ML20080S706

Expresses Concern Re Discrepancies in Const Completion Schedule.Public Meeting Warranted in Light of Varying Completion Dates

ML20080S706
Person / Time
Site:	Midland
Issue date:	10/13/1983
From:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20080S710	List: ML20080S706 ML20080S721
References
NUDOCS 8310180456
Download: ML20080S706 (2)

Text

GOVERNMENT ACCOUNTABILITY PROJECT Institute for Policy Studies 1901 Que Street. N.W., Washington, D.C. 20009 (202)234-9382 October 13,.1983 Mr. Harold Denton, Director Nuclear Reactor Regulator U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr. Denton; Recently Mr. Thomas M, Novak, the Assistant Director for Licensing of your staf f, wrote to Mr. J. W. Cook of Consumers Power Company (" CP C" ) regarding the Construction Completion Schedule for the Midland Plant. (Attachment 1) Mr. Novak essentially informed CPA that an October 9, 1983 letter citing a completion date of not earlier than October 19 85 would stand unless CPC responds within two weeks of the receipt of Mr. Novak's October 4, 1983 letter.

We believe that this position by Mr. Novak is seriously misleading.

In the . light of the factual controversy surrounding the unknown cost and completion schedule for the Midland facility, the recent Dow court actions against Consumers , aand the unknown results of the Quality Verification Program ("QVP") de te rmi ning the true extent of the problens on the Midland site. GAP believes that giving the continuous impression to either the agency or the public that the Midland plant is even two years from completion is deceptive.

Even the most basic review of the facts presented by CPC at the April 19-21, 19 83 prisintation expose f actual errors and mis representations . To illustrate, the "CCP Quality Activities" handout to the April 19-21 meeting (attachment 2) indicated that-NRC approval of the CCP would be in May. That approval j ust issued, adds, at a minimum, an additional seven months to the April schedule. Another example is the Licensing Schedule (attachment 2b) which indicates the OM proceedings would be com-pleted by the end of July 1983. Those hearings have a minimum of several months remaining before completion.

However, even more disturbing is the fact that the Case Load Forecast panel itself was not fooled by CPC's mythology. The panel completed its estimate by May 17th. This information was submitted to Mr. Novak on May25th. See Supplemental Memorandum in s-upport of Intervenor Barbara Stamiris' Motion to Litigate Dow '

Issues. (Attachment 3)

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Mr. HCrold Dcnton Page Two October 13, 1983 Mr. Novak did not issue the draf t letter that he received from the panel. He cancelled a scheduled public meeting for June and July and finally -- af ter GAP obtained a copy of the draf t memo through the FOIA -- released the August 9, 19 83 letter.

The two letters are substantially dif ferent. Much of the information available to GAP investigator 3 is detailed in an affidavit that was recently submitted to the Atomic Safety and Licensing Board in the Midland OM/OL proceedings in support of an Intervenors Motion. That motion and the supporting documentation is attached for your review. Evidence obtained through discovery by Intervenors Counsel Lynne Bernabei of this of fice confirms - that the allegations made by Dow in its July suit of a dual cost and s chedule , one for CPC and one for the public, is fact.

The NRC,ounder extreme presure from Cdnsumers, appears to have dropped its case lead forcast in 1980 and again in 1983.

One of the major charges in the Dow suit against CPC is that CPC kept dual scheduals. CPC's defense to this charge, up to this time is that the NRC knew about consumer difficulties and yet agreed to a large degree with consumers estimits. The NRC has a responsiblity to inform the U.S. Congress,-the f: state of Michigan and the public including Dow chemical of the realistic competionadates for the Mid-land Nuclear plants.

In the light of the above acticns and reasons, we believe that letter are totally unacceptable. Further, we point out that it is <

the NRC's practice that if completion dates proposed by a utility differ by at least six months, that a public meeting is held for the NRC to refute the licensee figures. No such meeting has yet been hold, although the public has been anxiously awaiting that meeting for over a year.

In light of Mr. Novak's haste to confirm completion dates we expect an immediate response to this letter and the scheduling of a public meeting.

Sincerely ,

aPJ Billie Pirner Garde dmg cc; without enclosures Mr. Scott w. Stucky Steven J. Gadler, P.C.

Frank J. Kelly James E. Brunner, Esq.

Dr. Frederich P. Cowan Philip Steptoe Charles Bechhoefer, Esq. Frederick C. Williams, Esq.

Wendell H. Marshall Docketing and services Section Myron M. Cherry, P.C. Dr. Jerry Harbour William D. Paton, Esq. Atomic Safety and Licensing Panel Lee L. Bishop, Esq. Ms. Barbara Stamiris Ms. Mary Sinclair

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~ ATTACHMENT #1

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'% ,\], # October 4,1983 Decket Nos. 50-329/330 OM, OL Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201

SUBJECT:

Followup Meeting on Construction Completion Dates My letter of August 9,1983, noted that since the April 19-21, 1983, NRC staff visit to assess construction completion schedules for Midland, Consumers Power Company had requested a followup meeting to' review the material previously provided, to provide additional information, and to discuss reconsideration of scheduling priorities between Units 1 and 2 in light of recent actions by Dow Chemical Company. The letter also noted that at Consumers' request, the staff would be seneouiing this meeting in September 1983.

On September 2,1983, Messrs. B. Hershe, N. Leech and others from your Company advised us that the week of October 24, 1983, would be the earliest time that

. Consumers would ha neanarad to discuss scheduling priorities between Units 1 and 2, ano snat some montns beyond this may be needed to establish a scheduling projection basis.

! The staff views this as a significant delay in our efforts to consider your l views regarding the schedule for plant completion at Midland. Unless your dates for establishing a firm schedule for plant completion are substantially l improved, the staff will consider the estimate it developed based upon the April 19-21, 1%3 visit to be appropriate for its planning purposes. Please advise me of y m e h* ant in this regard within two weeks of receipt of this letter.

Sincerely, 9 -

Thomas M. Novak, Assistant Director for Licensing Division of Licensing cc: See next page l

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Mr'.'J. W. Cook Vice President Cons:,ers Pcwer Company 1945 We3t Parnall Poad . . _ . . _ . . . . . _ _ . . _ _ . . . _ . _ .

Jackson, Michigan 49201 cc: M'chael I. ' Miller, Esq. M . Den van Farrcae, Chief Ronale G. Zamarin, Esq. Division of Radiological Health Alan S. Farnell, Esq. Depart.ent of Public Health Isham, Lincoln & Beale P.O. Box 23035 Tr.ree First National Plaza, Lansinc. , Michic.an 'S909 Elst floor Chicago, Illinois 50502 Mr. Steve Gadler 2120 Carter Avenue Jares E. Brunner, Esq. St. Paul, Minnesota 55108

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ATTACHMENT #2 UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board in the Matter of: ) Docket Nos. 50-329-OL

) 50-330-OL CONSUMERS POWER COMPANY ) 50-329-0M

) 50-330-0M (Midland Plant, Units 1 and 2) )

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SUPPLEMENTAL MEMORANDUM IN SUPPORT OF INTERVENOR BARBARA STAMIRIS' MOTION TO LITIGATE DOW ISSUES Intervenor Barbara Stamiris submits the f ollowing supple-mental memorandum in support of her motion to litigate Dow issues.

1. )ACKGROUND On August 8, 1983, intervenor Barbara Stamiris submitted a motion to litigate issues raised by the Dow Chemical Company in ire e"d* aa=4-e* ronsumers Power Company, filed July 14, 1983. - issues raised by the Dow Complaint, which' intervenor argued presented important new evidence on appli-cant's poor management attitude were the following:

(1) applicant misrepresented its schedule for completion of the two naciand plants to the Nuclear Regulatory Commission

("KB C") , including the NRC Staf f and this Atomic Safety and Licensing Board (" Licensing Board");

C' , .., ,1. - .. . s e d a n d .r el i ed on U . 0 , Testing test results to f ulfill NRC regulatory requirements even though it knew the test results were invalid; and l

(3) Applicant knowingly misrepresented to the NRC that a single test boring taken near the diesiti generator building l

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demonstrated that unmixed cohesive fill had been used as a foundation.

On iugust 17, 1983, applicant filed a lengthy response to intervenor's motion and offered to allow the parties and the Board to review a number of documents provided to Dow prior to its f iling suit against Consumers ("the Dow docu-ments").

In a conference call on August 25, 1983, this Licensing Board deferred ruling on intervenor's motion and request for

" discovery until such time as all parties had a chance to review'the Dow documents.

On September 14, 1933, applicant's counsel submitted a three-page letter and a fifth box of documents to the Licen-sing Board and the parties. Applicant presented a new argument in thi; _;t._: :n:t because the 3?80 NRC Caseload Forecast Panel estimated completion dates only three months later than Consumers, the information Consumers disclosed on schedule to the NRC was accurate. Unfortunately both Cansumers and the NRC were wrong by at least thr ee y ears .

Ma-aa-a- chase and other documents obtained by inter-l venor's counsel, the Government Accountability Proj ect (" GAP")

1. Mr. Brunner's letter is clearly an unauthorized pleading.

However, in tervenor will no t obj ect to its filing since l the documents submitted in support of the pleading support l

intervenor's position. Further, many of the documents and arguments are s imply irrelevant to the dispute before this Board.

pursuant to the Freedom of Information Act ("FOIA") demonstrate that the NRC staff has had long debates about the accuracy of i

applicant's schedule figures. However, it has always been true even up'through the present, that an informed segment of the NRC Staff has estimated completion dates years ahead of Consu-mers. Further, these completion dates have been revised after Consumers Power has exerted pressure to make the Panel conform -

their dates to Consumers' figuras. An informed and sizeable segment of the NRC Staff has always held the opinion that Consumers' figures are inaccurate and unreliable.

Even a cursory reading of the Dow documents re. veals that the f ue A Aoao dates Consumers presented to the NRC Staff from July, 1980, until April, 1983, indicate Consumers knew the figures were false and used them in the face of tough ques-tioning *o, . .1. cable segment of the NRC Staff.

Moreover it appears that Techtel did not use these comple-

. tion dates but the Bechtel Forecast 6 schedule to plan con-struction work. In these circumstances it appears Consumers

- d el ib e r .t al y submitted false figures to the Commission.

l Intervenor submits this Supplemental Memorandum to support its claim that the documents Consumers released support Dov's end i- t -- ---- ' a l l e ga t ion s that Consumers knowingly misrepre-sented the scheduled completion dates for the two Midland plants.

2. Intervenor does not address the second and If third issues she the Board believ e s are raised in the Dow Complaint.

should rule that she may not litigate these issues as manage-ment attitude issues, Mrs. Stamiris requests the opportunity to submit a supplemental memorandum demonstrating how the j Dow documents substantiate the se allegations .

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-4 II. DOCUMENTS PRODUCED BY CONSUMERS DEMONSTRATE THAT CONSUMERS AND BECHTEL DELIBERATELY MAINTAINED A DUAL SCHEDULE AND MISLED THE NRC ABOUT COMPLETION DATES FOR THE YWO MIDLAND REACTORS.

Bechtel released its Forecast 6 in January, 1980. In Forecast 6 Bechtel :alculated the fuel load dates for 3

Unit 1 to be September, 1984 and for Unit 2 to be April, 1984.

• On January 15, 1980, K. R. Kline requested that a Forecast ,

Review Team evaluate Bechtel vorecast 6. The Revies Team was comprised of staff from Consumers' home office, field offices.

, testing staff and Control and Administrative Services. This team concluded that it gerarally agteed with Bechtel on cost and schedule; it recommended a total proj ect estimate based on Forecast 6 Cost and Schedule figures. See Kline/Randolph Memo of May 5, 1980, Attachment 7 to Applicant's August 17, 1983 Response, Intro. at 1-4; History / Background at 7.

On June 23, 1980, Consumers and Bechtel held an " Executive Management Maating." At that meeting Consumers and Bechtel agreed to establish target dates of July, 1983 and December, 1983 for fuel load of Units 2 and 1, r e s p e c t iv ely . These dates were based on the assumption that the scope of work at the projecs =volo .. v 6 be increased. This assumption was clearly i

invalid as the magnitude of the soil s settlement problems became apparent. See July 31, 1980 Mo11enkopf Memo on 6/25/80 l

Meeting at 4 -5, Attachment 8 to Applicants' 8/17/83 Response.

On July 10, 1980, Mr. Rutgers reported that Bechtel would maintain two sets of cost and schedule figures. The first figures were defined as the " current project schedule." The current project schedule listed fuel load dates for Unit 2 as l

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July, 1983. (Consumers agreed to use the term " target schedule" for these fuel load dates.)

Bechtel was instructed to use these target or current project schedules in all correspondence with Consumers and in all documents intended for public consumption. Bechtel sas to continue to use its Forecast 6 schedule or the " current fore-cast" to plan and control its construction work. As. stated in Attachment 2 to the Ectgers' Meeting Notes, " Forecasting ...

is an ongoing schedule monitoring and control process which indicates the responsible team members' evaluation of construc-tion scope, duration, and time-of-accomplishment."

Obviously Consumers directed Bechtel to keep two schedules -

one false and inaccurate and the other based on Forecast 6 to guide its work. See generally, Rutgers Notes of 7/10/80 Meeting, attached and incorporated herein as Attachment 1.

In its August, 1980 Cost Trend Report submitted to Consu-mers Bechtel carried out these directions. In its earlier June and July 1980 Cost Trend Reports Bechtel presented two schedule columns for each reactor: A Trend Base Schedule and an Actual I

l Forecast. The " Actual Forecast" schedules were the Forecast 6 fuel load dates. See Cost Trend Schedules for June, 1980, and July, 1980, attached and incorporated herein as Attachments 2 and 3.

The August Cost Trend Report has the two " actual forecast" 3.- Apparently th e July, 1980, Cost Trend Report was prepared before the July 10, 1980 Management Meeting in which Bechtel was ordered to remove the forecast column from the Cost Trend Reports.

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columns literally " whited out" or cut out. The form of the chart which appears in the Bechtel cost trend reports does not chstge over the years up through 1983, even though all columns except for the current proj ect schedule columns remain blank. This leads one to believe that Bechtel maintained the two sets of s

figures in the cost trend reports it kept for its own uce. Not until April 2 7, 1983 do the current project schedule dates change. See April, 1983 Cost Trend Report Schedule, attached and incorporated herein as Attachment 4.

In a June 10, 1981 project management meeting, Bechtel and Consumers apparently discussed the internal proj ect schedules.

Don Millet exp ussed his concern that intermediate proj ect schedules had not been formally coordinated. John Rutgers sug-gested compiling a fully coordinated schedule of interim con-structi:.

. _. But James Cook vetoed the idea, apparently because Consumers did not want Bechtel to compile another com-pr ehen s iv e set of schedule forecast figures, such as Forecast

6. See Pxtgere Meetings Notes of 6/25/81 Meeting, attached and incorper :c: nerein as Attachment 6.

The Dow documents, therefore, illustrate that Consumers ordered Bechtel not to disclose to Consumers any schedule data other thea esa inaccurate schedule for public consumption, using fuel load dates of July and December, 1983. Moreover it is clear that Consumers, from the Summer'of 1980 until April, 1983, did

! 4. The two actual forecast schedule columns inexplicably appear in the January, 1981 Bechtel Cost Trend Report, and then disappear until April, 1983. See April, 1983 Cost Trend Report schedule, attached and incorporated herein as Attach-ment f .

did not change these fuel load dates, even when it knew the 1 Bechtel Monthly " Critical Items Action Reports" were reporting throughout 1981 and 1982, delays of 10 months and more. See, e.g., Bechtel Critical Items Action Reports for November, 1981 and December 1981, attached and incorporated herein as Attach-ments 7 and 8.5 III. FROM AUGUST, 1980 UP TO THE PRESENT THE NRC STAFF HAS BEEN DIVIDED AS TO THE ACCURACY OF CONSUMERS' COMPLETION DATES In August., 1980, af ter the release of Forecast 6, the NRC Staff came to a preliminary estimate of f uel load dates of May, 1984 and November, 1984 for Units 2 and 1, respectively. See Sulliv e n iciecou accord of 8/12/80; and Sullivan Telecon Record of 8/18/80, attached and incorporated herein as Attachments 9 and 10. Only af ter Consumers exerted pressure on the !dRC Staf f, throu e. .. ..__ __atings, did William Lovelace agree to revise the NRC Staff estimate to bring it in line with Consumers' fuel load dates of October, 1983 and April, 1984. See Sullivan Meet-ing Net:: ef */25/SO attached and incorporated herein as Attach-ment 11.

On September 16, 1980, the Staff publicly announced that l

its fuel load dates substantially agreed with Consumers',dif f er-l l in g h * ' - - - - - - * ' - See Hood Summary of 8/25/80 Meeting, attached and incorporated herein as At tachment 12.

5. In compiling Forecast 7, Bechtel did not estimate construc-tion completion dates. Rather it assumed the target fuel load dates of 1973 and determined an estimated cost based on these dates.

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Bidden behind the 1983 NRC Caseload Forecast Panel comple-tion dates is a similar debate. The Caseload Forecast Panel in May, 1983 estimated fuel load dates in the third quarter of 1986, not 'aking t into account delays caused by consideration of the Construction Ccapletion Program and time needed for rework and corrective action. See Dr, aft Novak Letter, attached and incorporated herein as Attachment 13.

This draft letter was never sent. Instead Consumers

,, succeeded in convincing the NRC Staff to cancel three public meetings scheduled during theSummer of 1983. Finally, after a FOIA request and administrative appeal by GAP, the NRC Staff released a tuvised case load forecast of fuel load dates in the third quarter of 1985. Mr. Novak's letter dated August 9, 1983, varies sienificantly in tone and substance from his earlier draft 1...... Sge Novak Letter of August 9, 1983, attached and incorporated herein as Attachment 14.

Consumers convinced the NRC to cancel three successive public =ccting: during the Summer of 1983 and ultimately con-vinced t i. : Oc cload Forecast Panel to shave an entire year off its estimated construction completion dates for the Midland plants. See Affidavit of Billie Garde and exhibits, attached i and ia-a ra--+ad herein as Attachment 15.

Just as in 1980, an informed segment of the panel wished to inform the Licensing Board a6d the public of the NRC esti-I mates, which differed from the applicant's figures by at least j i e two years. Through pressure exerted on the NRC Staff, Consumers i

succeeded in delaying any public meeting and forcing the NRC Staf f to radically revise its original completion dates.

It is obvious from the Caseload Forecast Panel's original astimates in 1980 and again in 1983 that at least a portion of the NRC Staf f has had grave doubts about the accuracy and reliability of information provided by Consumers. Yet under constant pressure from Consumers the NRC Staf f has been willing to change its forecast dates to conform more closely to those of Consumerv.

In these c ir cum s ta n c e s , the NRC Staff may see that liti-gation of the dual schedule issue will be embarrassing to the NRC Staff. Nonetheless the significance of this issue to the decision bef ore this Board is beyond argument. Clearly Con-sumers' duty to report full and accurate information to the HRC 56... ouw ca . Licensing Board at all times is absolute.

Consumers' failure to report accurate information about pro-j ected completion dates to the NRC from 1980 to the present is highly probative of its untrustworthiness today to carry out the sensitive soils r emedial work, even under strict Board-i~ ,

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IV. CONCLU? TON ra- eka fa-agning reasons, in tervsnor respectf ully requests this Licensing Board to allow litigation of the three Dow issues described above and reop'en discovery against the NRC Staff and Consumers regarding these issues.

Respectfully submitted, M c LY BERNABEI Cd RNMENT ACCOUNTABILITY PROJECT ,

Institute for Policy Studies 1901 que Street, N.W.

Washington, D.C. 20009 (202) 234-9382 Counsel for Intervenor Barbara Stamiris DATED: September 21, 1983 i

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