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UNITED STATES JO f A N T E ^^','i ) 5 _
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ADVISORY COMMITTE E ON RE ACTOR SAFEGUARDS
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August 9,1982 MEMJRANDUM FOR:
D. Oirent, Chairman, ACRS Subcommittee on Midland Plant Units 1 & 2 FROM:
D. Fischer, Staff Engineer hsc.k
SUBJECT:
SUBCOMMITTEE ON MIDLAND PLANT UNITS 1 & 2 - MAY 20 & 21,1982 -
MIDL AND, MICHIGAN I have prepared the attached c.eeting sum.ary for your revien.
Copies are being distributed to the other ACRS members and Subcom.ittee consultants for their inforc.ation and comment. Corrections and additions will be included in the Minstes of the reeting.
Attachment:
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ACRS reters ACRS Technical Staff
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P. Davis, ACRS Consultant jQ,gr (gl E. Epler, ACRS Consultant f:bp-~t
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W. Lipinski, ACRS Consultant f--
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---[ - fil.T'T Jh d J. Osterberg, ACRS Consultant F. Parker, ACRS Consultant l
P. Pomeroy, ACRS Consultant R. Scavuzzo, ACRS Consultant M. Trifunac, ACRS Consultant
- d. Minogue, RES D. Eisenhut, NRR R. Vollmer, NRR J. Keppler, NRR g870257e40718 R. Purple, NRR FOIA PDR E. Adensam, hRR RICE 84-96 D. Hood, NRR R. Hernan, NRR J. Knight, NRR r
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r 0!FICIAL USE ONLY FOIA EXEMPTION (b)5 PRUPUSED
SUMMARY
OF Tiil MAY 20 & 21, 1982 MEETIN3 0F THE SUBCOMMITTEE Oh MIDLAND PLANT UNITS 1 & 2 PURPOSE:
Tne purpose of tne meeting was to review the application of Consumers Power Company for a license to operate the Midland Plant Units 1 & 2.
PPlhCIPAL ATTENDEES:
ACRS NRC STAFF D. Oi re nt, Cr.ai rma n R. Tedesco W. Matnis, ACRS Menber E. Adensam D. Moeller, ACRS Meter D. Hood C. Siess, ACRS Menber R. Hernan P. Davis, ACRS Consultant (part-time)
J. Knight E. Epler, ACRS Coasultant R. Lobel W. Lipinski, ACRS Consultant L. Reiter J. Osterberg, ACRS Consultant J. Kimball F. Farier, ACRS Consultant J. Kane P. Fo wroy, ACRS Consultant (part-time)
J. Pescnel R. Sca vazzo, ACRS Consultant R. Cook M. Trifunac, ACRS Censultant (part-time)
B. Burgess Z. Zudans, ACRS Consultant W. Little J. McKinley, ACRS Staff D. Fischer, ACRS Staff CONSUMERS P0n'ER COMPANY J. Cook F. Buckr.an D. Sommers T. Sullivan G. Slade K. Drenobl R. Ham W. Hall D. Budzik B. Harshe H. Slager R. B. DeWitt J. Alderink R. Polich T. Thiruvengadam J. labritski L. Gibson W. Beckman PUBLIC C. Anderson M. Sinclair B. St ami ri s A
e.
I I
l O TICLAL lJSE 0 NLY PROPOSED
SUMMARY
MIDLAND 1 & 2 MAY 20 8 21,1982 MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS:
1.
Mr. R. Hernan (NRR/DL) provided the Subcommittee with a brief history of the Midland operating license (0L) review.
He discussed each of the 16 remaining open items.
Significant items which rerain unresolved include:
a.
tne potential ef fects of using natural gas onsite for auxiliary heating of tertiary steam in evaporators, b.
ongoing soils rec.edial actions, c.
the need for a reactor vessel head vent, and d.
Mr. Herr.an also suni.a rized the varioJs license conditions -which are being inpcsed on the Applicant.
For several of the open items and license conditions, Dr. Ukrent questio,ed tne NRC Staf f on now it de-veloped criteria to evaluate / resolve these issues.
The Staff, on oc-casion, has relied on engineering judgment as opposed to probabilistic estimates in determining the adequacy of' licensee-proposed fixes to saf ety-related issues.
2.
Mr. W. Little f rom the hRC's Region 111 Staf f described significant construction quality assurance (yA) and quality control (QC) experiences at the Midland plant.,lita l Qa n a s s e s s me ntpf_ Lof o ?Lcon11 r u c t i on cmg.e: ant While he indicated that TWQA record at Midland has been below average as corg.ared to other plants under construction, he ex_ _
pressed general satisfaction witn the current QA prosrnand orcaniza-11Dn He said LTarTeceht special inspections have concluded tnat the quality-related problems at Midland were generally isolated or limited to a specific area and not indicative of major progracratic weaknesses in the implementation of their Quality Assurance program.
Dr. Okrent asked the Staf f what conditi_on_s_ would promp_t_the Staf f to ensatre that.
A mor_
tail d reyiew ofylant des _)gn and construction _qu1]ity3 conducted
.g., past poor record relatedmuauty_3ssurance, large_
popula on neamett1Q.
Ur. 51ess questioned the Staf f on tne pur-pose of a QA program and asked how the Staff measured the effectiveness of a QA program, in his concluding remarks, Mr. Little said that Region 111 believes tnat Midland construction ranagement is staffed with com-petent people and that a program does exist such tnat the plant can be corpleted in accordance with design and regulatory requirements.
Dr. Okrent questioned the Staf f on the need for detailed audits to assure that plant quality is adequate..Mr. Tedesce (NRR/D/DL) said u
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i PROPOSED
SUMMARY
hTiiL4ND 1 & 2 ~
MAY 20 & 21,1982 MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS (CONT'D):
that the Staf f is asking all near-term OL applicants to provide the Staf f with an evaluation of why they believe that their plant has been designed and built in accordance with their application.
He added that this would involve a thorough look at their whole QA program and the experiences that they have had during construction.
The scope of these design re-verifications, and the need for an independent group to per-f orm them, have not yet been deemed a requirement by the Staf f.
Recog-nizing that an independent design re-verification ray be required, CPCo is currentTy having tneir arcnitect-engine.r, Bechtel, perform a design re-verification.
3.
Dr. Charles Anderson, consultant to Midland citizens /intervenors, dis,
cussed tracks in the Midland Plant diesel generator building and ser-vice water pump structure.
He demnstrated, using cardDcard boxes, how these structures might have lost their rigidity.
He stated that tne buildings do not have their designed structural integrity-because of tne cracks whicn exist in tneir walls.
He said that these cracks, wnicn were caused by dif ferential settlement, are numerous, quite long, and random in orien* ation.
CPCO stated that they have evaluated the cracks and have cetermined that they have no effect on the integrity of tne s t ru ctu re.
4.
Ms. Barbara Stamiris suggested several docunents which the Coanittee snould review related to QA/QC at Midland.
Sne indicated that CPCo was slon to correct deficiencies identified in the QA/QC area.
Sne also said that the generic implications of QA/QC ceficiencies was seldom addressed.
Finally, Ms. Stcmiris noted that the Staf f lacked criteria for evaluating an applicant's QA/AC program.
She indicated that this rade it particolarly dif ficult for an outside observer to determine the basis for a Staf f judgment as to the adequacy of a applicant's QA/yC program or activities.
5.
Ms. Mary Sinclair sumnarized the written statement she provided to the Subconmittee.
Sne encouraged the Subcommittee to pursue tne topics identified in tne ACRS letter to the AEC on Midland's CP application.
In addition, she commented on Midland's final environmental impact statement, evacuation plan, and radioactive waste disposal capabilities.
6.
Mr. Robert Hamm, CPCo, described the ongoing human f actors revfew of Midland's control room.
He described the preliminary control room design review which was performed and outlined that review's findings.
Control room ennancements resulting from the preliminary review were discussed.
No enhancement was identified to correct the preliminary review deficiency that alarms are not prioritized.
CPCo stated that tnis deficiency is still under review. Mr. Hamm next described the detailed task analysis of control room operator's functions which is on goi ng.
He related this to other human factors related activities at Midland.
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SUMMARY
MIOLAND 1 & 2 MAY 20 & 21,1982
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MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS (CONT'D):
7.
Mr. Hanm described CPCo's auxiliary shutdown panel.
Tnis panel provides those controls and indications necessary to maintain the plant in hot standby.
It also provides some of tne instrumentation and controls needed to bring the plant to cold shutdown.
8.
Mr. Hann oatlined methods CPCo is using to detect inadequate core cooling.
Tnese netnods include: a subcooling monitoring system, a hot leg level monitoring system, and 24 safety-grade, core-exit thermocouples.
The highpoint vents for tne Midland design will be off the top of the not leg (CPCo proposes not to have a head vent).
CPCo stated that a void in the reactor coolant system will not result in a loss of natural circula-tion.
The potential for losing the plant's natural circulation capability was addressed. Methods to reduce the concentration of both condensable and non-condensable gases in the reactor coolant system were discussed.
Dr. Okrent asked the Staff to discuss tne instrumentation required to detect inadequate core cooling at tne ACRS full Corcittee. meeting.
9.
Mr. J. Alderink, CPCo, outlined the basic system function of the process steam (ewaporator) system and gave an overview of its operation.
Tne system int erf aces witn Dow were hignlighted (including comanication interf aces ).
Mr. D. Sommers briefly described the radiation monitoring program associated with the evaporator system.
10.
Tne Subconmittee renbers aad consultants toured the Midland Plant site.
Subconnittee members and consultants divided into several groups.
One group took a general tour. Anotner group took an abbreviated general tour and, in addition, saw the chemistry and radiation monitoring faci-lities.
A third group took an abbreviated general tour and, in addition, saw the areas /s.ructures requiring soils remedial actions.
11.
Dr. T. Thiruvengadam, CPCo, presented a brief overview of the criteria to which tne plant structures and equipment were built.
He described the ground acceleration nagnitude Midland's OBE and SSE, the design response spectra, damping coef ficients, and CPCo's analysis methodology.
- 12. Mr. R. Holt of Weston Geophysical Corporation discussed Midland's site-specific response spectra.
He outlined two approaches to seismic design, one which results in a standard response spectra and another which results in a site-specific spectra. CPCo has developed a site-specific response spectra.
Mr. Holt explained the earthquake magnitude appro-priate to the Midland site, the various distances, the shear wave velocity profile, and the resulting final Midland-specific spectra. His presentation showed how CPC0's use of the Micnigan Basin as a tectonic province affects the seismic site-specific spectra.
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SUMMARY
MIDLAND 1 & 2 MAY 20 & 21,1982 MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS (CONT'D):
13.
H. G. Klimkiewicz, a seismologist with Weston Geoprysical, presented the results of a seismic hazard analysis (i.e., a deteridnation of the probability of occurrence of the spectra) performed for the Miuland Plant.
He concluded that the predominant source of seismic hazard at the site is tne local occurrence of a moderate earthquake.
14.
Mr. J. Kimball (NRR/DE/SEB) discussed the seismic portion of the NRC's operating license review for Midland.
He hignlighted several areas where the Staff and Applicant disagree.
Tnese areas of disagreement relate to:
the use of the Michigan Basin as a tectonic province, Tne use of the Parkfield earthquake records to develop the site-specific spectra.
The Staf f has found tne Applicant's site-specific spectra acceptable in spite of these aif ferences because of conservatisms of larger magnitude that have been incorporated into the spectra.
15.
Mr. L. Reiter (NRR/DE/GSB) discussed the use of probabilistic estimates to determine seisTiic hazards.
He also discussed some recent work on sensitivity of seismic hazard to variations in input parameters.
Finally, Mr. Reiter out.ned the direction tnat the Staf f plans on taking relating to the use of probabilistic estimates.
Tne Staff will use probability to obtain relative as opposed to absolute insights into seismic hazard.
Mr. Reiter said that reliance upon probabilistic esti-mates for very long return periods is not the way to alleviate concerns about earthquakes greater than the SSE. He did, however, encourage research to facilitate increasing use of proabilistic estimates.
16.
Dr. R. Kennedy, President of Structural Mechanics Associates and consulant to CPCo, discussed t'le seismic reevaluation of the Midland facilities.
He discussed the criteria that are being used in the seismic margin re vi ew. He also gave a sample of some of the preliminary results from tnis review. He explained that the site-specific spectra is being used in tne seismic margin review. The review involves botn structures and equipment.
- 17. Dr. Tniruvengadam, CPCo, addressed the potential for soil liquefaction at the Midland site. He briefly described the basis for the permanent site dewatering system.
Tne loose granular backfill supporting the diesel generator building and the auxiliary building railroad bay area will not liquefy during an earthquake with a peak ground acceleration of 0.199 provided the ground water level in the backfill is maintained at or below elevation 610. The dewatering system will maintain the water level under these structures at about elevation 595.
Total failure of 0FFICIAL USE 01LY i
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SUMMARY
MIDLAND 1 & 2 MAY 20 & 21, 1982 MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS (CONT'D):
all pumping capacity in the system would still permit an ample 60 days to repair or reinstall the system before the water reaches elevation 610 in critical areas.
At 0.25g there is a 1.1 margin of safety. The Staff agrees with the Applicant on the results of the liquefaction analysis.
18.
In response to a request from Dr. Okrent, the Applicant, NRC Staff, and ACRS consultants each gave their estimates of that earthquake having a return frequency of a thousand years, ten thousand years, and a hundred thousand years.
There were considerable differences in these estimates of low probaDility earthquakes of a certain size.
- 19. Mr. J. Cook, Vice President of Projects Engineering and Construction for Consumers Po.er Company, briefly outlined the company's corporate structure and the engineering and construction operation for which he is responsible. CPCo has considerable nuclear experience but Dr. Oirent questioned its sufficiency to ensure safe plant operation.
20.
Mr. R. DeWitt, Vice Presicent of Nuclear Operations, very briefly revie ed CPCo Corporate organization, Nuclear Operations Departrent organization, Energy Supply organization, and his nuclear experience /dackgro;nd.
21.
Mr. F. Buckman, CPCo's Executive Director of Nuclear Activities, briefly described the organization, staffing, and experience of the Nuclear Operations De; artment.
He similarly described tne Nuclear Activities Depa rtment.
The composition and functions of the Nuclear Safety Board were presented.
Mr. Buckman identified tne people on the board and gave tneir experience and qualifications.
Tne Subcommittee discussed how LERs from other plants were evaluated by CPCo.
- 22. Mr. G. Slade, CPCo's Assistant Site Manager for the Midland Site Manage-ment Of fice, discussed the organization of the plant staf f, human re-sources planning of the plant staf f, and the qualification program for the plant.
The composition and qualifications of the plant staff were discussed in detail.
The control room operator shift organizttion was presented to the Subcommittee.
It was gen'ioned that a two-unit simulator would be available for crew training by mid 1983.
Typical training programs were identified, including those for reactor operators, simulator training, and training to mitigate core damage.
Tne composition and qualifications of the training staf f were discussed.
- 23. Dr. T. Sullivan, Manager of Safety and Licensing for the Midland project, discussed Midland's ongoing probabilistic risk assessme t (PRA). Midland 's licensing staff is working with Pickert, Lowe & Gerrick, the Midland site organization (including STAS and the operating staf f) to conduct the PRA. The PRA was initiated in December 1980 and is 75% co.npleted.
Final results of the PRA are expected in Janaury 1983.
Dr. Sullivan discussed the objectives and' unique features of the Midland PRA.
MEICI AL llSEQIM o
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SUMMARY
MIDLAND 1 & 2 MAY 20 & 21, 1982
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MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS (CONT'D):
- 24. Mr. L. Gibson, CPCo, discussed Auxiliary Feedwater (AFW) system re-liability. After some disagreement on the need for a third AFW pump, CPCo has agreed to install a third pump by the second refueling outage.
The basis for the Staff's probabilistic criteria regarding AFW system unavailability was discussed at length.
25.
Mr. W. Hall, CPCo, discussed Midland's Emergency Operating Procedures (EOPs).
Mr. Hall has been working with INPO in tne development of an Emergency Operating Procedures Writer's Guide.
He also is chairman of the B&W Cwners Group Subcomittee responsible for developing B8W Guide-lines for writing E0Ps [Abnorral Transient Operating Guidelines (AT0G)].
Mr. Hall discussed AT0G and symptom-oriented procedures.
He outlined the methodology used to develop ATOG, the structure of the two-part ATOG product, the rethods used to validate AT0G, a plan to implement AT0G, and finally recent and proposed additions to AT0G.
26.
Mr. B. Harshe, CPCo, described Midland's AC and DC power systems.
He identified several features of each system which make thein more re.
liable tr an those whicn exist at other plants and/or wnich are re-quired by NRC documents.
27.
Mr. B. Harshe, CPCo, discussed the possibility of a station blackout at Midland.
He indicated that while such an event is not part of the design basis, procedures are being developed to cope wit'n it.
He said tnat greater tnan two hours (tne design life of the battery) would be available before serious consequences occurred.
He outlined procedJres which would be taken to restore AC power before that two-hour period expired.
Mr. Kindinger, CPCo, said that there would conservatively be approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> before a core melt occurred.
28.
Mr. L. Gibson discussed highpoint vents in Midland's reactor coolant sy stems.
He showed a diagram of and discussed the system configuration.
He said that a bubble in the head would be detectable by plant operators and that it would not interfere in the natural circulation flow path.
The control rod drive mechanism manual vents are not suited for system venting with the system hot and pressurized. Mr. Gibson indicatet' that the perceived benefit from installing a suitable vent on a control rod drive mechanism flange (af ter drilling and tapping) would not outweigh the cost.
- 29. Mr. G. Slade, CPCo, discussed several unique features of the Midland Plant site which affects the Midland Emergency Plan.
He specifically addressed the fact that the plant is located in the state of Michigan, within the city limits of Midland, and edjacent to a major chemical manufacturing f acility. A representative of the Michigan State Police discussed the state's role in carrying out Midland's Emergency Plan.
Tne coordination of CPCo, state, local, and Dow personnel was addressed.
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SUMMARY
MIDLAND 1 & 2 MAY 20 & 21,1982 MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS (CONT'D):
- 30. Mr. D. Sonvers nignlignted several controversial or outstanding environ-mental issues on the Midland project.
Issues discussed relatinf to the National Pollution Distnarge Elimination System (NPDES) include:
control of total dissolved solids in the Tittabawassee River.
thermal ef fects of dischargs to the Tittabawassee River, and tne assimilative capacity for ammoni? in the river.
Issues discussed relating to the Draf t Environcental Statecent (DES) include:
- the potential for fogging and icing, and the potential for increased deatn due to disease and starvation of water fowl in tne cooling pond.
CPCo indicated that all of these issues should be resolved without cifficulty.
31.
Mr. D. Sommers, CPCo, discussed the potential for ground water contam-ination at the Midland site.
He gave several reasons wny ne felt that tne potential for ground water contamination at Midland was minimal.
32.
Mr. W. Beckman, CPCo, briefly outlined the Midland Plant Fadiatio')
Safety Program.
He centioned the corporate guidance that nas gone into tne developc.ent of the Midland Program.
His discussion indicated that a strong ALARA program is in place at Midland.
Tne ALARA Program includes :
An ALARA coordinator who reports to the Radiation Protection Manager, Anneal ALARA goals.
A $5000 cost attached to each occupational man-rem projected to be consumed to install new equioment or modify tne plant, A rediation exposure tracking system, and Pre-and Post-activity ALARA reviews for jobs involving personnel exposure.
Mr. Beckman nighlighted Midland's normal dose projection and accident dose assessment methods.
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SUMMARY
MIDLAND 1 & 2 9-MAY 20 & 21,1982 FUTURE MEETINGS:
The ACRS Subcormittee on Midland Plant Units 1 & 2 will have a meeting on Wednesday, June 2,1982, coramencing at 4:00 p.m., to discuss tnose topics on this reeting's tentative schedule tnat were not discussed.
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i GOVERNMENT ACCOUNTABILITY PROJECT Institute for Policy Studies 1901 Que Street. N.W., Washington. D.C. 20009 (202)234-9382 i
l March 9, 1983 Mr. James E. Brunner Consumers Power Company P.O. Box 1593 Midland, Michigan 48640
Dear Mr. Brunner:
This letter is in response to your February 24, 1983 letter to me regarding the criteria under which an individual (" Individual A") who has provided a confidential af fidavit to GAP will be able to visit the Midland jobsite.
We appreciate the efforts that you have gone through to extend the opportunity to our client to visit the site and identify and explain his allegations to the Nuclear Regulatory Commission inspec-tors / investigators.
As I indicated in my December letter, as well as throughout our conversations, both GAP and Individual A are anxious to have the problems on the site identified and resolved.
The major criteria that we have agreed upon are summarized below:
(1)
A site. tour will be provided for Individual A during non-regular work hours (i.e., weekends, evenings, etc.).
(2)
Another individual, preferably a current er former plant employee, or union representative, will be allowed to accompany the individual on the site tour.
(3)
The Company and contractor Bechtel will "not disclose Individual A's identity to the media or general public."
We under-stand that in fact Individual A's identity will not be disclosed beyond the control group identified in your February 24, 1983 letter.
(4)
The Company will not refer to the fact that Individual A had supplied information, which was transmitted to the NRC, in any job reference or any other communication which the Company provides.
(~5)
That any reference to Individual A's allegations or to Individual A in company documents will be limited to the control l
l
\\
w Mr. James E.
Brunner
! ' I.,
i Consumers Power Company March 9, 1983
,i,
I l
group as identifie'd in your February 24, 1983 letter.
(We strongly suggest that any reference to the individual, including l
5 jj company internal documents, be done with discretion.
Both the
,i.
NRC and GAP use an alphabetical identification system in-house 4
as well as in any external communication.
We believe folloving h
that procedure would eliminate the possibility of an internal i;
leak. )
?I 1;
(6)
That the individual will not have to sign the usual site procedural sign-in book, since he will be accompanied at all 5
times by both NRC and company officials.
(This has been done at ji V both LaSalle and Zimmer.)
1 4
.p (7)
That the issue of depositions and confidentiality within
[
the ASLB hearing process will be dealt with at some future time y
through the ASLB under such protective measures as are guaranteed p
by the Board.
9 (8)
That Individual A will not be subjected to any question-ing by company officials attempting to challenge the validity of his/her allegations, or by technical consultants or employees.
The purpose of the site tour is to facilitate the NRC inspection
- i effort.
Subsequent to the NRC effort we assume' Consumers will j
take the appropriate corrective action.
i j
f We further wish to clarify the points raised in your February l
24, 1983 letter, paragraph 3.
I i
"Despite the above protective measures, the af fiant's identity might be guessed or inferred by a co-worker j
or other person outside the ' control group' as a result of the identification, tagging (if necessary), or cor-1 rection of the identified hardware, or because of the l
required QA documentation pinpointing the problem.
Certain persons may already have guessed or been told 1
by the affiant of his identity.
Obviously, neither j
CPCo nor Bechtel is in a position to guarantee that further disclosures have not or will not be made by
~
u such. persons, or that they have or will abide by the f
terms described below."
i E
l tj We assume that Consumers Power Company and your contractor, the Bechtel Corporation, are responsible for the actions of your l
i J
employees.
On an issue as sensitive as this one it would seem f
appropriate that extra precautions would be taken to ensure that y
(1) the individual's identity is not released, and (2) that even 2
if his/her identity were guessed or inferred by a co-worker or
[
other person outside the
- control group," that person would be aware of and f amiliar with the agreement made between your company 3,:
and us on behelf of the protected witness.
We can conceive of only 9
a very unusual circumstance where the knowledge of Individual A's
- 1 i
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Mr. James E. Brunner Consumers Power Company March 9, 1983 identity on the part of any of your employees would be beyond your control if the conditions agreed to are faithfully followed and since the on-site tour itself will be " secret" and unannounced.
We would certainly.. expect that in the event an employee guessed or inferred the -identity, such a guess or inference would not be verified or discussed by the company or contractor or its employees.
Finally, we wish to clarify your comments during our conver-sation in Midland about the number of people who would know the identity of the affiant.
You originally stated, and ycur December 28, 1983 letter to James Keppler indicated that "not more than two or three persons" would know.
.However, in the February 24, 1983 letter and via the NRC, it appears that number may be expanding.
We wish to underscore that our agreement is predicated upon the promise that the smallest possible number of individuals know our client's identity.
Sincerely, Billie Pirner Garde BPG/ea Director, Citizens Clinic I
cc:
SLewis, Region III WPaton, OELD MIMiller, IL&B MHearny OL/OM Service List JWCook, Consumers DBMiller, Consumers RAWells, Consumers JRutgers, Bechtel i
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