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NUCLEAR REGULATORY COMMISSION g
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May 19, 1981 NOTE TO: Midland Witnesses FROM:
Ellen M. Browdb Attached is an updated version of the contentions.
You will note that Ms. Stamiris has recently added further examples to Contentions 1, 2, and 3 and that she has changed the wording of Contention 4C.
NRC Staff testimony must address these additions-and changes.
If you are not already aware of which contentions you are responsible for, I have placed the appropriate reviewer's name in the margin next to the contcation.
With respect to Stamiris' contentions, we have designated a lead witness for each contention: C-1 and C-2, Darl Hood; C-3, Gene Gallagher; C-4 and C-5, Joseph Kane. The lead is responsible for putting together the input from the other reviewers and providing one document which represents the NRC Staff response to the contention.
Thus, the nonlead witness should provide their input to the lead witness as soon as possible. Testimony on contentions, like your other testimony, must be in question and answer form.
With respect to Warren's contentions, a separate document addressing her j
contentions is not required since she has withdrawn from the j
proceeding.
However, the Licensing Board wants the substance of her d
contentions addressed in NRC testimony. Thus, Messrs. Kane, Rinaldi, and Cappucci should make sure that their direct testimony generally covers the subject matter of Warren's contentions.
If you have any questions on contentions, please give me a call.
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!(0, APPENDIX
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I.
Contentions of Barbara Stamiris 1.
Consumers Power Company statements and responses to NRC
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regarding soil settlement issues reflect a MS wae w-a.c.=nditd.edismeiomso vorw % ;rdnaa t io n
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relevant to health and safety standards with respect to resolving the soil settlement problems, as seen in:
h a) the material false stat (enfent in the FSAR (Order of yoA Modification, Appendix B) ;
b) the failure to provide information resolving (O
geologic classification of the site which is perti-l
'i f nent to the seismic design input on soil settlement issues (Responses to FSAR Questions 361.4, 361.5, j
361.7 and 362.9);
d) the failure to provide adequate acceptance criteria
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(} w\\,ToheadWfor remedial actions in response to 10 CFR $50.54(f) gjdygg requests (as set forth in part II of the Order of jModification);
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and this managed.amcritude-necessitatestscrictertthan u
n (ALAB-106) to assure
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appropriate implementation of the remedial steps required by the Order Modifying Construction Permits,
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dated December 6, 1979.
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Er.amples of CPCo. reluctance to provide requested information
- 1. 3/31/8011RC r:ecting notation of ' Applicant's reluctan:c to provide NRC consultants with requested informatian.
p 2. Vol.111, tab 65 50-54f, 8/6/~[9 meeting, nttitude that "r.ccdlessly conservative decisions may be formulated on
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the 'what if' type ques tions " by the NRC on dcwatcring.
' % 3. The 11/24/80 S.A.I..P. assessment on CPCo - NRR interfacc as presented by D. Hood in the following statements regarding I
soil settlement issues :
" A big contributor to the' inability to make meaningt.1 l
propress in this matter is the cuality of responses I
gotten. We have set some kind of record on the number f
of questions re-asked, which speaks poorly for CP0o-NRR interface....The bottom!!ne is there seems to be a lack of appreciation or support of staff reviev.
l necessities and a tendency to push ahead despite the
!ack of proper assurances."
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4..The perfunctory manner in which CPCo. deponents answered ouest!ons. (1 w11-1 tabulate examples from the depositions I
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D: amp!cs of 'infor' ma't ton w!thheld or incorrectly given:
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,R1. The failure of CPCo. to discuss the Administration
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Pullding settlement problem with the NRC,as they did with their consultants,in the early meetings on the DGP settlement a The false FSAP statements beyond the one cited as a
" mater!al false statement" in the Dec.6 nrder, as discus:.; -
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Y,fr in the 4/3/79 Ecppler-Thornburg meno, and t.he e/13/79 S,k.,,mleaf M Thornburg -Thompson memo.
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2 2.
Consumers Power Company's ggg.b_im.senyttnTP ireuure rnaveras erywadVaFE=l a" affMMre^soAl- '
tio which constitutes a compromise of applicable health and safety regulations as demonstrated by:
a) the admission (in response to 550.54(f) question #1 requesting identification of deficiencies which contributed to soil set,tlement problems) that the FSAR was submitted early due to forecasted OL intervention, before some of the material. required to be included was available; s
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sdea A % comt,ean e.d A b
onkpediency a noted in Consumers Power Company y
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@iti' consultant R. B. Peck's statement of 8-10-79;
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g1 c) the practice of substituting materials for those originally specified for '.' commercial reasons" (NCR QF203) or expediency, as in the.use of concrete 4
\\in electrical duct banks (p. 23 Keppler Report)*;
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d) continued work on the diesel generator building while unresolved safety issues existed,' which precluded thorough consideration of Option 2 - Removal and Replacement Plan; and
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- March 22, 1979 Kehpler Investigation Report conducted by Region III,, Dec.
8-Jan. 79.
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e) the failure to freely comply with NRC testing requesti sA to further evaluate soil settlements remediation, l
(9 inasmuch as such programs are not allowed time for Cay (
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in the new completion schedule presented July 29, d
980.
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- h. Further examples of the effect of financial and time pressures on soil sett!cment issues: Tabit A,...
I 2A. Examples 3!B,Effect on so11 settle =ent i A issues
- 1. 11/7/73 Fechtel action
- 1. Root causes not adec. Investigated, item:' proceed with prepara-Organizational deficiencies not I
tions for preload as rapidly eliminated prior to proceeding as possible" with remediation 1
2 11/7/78 decision to f!!!
- 2. Affected piezometric measurements Y
pond "immediately, because the during preload bCE amount of river water ava!!
4 32 tr#
able for filling is restricted" 11/7/78 "5 month period 3.The surcharge was removed at the tr. available in the schedule end of this 5 months despite gg forpreloading"b p'
lacit of 1:RC satisfaction that j
secondary consolidation was assured
- 4. Failure to grout gr.ps
- 4. pesulted in additional stresses prior to cuttin2 of duct to DGB which could have been NtdE.w[.YoobtMh8%
bank:,failuretocItcon-avoided densate !!nes when 1st
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suggested, fa!!ure to 3
d break _up._mudmat.at.DGB 1
em fCmth k b o een A co o
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l. Choice to continuet
- 5. Eliminated practical cons,ld ration 5
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A construction of DGB of Re= oval & Replacecent Option
\\6.EarlyFSARsubmittal
'M Precluded early detection of and inadeouate review inconsistencies which could have I
of FSAT.
privented'some of the s.s. probicm3
- 7. Failure to reconstruct
- 7. Varying degrees of caution and geometry of area prior to conservatism were foregone in fill placement, @ fure to favor of cost and schedule await N)C~ app'roval before advantages proceeding with PreloaQhdwy\\b.*M selection of "least costly feasible alternative" for DGE.
g re p e,fo 4 % %.1.
[;i 8. Failure to excavate loose
- 8. Contributed to inadequacy Y%>6%
sands as committed to in PSAR of subsoils
'I hu,yht h h60t,l de odnM9F S..Instanlation of preload Q.Expendituresforpreload instrumentation was subject Ins tru::2cntation (CJD 11/1/78 to time pressure assoc. with memo) prior to formal adootica frost protection considerations of preload : aremature commitment 10./,opeals to NRC to consider jf. If granted, would affect u
financial plight and schedule seismic -so!! settlement deadlines as in Seismic standards Ocrerral ihtion
' ! M Q 11. Depth and breadth of
@r, Afforded less than opticura
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surcharge !!mited by practical conditions fo~ surqhar NCE %
M considerrtion of DGB, Turbine B. structures 17.'. Changes to ' design (DGB found-
- 12. Contributed to settlement or stlon), material, or procecdural strets preb! cms and a!! owed I
spcrificatlonr without proper conf!! cts to r.o ynnoticed as apprevt!
preventative indicators
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e Consumers Power Company has nWiuip1'emintieTE(uality
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Es sQrincE P7 air aMYg'aEdinPsioiE'sittidaidntCip sue s r.
accordiner to.riOrCFPP
$ ppendix B regblations,
' $ f) ' 4
'Q and this represents a repeated pattern of quality assur-ancedeficiencyreflectingamanagerialattitude]
2 inconsistent with implementation of Quality Assurance y
Regulations with respect to soil settlement problems, gO since reasonable assurance was given in past cases (ALAB-100, ALAB-106 and LBP-74-71) that proper quality assurance wou,1d. ensue and it; h'as not.
The Quality Assurance deficiencies regarding soil settlement include:
i a) 10 CFR Part 50, Appendix B, Criteria III, V, X and XVI as set forth in the Order of Modification; b) 10 CFR Part 50, Appendix B, additional criteria i
denoted by roman numerals below:
j I.
The Applicant has failed to assume responsibility iI for execution of the QA program through its
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failure to verify and review FSAR statements (pp. 6-8 and p. 2A Keppler Report) and through its reliance on final test results not in accordance with specified requirements (p. 16, Keppler Report);
II.
The QA program was not carried out according to written policies, procedures and instructions, 4
in that oral diYe'ctions were relied upon and repeated deviations from policies occured l;
regarding compaction procedures (p. 9-14,Keppler Report);
(,T VII.
Control of purchased material has not been l
maintained,in that examination and testing of backfill materials did not occur in accordance i.
with regulations (NCR QF29, NCR QF147);
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IX.
Control of non-destructive testing was noc I!j accomplished by qualified personnel using a
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qualified procedures regarding q
i a) moisture control (Keppler Report p.14-16; ll QA Request SD40, NCR QFS52, 172, 174 and 199);
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)4 b) compaction procedures (Keppler Report p. 9; NCR QFS 68,120 and 130); and 5 0 s
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- 1 c) plcnt fill work (p p. 24 cnd 25. Keppler
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Report);.
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XI.. Test programs did not incorporate requirements and acceptance limits adequately in the areas referenced in a, b and c above,, and do not meet these requirements regarding soil settle-ment remedial actions ;
XIII.
Measures were not adequately established to prevent damage or d'eterioration of material
'regarding frost effects on compacted fill (pp.16 and 17,.Kepp,ler Report);
(Q XV.
Measures were not taken to control non-conforming material in order to prevent the inadvertent use (NCR QF29 and QF127);
c) the settlement of the Administration Building in 1977 should have served as a quality indicator,
'l preventing the same inadequate procedures from occurring in the 1978 construction of the diesel j
generator building causing its eventual settlement.
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JE. Additional CA defic!cncies from the period of 1980-1951 re l at ing, to soll setticment Issues are set forth in NRC I.B. E. Reports, 6
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Sc-32,and 61-01; in S.A.I..P. assessment of 11/24/80; CPCo.
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acport 15.4.3.6 and NCR 3401. This 1Isting of addIttonal j
deficiencies, although tentative,. Is as complate as I i
i>l' can be at this time.
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.j, actionacregardifffii3115'-settle 5sEnt tYiat'are: Gadiga,j;,e 4 s;-
4 as presented because:
A b
A.
Preloading of the diesel generator building a%,%"d y M $b5 7
1) does not change the ' composition of the improper
~f soils to meet the original PSAR specifications; 2) does not preclude an unacceptable degree of further differential settlement of diesel generator building; p
does not allow prop:er evaluation of compaction 3) 3 precedures because of unknown locations of cohesionless soil pockets; Al$$
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4) may adverse affect undprlying piping, conduits
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(q or nearby struc(Mid MM.[d e
O Ou9W h'.6Tf ures; A
- 5) yields effects not scientifically b#
isolated from the effects of a rise in cooling water and therefore'% o a not measured properly ;
B.
Slope stability of cooling pond dikes is not assured
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/ because they were built with the same improper j
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s soils and procedures (NCR QF172);
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C.
Remedial soil settlement actions are based on untested j, g " g q t.-
assumptions and inadequate evaluation of dynamic
! M'**h, pst4 responses of those structures to such things as M
R,Gonnoles J.fone.
I dewatering, differential soil settlement, and
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p 5.%W seismic characteristics:
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Auxiliary Building Electrical Penetration Areas and Feedwater Isolation Valve Pits r
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Service Water Intake Building and its Retaining Walls l
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Borated Water Storage Tanks d.
Diesel Fuel Oil Storage Tanks; bum tMe, be b
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rf contention 4, part c should read," Remedial, so!! settlement
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actions are not based on adecuate evaluatton of ynamic responses s
recarding dewstering effects, differential so!! settlement, and
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seismic effects for these structures: a. Aux. Bldg. Electrical
'N Senetration Areas & Feedwater Isolation Valve Pits, b. Service A\\
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- fater Intaks Building & its Retaining Walls, c. Borated Water l
Storage Tanks, 'd. Diesel Fuel o!! Storage Tanks, e. D.rB, f Reinted fp 1
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D.
Permanent dewaterin's",...
- 1),would change the water table, soil and seismic characteristics of the dewatered site from their s
originally approved PSAR characteristics -
characteristics on which the safety and integrity of the plant were based, thereby necessitating a reevaluation of these characteristics for affected Category I structures; h%e.ded 2) may cause an unacce able degree of further settlement in safety related structures due to the anticipated drawdown effect; bpnk on kJ kh.hf@ -no$r yeed t' nod'd t.
3) to the ex ent subject to failure or degradation, would allow inadequate time in which to initiate shutdown, thereby necessitating reassessment of these times, ti Iy Therefore, unless all the issues set forth in this j
contention are adequately resolved, the licensee i
l; actions in question should not be considered an accepta-ble remediation of soil settlement problems.
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NT C.f b w M t ied % co on cooling pk - bifM4 f,
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MCb COO dub g chnN nut conduPoru Jncl ONutg,p rwCN ko CY(}(C QV10
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6 5.
The addit'ional information and testing requested of Consumers Power Company by the NRC and its consultant, g
the Army Corps, of Engineers, on June 30,,1980 ar.d
\\ ugust 4, 1980, is 'ssential to the aff's evaluation A
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of Consumers Power Compac sr dial soils settlement i
action.
Without this info tion and testing, the h
Staff does not have r sonable surance that the
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plant can be ope ed without. undue risk to the health x
Ahg and safety of/the public (part II, p.1, Order of Modifica
).
The requests must therefore be responded
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to fvfly and complied with totally.
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Contentions of sharon K. Warren 1.
The composition of the fill soil used to prepare the site of the Midland Plant - Units 1 and 2 is not of sufficient quality to assure that pre-loading techniques have per-i, manently corrected soil settlement problems.
The NRC has indicated that random fill dirt was used for backfill.
The components of random fill can include loose rock,
,i broken concrete, sand, silti, ashes, etc. all of which
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cannot be compacted through pre-loading procedures.
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A.
Because of the known seepage of water from the cooling pond into the fill soils in the power block area, permanent dewatering procedures being proposed i
by Consumers Power Company are inadequate, particu-larly in the event of increased water seepage,
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3 flooding, failure of pumping systems and power outages.
Under these conditions, Consumers cannot provide reasonable assurance that stated maximum levels can be maine'ained..
Gentrol SOme#5 htbow d vd kd No h/ )4b,079 I
B.
Give U he facts alleged in contention 2.A, and con-sidering also that the Saginaw Valley is built upon (O g#
centuries of silt deposits, these highly permeable soils which underlie, in part, the diesel generator
. building and other class I structures may be adversely
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affected by increased water levels producing lique-g4 faction of these soils.
The following will also be l
affected:
1; 1) borated water tanks
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2) diesel fuel oil tanks.
3.
hre-loading procedures undertaken by Consumers Power have A4 induced stresses on the diesel generating building struc-A$
ture and have reduced the ability of this structure to fC perform its eks nNa1 functions under that stress.
Those
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remedial actions that have bee taken have produced w4w uneven settlement and caused indrdinhte stress on the
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structure and circulating water lines, fuel oil lines, and electrical conduit.
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24.
The pres n site,,for the Nid nd ' c lity is forth i Conten-
" not only inappropriate for the reasons se
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tion 9, but also af f rmatively unsafe.
Serious _uestions-have been raised conc crning the ground tabilit of portions j
of the site.
At lease on'c of the esser tial b ldin,gs of the
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c struction has
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ported s
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been halted on that b i
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A a resu t.of the serious ndsktbility,QWl%
concerning gr and unresolved oue/stion
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- 0. 57 h) f 3) t.iie findings required by 10 C.P.R.
5 an Je (facunty'
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- 50. 57 (a) (6) can n t be made.
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Co.:ention 22 1
his contention,waich sinply asserts an inadequate discussion of
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- i the character,and effects of low-level radioactive wastes, is rejected
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as he'r.3 nsufficiently specific. -
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I Contention 23 a..
"I Tnis contention uust be rejected as ncn-specific. B e only specific example cited--that certain questions were unanswered at the time.of preparation of the contention--is 'a normal sit,prinn at that stage of a proceeding and not an adequate basis for a contention.
j Contention 24 ACC"f
,b, Tais contention, not objected to by any partf, is accepted except to the extent that the first sentence refers to previously rejected botention 9. Bis acceptan'm, however, is further conditi6ned by our_
- a. :teemnt with the Staff's c
.c (Novesiber 28, 1978 response, page 6) thit the question appears not to be one of site suitability, but rather of ti.a type of material used by tha Applicant under the building in
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- j A suitable restatemnt of the contention shall be provided-question.
by the Intervenor at the time required by the schedule below for j
_ snWsion of other restated contentions._ _.
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. l' 'l Contention 1.-
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This contention asserts that radi,oactive spills from j
Palisades plant indicate that the sa'me experience will a
1 take place at Midland. ' It is den.'ed kor irrelevancy, lack of-j basis, and because the issue of radiological releases from Y.idland is res judicata.
Contention 2 1
Thih is the same issue as Sinclair contention 24.
3 It is accepted as it relates to settling of the Midland 1
.1 diesel generator building.
1i Contentions 3 and 4 e a y f,MQ 3, ono 3,,no, Y3 C0/1 fylq(5 a j' Q Occ.3li l
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- x MAPLETON INTERVENORS i
Route 10
. Midland, Michigan 48646f2D m
M NOV 8 kJ 8 34 eb s
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October 31, 1978 f
UMIC-0 ELD Fr. Ivan W. Smith, Chairman h
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Atomic Safety & Licensing Board Nuclear Regulatory Commission c.
d Washington, DC 20555
Dear Mr. Smith:
' In compliance with requests by'Mr. William Olmstead of this date and in accordance with Nuclear Regulatory Commission Rule 2.714, the Mapleton Intervenors are submitting the following additional 2
contentions to support our previous contentions submitted on
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September 6, 1978.
Under the rules, the Mapleton Intervenors contend that:
1)
Illega @ otive chargel and spill from t lisades c
ar FowerA)@n ra on ro i
ic ive r@
wI a
a Mid1 clear
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Power facility.
y Present geological conditions, according to' newspaper t
' (h. p
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accounts, is causing the settling of the generator building q
Et the Nuclear Power Plant site.
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Cite 3)
Michig aw prev the lice of a nulsigan Cp]urt
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11 s.
sume s Pow ompan in rJ
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Appea on nuisan L
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4)
The eton rvenors en that th e
tion of t nt il aus nuis e'that ill urb eir e
j and r
uili g
. anteed b th nited S a onstitution fl l
and the St of Michigan ws..
M f
Icing and fogging will interfere with Mapleton Intervenors
,4 Il 5)
This was pointed
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lives and will damage their property.
j out in Midland, Michigan recently when the Nuclear Regula-
} 'hy tory Commission was obtaining information concerning the 1
operation of the Plant.
tien of the'P 6)
Stora f spe ne rods fr se w
ose ealt. and
.ety haz' d on the Izens d
side within
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%p cif c y on Ma et5n Interveno w
1-1/2 es of the Oint.
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. fr Ivzn W. Smith.
Atpmic Sofoty & Lic ncing Board
?- Octob2r 31,1978 Page 2 7)
P ese g techn g
prevents r power s
- a. ion z
o emi n, t ref the crea ion l
f of - )co L M nuous uis e and a
azard to the Ma n Inte s.
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With the above contentions which will be properly formulated for j
the Operating Hearing, the Mapleton Intervenors respectfully ri
. request that these be considered.
Sincerely, y
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