ML20093N920

From kanterella
Jump to navigation Jump to search
Discusses Status of Efforts Re NRC Midland Findings Due 831115.Requests Meeting at Earliest Date
ML20093N920
Person / Time
Site: Midland
Issue date: 09/23/1983
From: Hood D
NRC
To: Paton W, Wilcove M
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19258A087 List: ... further results
References
CON-BX17-041, CON-BX17-41, FOIA-84-96 NUDOCS 8408020202
Download: ML20093N920 (7)
v • d • e


Text

[?

s September 23, 1983 Note to: Darl Hood Project Manager - Midland From:

William D. Paton Michael N. Wilcove OELD

SUBJECT:

STATUS OF MIDLAND FINDINGS This is a report on the status of our efforts with respect to Staff findings which are due on November 15, 1983.

Consumers Power Company (CPC) filed ~ its proposed findings on technical issues (they exceeded 300 pages) on Friday, August 5, 1983. We had a copy in our hands on Monday, August 8,1983 and had copies made and distributed to all witnesse's and reviewers during the week of August 8.

We spent some time talking to George Lear, witnesses, and reviewers to describe the type of help we needed to review CPC's proposed findings and prepare adequate responses. Last week we received Ray Gonzales' coments with respect to dewatering. Ray agreed in full with CPC's proposed findings except for one portion of paragraph 456.

Ray gave us a complete explanation of that problem.

Last week we also received Jeff Kimball's comments with respect to seismology. Jeff gave us 30 comments and each one pointed out the

. precise portions of the record that were involved. His comments.were very helpful.

Joe Kane and Frank Rinaldi have committed to giving us 60% of their connents by the end of September. They have also stated that they will provide us before that time whatever comments they can.

In fact, we have already received a number of comments from Joe. Frank advised that he has finished 30% of his effort and expects to have that report to us this week.

Paul Chen (piping) is presently in limbo because apparently there is no contract between NRC and ETEC. The mechanical engineering branch offered hope that this can be resolved by the first of October. That will likely present a time problem.

8400020202 840718 hE 6

PDR

.c

-, ~ - -. -

- - ~ ~ ~ < * - ~ ~ - - - -

- ~ ~ ~ - ~

- ~ ~ -

s...

We recognize that the Staff has other commitments. However, as you can see from the above, we are not-in good shape. Half of the fourteen weeks available are gone. We would like to discuss this with you at your earliest opportunity.

[

William D. Paton I

t

~

kW/

W Michael N. Wilcove cc:

E. Adensam J. Kane (5 copies)

F. Rinaldi (4 copies)

M.~ Hartzman (3 copies)

P. Hadala G. Harstead J. Brammer S. Poulos P. Huang P. Chen.

R. Samuels J. Matra D. Hassell H. Singh J. Rutberg P.T. Kuo G. Lear M. Wilcove N. Wright t

e b

o e

4 p._-

J

& t %. _ m.... m s m.

..c

. _.m.

Mie-1 KA som -

y g

~&':,> :u-).

w on+<-

- r

'jf m,.,,: a Ohb.S l lon Wl

@d (C, o

(A D d (Ute R or1 t.

fifs ndca\\ s4 o-d a cornpc= ph.

n

(* ty ;,,

i.

?

O h

Qh D

D h

(A IO l

h G

t 3 son Asaa p h k e 4 h des o 6.A M.L 1.

m a p t< engineen, evo6b, q.h ypchd SI f

.:q vnchno trop.vb (e. 3. mmpshlk Qs6v shnykk y

i 71 ama h neorn w w phn A cL on., h cky ec ai j2 inphnb a sbdom\\ onops h % hp 4 wnshbn wld asolhn a se ksip bb accey me h % en3inarin3 p'un.

1 donh%hskyse \\ epnmn kt % cod!aenr9 d Ae t W

\\ sW?s an.desen deiaeocses' d-Rd <><.ws Ny 3

4,r s duussd h Magae.3 4 ut4 tw Ab

'n-

%.3 ansde< % % 6%, %ae-es.

41.

t 4

~;4. Je gm

. - + t. <;:

e.4 7.]

b

  • 5~
- (

._,t

.=*1 u.

..._7_.__.._...,..--

r

T.

  • L4l _

, i,; q [%,

+

, ~ '--.

.\\. '

'o**,

.{ - :(;

  • p -..:.:.-.

.=

...... ~. -.

=.-

1.-

h s ma o % a u s v.a,,s W 3

I i

oc mding 4 w vc wat m opee~xter $cK.

RC cow wh ick appcd tK hd$ 4wumbiA whlech hs.

bstd M.\\v3ca h uA reuw %-enh na whduk Jud seh%s e cyc Fi,di33 4 Ads %bc 1L 3

\\ bab in a atmed 4 and whet, m 6e woums (w, e an

. ~

h h* h yns ' ems). h h h Ib,m3 4% wi<m3 N weec g

Sq be h,ee:546<.3(asAu) t pJ h.i 2 p& gM c dlechmenI.ha$c 3Yl.\\%dec t e.

Vtde. O m rnewh in E-Pos)4

%.4 c pd,,3> A e

mau uma blMkcM e y(6Abt eAhbk ho fc@tWf6.(udvcli Q/h eddih) cap <al noe sAs %+ some<ms A kw awa mes coec.le3cn f e h6LB %J A.b. 6, i

~19 order 4

p 1

e3 aest44 I4 o na m.eso<3 % + rmem a pov 4 iny h ying dhJun soyyd 4 shptdiom.

-..m

-._,.m._.

'O...' -.5.i I _..

_I :_2 1.

i Il

.i kK Fmcm3,s 4-E.ts - Micitartot ~

4 Y*

\\

9.a

\\b Om

(

Tde4 4 4at ma ma A,t onc Le A:est 4

QA Wh Magreemed (q5,2 3

i GEL 3 send p%umeaI % e @NZ D MehlehGELD Sep. " 5, \\

h flo e \\ 4t $W"n' b d TP (o o k 4 i n g t Y

R n ]4 1 g i-

~

- G Mo, s%3 y

100% h)~yd $

cd. LS, MD u, o_a h sa

/7

.kCO( 'Mn d

d,a d a M k d%

~

3 ma

?,ps j

i l-

.e

.;f i

J

(r_

L W:7 :$; '.

T.x-k h, C g w d.d D. N b. W qQ on r 10:1 a\\i.) S3

' CM f;'y>f) t4 J,44 r;:.;.;d o!y:

bm s b% Ll540n3 c d QE.\\ Nn[ibC l',

L3IFo$n3

-9m@e.jlto % y o O

40 3

a M

m, wp4 TenOJek I% hhw}ng tu,dJA Wlk h hllaWeb *

- ht, sq% %e aan 4 mpnAk()h cec 4e h pom

/M~s

.aviece wii aew L A Amy NH og ca A 3

.K. as u4 h

C. ~ ]

W.bbn h id nkh h revteterd fo< egcl, ;aggQ

~

w4w

- %,e m u aeta,mh a ue e31 prayayL, o

c) are rpem\\

Eo,4

artua, 3;

< p r a r a + ya x.

y ep - n re, ewe a a ~

g..

k idedt g hd,sg%ic_ (brns Whicf1 ort )eY accdhl}e li 1

6..wacwa, Meme h, omeon's, $ pb n>,seulin3 h m,e4 3

n d auweh or reasonab. reyese Anon e} s

_d

- eet9 w,1\\ reseuch % %menph & Ne ctau J,e,e a

Y dhms 6tbeen dev.hhed h N. sM raitwer and ernt Ec b 6snss % % s w g ch M D p u ut a ims 7 t

H W M Ynca

c. dLscVSSM Ws% ShM (eViewe t)Ga.DdEh s

ff

(~%k 5%vens o<t stqnheont ore wona new-bajw a

(

e 70 $

{h(,.VM

~

- NR(., Endsn3s vai)} yeeni hh4)'s vosdion ad airo o

wsdwidual remwers 70sihoas,t} dipent 4-opcial

.e de piho.

3

- bs ma is esu ah a gac co,yA L

  1. 9 inA m s m iew 4 solumimes w e,mg reeds em p y

?

Ji eliew ch )C4 conce.vns odihno, M ?> hv,in$ sesstons 3

.?1

%4scbMd

- bb 43.and obv we<( outed a dog ruiewens (% 7 j

be y tpc La 4

. +.

o v.

' +--

7 m--

.Si '.

v.. :?' '

?l$ h !

  • l l' -
Y-9

.m.e

.__,.m~

' { * '*

\\L,

  • 2;;,;j;;;

. _ _fP :-

l Qk$ _-. * * * <m.; 7, -ya.s.h$.[

" ~

'N'd u

,3.

t W#

k Q^'h:I p:e.w' j

^

q j,?

[& ~:.:..

dN-y., ; '..

RECORD OF TELEPHONE CONVERSATION f.::pg-ij w

DATE:

7- %~b PROJECT:

0 b +t zc

\\

i ge:qw RECORDED BY:

).

Ont CLIENT:

g L.

h T.U.KED WITH: Q.Mqb.3 0F Nd u,e i ;g:

7,4 ROUTE TO:

INFORMATION ACTION

[d[.M L.y\\db.

~'

}1 G. Lea r rg};

],y

.a.2 '- i '

- To mk.rm b M d. A'0,9,0y a:w., td CEG i

. d. '

MAIN SUBJECT OF CALL:

P

% hdiw,s %dios chEch 1

gs n

W.Pcb denied d.Nou tLd Conwme N FindiSs

,1 ITEMS. DISCUSSED:

h[ >

4 bd o^ h b Wh'*bd ca bat IC 3 ti$. Ec h u n g b % b nii b 5 r

j.-

3.6 wh k osced hs nw QC Finkmn a,d he,n<hwA h%

oEt.b h Acctdt in dd wmne NRc'u:>s6 h fehow m cowkhnq b< b. \\inu A b b N Jeh_ Gea inds,sr

[V

(

)b L

s e u.w Eh bN Ih i.OELS d preps memc k 3.Enqu ide nktbiqdd ehuis k G65 dM j?fd cov. nudd cm.d m whd hme komt: b u/ Oft. u te b< e ykfect.

m

-.;.$[

'l. c m.t.b m h Jiceword to d%om o hs4 4 A c<sf perd3Gwd.aN i

gi hb es sceu,4 %cco f%es W< D'one % iden% 6t bnscapb

[j]

c<e riedd Jfor c& YMew c}. b hdincg d hhh tdgnhpd p

b u iyh w.A\\ 6 h ye &d h cat.

1.m a

(. ;:). ! }

L ',.,

.(

p-

,t'

~

f' s

\\-

-i 1

1 5

l Gl2 h, h.ifN% /

-.,9.%.'.?,lfm:z.. ?.,; ?kW : h O }fQi,y;s.i

. L.

,~:..e p.nn,.. m-..

s, w, :.,.-

vn.

n.

g -S;,1%,.

.g;;r,. l;;:.... <

. ~. 3 v..sg y.;g __ _

qg

. ~. ~.........

.w

. [ h O Yrityt 5 E in d u S 5 c. E g oI M

Ad i3 e4

/"'

00CXETED

\\

'JSNRC

~

U.S. NUCLEAR REGUIATORY COniISSION

'83 DEC 19 All:13 Serge the Atoalc Safety and Licensing Boarxi In the. Matter of Docket Nos. 50-329 OM-OL 50-3.30 OM-OL CONSUMERS POVIER CO.

Midland Plant,. Units 1/.2 INTERVENOR PROPOSED FINDINGS OF FACT.AND CONCLUSIOJS 0F LAW ON. REMEDIAL SO'ILS ISSUES..

2 Decembe'r IG, 1983 b

_t-

$Y2111 i$ 2

~

Barbara Staniris 5795 N. River Freeland, Mich. 48623 h

PDR ADOCK 05000329 0

PDR A

A a

a O

e.

%./k v 'v TT""

(39 9

'y.~. a.: =. ~.

..w E.. :.,. A..- ~ ----- - --- L -.. -

^

-~a~~--

I-Intervenor Barbara Stamiris submits.the following brief, resconse td the 'Anolicant's Proposed Findings of Fact and Conclu-sions of Law. The roman numerals in parentheses correspond with those* sections of the Applicant's Proposed Findings.

INTRODUCTION The history of the soll settlement proble=s at Midland (II) should indicate that the Applicant first became aware of the fill soiI deficiencies in 1977 as a result of studies and audits follow-ing the settlement of the Administration Building (1).which occurred prior to, not.rubsequent.td> the" settlement,at the DGB'.'

'In~ fact the Applicant was aware of filissoil testing,.compactier, and placement

(

deficie~ncies prior to beginning c.onstruction of the DGE, BWST, and portions of the SWPS on till, (2)

The voluntary workstop by the ApoIicant in Feb 1960.(VII).did not stop a11 solls remedial actions (3) and it.was not unt i'l later

~

in.the heariJng that the Applicant verbalIy committed to obtain Staff review and concurrance for any further soils remedial work.(4)Because

~

of continuing problems of CPC-NRC interf ace over permissibility of.

soils related work in 1982, and to imoose. tighter CA controls, the April 30, 1982 Board Order,was issued.

Although Intervenor Stamiris specifl'cally suggested in the May 5,1982 Conference Call 3. hat the " prior explicit appYoval" for soils remedial week recuired by the Board's April 30th Order should

('.

be written prior explicit approval, to avoid further communication D

4 4

,,n--

,,---.r

-.-.-~,,,..--n.

g.---

-, - +, - - - -

.e,---,---

-,m.w,-p,

---wv

.w

.,..u. :.

..--.:.=..

~

).,

-z-(~

\\

problems or abuses; we declined to adopt that suggestion agreeing

~

with the Staff and Apolicant that some flexibility was needed in such interface.

Subsecuent to the April 30, 1982 Order, severil instances of 9 use of its terar. (to be the subject of CA Findings), necessitated 7

the establishment of the Work Authorization Procedure in August 1982.

I The Work Authorization Procedure which remains in effect today, re-cuires the prior written approval of the NRC for all soils remedial work.

4 THE SOILS REMEDIAL FIXES 2

m.,

3 1

The technical findingr proposed by the Applicant and the NRC Staff' regarding the soils remedial issues represent testimony on the

~

proposed fixes presented in 1981 and 1982 prior to the inception of the soils remedial underpinning work on Dec.9,1982. Tnsrefore, tnesc findings portray the remedial progras on paper only--the proposed remedial plans to remedy the soil settlement problemsynet the actual' remedy.'Given'the history of this case: that Consumer's probisms have always been not sith their conceptual programs, but with the implementation of those progra=*(5) and given the performance in the soils work to date(6), this becomes an important distinction which must be addressed.

- ~

Both the Applicant and the Staff acknowledge the Ilmitations of their own findings in this regard by their conclusions that the remedial measures in cuestion are adecuate and sufficient to address contentions ann safety functions only "if properly imolemented". To address the cuestion of the adequacy of the remedial fixes apart

~n m- -,,,,

g---

,,.m wg

.u___--=.-_....a.

......_.L....-

3 from their implementation would be Iogical only if the soils remedial 9

work had been ruspended and was awaiting a go-ahead decision.as the Dec. 6, 1979 Order Modifying Construction Permits had intended. In that case it would be a necessary evil. But to address the question of the adecuacy of the reme' dial fixes apart from its implementation when th's very work in question has been going on for a year is an empty exercise at best and an evasion of regulatory rssponsibil'ty to protect public health and safety at worst.'

Therefore we reject the Applicant's statement (IX, p.7) that

" wathave not allowed the. status of plant construction, Ipeluding'

,,'....'.,..'thepartiaic,ompletion'ofsSiksremedialwork, to influence o'ur'dec'i-

..~

......s.

ci'on as* to' whether npplicant 's ' rolls remedi,a1 measures are adecuate

/

(

to protect the public health and safety 7 as an incautious ~and incom ~

plete approach to our responsibilities in deciding the issues before us in this proceeding.

Due to the foregoing considerati ns, and due to the numerous p{oplems encountered-in the remedial underpinning work td date (7),

we consider the technical findings as submitted to be of very limited value.

All parties agree that "the important question of whether -

Apolicant can carry out die soils remedial measures in accordance with design and cuality assurance requirements " (X) will be addressed

~

in our Partial Initial Decision on OA and Management Attitude Issues.

We will further address this cuestion in uoco. ming hearing sessions.-

assessing.CA implementation (8) and their decisions.

Since a decision on the technical adecuacy of the proposed remedial fixes can only be 1

meaningful in conjunction with a decision on the adegaacy of their f

v.w

,1 a

~._ a_.

..,..~._..m.,;-_..

.n_..

..t w

implementation, we will combine these Partial Initial Decisions.

AUXILIARY BUILDING Intervenor Stamirls agrees with the exccotions noted by the NRC regarding paragraphs 215-242. Intervenor Stamiris submits that while " dwelling on the causes of the cracks is not necessary"(p.16

(

NFC Findings), the establishment of their cause,1,s necessary. Indeed the Applicant.'s reluctance to face up to the plaus ible explanation that the cracking at the Auxiliary Bldg. is a result of its differ-ential settlement and stress (p.15 NRC), and the NRC's attempts (9 6) tp 1

. skirt thisfissue; altogether, are indica.tive.or.a tendency to be less g.

.. ~.

than ferthright about-soils problems by the Apolicant and acceptancc

[~

of this attitude by the Staff.

%~

Intervence Stamiris agrees with the NRC that the issues regard-Ing the p oblems with the Pier 11 Ioat. t e s t (p.19NRC) should have beer ciscusred,. Sin.iIarJy,.proi,lems regarding the cracking of the

.FIVE. (9 ), t'he. unexpe.cted.Jrising. of the EPA wing:.(10), and therchmonfe water seepage problems '(10should at:iro have been discussed in these.

technical findings.

Based upon recent documentation of and discussions of problems with the soils remedial underpinning operation, as proposed and exe-cuted'by the Aoplicant (BN 83-16710 /28/83,..BN83-155.10/24/83, BN83-174 11/2I/83, poss ibly BN83-181 11/21/83, and statements at the 1.I/

10/83 S&W meeting on cracking),and based on earlier problems cited in the preceeding paragraph, Intervenor Stam. iris does not agree that

.the Applicant has "adecuately and conservatively taken into account

/

.y

..m

,-e

,i

--ae

-._;... _._ i a. _., _ _.- _.

.-___s the dynamic responses of the control tower, the EPAs,,and FIVPs with regard to-dewatering effects, differential soil settlement and seismic effects in the design and evaluation of those remedial soils measures"(par.242 CPC).

In light of the NRC Staff's " questions about whether the App-1.

ii licant has adecuately taken into account differential soils settle-ment at the Auxiliary 31dg" as raised at the Sept. 14-15, 1983 design audit (NRC p. 21)' and t' heir commitment to bring the resolution of I

these issues before the Board; and based on the related issues raised by Intervenor Stamiris in these findings, we find it imperative to recui're further testimony explaining the reasons for and the effect's-of the following outstanding issues regarding the Auxiliary BIdg.

[

underpinning operation :

~

1) The discovery that the bearing capacity of the base soils for the undcrpinning is i that used'in'the original anal '

ys is.' ( BN83-174 )

%) The disecvery of incorrect and unconservative calculations of,. differential settisment between the Auxliiary Eldg. ar.d m

'the Csntrol Tower (EN 83-174) a 3Q The. Iack of criteria and assessments of upper movements of structures and the related structural stresses ( BN 83-174 )

4) The Applicants decision to substitute ACI 318 for ACI 349 End the related monitoring of the eye bars 6r. Other com-ponents affected (BN 83'-174)
5) The effects of expected elongation on ecuipment between the Auxialiary Bldg. and the Con, trol Tower. (BN 83-174)
6) V/hy alert icvels for cracking (and movement?) have been exceeded and not properly reported to the NRC. (11/10/83 discussed by D. HoodStone /, Webster meeting /3/83) upcoming EN on excessive NCRs 12 l

('.

7) The continuation of repeated drilling incidents despite

\\,~

past controls and commitments intended to rectifv this problem: ( SN 81-Z55 Stopwork and 10/5/83 memo) 1

- -2._ _ 2._.. :.u t. _

w.__

_ =-

8) The deficiencies in the design change crocedures and and document control problems involving remedial soils work. (BN 83-167 Stopworks)
9) The continued water seepage problems in the underpinning excavations (Stone & Webster Vreckly Reports
  • 1 According to the terms of the Dec. 6,1979 Order, we must resolve the issues of the'adecuacy of OA implementation, t_he Material False Statement, and the adecuacy of the technical fixes for the soils settisment problems. We can only resolve these issues by addressing the significant cuestions which remain unresolved regarding the soils remedial work undertaken and the state of CA performance to date.

'The safety issues related to the 'adecuacy.of CA implementatlon.

and the adecuacy of the soils remedial measures which are cit.e'd i$1 the Dec. 6,I979 Order, remain unresolved and have even expanded today in k

the f ace' of what NRC tes,timony has called, a deteriorating perfo:mance record in sclIs related work.as evaluated in the annual SALP Reports.

(*12)

Pub!Ie hea2th and. safety issues cannot he resolved by a dectrion asses' sing.the' adequacy of oils remedial fixes based upon theory alone-and upon proposed plans without regard for implementation of those plans, as, the Applicant would have us do(IX, o.7 CPC). Niether the NRC Staff (p. 19-2,1 NRC),. the Intervenors, nor this Board consider that the OM 4L Proceeding can be closed out without. resolution of the safety related issues recardino the.huxiliarv 91:'r. underoinning ooer? tion.

UNDERGROLWD PIPING Contrary to statements in Applicants propcsed findings, the Condensate o! ping below the DGB was only disc 6nnected at one end,

nd stress was induced in the siping. (Stara!ris Findings 12/10/S1 p. 55~57 - )
. _ - m..

. -. - - -. = -

~--

i Intervenor Stam!ris agrees with the exceptions cited by the

'!RC to Applicants preposed findings on undergrocnd piping. Howeve,r Intervenor Stamiris is not satisfied with Applicant 's strain and set-tiement monitoring program. because, due to the */ariable soil croper-t ties, maximum differential settlement could occur at any. point along the length of the pioing.(tr. 7364-5, 7765-6) CFCs unconservative assump-tion (par. 336) that "the maxi =um differential settlement along the longitudinal axis of buried piping is anticioated to occur at anchor points" leads to a false sense of assurance that potentially unsafe conditions are being sonitored.

..s..Iuhthehmore.we. believe\\.that the inherent difficulties.with t.he,

reliability of the sensitive instruments of the pipe monitoring systemf (tr. 7380-7681); the concerns about whether strain gauges can function for the forty year lifetine of the plant (tr. 7763-4); and the Applicant' past record of improper and unconservative reporting practices (of

. Ad. BIdg. -DGB settlements, cf surcharging instrumentation-Sondex data' elimination and bidg. settlement readings, an most recent'ly of the f ailure to report properly the ' excessive cracking at the Aux. Bldg) give us no choice but to reject the Aoplicant's settlement and strain monitorkng progrma as proposed in these findings.

CORROSION l

Intervenor Stamiris agrees with the exceptions noted by the NRC to the Applicant's propored findings regarding the effects of cerr-osion on underground pioing.

Since the' corrosion-inhibiting orotective wrappings described by the Applicant (car.385) are subject to degradation due to differential set tlement bending, the combined effect*of oices

.h..~-

-m___.-.

.a.-__.

-..,.......~_..

m

.1

. -g weakened by bending and by corrosion at the sa:ne'-16 cations -a.re?lt'13e.-pgg v

conditions we must here consider.. We note _that neither the Applicant nor the Staff has addressed this concern raised by Judge ne'cker at the February 1982 hearir.g session. (13) The amplicant's statements that the protective wrapping: are ir.herently flexible and should not fail (par.39'2), are unsupoorted assumptions. (footnote, 675 does not correctly address the wranoings themselves)

We further note that neither the Asp 11 cant nor the Staff has addressed the concern raised by Resident inspector Ron Cook'that if a galvanic protection system is improperly installed it can actually p'romo,te corrs ion problems.(14) The problems with' anodes being. encased i n ' c onc r.....ete. (.t r. 922'3 -9226 )~

and with. carbon steel lugs being?welde'd' to stainless steel pipes (15) constituted unconservative and potentially k'

unsafe oractices which make Mr. Cook's cc,ncern more than a hypothetical.

The Aspilcants finding (par. 391) that corrosion would not te serious even witnout '.he calvanic protection system or protective ivrappings,?for ocrices. of.uo sto. at 1 cast s.ix months", offers no assur-ance of safety in that:the corrosive effects would be cumulative,"the galvanic protection system has periodically shut down for extended periods". during plant const ruction, Iike the six months in 1962 (CPC footnote 674), and because there is no oractical way to observe cumu-Iatiut corrosion effects on buried cloing.

The Aoplicant 's assertion that the severe pitting cerrosion found in the stainless steel condensate lines (Stamiris Ex. 35) was due to stray welding currents is faulty and reoresents an unconserv-tive assumpt ion. (par.393 ) The 1979 Condensate. Dice Corrosion Study performed to assess this oroblem (St amirls Ex. 36) adcressid and rul:d

- __..._._.u._t_

.g.

m

....= = ::... 7.. -

'out this very theory on the basis that "there were nc known electrical sources in the vicinity of the corroded section of the pipe. There were no adjacent buried olpes or oower lines nor was there any field welding ;crf rmed in the != mediate vicinity of the corroded section".

(p.3, Stamirls Ex. 36) l Applicants explanation that "it Is unlikely that.this pitting would have been ca.used by interaction between the piping and'the soil" in view of the good soi1,chemestry at the Midland site (car. 393) is also faulty. The 1979 Corrosion Study states that " based upon the results of the analytical: chemistry tests which were conducted on the sand. samples., corrorien eroducts and pipe metal, it is not possible

.~

.a to establish the cause of the corrosion." (p.2. Stamiris Ex. 36)

/

I Furthermore the existance of "several areas of reddish brown

('

surface stain " composed of corrosion creducts (p.6 lbid) woul* tend

~

to indicaLe the existance of a more benign or gradual corrosive cgent,such as ches.ical as opposed to "we1 ding current" causes. acting on'ithe Cobdenist' lines..lThe fact that the~ Corrosion Studiek were e'

/ based upon. The exam'ination of only two local sand samoles,unscientir-

.],

ically collected, and one " clean" samole, (p.6,Z Ibid) contributes to the 'fnability of t'nis study' to rule out chemical contamination.

The second Corrosion Study c'onducted on a stainless steel l

nitrogen line three months' later in January 1.981 (Stasiris Ex. 37)

,hich concludes thr.t both this corrosion and that in the first study w

f were caused by stray welding currents (despite the contrary evidence in the first report), represents a classic case of interpreting data

.to succott a.3recencieved conclusion: that stray welding currents were N

L

w.a

. -- - _ a u.=....

.. =

a..,.

\\~

t he 'c a'us e "o f' 't'h'e" c oY r'o s i o n. ' T h'i s c o ne'l us i o n a f f o rd e d is m'o r e ' es?it:d-NNW

~

r able problem than what the second study calls "the ubiquitous sugges-tion of random contamination " es tablished by the first study. (P*2 r Ibid)

Based upon the foregoing inrdequacies in the App.icant's anal-yses and the Staff's essential concurrence, we rcJect thei-r conclu-rion that corrosion,by itself or in conjunction with differential settlement effects, does not pose a significant threat to the integ-rity of'the function of the underground safety piping at Midland.

Although selected portions of buried piping ha.ve been exa=ined for corrosion,the. potential for undetected damage to buried piping whether

. caused by past -welding' practices, ehemical contamination, or other agents, is too great to be ignored c.

condoned if regolatory safety requirements are te be upheld.

~

PriOPO3TD CCNOLUSICPIS OF LAN

.o.

I. Absent a dectrion upholding the a'dequacy of the Applicant's implementation of the soils remedial work ' undertaken to date, we do not have reasonable assurance that the reme' dial measures described in the foregoing findings are adecuate and sufficient to correct the safety concerns at issue in this proceeding, or to enable the affected safety systems to perform their intended function.

l

2. Absent resolution of unresolved safety issues which were not s_7 adequately addressed in these findings regarding the Auxiliary suit M t.1e Sidg. underpinning operations, or wer: r a l w*

w m

~ '..

.w..

.._a._...-..;

~ ~s v.u'...~.

a - - u.;..~ ~ -.

~

')

~

(

6 -

September 14-15,. 1983 Audit, we conclude that the Applicant still has not ocovided tb-Staff or the ASLB with the appropriate k.echnical information and acceptance criteria necessary to accept the proposed remedial measu res.

[

3. Based on the submitted findings, we conclude that the Auftillary 31dg. underpinning operations do not provide reasonable assurance that this structure and its related systems can perfor:a their recuired safety function $s.
4. Based.upon t e submitted findings, we conclude that the underground

~~s'afsty pI;iing bannot be reasonably expected to perfo = its recuired safety functions due to differential. settlement, corrosion, and the i.

inadecuate means of monitoring these problems,

5. As.a result of the foregoir;g conclusions, we will combine the assessment of OA implementation of our upcoming *P.I.D.

with c.

...e.....,,...

Issues, to provide a more meaningful'

,this'?.I.D. on' technical decision.

s

6. As a result of the most recent unresolved safety issues regarding underp inning. work, (Conclusion 2. and the nine issues listed on Stamiris p. 7,8) we hereby prohi. bit further underpinning work from occuring until we have had the opportun'ity to hear and assess these

?

1 Issues.

7 On the' bases of these findings and conclusions, we will hold the OM-OL Hearing open until the safety issues of C.onclusion 6 are resolved before this ASLE.

g.,

..-.w----

.:.--._w.-.a.....----

~

,y6 g.. -

a.

e FOOT!KRES s

acch 15.'.

(x

~

U

.~ -

7' t

1977 Ad. BIdg. Settlement Recort, attached Stamirls 10/5/tg @C19 y motion; Audit F-77-32, Board Ex. 3

2. Keeley tr.. 1313-14;'

Ho od t e s t imony p. I2,. f o l. t r. 1560, *DVIST ;

S'.'?D S-7Kee ley aren. tes t imony o.4 ; Gallaghe(0C.-il f.tr42573-4 BR1ffcy.n

3. He 1ey tr. 1210-12; Howe 11 tr. 2026-27; 7/7 /* I tes t icony
4. 4/15/82'Sp/30/82 Order esserd memo; t. r. 7 784-S8 ; un'a ut ho r i z e d drilling ' excava t i cited'in 4
5. Gilray testimony p.2, fol.tr. 3718; tr. 3834; tr. 3719-21
6. Stamiris 9/4/82' mot lon,. attachment ' A; SNs83-155, 83-167,83-174, 83:-106, and 82-98 7 SALP II & SALP III Soils & Foundations ; Stam-iris Ex. 40-44, 76,7Q,89,. 92, 97,a'nd lo3
7. Ibid
8. I1/1/83 tr. 2'312, 2321
9. Landsman Cook.tr. 14632-14658

' f0". I/19AfNRC mem6handsinan'tr..'14671-14680; Stamiris Ex. 52'

11. CPC ex. 33
12. SALE.'Ill,,p. 8, part b.,

stamiris Ex. 55 13.

l'4.

15..'

.l,.

- ~.,.

.. ; 4_ _ _.

~ '

The appropriate transcripts were missinc from the library; therefore I have no way to find the correct citations at this time I

s w.

m o

N w&

w-w ma n

J u :-

t Dup \\ic a 4 cC. - Il XA-['

l l

i

_

Retrieved from "https://kanterella.com/w/index.php?title=ML20093N920&oldid=4327345"