ML20082N929

Forwards Stamiris Exhibit 140,consisting of Applicant Responses to Stamiris Interrogatories 14,28,31 & 19(a). Applicant Two Sets of Supplementary Responses Should Be Filed W/Aslb.Svc List Encl

ML20082N929
Person / Time
Site:	Midland
Issue date:	12/05/1983
From:	Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT, STAMIRIS, B.
To:	Bechhoefer C, Boechhoefer C Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8312080022
Download: ML20082N929 (6)

Text

COCKETED UWC GOVERNMENT ACCOUNTADILITY PROJECT Institute for Policy Studies '83 CEC -7 P4:16 1901 Que Street, N.W., Washington. D.C. 20009 (202)234 9382 criac cr y ' t. ;ic -

Decemb6rC5(i,lg8VW-Charles Boechhoefer, Esq.

Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Harbour Administrative Law Judge U.S. Nuclear Regulatory Commission Washington, D.C.

Dr. Frederick Cowan Administrative Law Judge U.S. Nuclear Regulatory Commission Washington, D.C.

Re: Midland OM Hearing Document Numbers: 50-329 OM, OL and 50-330 OM, OL

Dear Administrative Judges:

I am submitting a copy of Stamiris Exhibit No.140, which are the interrogatories and interrogatory responses to Stamiris Interrogatories 14, 28, 31 and 19(a).

I do not believe that Applicant's two sets of supplementary responses have yet been filed with this Board, and would recommend that they be filed in order to complete the record.

Sincerely yours, N

g kh, c _.

B Lynn \ernabei Counse for Intervenor, Barbara)Stamiris

/ /

LB:me h

Enclosures:

a/s cc: 0M/0L Service List 8312080022 831205 n DR ADOCK 05000

OM/0L SERVICE LIST Mr. Frank J. Kelley, Esq. Atomic Safety & Licensing Attorney General of the Appeal Board State of Michigan U.S. Nuclear Regulatory Commission Ms. Carole Steinberg, Esq. Washington, D.C. 20555 Assistant Attorney General Environmental Protection Division Mr. C. R. Stephens, Chief 720 Law Butiding Lansing, Michigan 48913 Docketing & Services U.S. Nuclear Regulatory Commission Office of the Secretary Mr. Myron M. Cherry, Esq. Washington, D.C. 20555 Cherry & Flynn 3 First National Plaza Ms. Mary Sinclair c go 5 S" 111nois 60602 -

n Mc g. 640 Mr. Wendell H. Marshall Mr. William D. Paton, Esq.

4625 South Saginaw Road Midland, Michigan 48640 Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr.' Charles Bechhoefer, Esq.

Atomic Safety & Licensing Board Panel Atomic Safety & Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Frederick P. Cowan r a bou 6152 North Verde Trail ,

Apartment B-125 Boca Raton, Florida 33433 U. c1 r Regulatory Commission Washington, D.C. 20555 Mr. Michael Miller, Esq.

Isham, Lincoln & Beale 3 First National Plaza Mr. Frederick C. Williams Isham, Lincoln & Beale te 1120 Connecticut Avenue, Northwest cg llinois 60602 Suite 325 Washington, D.C. 20036 Ms. Barbara Stamiris 5 95 North River Road Mr. Samuel Haubold, Esq.

K kland & El is Freeland, Michigan 48623 2 Chicago, Illinois 60601 Mr. Steve Gadler 2120 Carter Avenue Mr. James E. Brunner, Esq.

St. Paul, Minnesota 55108 Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201

STAMIRIS EXHIBIT 140 UNITED STATES OF AMERICA c NUCLEAR REGULATORY COPEISSION Before the Atomic Safety and Licensing Board

) -

In the Matter of: )

Docket Nos: 50-329 ON CONSUMERS POWER COMPANY Docket Nos: -

(Midland Plant, Units 1 & 2) 50-330 OL

)

APPLICANT'S RESPONSES TO STAMIRIS INTERROGATORIES OF OCTOBER 11, 1983 QUESTION 14 Explain the following portions of your typed and handwritten notes for the May 21, 1982 Remedial Soils Meeting:

a. " target freeze activation on Wednesday, May 26, 1982";

b. " Pit 4 critical";

c. " Clear space duct bank...Brien Palmer";

d. "have QA...look at all pits for any quality concern before Dr. Landsman looks at them..."

RESPONSE 14 To the best of Mr. Sevo's recollection, the following is an explanation of his notes of May 21, 1982, which were made from a QA point of view:

a. The scheduling goal was to activate the freezewall on Wednesday, May 26, 1982.

b. Pit 4 was the pit which provided the interface between the deep Q duct bank and the freezewall. Pit 4 was " critical" from the standpoint that it 4,

had several outstanding items which had to be completed prior to the NRC inspecting the freezewall and giving its authorization to activate the freezewall.

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c. This item indicated a notification to Brien Palmer to assure, during the overinspection activities, that the required clear space was present beneath the deep Q duct bank. The clear space was a designed gap between the bottom of the deep Q duct bank and the existing soil prior to freeze-wall activation.

d. This item is a notification to the QA overinspection group (Brien Palmer) conduct a review of all pits to assure accomplishment of all quality inspection, quality overinspections, and the completion of all other open quality items before the NRC inspection of the monitoring pits.

-NOTE: Mr. Sevo's answers to interrogatories numbered 10,11,12,13, and 14 do not include information already provided in the Weil Report, dated September 14, 1983.

QUESTION 19(a)

Identify all activities determined by Consumers or by Bechtel, during the period from April 30, 1982 through September 30, 1982, to be covered by the ASLB Order.

RESPONSE 19 Messrs. Mooney, Wheeler and Schaub respond as follows:

a. All work not approved by NRC staff before April 30, 1982 and involvir.g digging or drilling in Q soils or remedial soils work was considered to be under the Order. Work believed to be previously approved was des-cribed in the May 10, 1982 letter attached to the initial 01 investigation.

No complete list consisting solely of items regarded as under the Order was, to our knowledge, generated. A description of certain activities identified as of May 11 is provided in the response to the previous

3 question. A listing of soils-related activities, without necessarily indicating which had been approved by NRC before April 30 is contained in the "Short Term Action Plan." The method used to control approvals on work falling under the Order as defined above, was described in the state-ment of R.M. Wheeler to NRC investigator Weil.

,UESTION Q 28 Explain what you meant when you stated to NRC investigators, "It's on there I assume I got the information," which is referenced on Page 29 of the Supple-mental O! Report.

RESPONSE 28 Mr. Kostielney does not recall making a statement, "It's on there I assume I got the information." This statement means to him that if an asterisk was placed by a work activity, he would assume he got the information from John Schaub and/or Dave Ronk to put it on the report.

QUESTION 31 Identify all documents you read or reviewed prior to approving the excavation permits for the fireline relocation a'nd deep Q bank excavation.

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-Identify what portion of these documents indicate the NRC gave prior approval l

for the activity and/or that prior NRC approval was not required for the activity.

RESPONSE 31 Mr. Murray signed the excavation permit for the deep Q duct bank only; he

signed the work permit for the fireline relocation.

As to the fireline relocation, Mr. Murray recalls that there was no documen-tation which specifically dealt with the relocation. Since the activity l

4 covered under the Board Order was the excavation in Q soils, it was Mr.

Murray's understanding that this activity was minor and, therefore, covered in the Wheeler-Landsman agreement. Mr. Murray also recalls that prior to signing the work permit, he telephoned John Schaub to confirm the above reasoning.

Mr. Murray does not specifically recall signing the excavation permit for the deep Q duct bank, nor does he recall any specific document which he reviewed.

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