ML20071M545

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Response to 820830 Interrogatories & Document Requests. Related Correspondence
ML20071M545
Person / Time
Site: Midland
Issue date: 09/18/1982
From: Stamiris B
STAMIRIS, B.
To:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
ISSUANCES-OL, NUDOCS 8209270167
Download: ML20071M545 (8)


Text

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'82 SEP 24 Pi 52 CFFICE 0 SECPE7p,:

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U. S. Nuclear Regulatory Comission H:ANCH Docket Nos.

In the Matter of 329-OL CPC Midland Plant 330-OL Units 1 & 2 BEFORE "INE ATOMIC SAFETY AND LICENSING BOARD STAMIRIS RESPONSE TO CPC 8/30/82 INTERROGATORIES AND DocuM&lX REQue2TS 9/18/82 CONTENTION 1: COST / BENEFIT ANALYSIS lb: Decommissioning costs Q1a. Midland's decommissioning' estimate of $235 million in 1982 dollars repre-sents $95 thousand/MW while Big Rock and Palisades $111 decommissioning esti-mate in 1980 dollars is $159 thousand/MW (CPC dacommissioning pamphlet MP 6/81-50M).

CFC In Applicant / Staff exhibit 1 of MPSC Case U-6041,' estimates that $526 million will be needed to decommission Big Rock and Palisades at the end of the'r full life expectancy. This represents about 200% of their original construction costs. Yet Midland's decommissioning is represented as 7% of its original construction costs.

If inflation allowances are taken into account in computing cost-savings in the cost / benefit analysis to the public, they should be similarly considered in computing actual decommissioning costs.

Based upon the 1973 Elk River decommissioning experience, even in comple-tion year dollars, approximately 28% of original construction costs thould be allowed for decommissioning (table 1 attached).

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2 The documents upon which I have based these statements are: 1980 news-paper articles; CPC 1981 decommissioning pamphlet; MPSC case U-6150 9/15/80 testinony of Peter Skinner (table 1) : and 6/11/79 petition for generic pro-ceeding, p. 5 (attached per document request 3).

Q1b, c, di 2 and 3 I will I have no witnesses at this time for any of my contentions.

supplenent these responses accordingly if I am able to secure any witnesces.

Q4 See response to la, to NRC interrogatory la; and Stamiris 8/24/82 plead-ing.

CONTENTION 2: QA/QC INTERNAL REFORTING SYSTEMS QS and le The attached 8/26/82 and 9/7/82 newspaper accounts exemplify two instances I do

  • of job loss resulting from QA/QC reporting with Bechtel at Midland.

not know the addresses, dates of disciplinary action, or have information beyond that given in the articles regarding suits by Ronald Certo and Leo Krashfeski regarding drilling of core holes into reinforcing bar contrary to QC procedures.

I am personally aware of two other individuals, former plant employees, According to their who assert they lost their jobs due to QA/QC reporting.

wishes, I will not reveal their identity. I do not presently intend to call I will promptly provide them as witnesses, but should this situation change.

the information sought in tM.s interrogatory . ,

No other person participated in the preparation of the answers to these Q6 iaterrogatories.

CONTENTION Ici DEFECTIVE BELTLINE WEID UNIT I Q1a Ihe EFPY estimates for the Unit I reactof~ are inconsistant within' the The life expectancy duration of Unit I depends on the SER ( P 6'l'ly C-10 ) .

, . 3 feasibility of post-operation thermal annealing which is an untried experimental procedure (8/14/82 Board memo, p.23 ). In-service surveillance of reactor weld conditions as described in the SER ( p 5-11 ) can not provide adequate safety assurances or life expectancy estimates accounting for the possibility of sudden brittle fracture armi Basedekas concerns (4 29 82 meno to Palladino).

Docunent Request 1 I have no documents beyond the aforementioned SER and hearing records on the subject of the Unit I estimated lifespan. I have not personally esti-mated the lifespan of Unit I. The only calculations I have performed in this regard were an attempt (as explained at the August 13, 1982 prehearing con-ference) to determine what the NRC Staff's underlying lifespan estimates were for Units I and II.

CONTENTION 6: DEWATERING EFFECTS Q1a and Document Request 3 At this tine I do not have any documentary support or background informa-tion regarding my contention that permanent dewatering effects on ground water relationships over a period of decades, has not been adequately assessed.

CONTENTION 8: INDEFENDENT DESIGN AtDIT Qal and Document Request 3 Shortly after the August 12-14, 1962 prehearing conference, I obtained a copy of the Houston Light and Power Co. , South Texas Project, Docket Nos.

50-498, 50-499 " Order to Show Cause" regarding the i tpendent audit sought by the NRC order. Upon reviewing this document, it appears that the requested S uth Texas independent audit was directed more to the QA/QC pro 6 ram and imple-mentation than to an independent design and construction audit as sought by my contention.

s .

Document Request 2: b and c At this time I do not have any exhibits or documents for the purpose of cross examination of witnesses prepared.

Respectfully Submitted, Barbara Stamiris 5795 North River Road Freeland, MI 48623 cc. ASLB members W. Paton, NRC M. Miller, CPC Secretary, NRC

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Ostgtnal Disma.itlement y .bitcation Reactor Reactor Age At Psc111ty Coat (I

Am 3 at o r a r. t a a !

Date Type Size DacoustestoninR Coots (including luc) Factitty Coat Q(A .

( od. - i .. o ..v em be r PWR  !!60 MWe 40 yta. et 80% }_76.87-31.30 million N.C.

> 1976 Q r (P. 3.3) Utilization ($s975) (P. 24, 25)

(2p (P. 19)

. 550 HWe Same 18% less than above N.G.

(P. 21) -

BWR 1878 MWe Same _$11.16-31.50 militan h (P. 21) ($1975) (P. 24-25) -

550 MWe Some 20% less than above N. C . 7 (P. 28) ---

1

!!UFCCf".-0130 June 1979 PWR 1875 MWe 40 yrs. 752 _$37.0-42.I m:111on 8 (P.2-6) Full Pawcr ($1978) (r. 2-12)

(P. 7-16)

NUREP/CR-0672 June 1980 8WR 1155 MWe 30 yra, at $4).55I-66.671 stilton

  • N.C.

(P. C-1) Full Pouer ($1978)(P.2-11) mer -

(P. E-2) r Finst Program Rev. Nov. PWR 22.5 HWe 6 yrs. at $6.I48 million $12.1 altiton 281 Report AEC-ELK 1974 (P.3) (P. 3) less than (mixed $1972- ($1961) (Letter River Reactor 50% full 1973) (P. 40) Clanberman-Sommer, power (P. I 1976) and 3) and (P. 7-16 NUREC/CR-0130) _

Skinner Estimate April 7 PWR  !!60 MWe 30 yrs, at $249 million $947/Kwe (1977) 28%

Letter. (Skinner 1978 (North- 551 capacity - ($1977) (Based to All Parties, east factor on Elk River root etc. April 7 Location) percentage above) 1976)

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'11'( /9 !~cTIT/0r1 m t.;mrreric. rvcceay thAS C. U-fo /SD . '

Gl4 Authority, Oct. 25, 1977), Ordsr at 45. .

c.

Decommissioning costs are the subject of widely varying estimates as to the substantial sums of money involved.

(1) For totally dismantling 700 to 900 E' f acilities, and in present value terms, utility company escinates vary from $50 to S100 million; for federal agencies the estimates are much lover, $35 to $50 million; and still lower are the Atomic Industrial Forum's estimates of

" Costs and Financing of Reactor Decomissioning:

$27 to $31 million.

Some Considerations," Vincent L. Schwant, Staff, California Enargy Commission in NUREG/CP-0003, Conference Proceedings for State _

Poliev, Sept. 18-30, i

Workshops for Review of the NRC Deco-issioning 1978 at 294, Office of Standards Development, Of fice of State Programs, ,

i U.S. NRC (on file with the MPSC) .

(2) Michigan utiliti2s have presented conflicting estimates of the relative costs of decommissioning.

(A) The Consumers Power Company projects decommissioning / dismantling costs for the Palisades and Big Rock. facilities at more than 200% of the cost of the facilities, or $526 million in funds.

collected. Stipulation between Staf f and Consumers Power Company, This represents a revenue U-6041 (filed as Exhibit A/S-1) .

requirement of approximately $1 billion to be collected from ratepayers over the remaining 20-30 year life of the facilities, approximately $460 million of which would be paid to the U.S.

~

The Government in income taxes on the increaseil revenues.

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Consumers Power Company has reported to the NRC that duommission-l

e ,.uta for the Midland f acility will equal only 5% of the plant I

capital cost.

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v Midland Daily New Mediand, Mechigan

, e Thursday, August 24.1982 Page 3 Worker files n-plant suit Hy IDRIE $H ANE requested a transfer from second shift to Consumers would not be required to fde Dasly News staff writer first shift. He was told he should resign a report with the NRC an the matter.

A jnurneyman pipefitter emgloyed at from the second shift positJon and report Foster said the Midland nuclear plant is susng for work on the first shift, winkh he dad, Cook informeJ ham of thc procedure Dechtel Power Corp. and his union, accordmg to the complemt. violat&on sometime last year, Foster claiming he was densed work for a teme Corte later became involved in a said.

s in 1980 and list because he reported series of shift change disputes,la which quahty control ventalians to Consumers he attempted to move from a second CORTO TOOK 36ck leave begmning Power Co. and the Nuclear Regulatory shift position to a first positaon. He sometime in January 1980 and was

( Com mhsmn reported to a first shift positson twice, advised later that month that he had in a compt.sintIsled in bladland County but was not allowed to work either time, been laid off. After recovermg. be tried Circuit Court on Aug. 3. Ronald Corto of secording to the connplamt- to be re-hired at the plant *oser a period Sanford alleges he was told by his Taking the case to union business of many months and was contmucutly umon's business agent that "Bechtel agent Robert Ducharme, he was given a advised by the local union that no work was'rcluung to allow plaintiff (Cortal to referral to begin work with Babcock & m as a val:$bte," the complamt states work at the site because he was a trouble Wilcox, another contractos at the site. He then was told by Ducharme that malier .and had made complatnis to After r,tartmg work for Babcock & Bechtel was refusing to allow Corto to Consumers Power and/or the Nuclear Wilcos. he was told by Bechtel personnel work at the site because he was a Regulatory Commission." that he was still employed by that troublemaker and had made reports to The union is local 45 of the United corporation and that he would be fired the NRC and Consumers, the complamt Association of Journeymen and A p. for not reporting to his former second states.

prentices of the Plumbing and Pipe. shift posstson. It is not clear from the complaint when fittmg Industry of the United States and Corto's sich leave ended or when i Canaos. AFL-CIO. based la Sag naw. RETURNING TO Ducharme, Corto's Ducharme allegedly made the com.

l The local and Bechtel are named as complaint states he was told he would ments about Bechtel. O'Farrell declined l defend.ints m the sult, Bechtel is the have to resign from Bechtel or else he com ment on that Wednesday.

prim.ary contractor for Consumers at would not be ehgible for re hire with Corto returned to work for Bechtel at the nuclear plant. Babcock & Wilcox. Corto then resigned the plant site sometame in May 1981 The Contacted at his P.ome Tuesday, Corto from Bechtelon Aug.28.1979. complasnt does not discuss why he was said he has hern advised by his attorney Following the shift disputes. Corto re. hired and O'Farrell also refused to not to discuss the case, lie is being reported the quahty control violations to com ment on that item.

repi csented by R od O'Farrell, of the NRC representatsve on the site and OTarn ell. Basner & Smith. Sagmaw, to Consumers, the report staies. CORTO IIAS " suffered and enntmues OTarrell dechnd comment on why to suffer loss of pay and other frmge OTARRELL SAID Wednesday his Corto did not report the alleged gaahty benefits durmg the period for whsch he chrnt is asking for damages m escess of control yiolations until after the shift was barred from re.here and h.s* further

$10 000. but decimed to name a specifac disputes. suffered and conti ucs to suffer great figure. Both the NRC and Consumers personal anxiety, pain and suffeeing.

A e uurt date for the c.ase has not been anvestigated his claims, according to the loss of self esteem and fear for ha set complamt, but the results of any contmued employment." the complamt l>lant spokesman Norm.an Saars investigation are nr4 discussed in the States.

derhned comment on the suit Wed. document.  !{e is contendmg that Bechtel ssolated nwlay, oiher than to supply information S.sa ri decimed comma on any the National Labor Relations Act and

.sbout s arious buildings on the plant site ins catigation done by Consumers. that the union "did violate its duty of fair w hoch are n.amed m the suit. James Foster, with the NRC's Region representation" by fathng to mform him

' He said he has not seen a copy of the III Office of Investigations, confir:ned why he was not being re hired and by complaint und th.st Consumers and Wednesday that Corto discussed the failing to invoke grievance procedures Uechtel would rtply through the legal alleged violations with Ronald Cook. the against Bechtel.

system. N R C's on-site inspector. Also, he is contending that both Corto's complamt states that he was Foster said his files show that Bechtel and the union " conspired workmg for Bechtel .at the nuclear plant Consumers mventigated Corto's claims together to deprive plamtiff of has ute in July 1979 when he was ordered by and found that procedures were not employment." which "is contrary to the supervisory personnel to drill "cor. followed. The foreman and super. public pohey of the State of Michigan."

choles" m the evapor.stor building. intendent "were admonished concerning and that their actions violated state Corto and ot her piper.tters were work requirements on this project." com mon taw, ordered to drill the hoics through accordmg to Foster's records. A spokeswoman m the Local 85 offire remforcing hars located m the concrily Foster said the only building named in said Tuesday that Ducharme is out of

w. alls of the hustding, the complainh his records is the evaporator buildmg. town and will not be back until Friday.

states. / Since that building is not safety.related- Ducharme manages the local's olhce.

S. .ari said corcholes generally are the NRC does not regulate it and she said.

drilled in order to put something into the wall or for samphng or inspection f purposch. ,

Quahty control procedures at that '

time stated th.st if workers encountered remfaremg bars durmg drilhng they I w ere lo contact quaht y control personnel to see if drilhng should contmue or of the hole should be relocated, accordmg to the cumplamt.

CORTe WAS aware of th.at procedure.

but w. . ordered to sgnore the quahty control pobey then in effect and was further ordered to dispa*e of the scrap from the remforcmg barn,immediately so that the viol.itions of quahty control policy would not be dncovered.", the complamt states.

Corto completed the work as ordered and. apprusimately one week later, was ordered to drill holes through re.

mforcing bars in buildmgs located m the tank farm area - again without contactmg quahty control personnel, accordmg to the complaint. f Corto apparendy did not imm* instely l rt port the alleged siolations. 1 In gnid. A ugust of that yes.,, he Y

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By S 1 7

v .TEVECALLANDER p A former Bechtel Power Corp.

employee who etalma he was fired for reporting the enm-pony's alleged vioLatacea at the Consumers Power Co.*s Midland Nuthear P6 ant has filed cult la federal court agataat Bechtal

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and a union local tso Krashfeskt la seeking un-spectfwd damages ever $18 000 from Bechtel and taral 55 of the AF'trCIO branch of United Asso- .

clation of Journeymen and Ap-prestaces of the Plumbing and 19petitting industry of the U P and Canada Krashfeskt flN a joint ault alth bla elle. Sarah.

Krashfeski, now a traveting pt-petitter in the Buffalo, N Y.,

area, claima Bechtet fired tum after he reported alleged 9uality contrul tholations while morning in July Is7s as a pipefitter at the nuclear plant, mhere Bet.htet is the generel contractor.

The alleged vlutataons were re-ported to Consumers and to the Nuclear itegulatory Commis-soon Consumers ordered Bechtel to make "some modifications" to the building as a result of the investigation, conducted in Sep-tember Is79. according to Con-sumers' Pubiac Affatra Director Norm Saarl.

The NRC found violations. but look no action against Bechtel because the bulldog, which in-cludes a set of heat enchangers designed to produce steam for industrial use, doesn't fmune safety systems that control the nuclear plant, $aart said e . Bechtet considered Krashfeskt a troublemaker and manufac- '

tured reasons to fire him, the suit say s.

Another Bechtel worker, Ron-1 aid Corto, of Sanford, filed a companion suit an Midland Coun-ty Circuit Court Aug 8. That suit has now been tiansferred to fed-eral court In Bay City.

Corto had accepted retnatate-ment and attil works for Bechtel The suits filed by Xrashfenkt and Corto both ask unspecified damages over 510,000 for the pe-rlod when they allegedly were not able to regain their jobs uIth Bechtel Bechtel officiale declined com-ment and referred all questions to Consumers Power Co. The un-lun's business agent. Robert Du-charme, also occtined comment and referred questions to the n.nion attorney. Gerald Per-gande,of Bay City.

"They both (Krashfeski and Cortel quit their jobs witti Bech-tel and ment la work with Bate com and Wilcos." said Fergande.

"There was no reason for the union to get them their jobs back. Bechtel didn't discharge them, they just = alked out.

"They had originally volun-teered to work second shift, then wanted go back on first shift.

There is nothing in the cellective bargalntag contract that allows choice of shitta."

tse Krashfeski was unavall-able for comment and Sarah Krashfeski dacitard comrnent.

Corto also declined ccsument on the advtca of his attorney, Rod 07arrell,of Saginaw, Krashfeskt and two other Bechtel employees were ordered to drill botes through reinforcing bars in concrete mana at the Evaporator Build 2ig, according to the ault. .