ML20054H757
| ML20054H757 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/18/1982 |
| From: | Stamiris B STAMIRIS, B. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8206240398 | |
| Download: ML20054H757 (8) | |
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U.S. Nuclear Regulatory Commission Docket Nos.
In'the Matter of 50-329 OL CPCo. Midland Plant 50-330 OL g
Units 1 & 2
- a BEFORE THE ATOMIC SAFETY & LICENSING BOARD OPERATORS LICENSE CONTENTIONS OF IN1ERVEN0R STAMIRIS 6/18/82 I am an accepted intervenor.in the 0.L. proceeding regarding soils related matters. On March 28, 1982 I sought to expand my 0.L. participation to other matters for the good cause mentioned therein. In subsequent conference calls of OM-OL parties, I was directed to submit contentions for O.L. consideration by
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June 21,1982.
I contend that:
Bechtel's design audit (discussed by J. Cook at 5/20/82 ACRS meeting) consti-1.
tutes self-monitoring which cannot provide reasonable assurance of safety and conservatism in the plants implemented design, and should not be relied upon for such assurance.
The NRC has allowed significant departures from original design criteria on 2.
the basis of financial hardship to the applicant, as seen int 9
a.
Soils remedial measures b.
Reactor pressure vessel remedial support system c.
Reactor vessel welds These departures do not provide adequate margins of ' safety for plant operation p
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2 and place undue consideration on financial hardship as opposed to safety con-siderations.
3.
The NRC's economic analysis presented in the February 1982 DES misrepresents facts to the public in an attempt to justify Consumer's financial investment because it fails to consider the $3.39 billion construction costs although a.
these costs will be borne by ratepayers I
b.
estimates only $235 million for deco =missioning when Consumer's estimated about $500 million to decommission Big Rock and Palisades in 1980 estimates about a 36 year lifespan, despite the shorter life expect-c.
ancy of unit one due to the defective weld (p. C-10 SER)*
d.
uses Consumer's estimated annual growth rate of 3.2% while recent 5
studies by Michigan's Attorney General project a 1-1\\% longterm growth rate in Michigan.
u And such a faulty analysis cannot be allowed to stand unchallenged by a rule which prevents one party (ie intervenors) from considering financial issues, when another party (the NRC) has already raised thor.e issues.
r 4.
The NRC has not enforced its own 10 CFR 50 Appendix B regulations adequately, and this pattern of NRC leniance has aggravated the Applicants Quality Assur-ance problems over the years, resulting in an unsafe nuclear plant.
5.
The NRC practice of accepting significant design changes to the PSAR/ESAR, af ter the construction in question has been completed, has allowed much of E
the Midland plant to be built without pre-set design requirements, resulting in a plant considerably less safe than the approved construction permit design.
- all page nos, refer to 5/82 SER, but do not exclude other possible uncited EH references.
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6.
The Applicant's frequent failures to follow design requirements, as reflected
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f in 55e construction deficiency reports and I&E inspection reports, cannot f
i provide assurance that inaccessible or unverified plant areas have been built I
as designed to meet safety standards.
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E 7.
Utility /NRC " proceed at your own risk" agreements as practiced at Midland are E
E contrary to Atomic Energy Act mandates, because financial " sunk costs" are h
l considered in the end by the NRC, rather than basing ultimate decisions on
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I safety alone as implied.
These end resylts negate the element of financial
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I risk to the utility, and instead risk public health and safety by cocpromising I
i original safety standards. Such weighing of financial investments against
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safety standards necessitates value judgements by the NRC that go beyond the
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f authority vested in them to protect public health and safety only.
[i 8.
The NRC/CPC reporting system intended to allow plant workers to raise concerns
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l or criticis:s about inadequate workmanship or practices is ineffective, and i
therefore plant safety issues go unresolved.
3 i
It is improper for Bechtel workers to have to sign a promise not to divulge 9.
information about the nuclear plant to the public as an initial job condition, h
I because it tends to intimidate workers from raising safety concerns when E
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frustrated with internal reporting system limitations or repurcussions.
[r 10 The NRC has placed undue consideration upon Consumer's financial and schedul-f L
ing needs resulting in significant reductions to public health and safety
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standards wnich were wholly preventable.
11.
Consumer's installation of the Unit I reactor subsequent to the identification f
5 of its seriously defective condition (weld WF-70), the failure to follow proper E
i weld testing procedures, and the failure to include this "most limiting" WF-70 fI material in surveillance measurements for reactor welds, represents a pattern i
t of careless disregard of safety principles which cannot assure safety or trust-l worthiness and should not be accepted by the NRC (p. 5-17 to 5-24).
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U 12.
The NRC practice of allowing Consumr's exemptions from minimum safety require-n:
ments because of economic hardship cannot be accepted on the basis of Consumer's E
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...r commitment to future monitoring (ISI programs), because Consumer's has not ET proved themselves worthy of this trust. Such exemptions include j
n a.
reactor vessel weld conditions (p. 5-14 5-25)
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b.
relief from code testing requirements on safety pumps and valves E
(p. 3-35) g postulated high energy pipe break criteria (p. 3-13) i g
c.
and these exemption / inspection arrangements. jeopardize,public safety.
13.
Consumer's failed to apply required single failure criteria throughout' the E#
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plant design and construction as seen in t-Small break / Reactor Coolant Pipe Interaction (79-03)
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a.
tj';.1 b.
Letdown Cooler Supports (30-01)
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IELBA restraint design (80-03)
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CCM deficiency (80-06)
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E NSSS: Seismic /LOCA analysis (80-07)
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Auxilliary Building Seismic Analysis (81-02) e C.
Shear reinforcement lacking in containment (81-05) y g.
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Reactor Cavity Cooling deficiency (81-06)
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AW Valve System (82-04) and Header design issues and reiated AW bc (82-06)
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resulting in a nuclear plant unlikely to withstand design basis accident con-E
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14.
The 1978 identification of extensive deficiencies in the procurement system r
h for' seismic and environmental qualification of equipment (78-10) should have prevented the following equipment qualification procurement errors:
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ITE Could, Class 1E equipment (81-04), Gould starters (1979)
~ll a.
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b.
Long electrical cables (81-07)
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c6 Inadequate station batteries (1979)
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S d;'. T3 mit';rque termNnL ctrijp (611011
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g MSIV Equipment (82-01) g e.
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A W Power Supplies (82-03) f e
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Wiring insulation deficiencies (82-02) b These equipment qualification deficiencies combine with design deficiencies h
6f contention 13 to result in a plant unlikely to withstand design basis acci-
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dent conditions, y
15.
He Bechtel errors in Seismic calculations, diso. overed as a result of reactor vessel support modification inv6tions, had extensive generic implications which should have precluded further plant construction involving siesonic h
5 parameters until the safety significance of these errors were resolved.
16.0 The Oct 23,12981 CPC response to the 1978 identification of the accident con-fi dition unavailability of pressurizer heaters during plant hot shutdown does E
not provide the margin of safety required in original design documents.
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17.
Le NRC states in the SER that "because the design of a majority of the Seis-b 5
mic Category I Structures was completed before 1973" their load combinations IE n:
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' do not meet current' NRC requirements (p. 3-21). Yet new design information%,"r y
regarding Seismic /10C1 design criteria was submitted by Bechtel in 1981 as i
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li reflected in the new design responsibility matrix. Therefore a waiver of IE E
current NRC Seismic requirements for concrete safety structures is not war-k ranted for these reasons and does not provide adequate safety for design basis
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accidents.
18.
De containment structures were designed for' saturated plant fill soil condi-i tions. He permanent dewatering system changes these conditions and the resul-
[5 tant soil-structural interaction effects, thereby reducing the ability of the
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containment structures to perform thei'r intended safety function under design h
ff basis conditions.
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19.
he containment structures are subject to so many design and construction m
deficiencies that taken together they render the reactor containment system gq
6 ye5 incapable of performing its intended safety function. These deficiencies include e
the effects of inadequate loading combinations (contention 17) and a.
NSSS. Seismic /LOCA deficiencies b.
the effects of dewatering (contention 18) c.
tendon sheath omissions (1977) d.
post-tensioning errors (1979)
RVP potential bolt failure stresses (further missle effects)
,s e.
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f.
RVP support modification effects
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$e lack of adebuate shear reinforcement (81-05), cooling system deficiencies d
g.
(79-07, 81- )
hs failure to postulate containment penetration pipe break effects Ej rs x--
1.
1974 Unit II fire effects (74-01):
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- 1) bulge in containment liner g
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- 2) bulge in blade steel I;
- 3) protective coating damage a:-
- 4) possible. concrete damage ar j
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- 5) possible damage to horizontal rebar at floor 5
20 The extensive problems concerning RFV anchor bolts and IAQT high tension bolt-B ing in support of safety systems represent serious safety degradations could 9
have been prevented by proper procurement qualifications and QA inspections of supplied materials, f..
21.
The remedial reactor vessel support system intended to compensate for failed j
anchor bolts
- does not meet original safety standards and is unlikely to provide i
adequate protection against reactor internernal forces under design basis S
i accident conditions.
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- 1 22.
The defective bolting in support of reactor coolant pumps results in a seriously
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t degraded safety system, which taken in' conjunction with other cooling system
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7 weaknesses results in an unreliable safety system under design basis accident conditions.
23 Welding on class 1 and class 2 piping does not meet current safety standards (p. 5-12 to 5-14).
24 Deficient welding conditions and practices have not been adequately addressed by QA/QC supervisors upon the request of,QC personnel, and unsafe welding conditions remain uncorrected.
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25.
The absence of design features f,gggiation exposure control during plant 3
decommissioning and the absence of a specified decomissioning plan constitute's i$i G
a public health and safety hazard.
5 EL 26.
Numerous design and construction deficiencies' combine to make the decay heat g
removal system unreliable for perforr ng its intended safety function.
These.
b EE deficiencies include
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a.
B&W system sensitivity issues Ifd
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AEW System deficiencies' (82-03, 04, 06)*and piping not all to C. I
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~ ':2 standards;... ;a.
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.y c.
Containment -coolers water supplies (79-02)
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d.
Reactor coolant pump defects (79-03, 80-09)
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e.
CCW system deficiencies (80-06)
GE f.
Required manual valve operation for emergency boration and auxil-
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W 11ary pressure spray, and location of manual DHR valves (p. 5-32)
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Boration capabilities (79-11) l
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Unusual corrosion in BWST stainless steel piping (1979) and generic
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S' oil settlement effects on reliability of BWST, SWS, piping, and' E4
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shared UHS i==[
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Reactor Cavity Cooling System deficiencies (79-07, 81-06)
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- All year numbers refer to 55e reports, not to exclude other possible refer-E=f-ences.
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Lep 27.
Despite the extensive deficiencies and reliability questions associated with i(
the DGB onsite power supply due to soil settlement problems, the combined i
t offsite/onsite blackout power failure accident is not a postulated design I
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basis event for safe shutdown and this represents a serious unconsidered threat
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to public health and safety, k
i The AW system and a turbine driven pump are not designed for and cannot be relied upon (see contention 26) to provide sufficient cooling water for this
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essential safety function from tne non category I condensate tanks.(p. C-17).
28 An. extensive pattern of electrical errors and deficiencies cannot provide
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assurance that these and other electrical systems will function properly Il bE to perform their essential safety function.
These include:
I' a.
NSSS component wiring (80-02) in:
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ECCAS wiring (80-03)
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c.
MSIV actuators (82-01)
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d.
AW valve power supplies (82-03)
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improperly qualified electrical equipment (contention' 14) e.
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cable spreader room designed 50% too small 5
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ongoing electrical problems (80-81 SALE) 5 29.
Pressurized thermal shock probability, and over pressurization as discussed in r:z
[ Sit I.N. 82-17 create a hazard aggravated by deficiencies in other safety systems i,i, 5":
which has not been adequately addressed in an integrated fashion to assure j.5 that public safety will be protected in the event of an accident.
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Respectfully Submitted, M J % div El
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Barbara Stamiris
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5795 N. River Road i{._
Freeland, MI 48623 nti tz: :
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cc: ASLB Judges
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W. Paton, NRC M. Miller, CPC E" 5"5
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Secretary, NRC T. Devine, CAP
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