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NUCLEAR REGULATORY COMMISSION 3
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DCT 221982 P in tral M h
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MEMORANDUM FOR:
K. Steyer, Chief at l
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,I'O l-C.iemical Engineering Branch, RES R. Warnick, Acting Director Special Cases Staff, RIII FROM:
Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing
SUBJECT:
MIDLAND INTERROGATORIET Enclosed are additional Midland interrogatories submitted by intervenors Barbara Stamiris and Mary Sinclair. The reviewer assigned to answer the Stamiris interrogatory is Frank Cardile. The response to this interrogatory should be forwarded to Melanie Miller by November 22, 1982. The Sinclair interrocatories have been assioned to Wayne Shafer, RIII. Answers to these interrogatories are not_reouired until the completion of the related NRC investigations in Januarv lort If there are any questions contact Melanie Miller, Extension 24259, or Darl Hood, Extension 28474.
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Elinor G Adensam, Chief Licensing Branch No. 4 Division of Licensing
Enclosures:
As stated cc:
'W. Shafer F. Cardile j
W. Paton l
M. Wilcove j
N. Wright
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U.S. Nuclear Regulatory Co= mission In the Matter of Docket Nos.
CPC Midland Plant 50-329 OL Units 1&2 50-330 OL [,-/.)/M
.k II70?.E ThE ATO.*1C SnFi.TY /JiD 1.1CENS!I!G BOARD
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ST./.1R15 DISC.'// R': TO ::RC *..'.5Eh Gi NEV1 liiFDR:.U.TICU IN FES Y
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W (Stamiris 8/30/81 Interrogatorf.. definitions contained an erros.
In line 2 substitute "NRC Staff" for "CPC/Bechtel or other plant g
e=ployees. Definitions apply henceforth as corrected.)
Contention I b.
In the FES,(p5-51) the NRC states,"Since 1960, 68 nuclear reactors 1.bave.bcen or are in the process of being deco =missioned.
Although no large commercial reactor has undergone decommissioning
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to date, the broad base of experience gained from s= aller facilities is generally relevantto the decommissioning of anyytype of nuclear facility.'
Interrogatory 1 Name the reactors from this group of 68 which have been or being decommissioned by the prompt removal / dismantlement _ method are and provide thefr: a) datacdf completion, b) cost af co=pletion, c) megawatt capacity (or other description of size), d) data of decommis-sioning, a) cost of docccmissioning, f) d.ecommissioning cost as % of construction cost, converted into like completion year dollar values.
(Ple ase explain this inflation-conversion calculation.)
g Respect'. fully Submitted, cc: ASI.B members W. Paton, NRC Barbara Stamiris M. Miller, CPC Secretary,NRC
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4 // C-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS$ ION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
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Docket No. 50-329 CONSUMERS POWER COMPANY,
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50-330 1 pl) do its 1 and 2))
Operating License aio (Midl nd Plant, Un Nt (C Vm
[D INTERVENOR MARY SINCLAIR'S INTERROGATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF ON CONTENTIONS 6, 8, AND 16 FF ft*f C Ocf.l219 During the conference call on August 20, 1982, the Board set September 20, 1982, as the date by which interrogatories on the Zack issues were to be completed.
Intervenor Mary Sinclair submits the following interrogatories concerning her I,I.:f Contention Nos.
6, 8 ar.d 16.
y INSTRUCTIONS FOR USE c:
i The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Nuclear Regulatory Commission with personal knowledge of the facts or information requested in each interrogatory.,
The following definitions shall apply to these interrogatories:
I 1.
" Document" shall mean any writtep or graphic matter of communication, however produced or reproduced, and is i
intended to be comprehensive and include without limitation i
any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda,
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electronic or by other means, computer data, computer print-outs, l
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photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, oMers, confirmations and all other written or
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graphic materials of any nature whatsoever.
2.
" Identify" shall mean with respect to any document, to state the following respecting the document:
its title, its date,'the author of the document, the person to whom the document was sent, all persons who received or revieued the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.
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3.
" Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; any document recording or_
documenting such action.
4.
Describe" with respect to any action or matter shall mean state the~ following regarding such action or matter:
the i
i substance or nature of such action or matter; the persons
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participating in or having knowledge of such action or matter; I
l-the current and past business positions and addresses of such
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relating to such action or matter.
persons; the existence and location of any and all documents' l
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3 INTERROGATORIES 1.
Describe any information, problems, allegations, or documents provided to the NRC by Dean Eartey from 1980 to the present.
2.
Describe any official or unofficial response or action taken by the NRC in response to information provided to the NRC by Mr. Dartey.
1 3.
Describe any action taken by Consumers Power Company
(" Consumers") in response to Mr. Dartey's disclosures or to actions taken by the NRC from 1980 up to the present.
4.
Identify all documents provided to the NRC by Mr. Dartey that demonstrate or substantiate the allegations he made about problems at Midland.
5.
Identify all documents inspected or collected by the NRC to investigate Mr. Dartey's allegations.
6.
Describe what investigation if any the NRC made of Mr. Dartey's ' allegations of prcblems at Midland and identify any report on the investigation.
l-7.
Describe any action taken by the NRC to remedy the..
l retaliation taken against Mr. Dartey.
Under what authority did the NRC chose to act or not to act to remedy such retaliation?
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l 8.
Identify any conclusions the NRC reached after i
investigating Mr. Dartey's allegations if not contained in i
its investigative report and findings.
9.
Describe any correetive actions the NRC recommended
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or esodred at Midland after its investigation into-Mr. Dartey's allegations or charges of problems.
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10.
From 1980 to May 3, 1982, describe any other report of problems or allegations of problems reported to the NRC l
by any person concerning deficiencies in the QA program at Midland, including but not limited to allegations about improper l
t procurement; improper document control; improper control of material, equipment or services purchased from vendors; improper inspection or handling of nonconforming materials; improper, deficient, or insufficient audits; or improper documentation or documentation systems.
Regarding each such allegation, state whether or not the allegation or information was disclosed prior to disclosure to the NRC to Consumers, the Bechtel Power Corporation ("Bechtel") or to any Consumers' mr-Sechtel contractor.
s 11.
Describe any action or investigation by the NRC in response to the allegations listed in Interrogatory No. 10 above..
12.
Describe any action taken by Consumers in response either to disclosure of any such allegation listed in Interrogatory t
No.10 above, or in response to a requirement or response of -
the NRC to such allegations.
13.
Describe any and all NRC records or documentation -
of Mr. Howard's allegations of deficiencies in the QA program at Zack and at Midland.
14.
Identify all documents Mr. Howard gave to the NRC to substantiate or explain his allegations of deficiencies in the QA program at Zack and at Midland.
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15.
Describe the scope of the NRC investigation of deficiencies at Midland, including but not limited to the scope of its investigation of problems with QA documentatica; problems in the approved vendor lists; problems with harassment, intimidation and retaliation against employees disclosing
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deficiencies in.the QA program; and inadequate training of QA personnel.
16.
Describe any and all documents reviewed by the NRL relating to allegations and charges of deficiencies in the QA program at Midland and in Zack.
17.
Describe what if any conclusions the NRC has reached about deficiencies ~1n the QA program at Midland, including but ne:. limited to conclusions about retaliation against Zack and e ther employees at the Midland site; deficiencies in QA documentation; deficiencies in approving vendors for the approved vendors list; deficiencies in ensuring materials conform to Consumers' and Bechtel specifications and to all NRC requirements.
f 18.
Identify what if any action the NRC has taken or intends to take to remedy or respond to the findings listed 1
in Interrogatory No.17 above.
19.
Describe any and all documents or oral communications received by the NRC from May 1980 to the present, from Consumers, regarding deficiencies in the QA program in Midland.
20.
Describe any and all documents or oral communications received by the NRC from May 1980 to the present from Bechtel regarding deficiencies in the QA program at' Midland.
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21.
Describe any and all documents or oral communications
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receive'd by the NRC from May 19'80 to the present from the Zack Company or any other contractor of Consumers or Bechtel regarding deficiencies in the QA program at Midland.
22.
Describe all corrective actions taken by Consumers, Bechtel, Zack, or any Consum'ers' or Bechtel contractor to
- remedy the problems raised by Mr. Howard in his affidavit.
23.
Describe all information the NRC currently possesses concerning the Zack Company's purchases of steel from U.S. Steel for 26 purchase orders at three plant sites including Midland, referred to in Mr. Howard's affidavit.
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24.
Describe all information the NRC currently possesses about the Delta Screw Company and any other vendor who was placed or maintained on the approved vendor list even though it did not comply with applicable'NRC requirements.
25.
Describe all information the NRC currently possesses about the December 21, 1982, letter from Bechtel to Zack that labeled reported deficiencies as " paperwork problems" as referenced in Mr. Howard's affidavit.
26.
Describe all information the NRC currently possesses 1
about the Jack Company's report on QA deficiencies at Midland, including but not limited to the report reviewed by Mr. Howard i
on Novmeber 30, 1981, and the Calkins report received by Mr. Howard on November 30, 1981,_ describing the QA program i
breakdown, both referenced in Mr. Howard's affidavit.
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27.
Describe all information the NRC currently possesses N
about Mr. Howard and other Zack employees' reports to Zack management about nonconformance of materials delivered to i
the site or deficiencies in the approved vendor lists.
28.
Describe all information the NRC currently possesses about the November 5, 1980, Bechtel letter to Zack referenced in Mr. Howard's affidavit.
29.
Describe all information the NRC currently possesses about the September 1981 letter from Zack to U.S. Steel describing a " serious misunderstanding" regarding purchases of steel for 26 purchase orders at three sites, including Midland, referenced in Mr. Howard's affidavit.
30.
Describe all information under the custody or control of the NRC concerning the inadequacy of training of Zack, Bechtel or Consumers' personnel.
31.
Describe all information the NRC currently possesses concerning the MPQAD allegation system.
32.
Describe all information the NRC currently possesses ahnut alleged retaliation taken against Mr. Howard because l
of the allegations he has n.ade.
l 33.
Describe tne NRC Staff position with respect to i
Sinclair Contention 6.
In addition'to stating whether or not l
l the staff will' support or' oppose this contention, identify.
all documents upon which the NRC Staff intends to rely and t
any facts or opinions which support the Staff position.
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' Contention No. 8 34.
Describe any and all information the NRC currently has obtained about the failure of shop records to match QA i
records at the Midland site.
Identify any and all documents 4
relating to these failures or deficiencies.
35.
Identify all NRC requirements violated by such failure of shop records to match QA records, a's described in response to Interrogatory No. 33 above.
36.
Identify any and all conclusions the NRC has reached concerning the failure of shop records to match QA records, and any action or intended action of the NRC in response to such failures.
37.
Ident1fy any corrective action taken either by Consumers, Bechtel, Zack or any other contractor to remedy the failure of shop records to match QA reccrds.
38.
Identify all instances of which the NRC is aware in which Zack has failed to file required reports on welds, welder qualifications, or welding procedures.
Identify all documents relating to such failures, and any NRC requirements which are violated by such failures.
I 39.
Identify all instances of which the NRC is aware in which Zack has filed erroneous or falsified reports on i
welds, welder qualifications or welding procedures. Identify all documents relating to these failures and any NRC~ requirements I
which are violated by such failures.
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40.
Identify what if any corrective action -the NRC has ordered or intends to order recarding the failures listed in Interrogatories Nos. 38 and 39 above.
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e 41.
Describe any allegations received by the NRC from 1978 to the present regarding failure of shop records to ma'tch QA records at Midland.
Identify all documents relating to these allegations.
42.
Describe any corrective actions ordered by the NRC or taken by Consumers, Bechtel, Zack or any other contractor at Midland to remedy any failure listed in Interrogatory No. 41 above.
Identify all documento relating to such corrective action.
43.
Describe NRC procedures from 1979 to the present to monitor or check whether Zack and other contractors at the Midland
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site have complied with NRC requirements, including the QA record-keeping requirements.
44.
State the NRC's position' with respect to Contention 8.
In addition to stating whether or not the NRC Staff supports or opposes this contention, identify all documents upon which the NRC Staff intends to rely, and all facts and opinions which support its position.
I Contention No. 16 45.
Describe all information the NRC currently has about welders who are unqualified to do fabrication welds at Midland s
or whose qualifications are not_ verified for fabrication welds.
l Identify all documents relating to such welders.
i 46.- Describe all-NRC requirements violated by welder's-l
'b who are unqualified or whose qualifications are unverified-l
- i to do fabrication welds.
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Describe the number and location of all welds potentially affected by such unqualified welders.
Stat'e whether or not each weld is currently accessible for inspection and/or rework.
l 48.
State the NRC's position with respect to those welds which may be affected by unverified welder qualifications but are no longer accessible for inspection or rework.
49.
State the NRC's position with respect to those welds which are currently available for inspection and/or rework.
50.
State the NRC's position with respect to Contention 16.
In addition to stating whether or not the NRC Staff supports or opposes this contention, identify all documents upon which
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the NRC Staff intends to rely, and all facts and opinions which support that position.
51.
Describe any other reports received by the NRC from 1979 to the present about unqualified welders or welders whose. qualifications were unverified.
52.
Describe any investigation or action taken by the l.
NRC in response to the Part 21 report referenced in Contention 16, and all conclusions reached by the NRC about the problems described in the report.
3 53.-
Describe any corrective action ordered or intended to be ordered by the NRC with respect to the problem described in the Part 21 report.
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54.
Describe any action or response by Consumers, Bechtel,
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in the Part 21 report or to any NRC investigation or action concerning this Part 21 report.
Respectfully submitted, i
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AJ Lee L. Bishop /
HARMON & WEISS 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070 e
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I CERTIPJ CATl; OF.31:1<1 VCE I hereby certify that copih of the foragninn n.'i s e.'.
e Contentions of Mary Sinclair, Interrogatories to Consumers Power Co. on Zack Issues, Interrogatories to NRC Staff on Contentions 6, 8, and 16, Resubmission of Contention 56, and Response to Second Set of Interrogatories have been served on the following by deposit in the U.S. Mail, first class, this
'20th day of September, 1982:
Charles Bechhoefer, Esq.
Frank J. Kelley
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A &.ir.istrative Judge Attorney General of the State k'
At:'mic Safety and Licensing Board of Michigan U.S. Nuclear Regula. tory Comission Steward H. Freeman Washington, D.C.
20555 Assistorit Attorney General Environmental Protection Division Ralp5 5. Decker Ad:.iinistrative Judge 525 H. Ottawe St., 720 Law S1dg.
Lanting, Michigan 48313 Routc e4, Box 1900 Carbridge, Maryland 21513 I
Dr. Frederick P. Cowan i~
Administrative Judge i
6152 N. Verde Trail Michael I. Miller, Esq.
Apt. B-125 Ronald G. Zamarin, Esq.
Boca Raton, Florida 33433 Alan S. Farnell,' Esq.
Ishars, Lincoln & Beale Dr. Jerry Harbour Three First National Plaza i
Adeinistrative Judge 42nd Floor l
Atomic Safety and Licensing Board Chicago, Illinois 60503 U.S. Nuclear Regulatory Comission j
Washington, D.C.
20555 James E. Brunner, Esq.
l Consun:ers Power Corpany
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?l2 k'est Michigan Avenue Jackson, Michigan 49201 t
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