ML20063M278

Interrogatories & Document Requests Re Contentions on Cost/Benefit,Qa,Effects of Dewatering & Independent Design Audit.Related Correspondence

ML20063M278
Person / Time
Site:	Midland
Issue date:	08/30/1982
From:	Stamiris B STAMIRIS, B.
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
ISSUANCES-OL, NUDOCS 8209100199
Download: ML20063M278 (7)

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CO gte, TEM 00cKETED USHRC g p -3 50 52 f0C IIG SUN ERANCH U. S. Nuclear Regulatory Commission In the Matter of Docket Nos.

CPC Midland Plant 329-OL Units 1 & 2 330-OL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD STAMIRIS INTERROGATORIES AND DOCUSENT REQUESTS TO CONSUMERS POWER COMPANY 8/30/82 (Documents are meant to include studies, models, notes reports, working papers, or other written records of communication of CPC/Bechtel or other plant employees, or outside consultants, experts, agencies, or companies contacted on the subject.

Provide names and address of authors or sources for documnts provided.)

COST / BENEFIT: CONTENTION'Ib and 1 c

1. Explain in detail the " prompt removal / dismantlement decommissioning plan for i

l Midland. Describe any special procedures or equipment which will be used to 1

protect the workers and the environment from radiation. Include estimates of length of time to complete the job and the condition of the plant site upon comple tion.

2. Provide documents which form the basis for the decommissioning plan described in 1 above.

3. To what extent if any will Midland's decommissioning be affected by soils remedial measures such as underpinning supports, dewatering equipment, or others?

4. Explain in detail how the $235 million (1984 dollars) decommissioning estimate was derived for Midland. Include breakdown of costs for the component steps described. 8209100199 820830 l

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5. What does CPC calculate Midland decommissioning costs to be as a % of its projected lifetime production cost savings? Explain this calculation.

6. To what extent is the Midland decommissioning financing, and collection plan based upon the Big Rock and Palisades models? Explain any differences if they exist.

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7. Explain in detail the method CPC proposes to finance and collect Midland decom-missioning costs until the year 2000 Include explanations of inflation allow-a::ces, interim use of money collected by CPC, liquidity of these assets, and method of guaranteeing availability of money when needed for decommissioning.

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8. Provide documents which form the basis for the financing and collection plan described in q. 7.

9. If Big Rock and Palisades' combined $111 million decommissioning cost in 1980 dollars (MP 6/81-50M, 62-51912 CPC decommissioning pamphlet) results in the collection of $526 million (exhibit A/S-1, MPSC case 6150) by the year 2000, what amount is estimated to be collected for Midland by the year 2000 according to your plan? Explain these calculations.

10. Does- the $235 million estimate represent the full amoun't to be co'11ected accord-ing to your decommissioning plan described in' the last part of your pamphlet cited 'ab' ave , if not , explain why it shouldn' t.

11. a) According to current laws, explain the federal income tax rate and manner by which CPC will be taxed for' decommissioning money collected early. b) What are these tax amounts projected to total through the year 2000 on the decom-1 missioning amounts projected in q. 9? c) Will money be collected from rate-payers above and beyond amounts estimated in q. 9 to support these CPC tax expenditure s? If so explain and estimate these added ratepayer contributions.

12. What was the projected life expectancy for Midland units 1 & 2 respectively.

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13. Explain in detail how the 66% lifetine capacity factor is derived for Midland.

Does this estimate take into account any expected differences between Unit 1 & Unit 2 operating capacity, pressure, or temperature limitations due to the defective beltline weld in Unit I? Explain these differences if they exist.

14. Explain in detail the apparant diacrepancy in the EFPY estimates for Unit I operation appearing on pages 5-19 and C-10 of the SER?

15. What is the EFPY estimate you are currently using for Unit I? Explain any e differences between this estimate and those submitted for the SER.

16. Explain in detail the apparant discrepencies between flux properties on SER

p. 5-19 and FSAR section 5.3.1.6.1.3 fcr surveillance samples and actual belt-line material samples. Provide the calculations and other documents which 4

form the basis of this explanation.

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17. Provide documents relating to reduced operating capacity or life expectancy of Unit I.

18. Explain any contingency economic plans for shorter life expectancy of Unit I in terms of electrical production and related costs to ratepayers, and in terms of inability to produce steam f or Dow according to contractual obli6ations.

what will happen if Unit I must shut down after 10 years?

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19. Has CPC considered performing' preventative rather than remedial thermal an-nealing or other corrective measures for defective reactor welds prior to plant A

i operation to avoid the safety and economic costs associated with post opera-

tive radiation? If yes , explain. If not why not.

2d. Explain in detail the nethal of performance and frequency of inspections planned by the B & W Owners Group Surveillance program for monitoring reactor weld

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' fracture toughness and other weld conditions? How does this program protect

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against the possiblity of sudden failure?

s 21. Provide documentation for B & W program above.

22. Explain in detail when and how CPC first became aware' of the defective weld material--or the questionable quality of weld materi'al in heir reactors.

23. Provide all documents and correspondence sent and received r,egarding the reac-

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tor vessel weld properties prior to the installati~on of the reactors at Midland.

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24. When were the Unit I and Unit II reactors installed (give month and year)?

l 25 Were Unit I and Unit R reactors ever switched from their originally planned f , 's containments? If yes, explain why.

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Did anyzconfusion tification of Unit I and Unit II reactors ever occur.

If so explain when' and .how this occurred, what occurred and how it was resolved.

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QUALhTY7 ASSURANCE: SINCLAIR CONTENTION 6 j t

1. If a plant workeb(has a safety concern, what is the chain of re' porting open I

to him? Describe the workings of this, internal reporting system.

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2. In' reporting a safety concern to the NRC would a plant employee be free to T

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provide the NRC with back up site work documentation without the permission t

l of Bechtel or CPC superiors?- -

3. If the answer to q. 2 is no, how does this affect the z necessary free flow of

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s information to the NRC7

4. Does CPC, Bechtel or any subcontractor encourage workers with safety related

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complaints to keep 'the problems "in house" as opp' osed to going to the NRC?

Explain. ,

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5. If a plant worker has pursued the internal QA reporting system, and gone to the NRC, but still feels his safety concerns have not been properly addressed, i is he free to go to the public with .those concerns as an employee of CPC, or Bechtel--as an ex-employee of CPC or Bechtel? If not, explain why.

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6. What records are kept of worker safety related cosiplaints, reports of violations l of QA procedures allegations, or use of internal reporting system described

. in q. 1 above? (I am interested in the incidence of reporting, not the reports themselves.)

j 7. Provide a list of former plant employee names and forwarding addresses who lef t in 1981 or 1982 and had reported a complaint about improper QA/QC proce-4 dures, made use of the internal reporting system described in q.1, or filed an allegation.

8. How long has the MPQAD internal allegation form been in existance? Is this form made available to all plant workers--how? Please provide a copy.

EFFECTS OF DEWATERING: CONTENTION 3

1. Explain in detail the prolonged (40 year) effect of permanent dewatering upon i

the various subsoil layers and underlying groundwater.

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! In answering this question:

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a. Include explanations of the potential 40 year effects of removal of fines from soil layers, and how this is monitored.

b. Discuss the interrelated effects of one soil layer upon another.

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! c. Explain the potential 40 year effects of groundwater movement from lower to upper levels during dewatering.

,d. Discuss the possible weakening of the " essentially impervious" intermediate I clay layer separating the perched ground w:1erfr(m ehe underly.confinea aquifiers.

under artesian pressure. In so doing consider all possible combined effecte of a 40 year dewatering system.

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e. . Discuss the possible af ter-effects of 40 year dewatering on groundwater movement between upper and lower levels and upon interrelated soil layers,

,' possibly weakened or changed by dewatering.

2. What studies or other data exist concerning prolonged (40 year) effects of de-watering upon subsoils and groundwater relationships?

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! 3. Provide documents upon which answers to q. I are based.

i l 4 '. Did the assurances provided to the NRC for the FEs analysis regarding the effects j

of possible radioactive release to groundwater following a core-melt accident take into account the effects of prolonged dewatering on subsoil and ground-j water conditions? If yes, explain. If not, why not.

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INDEPENDENT DESIGN AUDIT: CONTENTION 4

1. How much time , money, and ef fort is involved in the Bechtel Audit of Bechtel construction and design announced at the 5/20/82 ACRS meeting? What is the purpose and justification for this self-audit? Who will pay for it?

2. What plans have been made toward an independent design and construction audit I

j at Midland?

3. What contacts have been established thus far with various firms concerning the design and construction audit?

i 4 Provide names and addresses of all firms considered for performing the indepen-dent design and construction audit.

5. What criteria are being used to select the firm for the independent design and construction audit--what are the job requirements, t 6. Explain in detail the job description, scope of the audit, and other descrip-tions of what exactly is to be done during this audit.

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7. Provide all docunents and correspondence exchanged thus far between CPC and prospective companies or individuals regarding the design and construction audit.

8 Explain to what extent the audit scope, depth, or nothodology will be controlled by CPC.

9. Explain CPC's proposed plan of action for responding to audit findings.

10 When does CPC exrect the selection of this audit firm to be decided?

11. When does CPC expect the audit to begin? To be concluded?

12. How is it possible for an outside auditor to independently assess the struc-tural adequacy of the containment structures and other structures (due to the missi g reinforcing bars) without relying upon CPC's statements and analysis of internal wall conditions?

ADDITIONAL 9 The Midland Daily News (8/26/82)QA INIEFROCATORIES reported a Suit against Bechtel by Ronald Corto charging job loss due to QA reporting. Why were coreholes being drilled into structures--name all structures into which coreholes were drilled? Provide documents related to QA procedures for this drilling and to the Carto allega-tions.

l Respectifully Submitted, Barbara Stamiris cc. ASLB members l

W. Pa ton , NRC NRC Secretary l .

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