ML20105C752
| ML20105C752 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/06/1981 |
| From: | Stamiris B STAMIRIS, B. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20105C399 | List: |
| References | |
| FOIA-84-96 OL, OM, NUDOCS 8502090515 | |
| Download: ML20105C752 (11) | |
Text
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U.S. NUCLEAR RE31LATORY COMKISSION s
In 5h's matter of Docket Mos. 50-329 OM,0L C. P.Co. Mi di and P1 ant 30-330 OM,0L Units 1 and 2 0
BEFDRE THE ATOMIC SAFETY AND LICENSING BOARD cj/A/4 1 INTERVENOR ANSWER OPPOSING APPLIDANTS MOTION TO DE7ER CONSIDERATION OF SElSMIO ISSUES Uh7IL THE OPERATING LICENSE PROCErRNG This seimie motion begins with the statment that at the second orchearing conference a the NRO Staff reneging on an agreement oreviously worked out with applicant, proposed that the scope of this soil settlement hearing be expanded to include sei mic i ssues."
Whether or not the NRO Staff was reneging on an informal agreemer.t i s irrelev nt. The scope of this soil settlement croceeding already included a
sei smic issues as set forth in my contentions Ib,4c, and 4d; in the many re ereneas te seismic issues cortained in cart II of the December 6,1990 c
Order (50-5ur questions, acceptance criteri a, and unresolved safety issues regarding remedi al actions); and in Mr. Linenburger's statment at the last prehearing conference that "thi s board will absolutely not ignore seismic in arriving at its decision about the adequacy of pronosed remedi al actions."
For these reasons alone, it seems clear that the motion cannot ba j
granted. But an exsination of this motion and its suoporting arguments is important for many other reasons.
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.' ll I. IX AKINATION OF APPLIC ANIS ARGLMENTS AS PRESENTED Having made irrelev nt a guments about the Staff position, the a
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Applicant accuses the Staff of a misreading of the Dairyland cases. The Applicant points out that Midland is not an operating resetor like Ddryland and "thus for Midland unlike Dairyland,. deferral of consideration of seismic issues until the 0.L. proceeding 411 not ha e any adverse effect on the v
public health and safety.*p.4 Applicant draws the conclusion that Midland's seimale deferral does not pose a health and safety threat sinnly because it is not an operating reactor. In so doing, he concedes that a fseility that operates dthout seismic updates does represent a threat to public health and safety. What he actually is saying then is that because Midland is not presently an operating reactor, it does not presently recrosent a threat to public health and safety.
Aoplicants second argument is that
- definitive safety findings can be deferred in the NRO licensing process until operation is actually licensed." They can if in so doing public health swi safety is not jeopardir.ed.,
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For according to the Atomic Energy Act "public safety (is)a paranount issue at every stage in processing aoolications for cournercial use of nuclear power.
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Aoplicant further differentiates Midland from Dairyland saying, "because a desi gn basis earthquake has been femally established for the change in this dod gn bad s would be a 'backfit' decision Midland site, a shich pursuant to to CFR 50-109would require that there be a firding that (1) C.P.Co. Midland Plant Units 14 2, 2,AB 315.1975, p.103 i
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,Jl such actien will provide ' substantial additional protoction which is required for the public health and safety or the common defense and j
security
- p.5 such a 'beekfit' finding seems almost a given. For if at Dd ry land the adoption of the most recent and conservative seismic standard was deemed necessary for safety, then the _undate of seistic standards for Midland would be necessary for the see reasons.
Aeplicant concludes his arguments by declaring that " uncertainty concerning possible backfits required by a redefined SSE* is a"financi al risk"o.6 and he makes manerous legal citations supporting the statement that "the licensee always builds at its own risk." These statements,true in themselves,do not mean that it is a financial risk eniv. Here and in Jees Cookh attached affidavit,the Aeolicant infers that the seismic uncertenty rpresents a financial risk as opoosed to a health and safety risk and does so in the absence of any supporting arguments.
In reality the basis for each of these arguments is the see :
that neither public health and safety intrests, nor the NRC regulations intended to safegu rd these intrasts will be violated by the granting of a
thi s motion to defer seismic issues to the 0.L oroceeding. It is this one basic argument that I intend to refute.
II. EX AMINATION OF APPLIC ANT'S ARGUHFETS IN THEIR FULL IMPLICATION There are certain inconsistencies if not contradictions involved in the statements in this motion which must be exsuined. By the title of the notion and the statenents therein, Aeolic nt says clearly he is willing to a
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b defer prior EC approval or agreement on final sei smic standards to proceed at hi s own financi al risk (the risk being whether o'r et he will meet EC solistic st andards in the end). But whether he intends to meet E0 standards l
so deferred is not stated.
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Aeolicant is willing to give uo the " reduction in riska gained from preliminary seismic design reconsiderattorr with the EC, because *it means lengthy delays in this proceeding and in the start up of the Midland units."
p.6,7. So stated, the Apolicant is willing to risk the ultiwate disanproval e plant s;:;ct up of hi s actions because he cannot afford the concomitant delay'in waiting to be sure of his actions. It must follow then,that neither can he afford di saporoval in the end, for that too would mean delay to plant start up.
By hi s own secount of financial inflexibility, he can't afford to f all short of the final seismic standards, yet he " strongly urges this board to defer until the 0.L. proceeding the issue of whether the seisuie dest en basi s establi shed at the c.p. stage for the Midland plant ( by which he seeks to proceed ) is adequate p.9. Aeolicant has incorporated what ne a
dems "a reasonable" margin over FS AR seismic criteria, but only to reedi al wry, excluding the structures affected by such erk,(p.7 Thiruvengedesi af fi d a i t).
Nevertheless he bell' eves that* " all outstanding seismic v
questions can be successfully resolved." p. 3,4 If ultimate E0 seisrile standards are not incorporated now, they never can be,for the Aeolicant cah't afford correction to completed structures at the 0.L. stage any more than he can afford delay now.
Then the effect of this motiort becomes one not merely of deferral of seismic considerations,but one of compromise to EC seismic standards, particularly if compromise is the ordy way to sa e what by then will be a completed v
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$3 to Sk billion dollar fsaility, l
In financial straits as difficult as these(ahd portrayed in-Joes Cooks attached affida it) it would seem that Consumers Power Company v
would have begun pushing the RC to get some agreement on seismie-standards in 1978 when they first *1 earned that the NRC Staff had amt concern about the magnitude of the design basis earthquake sporoved at the c.o. stage." p. 7 For Consumers has certainly not been reluctant to criticize NRC alowness or resource allocation decisions in the past* when they did not meet their own ends..
NK Despite nurserous attempts to obtain adequate resolution of seismic issues (in FS AR questions 361.2,.4,.7,.9; in 50-Shf requests regarding acceptance criteria for soil settlement remediation; and in aany meetings involving these issues since 1978),
accontable seisde input parmeters still have not been established. The October th, 1980 Tedeseo letter went so f ar as to suggest two acceptable seisuie accroaches to C.P.Co.
But now, when progress was just beginning with the site-specific aporoach, Consumers says that this analysis is too late and too time consuming.
Furthermore, Consumers says although they are pursuing this site-specific anoro ach with the NRC, they *have not conceded that the design basi s of the Midland plant approved at the c.p. stage is inappropriate, or that the Michi gen basirr is not a separate tectonic crovince." (p.h, Thiruver.gadem affidavit)
I believe that Apolicanth argments 'as exsined in their full iinplications'- are very revealing if not self defeating. Yet more important issues must be explored regarding the ' proceed at own risk' requestsin this motion.
- Selby letters of 12/10/80,1/16/81 toNRC ; 6/13/80 & 8/25/80 meetings C.P. -NRC
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i III. PROCEED AT OWN FINAEI AL RISK BECOMES A FUBLIC HEALTH & SAT &TY RISK s
Iwill now return to my original intention to refute the Aoplicant's l
basic argument that he should be allowed to defer seissie cenddarations' because this represents a financial risk to the Applicant as opposed to a health. and safety risk to the public. Applicant by this motion seeks to proceed at his own financial risk in seismic matters just as he did in soil settlement matters in 1978. I do not deny Applicanth claims that allowing the licensee to build at its own financial risk is the established MRC policy, but I will hereby show how this eccepted practice is at v riance a
with the ultimate and ove riding responsibility of the NRC as mandated by the Atomic Energy Act " that public safety is the first, last, and a pomanent consideration in any decision on the issuance of a construction pemit or a license to operate a nuclear f acility." (2)
Both construction permit and onorators license decisions are involved in this motion. The original c.p. decision is questioned because of si mificant desi gn changes which led to the Order Modifying Construction Pomits (a cording to 10 CFR 50-100), and 0.L. decisions are involved because c
this is a consolidated proceeding.
NRC practice allows ' proceed at own risk' arregements, yet NRC regul ations mandate prevention of health and safety risks I sutadt that this caradoxical situation arnounts to what is almost an impossible charge I
to the NRC. Financial considerations effect safety,just as safety considerations effect finances. The two cannot for all practical purposes be separated.
But if such separation is attempted as in the case of ' proceed at own risk'
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(2) 5,AB 315, p.103
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g agreements, the ultimate risk of disapprov l undertaken by the applicant a
at,one point, cannot later be denied..ne matter [at the consequeness.
For' ultimate oompmmise negates the element of risk'imelved, and regulation gives way to license.
Yet weidting of practical financial considerations against safety considerations becomes almost una oidsble ar a rePult of these 'cun risk' v
policies. The oostly and difficult consequeness of such policies can be illustrated by the esse in point of the Diesel Generator Building- (D2) at Midland. I M11 briefly review the history of this one aspect of the soil settlement matters to show how public health and safety is at' stake in any 'at own risk' arrangement like the one sought in this motion.
The settimeent of the D2 was first noted den the building was in its initi al stages in 1978. Since therrits construction has pmeeeded
' at C. P. Co s. owrr ri sk' concurrent d th its remedi ation. The adoption of the Preload Option and the resumption of work on the D2 took place 4 thin ordy a few months of its initial settlement discovery, before root causes had been thoroughly analyzed, and before the full implications of soil settlement problents and their effects were understood by wither C.P.Co.
or the NRC ( the potential for liquef action for example )..
l When asked by the NRC in 1979 to defend their choice of the Preload Option over the Removal and Replacement Option for fill (10CFR 50-5hr 9 21)
Consumers replied, (part d(5) )*Preloading was the least oostly feasible dtornative for corrective actiorr. Also, construction of the structure 4
oan oontinue while the surcharge load is being applied. Thus, thie alternative will minimize the impact on the construottom sohedule.*
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By taking the a tions that they did, when they did, C.P.Co. chose c
not to thoroudsly oondder the most conservative Remov l and Rep 1'acement a
Option. But now as a result of their chotosto proceed, full and fdr consideration of the remov l and repleeement offill a
e pmgressively a
negated. Few individuals withirr the RC, or C.P.Co. I dare to say, would frankly deny that statement.In fact NC personnel have themselves expressed concern over the realities of these policies at Midland. (see attached Chilk meno on possible ex-parte contact)
Yet the f act retains that the DCB now stands virtually complete, despite serious questions regarding its subsoils and its settleront effects.
Removal and replacement of its f aulty fill is no longer a viable option for C.P.Co. in li ght of financial statements made in this motion.(Ironically, the Renoval and Replacement Option was rejected in 1978 orr the basis of cost despite the f act that it afforded the most conservative solution, and ro w i t appears that' removal and replacement' in 19F might have been the most vi able financial option precisely because it was the most conserv tive.")
a Full and f air evaluation of safety questions by the. EC at the ord of 'nwn ri sk' prneeedings becomes extremely difficult if not impossible when structures or actions are comoleted. Yet that is vrecisely diat the Apolieant seeks onee asain in this seis'de motton to preeeed.
As a result of ' at own risk ' policies, NRC safety decisions a e r elevated to 'make-us-or-break-us' financial decisions and held up as such to the RC and now to this very Atomic Safety and Licensing Board as in Jsses Cook's attached affida it to this motion.
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The Applicant almost cha11anges the IRC and the ASLB on their literal i nterpretation of ' at own ri ak' agreements. Can the HRC carry through on its implicit power to danand renoval and replacement of subseils, or saissie update, orany other safety decision.if it carries 4th it the certen doom of the tole plant? The tremendous burden of such weighty and unsa ory decisions makes them almost impossible, and in looking for v
ways to help a utility out of such predicaments, publie health and safety i e compromi sed.
It must be remembered that C.P.Co. not only could have been more careful and less hurried about proceeding in soil settlement matters, they should have been more careful and less hurried in soil settlement construction pomit ca ries 4th it no concomitant right a
matters, for s r
to operate the completed f acility. Rather, to obtain an operating license, the ( Atomic Energy) Act requires the utility to shoulder once agdn-the burden of croving to the Commissinn (at a public hearing if need be) that it has, inter alia, constructed the plant in conformity with its aoolication, the Act, and the Commissions rules and regulations. And even at thi s late stage the Act permits the Commission to withhold the license for stood ca se.
u it was not happenstance that Congress structured Atomic Energy Act proceedures in this manner. Rather, it was intentionally done to make certdn that public safety was a paramount issue, at every stage in processing applications for commerci al use of nuclear power.* (3)
(3) SaB 315, p.103 l
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Therefore, when I ask this Board, by denying this motion, to l
l begin to ohange dat has become peopted BC pratise of allowing-1 2
' proceed at own risk' policies, I er not seeking to change the rules of the goe as it urar at first appear. Eat I do seek is the abange of f
dat has beoone peopted praptioe, in order that the rules of the goe I
are upheld.
Proceed at owir risk policies fores all parties isolved into an unrealistio world of extremes. The BC, committed *to conduct independent analysis and reseh' independent conclusions ort whether reasonable assurarce of plant safety exist (s)* (4) must urake such independent safety decisions totally aside from financial realities that may spell certain doom to the Applicant. The ' Applicant is forced to cha11ange that ultimate authority I
i if in the and it is his only hope of saving his plant. So in response, I l
too must challenge the BC and this ! bard on their ultimate authority.
Since the Apolicant has said in effect 'you can't make your decisions apart from these Anancial realities', I a forced to say.
'you must make your decisions apart fmer these financial realities.'
All safety questions in this soil settlement,Prossed:rg including seissio oness must be based on purely scientifie"and technical grounds, rather than based everr in part on pratical finansial consider ticas.
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I ask you to presume,for instance,that the D2 were still in its initial stages, as den its settlement was first discovered irr 1978 (4) MC STAFF'S ANSWER TO INTERROGATORIES FILED BY C.F.00.g 3-329 OM-OL, 5 3% OM-OLg In the matter of Midland Flant, Units 1 & 2 Interrogatory Answer 1, p.2,) referring to S.R.F. sootions 2.54 and 2.5.5 ; F b.25,1981 ee
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Enodng what is known now, and for the greatest part oculd have been known prior to its remediation,vould the safety related decidons for the DEI be 'any easier? Even more importantly would the decisions themselves be any different under these situmustances? These deterical questions are relevant to the present motion. For this is a notion that ooppells the siesseio-udstes either gy.gf never,,just as the removal and replsesment of faulty fill was a now or never deoidorrirr 1978 The salient question must finally be asked, no is really taking the risk in a ' proceed at your ourt risk' arrangement? The answer is the publio 'first, last', and always'. For whether speaking of financial costs 4
or safety costs, it is not the Applicant do bears tne ultimate risk, It is we the publio who dll pay the price for the Midland nuclear plant.
1 This motion cannot be granted without seriously endangering the health and safety of a public totally dependent not only on the bade tenants of the NRC regulations, but also on the actual practices and j
policies as carried out by the RT.
For this reason, a thorough and oonplete analysis of ultimate seismia j
standards must ooour now, as an integral part of remedial soil settlement fixes and the structures affected by them. If such analysis entails delay i
to this soil settlement proceeding, then that is unfortunate, but not nearly so unfortunate as the implications of not doing such an analysis.
For nuclear safety transgressions pose *at least as serious a threat to I
public health and safety" as the Federal Safety acts in which
- Congress (has) deemed the safety considerations at stake more important than any financial detriment to the party involved." (5)
Respectfully Submitted, (5) AL2 315, p.109 hM
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orret or wr December 29, 1980 CoMtMSSIONrR m
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MEMO TO:
Samuel J. Chilk yce. g. g -5 8
Secretary
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Thomas R. Gib
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Legal Assistahf.
to Comissioner Bradford
SUBJECT:
50-3290M AND # 50-3300MPOSSIBLE EX PARTE CONTACT IN MIDL On July 30. 1980 I had extensive discussions with James G. Keppler Director of Region III, and other Region III personnel on general NRC enforcement issues.
touched briefly upon the Midland case.During the course of these general discussion conversation could be considered an ex parte contact. notes the atta:hed sumary of discussion upo,n all' the parties in Accordingly, I proceeding and also place these documents in the PDR.
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. the summary of the discussion, Mr. Keppler notes t With regard to correctly.
Attachment:
As stated cc:
James G. Keppler Keppler also stated that in one form or another the philosephy that oncthe Commissioners needed to expres wrong at the construction site, e something is found area until the item was resolved. construction will stop in that He gave the example of r.idland where I&E found that They also found thatthe diesel generator building had settled excessively.
said' there really wasn't a Q/A program in this area.any sub He to this,.the NRC issued an order which said that In response be remedied or work would be stopped in' 30, days.this should roquested a hearing and, therefore, stayed the order.The company in continuing work today which will make resolution of the Midland cettlement problem much more difficult.
S' taff had not yet made up their minds on whether the fiXeppler said that the by tiidland.is acceptable.
x proposed be built and the problem gets worse.Therefore, the project continues to He wanted the. work stopped until the problem is solved.
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- L CDDSUmWS L L /T i PO'.'lBr a p James W Cook
.i Vice President - Projects. Engsneering and Construction
- osmeret of Hces: 1945 West Pernell 7taed. Jackson. MI 49201 * (517) 788-0453
~ December 10, 1980 Harold R Denton, Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 This letter is in response to the June 13 and August 25, 1980, meetings between CP Co and NRC management concerning timely resumption of formal docket review of the Midland Plant. As noted in the NRC minutes of these meetings issued September 16, 1980, there is reasonable agreement between the CP Co scheduled fuel load dates of 7/83 and 12/83 for Unit 2 and Unit 1, respectively, and the corresponding NRC Caseload Forecast Panel projections of 10/83 and 4/84. However, I note with some dismay the statement in the meeting minutes that the staff's still to be announced licensing schedule "may not necessarily coincide with the construction completion date."
If this should occur, it would create severe adverse consequences for Consumers Power and would be a direct reversal of the NRC's stated objectives of completing the licensing process coincident with the completion of the construction process.
Recognizing the staff's resource constraints, it is imperative that we take steps now to allow timely resumption and efficient completion of Midland docket review.
At our August meeting, you made certain suggestions on'how we might assist in moving the Midland Licensing process forward. We have pursued these ideas ano ot.hers and. t.h.e b.a. lance or t.h.i.s l.et.t.er i.s"a 'tatus report'on these s
y In the Post-TMI time frame most nuclear plant projects have been reassessed and he' majority have ~already deterinined significant impacts on completion t
dates based on current requirements. Consumers Power Company was among the first to publicly recognize the current realities and has taken significant steps to focus all the Company's technical and financial resources towards the expeditious completion of the plant. The reorganization of the Midland Project in early 1980 was but one facet of this effort.
Even prior to the project reorganization the Consumers Power Midland Nuclear Safety Task Force utilized a formal ' ask description and recommendation process to t
coordinate the resolution of major pre-TMI open items identified by the NRC staff and to determine the Midland specific response to post-TMI issues and events. These efforts were formally documented in Revision 30 to the Midland FSAR submitted iu October 1980. An updated Security Plan and associated documents along with Revision 11 to the Midland Environmental Report have also been submitted recently.
In addition the revised Site Emergency Plan is scheduled for submittal this month.
In summary, the application is ready for post-TMI review.
oc1180-0094a100 bhM
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i We continue to monitor the. evolution of requirements for more explicit i
documentation of compliance with regulations.
In,particular we have undertaken a review to assure that Midland positions on the General Design
.Crfteria and applicable Division 1 Regulatory Guides are sufficient to meet
.our understanding of the staff's needs, and we stand ready to expand this effort as specific requirements are established. As mentioned above, we
.have presented Midland positions on pre-TMI open items and post-TMI issues and events in Revision 30. We have also undertaken a probabilistic risk assessment of the' Midland Plant to support overall safety decision making-l and, where appropriate, to assist in the justification of acceptable alternative approaches to NRC staff interpretive documents.
In conjunction with the above efforts and in view of your stated j
willingness to provide NRC staff participation in final design review meetings on critical issues, we will contact our NRC Project Manager to arrange with the staff for such participation on a trial basis. Such meetings.are a logical conclusion to ongoing design review meetings and provide an opportunity to review critical design aspects and compliance with applicable design, availability, safety, and licensing requirements.
These meetings will now have the added benefit of NRC participation with a i
resulting increase in the NRC staff's understanding of critical design issues. Meeting minutes are utilized to document major points of j
discussion and action items. Action items are resolved within the context l
of our existing design change control program. Our' staffs should work to establish the protocol for NRC participation.
In order to assure proper i
utilization of our limited resources, we should personally monitor the l
progress of this effort to ensure that it is achieving the desired results.
We continue to believe that a relatively higher review priority is justified for Midland based on the realism of our current scope and j
schedule, the OL application docket date of 11/77 and approximately 16
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months of NRC staff review prior to TMI, and the unique. cogeneration aspect i
of the facility. We encourage more NRC staff participation in appropriate forums for the review of the Midland docket.
We also encourage the use of l
NRC contractors if lack of staff resources leads to projection of an OL l
issuance date which is not consistent with construction completion dates.
In particular, based on what we believe is a reasonable projected licensing schedule (See Enclosure 2 of the staff's September 16, 1980 meeting 4
minutes), an SER issuance date in 1981 seems essential to be consistent with the schedule analysis of both our organizations.
In conclusion, the effort outlined above hopefully conveys Consumers Power Company's commitment to facilitate resumption of the Midland docket review.
Cooperation in these effo,rts is essential to timely completion of the NRC staff review.
I would appreciate receiving your comments on our proposal f
f 4
4 oc1180-0094a100 I
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- and would also like the opportunity to meet with you periodically to review the progress of our licensing review.
In the meantime we will pursue this approach in detail with your staff.
w CC JDSelby r RJCook, Resident Inspector GSKeeley teliller, IL&B TJSullivan FPCowan, Hearing Board Member GLinenberger, Hearing Board Member CBechhoefer, Hearing Board Chairman
,4 oc1180-0094a100
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ONITED STATES
! % f's NUCLEAR REGULATORY COMMISSION 7
OFFICE OF PUBLIC AFFAIRS, REGION Ill 799 Roosevelt Road, Glen Ellyn,lilinois 60137 NEWS ANNOUNCEMENT:
81-2
Contact:
Jan Strasma 312/932-2674 w
NRC STAFF PROPOSES $38,000 FINE AGAINST CONSUMERS POWER COMPANY FOR ALLEGED QUALITY ASSURANCE VIOLATIONS AT MIDLAND CONSTRUCTION SITE The Nuclear Regulatory Commission's Office of Inspection and Enforce-
,ment has proposed a $38,000 fine against Consumers Power Company far alleged violations of NRC regulations in the installation of safety-related ventilation systems..at the Midland Nuclear Power Station, under construction at Midland, Michigan.
The alleged violations were identified during an investigation in March through July 1980 at the Midland construction site after allegations of deficiencies were received by the NRC from several individuals.
The allegations concerned work being performed by the Zack Company, the heating, ventilating and air conditioning contractor at the Midland site.
p The URC investigation identified major deficiencies in both the Consumers Power Company and Zack quality assurance programs for the Zack Company's fabrication and installation work.
All safety-related work by the Zack Company was stopped by Consumers Power Company on March 21, 1980 as a result of the initial NRC investi-gation findings and the utility's own quality assurance program findings.
The NRC issued a letter confirming that work was stopped and would not resume without NRC authorization.
Work was permitted to resume on August 14, 1980.
During the period when work was stopped, there was extensive revision to-the Zack and Consumers Power quality assurance programs for the ventilation system work, as well as development of a program to identify and correct any deficiencies in work already fabricated and I
installed.
NRC inspectors reviewed the corrective action before permitting the l
Zack work to resume.
The NRC inspection program will continue to l
monitor the Zack work closely.
The NRC investigation team -- composed of seven inspectors and investigators -- identified alleged violations of 10 of the NRC's 18 l
quality assurance criteria, with multiple examples of some violations.
l The alleged violations include:
inadequate material procurement practices use of materials without adequate quality certification components were fabricated without required design documents inadequate documentation and material identification to assure that proper materials were being used use of different welding procedures than specified inadequate welding material control procedures completed welds not identified by the welder's identifying stamp
-More-
81-2 two welders issued the same identification stamp material not meeting specifications was not properly identified to prevent its use inadequate quality assurance inspection procedures quality control inspection reports (nonconformance reports) not promptly resolved quality deficiencies not identified in inspections of materials when received inadequate quality control records a Zack quality assurance audit was performed by an employee responsible for the work being audited rather than by an independent Zack employee Consumers Power Company has until February 2, 1981 to pay the fine or protest it.
If the fine is protested and subsequently imposed formally by the NRC, the utility may request a hearing.
January 7, 1981 I
l UNITED STATES NUCLEAR REGULATORY COMMISSION POSTAGE AND FEES PAID CFFICE OF INSPECTION & ENFORCEMENT uNrTED STATES NUCLEAR m
EAI' MAIL REGION lli REGULATORY COMMISSION 799 ROOSEVELT RO AD k
j CLEN ELLYN, ILLINOIS 60137 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 l
- Ronald Cook 8 Route 7 atory Com.
. Midland, MI 48640 1
PUBLIC ANNOUNCEMENT from U. S. Nuclear Regulatory Comnussion
.~
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