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UNITED STATES F3t'.CIPAL STAFF
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Docket Nos: 50-329 OM,0L
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MEMORANDUM FOR:
R. Ballard, Chief, Environmental Engineering Branch G. Burdick, Chief, Reactor Risk Branch L. Hul, man, Chief, Accident Evaluation Branch K. Kniel, Chief, Generic Issues Branch G. Lear, Chief, Hydrologic and Geotechnical Engineering Branch S. Pawlicki, Chief, Materials Engineering Branch Z. Roszteczy, Chief Equipnent Qualifications Branch A. Toalston, Chief, Antitrust and Economic Analysis Branch 4
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Chief, Reliability and Risk Assessment Branch
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FROM:
Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing
SUBJECT:
J MIDLAND INTERR0GATORIES
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Enclosurd 1 is additional Midland interrogatories submitted by intervenors Mary Sinclair~ and Barbara Stamiris for the Midland OL hearing. The contentions referred to in the interrogatories have all been accepted by the Board f.r hearing purposes in the August 12 - 13, 1982, Prehearing Conference (Enclosure 2). Also enclosed as is a list of reviewers assigned for staff response. Reviewers are requested to forward responses for all interrogatories other than the interrogatory dealing with Stamiris contention 6 to Melanie Miller (X24259)/5F October 25D Responses to interrogatories dealing with Stamiris contention 6 should be submitted by[0ctober__6)because this contention will be discussed at the October 26-29 soils hearing.
If there are any questions about the assignments contact Melanie Miller, X24259 promptly so that reassignments may be made if necessary.
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Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing
Enclosures:
As stated
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UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COhBilSSION Before the Atomic Safety and Licensing Board In the Matter of:
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Dec. Nos. 50-329 l
CONSUMERS POWER COMPANY,
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50-330 (Midland Plant, Units 1 and 2)
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O perating License DISCOVERY OUESTIONS TO THE NUCLEAR REGULATORY COhntISSION ON NEW CONTENTIONS ACCEPTED BY BOARD ORDER,
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AUGUST 14, 1982 h-fon / D d August 25, 1982 h[!44VC RA<m FF These interrogatories are filed in accordance with the Board Order of August 14, 1982, following the pre-hearing conference of August 12-13, 1982.
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$ep.kfM Terms are defined as follows:
" Staff"--means 'any consultants or expert witnesses retained by the Nuclear Regulatory Commission (NBC) for any issue discussed as well as the regular NRC staff.
" Documents"--shall include reports, studies, notes, worksheets, meeting reports and summaries, correspondence, telecons or other communications.
I. Contention 3 questions the a'dequacy of the methodology in the DES for determin-Ing the possibility of severe accidents at the Midland nuclear plants, and recommends l
NUREG/CR/2497, as a better basis '
Questions:
- 1. The FES includes an extensive discussion of the uncertainties associated with the numerical estimates of the likelihood, as well as the conseg uences, of severe j
reactor accidents that the DES did not carry. For example, the FES states that it is i
the judgment of the staff that "the uncertainty bounds could be well over a factor of 10, but not likely to be so large as a factor of 100 (5-4 8). NUREG/CR/2497 estimates that the Ras usse tudy (relied upon in DES 5-46-66) underestimates the risk by a
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To what at did the new uncertainty bounds in FES depend on o,,
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NUREG/CR/2497 for their new uncertainty estimates ?
- 2. Provide copies of any studies (including NUREG/CR/2497) whii:h address risk assessment of accidents subsequent to the Rasmussen study.
- 3. What other studies were.done after the DES was issued to prompt this new evaluation of uncertainties in the FES ?
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j 4.
Provide correspondence, memos and any other appropriate documents that deal with this new evaluation of uncertainties identified in the FES (5-48) in the l
following areas: 1) oversimplified analysis of the magnit'ude and. timing of the f
fission product releases; 2) uncertainties in calculated energy release; 3) radionu-clide transport from the core to the receptor; 4) lack of precise dosimetry; 5) statistical i
variations of health effects.
- 5. The study, NUREG/CR/2497, bases the probabilities of severe accidents on l
the basis of actual accident consequences and significant events. Using this method--
ology:
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- a. What percentage oficcidents were initiated by operator error? List them,
- b. What percentage were initiated by non-safety systems that failed and impacted on safety systems? List them, f
- c. What percentage were due to disbelief of actualinstrument readings which j
were not safety grado equipment? List them.
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- d. What percentage were due to instruments actually giving a false reading to 1
operators? List them.
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- e. What percentage were due to maintenance during plant operation that disrupted the safety systems ? List them.
- f. What percentage were due to minor mishaps that disrupted larger systems ?-
List them.
- g. What percentage of accidents were due to failure of safety systems ? List them.
- h. What percentage were due to poor QA procedures during operation?
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- 1. What pe,rcentage took place when the plant was at less than full power?
- j. How inany of the accidents studied took place at the Applicant's Palisades and
' Big Rock plants ? Describe them.
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- 6. Based on the new.information in the FES of the probability of accidents 'that has '
increased by a factor of 100, what is the worst case probability of accidents at the Midland reactors and the U.S. ?
7.
What is this new probability of risk of accidents calculated for' Unit I that has I
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II. Contention 5 deals with que'stions about the adequacy of'the basis of theista in the
-Monthly Cooling Pond Performance Tables on the cooling pond provided in the DES (4-7, 4-8) and the extent of the fogging and icing.
j Questions:
- 1. What was the source of the data relied upon for these Tables in DES (4-7, 4-8)?
,Give the basis of data for each factor in the Table and FES (4-24, 4-25).
- 2. Explain in detail the effect on the efficiency and safety of the n-plant's operation when blowdown will have to be withheld when the conditions listed in FES (4-8) (last para-4 graph of 4.2.6.2) occur.
a.-What percentage of annual time or days per year will. Dow Chemical's plant dis-4 j
charge utilize the entire T_DS capacity of the river and thus require withholding of j
blowdown?
- b. What percentage of annual time or days per year will ambient river temperatures be i
equal to or greater. than the monthly maximum allowable specified inthe NPDES permit?
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- c. What percentage of annual time or days per year can makeup not compensate for pond water losses caused by evaporation or seepage ?
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- 3. What will be the effect on the efficiency of plant operation when more than one i
of 'he conditions listed above occur? (As are listed in the last paragraph of 4.2.6.2 of j
FES) (4-8).
- 4. What will be the effect on plant efficiency when all of these conditions occur at the same time?
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- 5. What will be the effect on safety of plant operations,when more than one of these coni!!tions occur (as are 11stell in the last paragraph of 4.2.6.2 of FES) (4-8)?
- 6. What will be the effect on the safety of the plant when all of these conditions l
occur at the same time?
- 7. James Carson, meteorologist from Argonne National Laboratory, met with
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the Midland County Road Commissioner and City Planners on September 8,1978, l
and said the Dresden pond model was rnore applicable to the Midwest than the Bechtel f
cooling pond model of 1973 which was based on data from a Southwest cooling pond..
- a. Was the Dresden pond data used,for calculating either the thermal efficiency or' the fogging and icing at Midland in the DES and FES?
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- b. If it was, provide the base line data and methodology,used to reach the conclu-
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sfons in the DES and FES.
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- c. If the Dresden pond was not used for either (thermal efficiency or fogging and I
icing), explain why not.
- 8. Has this cooling pond model as given in the DES been applied anywhere that is comparable to Midland? If so, where?
- 9. If so, provide the data to show that projections in the model are consistent with..
i actual operating experience.
- 10. If it has not been tried, how can you be sure it will be an effective cooling pond for the Midland plants ?
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- 11. What studies have been made to determine the effect of the fogging on the l
people in the area and thelullock Creek elemennry school? (Dr. Edward Epstein, the meteorologist from the University of Michigan who was our expert witness on fogging, discussed this at a seminar of the nuclear engineering department in October, 1972, and said, "I don't know how those people are going to live.")
i Contention 7 deals with the issue of synergism between chemicals and radiation 4
as it affects insulation in nuclear plants.
i Questions:
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.1. Please provide NUREG/CR/2156, June,1982.
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2.
On what basis was the environmental qualification and durability of the insula-
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tion of electrical equipment that is now in place,' determined for the lifetime of the plant ?
3 How are the results of the Sandia study (NUREG/CR/2156) Interpreted as to their effect'on the performance of the, cable insulation during the lifetime of these reactors ?
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- 4. To what extent is the cable insulation that will be affected not subject to i
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- 5. What percentage of the cable insulation will not be available for inspection once the plants begin operations ?
Respectfully submitted,
.MIE m
Mary P.
clair cc:
Secretary, U.S. Nuclear Regulatory Commission Michael I.* Miller, Esq.
William Paton, Esq.
Mr. Wendell Mars, hall Ms. Barbara Stamiris James E Brunner P.S.
Discovery questions for Contentions 6, 8 and 16 will be submitted at a later date.
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f0C TtG SE BRANCH U. S. Nuclear Regulatory Convaission a
In the Matter of Docket Nos.
j CPC Midland Plant 329-OL Units 1 & 2 330-OL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
STAMIRIS INTERROGATGLIES AND DOCUENT REQESTS
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TO CONSUERS POWER COMPANY 8/30/82 1
l (Docunants are meant to include studies, models, notes reports, working papers, or other written records of coassunication 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 documents provided.)
COST / BENEFIT: CONTENTION'1b and 1 c 1.
Explain in detail the " prompt removal / dismantlement decommissioning plan for j
i Midland. Describe any special procedures or equipment which will' be used to protect the workers and the environment from radiation. Include estimates of t
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length of time to complete the job and the condition of the plant site upon i
I completion.
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2.
Provide documents which form the basis for the deconunissioning plan described i
in 1 above.
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To what extent if any will Hidland's decommissioning be affected by soils remedial measures such as underpinning supports, dewatering equipment, or
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others?
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4.
Explain in detail.how the $235 million (1984 dollars) deconunissioning' estimate was derived f or Hidland. Include breakdown of costs for the component steps de scribed.
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What does CPC calculate Midland decomissioning costs to be as a % of its
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projected lifetime production cost savings? Explain this calculation.
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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.
4 7.
Explain in detail the method CPC proposes to finance and collect Midland decom-i j
missioning costs until the year 2000 Include explanations of inflation allow-i ances, interim use of money collected by CPC, liquidity of these assets, and method of guaranteeing availability of money when needed for itecomissioning.
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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 deconsnissioning cost in 1980 2
j dollars (MP 6/81-50M, 62-51912 CPC decomissioning pamphlet) results in the 4
1, collection of $526 million (exhibit A/S-1, MPSC case 6150) by the year 2000, I
what amount is estimated to be collected for Midland by the yea'r 2000 according o:
to your plan? Explain these calculations..
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- 10. Doss the $235 million estimate represent the full amourit to be co'Llected accord-1 1
I ing to your decomatLssioding > plan described in the.last part of your. pamphlet cited 'abbve,. if not, explain why it shouldn't.
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- 11. a) According to current laws, explain the federal income tax rate and manner I'
by which CPC will be taxed for decomissioning money collected; early. b) What i
are these tax amounts projected to total thtough the year 2000 on the decom-
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I missioning amounts projected in q. 97 c) Will money be collected from rate-6 i
payers above and beyond amounts estimated in q. 9 to support these CPC tax i
l 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% lifetime capacity factor is derived for Midland.
i Does this estimate take into account any expected ' differences between Unit 1 & Unit 2 operating capacity, pressure, ~de temperature limitations-due to
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the defective beltline weld in Unit I? Explain these differences if they exist.
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.14.
Explain in. detail the apparant di.scttpancy in the EFPY estimates for Unit I operation appearing on pages 5-19 and C-10 of the SER7 i
l 15. What is the EFPY estimate you are currently using for Unit I? Explain any differences between this estimate and those submitted for the SER.
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- 16. Explain in detail the apparant discrapencies between flux properties on SER
- p. 5-19 and FSAR section 5.3.1.6.1.3 for surveillance samples and actual belt-f line material samples. Provide the calculations and other documents which I
form the basis of this explanation.
17.
Provide documents relating to reduced operating capacity or life expectancy of Unit I.
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- 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 I
of inability to produce steam for Dow according to contractual obligations..
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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 operation to avoid the safety and economic costs associated with post opera-tive radiation? - If yes, explain. If not why not.
l 2d. Explaln in detail the method of performance and frequency of inspections planned I
by the B & W Owners Group Surveillance program for monitoring reactor weld l
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4 fracture toughness and other weld conditions? How does this program protect against the possiblity of sudden failure?
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 mater'al in their reactors.
i 23.
Provide all documents and correspondence sent and received regarding the reac-tor vessel weld properties prior to the installation of the reactors at Midland.
24.
When were the Unit I and Unit II reactors installed (give month and year)?
25. Were Unit I and Unit It reactors ever switched from their originally planned containments? If yes, explain why.
26.
Did any confusion in identification of Unit I and Unit II reactors ever occur.
If so explain when and how this occurred, what occurred and how iti was resolved.
QUALITY ASSURANCE: SINCIAIR CONTENTION 6 l
1.
If a plant worker' has a safety concern, what is the chain of reporting open 4
l-to him? Describe tt}e workings of this internal reporting system.
1 2.
In reporting a safety concern to the NRC would a plant employee bd free to provide the NRC with back up site work documentation without the permission of Bechtel or CPC superiors?
3.
If the answer to.q. 2 is no, how does' this affect the necessary free flow of i
information to the NRC?
4.
Does CPC, Bechtel or any subcontractor encourage workers with safety related complaints to keep the problems "in house" as opposed to going to the NRC?
Explain.
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If a plant worker has pursued the internal QA reporting system, aM cone to I
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-l the NRC, but still feels his safety concerns have not been properly addresse5,
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is he free to go to the public with those aoncerns as an employee of CFC,
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or Bechtel-as an ex-employee of CPC or Bechtel? If not, explain why.
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- l 6.
What records are kept of worker safety related compla.ints, reports of violations
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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. )
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7.
Provide a list of former plant employee names and forwarding addresses who left in 1981 or 1982 and had reported a complaint about improper QA/QC proce-dures, made use of the internal reporting system described in q.1, or filed an allegation.
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8 How long has the HPQAD internal allegation form been in existance? Is this j
form made available to all plant workers-how? Please provide a copy.
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EFFECTS OF DEWATERING: CONTENTION 3 1.
Explain in detail the prolonged (40 year) effect of permanent dewatering upon I
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i the various subsoil layers and underlying groundwater.
l In answering this question i
- a. Include explanations of the potiential 40 year effects of removal of fines from soil layers, and how this is monitored.
j b.
Discuss the interrelated effects of one soil layer upon another.
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Explain the potential 40 year effects of groundwater roovement from lower i
i to upper levels during dewatering.
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,d.
Discuss the possible weakening of the " essentially impervious" intermediate I
clay layer separating the perched ground is. erfecm the underly.confinea aquifiers.
I under artesian pressure. In so doing consider all possible combined effects of a 40 year dewatering system.
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Discuss the possible af ter-effects of 40 year dewatering on groundwater movement between upper and lower levels and upon interrelated soil layefs, u
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possibly weakened or changed by dewatering.
2.
What studies or ott:er data exist concerning prolonged (40 year) effects of de-watering upon subsoils and groundwater relationships?
3.
Provide documents upon which answers to q. f are based.
4 Did the assurances provided to the NRC for the $$ analysis regarding the effects of possible radioactive release to groundwater following a core-melt accident take into account the effects of prolonged dewatering on subsoil and ground '
water conditions? If yes, explain. If not, why not.
INDEPENDENT DESIGN AUDIT: CONTENTION 4 1.
How much time, money, and effort is involved in the Bechtel Audit of. Bechtel construction and de. sign 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 at Midland?
3.
What contacts have been established thus far with various firms concerning the desi n and construction audit?
6 4
Provide names and addresses of all firms considered for performing the indepen-n 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.
6.
Explain in detail the job description, scope of the audit, and other descrip-tions of uhat exactly is to be done during this audit.
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- 7.. Provide all documents and correspondence exchanged thus far between CPC and
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prospective companies or individuals regarding the design and construction audit.
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8.
Explain to what extent the audit scope, depth, or methodology will be controlled l
by CPC.
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i 9.
Explain CPC's proposed plan of action for responding to audit findings.
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10 When does CPC expect the selection of this audit firm to be decided?
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- 11. When does CPC expect the audit to begin? To be concluded?
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- 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 misshr. reinforcing bars) without relying upon CPC's statements and analysis of internal wall conditions?
ADDITIONAL The Midland Daily News (8/26/82)QA INIEPROCATfRIES reported a, Suit against Bechtel by Ronald 9
Corto charging job loss due to QA reporting. Why vere coreholes being drilled j
j into structures--name all structures into which coreholes were drilled? Provide l
documents related to QA procedures for this drilling and to the Carto allega-tions.
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Respectifully Submitted, i
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J Barbara Stamiris t
cc. ASLB members W. Paton, NRC l
NRC Secretary-h W OGDu a.S 94 s$ 6 #84.-
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Sensitivity of Risk Parameters to Human Errors... eactor Safety Studies for a WR (Brookhaven Laboratory, Jan.,1981) 'everthele, the staff SER imple-r nts the TMI Action Plan'by requiring ergency opera ing procedures necessary
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to ope with accidents analyz'ed in the SA5'an'd SER. (SER st 13-34) Thos'e acci!-
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d ssume "no operator action for at lea'st 15
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- .l minute ', and eventual long ter proper operator action.(SER 15-3) Thus, gj y
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y the SER is eficient in the i ementation of the TMI Action Plan a t fails to analyze the con
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s of operator error as described in NUREG/CR/lU gI
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- 3. The assessment of the likelihood and severity of." severe accidents" (or jVN ss 9 accidents) in the DES is inadequate in that it relies for methodology and
,.f 7 probability of occurrence of severe accidents on the Rasmussen Report (WASH-1400)
DES 5-45-66. However, a new NRC report reveals that the Rasmussen method
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ology, at least as it pertains to more severe accidents (total meltdown), significantly w
understates the risk of such accidents by a factor of 20. Precursors to Potential -
Severe Core Damage Accidents: 1969-1979, a Status Report, NUREG/CR/2497
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,1, This report shows that probabilities of severe accidents should be derived on the basis of actual accident sequences and significant events, rather than the Rasmussen methodology. The failure of the DES to incorporate this analysis cripples the entire Class 9 analysis of the DES.
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E.sperience at pvis-Bersc-1 (NBC Res se to Interrogatory 151 s shown that maintenance cri.ical safety related
. pc nents can disru' t t se systems, p
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Nevertheless, e SER c oes not place limitation on the type o maintenance that can b,erformed d ring plan peration.thereb '
threa ing public safet (S
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. 5.
The staff DEIS is deficient in that it continues to base its analysis of the
[j cling pond's effectiveness in controlling thermal discharges (DEIS at 4-6) and 6
ice and fog generation (DEIS at 5-9) on's study based on cooling pond ' performance
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mation from the Dres' den, Illinois nuclear facility (or other data from a comparably
.4 sized and situated facility) for both purposes, and present the baseline data from j
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Q that facility to allow the agency and the public to reach an informed decision on the adverse eUde M the-eeohng-pond.
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Albert T. Howard, formerly of the Z,a Compan has provided a signed
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. i, affl avit to the NBC staff stating that substandard material ave been used in eating and ventilating system of th Midland nuclear plabt that will not be
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ablejo withstand the temperatures,and the radioactive and che'npcal environments, ' '
that ske part of the operating cop 61tions for the Midland nuclearMant. Since these materia s that went into the uctwork are built-in all through the pl t, including all safety ated strue es, no assurance can be giveis for the safe ope -
of this plant as far as the workers or surrounding population is concerned.
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- 7. Tho issue of synergism between chemicals and radiation (Contention 61,
- (old 55) Contentions of Mary Sinclair,1978) must be re-opened based on a new
[f study. Scientists at Sandia National Laboratory, Albuquerque, New Mexico, have j
conducted tests sponsored by the NRC cn polymer cable insulation and jacketing used in nuclear power containment buildings. (Industrial Research and Development, j&{.
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June,1982) They have found ong-term lhses of gamma radiation degrades A
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many polymers more than do $::1 huNdmin stered at higher rates in shorter b) kesting times.
Besides the dose rate effect, the researchers have also found that s,- reistic effects can occur w$en polymers are exposed to radiation and mildly
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elevated temperatures. Dr. Roger Clough, of Sandia National Laboratory, has
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stated that the present testing method underestimates the long-term effects and synergisms that display themselves only in longer tests. This stuoy indicates that y
a the usefullife of the plaht will be shortened considerably because of this problem 9m [4
..,hepng, cooling and ventilatlhgo w cb has b
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for the h'e t stem of the Midland n I 99 nied nen-compliance report with the NRC on or iuuu 1982, indicatin
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