poors.

This ruling on not reviewing financial quallfications is being appealed in court.

o h

PROOF OF SERVICE I certify that on June 18, 1982, I mailed copies of the foregoing &

Interrogatories of Intervenor Mary P. Sinclair to the Nuclear Regulatory Commission Docketing and Services Section for filing, and that on the same day I mailed copies of said Interrogatories to the persons shown on the attached Service List below, all by first class mail, postage prepaid.

• M' s YY Mary P. Sin (lair, Intervenor Charles Bechhoefer, Esq. Michael I. Miller, Esq.

Atomic Safety & Licensing Board Ronald G. Zamarin, Esq.

U.S. Nuclear Regulatory Commission Alan S. Farnell, Esq.

Washington, D.C. 20555 Isham, Lincoln & Beale Suite 4200 Mr. Ralph S. Decker 1 First National Plaza Atomic Safety & Licensing Board Chicago, Illinois 60603 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Wendell Marshall Route 10 Dr. Frederick P. Cowan Midland, MI 48640 Apt. B-125 6125 N. Verde Trail Ms. Barbara Stamiris Boca Raton, Florida 33433 5795 N. River Freeland, MI 48623 Jerry liarbour, Esq.

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Services Section

.