ML20105C885

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Forwards Notice & Agenda for Aug 1981 Caseload Forecast Panel Meeting & Results of 1981 Caseload Forecast Panel Visit,In Response to
ML20105C885
Person / Time
Site: Midland
Issue date: 02/09/1982
From: Cook R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Budwani R
NEW JERSEY, STATE OF
Shared Package
ML20105C399 List:
References
FOIA-84-96 NUDOCS 8502090540
Download: ML20105C885 (1)
v • d • e


Text

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UNITED STATES 8'

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NUCLEAR REGULATORY COMMISSION 3

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799 ROOSEVELT ROAD Q

GLEN ELLYN, ILLINOIS 60137 o

February 9, 1982 i

R. N. Budwani Rules Court West, 12W Route 46 Lodi, N.J.

07644 Dear R. N. Budwanit

< In response to your letter of December 18, 1981, received by my office on January 22, 1981, I am enclosing a copy of the Notice of the Meeting and Meeting Agenda for the August, 1981 Caseload Forecast Panel and a copy of the Results of the 1981 Caseload Forecast Panel Visit.

My conversations with Mr. Darl Hood, Licensing Project Manager have revealed that he has made a similar response to your inquiry.

To receive a copy of the applicant's presentation, I would suggest that you contact the applicant at Consumers Power Company Midland Project 3500 Miller Road Midland, MI 48640 Attn: Donald B. Miller, Site Manager or call Mr. Miller at (517) 631-8210.

Sincerely,

/

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R. J. Cook Senior Resident Inspector cc:

Darl Hood D. C. Boyd 8502090540 840517 PDR FOIA RICE 84-96 PDR i

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Docket Nos:

50-329/330 y WT

- p MEMORANDUM FOR:

Elinor G. Adensam, Acting Branch Chief

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Licensing Branch #4, DL pEncd ile g

FR0!!:

Darl S. Hood, Project Manager Licensing Branch #4, DL

SUBJECT:

NOTICE OF MEETING AND TOUR BY CASELOAD FORECAST PANEL TO ASSESS CONSTRUCTION COMPLETION SCHEDULES - MIDLAND PLANT, UNITS 1 AND 2 DATE & TIME:

August 25,1981 (Site Tour) 8:30 a.m.

August 26-27, 1981 Meeting 8:30 a.m.

LOCATION:

August 25 (Plant tour): Midland Plant Site August 26-27, 1981 (Discussions):

Consumers Service Center 1100 S. Washington Street Midland, Michigan PURPOSE:

August 25: To tour and observe plant construction progress.

August 26-27:

To discuss completion status and schedules for Midland Plant, Units 1 and 2 PARTICIPANTS:--1/

NRC Consumers Power Comoany W. Lovelace J. C90k, et al J. Matore D. Hood Bechtel J. Rutgers, et al J==ra M &

Darl S. Hood, Project Manager Licensing Branch #4 Division of Licensing l

cc:

See next page l

--1/

The meeting of August 26-27 is open for interested members of the public, petitioners, intervenors, or other parties to attend as observers pursuant to "Open Meeting and Statement of NRC Staff Policy", 43 Federal Register 28058, l

6/28/78. For the site tour on August 25, 1981, permission to enter construction site must be obtained in advance from Consumers Power Company.

WC O M v i6 -

AUS 101989

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MIDLAND Mr. J. W. Cook Vice President Consuiers Power Coganv 1945 West Parn'all Roac Jackson, Michigan 49201 cc:

Michael I. Miller, Esq.

Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.

Division of Radiological Health Alan S. Farnell, Esq.

Department -of Public Health Isham, Lincoln & Beale P.O. Box 33035 Suite 4200 Lansing, Michigan 48909 1 First National Plaza

Chicago, Illinois 60603 William J. Scanlon, Esq.

2034 Pauline Boulevard Jares E. Brunner, Esq.

Ann Arbor, Michigan 48103 Consumers Power Cogany 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Myron M. Cherry, Esq..

Midland, Michigan 48640 1 IBM Plaza Chicago, Illinois 60611 Ms. Barbara Stamiris 5795 N. River Ms. Mary Sinclair Freeland, Michigan 48623 5711 Summerset Drive Midland, Michigan 48640 Stewart H. Freeman Assistant Attorney General State of Michigan Environmental Protection Division.

720 Law Building Lansing, Michigan 48913

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Mr. Wendell Marshall L

Route 10 Midland, Michigan 48640 Mr. Steve Gadler 2120 Carter Avenue 55108 St. Paul, Minnesota,

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NIDLAND FIAf"f UNITS No 1_ AND 50 2 j

Caseload yorecast Panel Site 41 sit Meeting Acenda August 25-26, 1981 l

Drerview of project construction schedule including progress and major i

1.

milestones coupleted since caseland panel visit of July 1980, current I

problems, bases for current dates and any anticipated problem areas that may impact the current projected feel load date.

r 2.

Detailed review of project schedule identifying critical path items, near critical items, maount of float for various activities, the current critical l

path to fbel loading, methods of implementation of corrective action for any

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activities with negative float and provisions for contingencies.

Estimated percent complete for (1) Unit No 2 and needed eammon facility, (2) Unit No 1 and (3) total project all as of July 31,1981.

3 Detailed review and eurrent status and forecast of design and engineering i

i effort including any potential probicas that may arise from necessary f

rework.

f is. Detailed review and current status of procurement activities including I

valves, pipe, instrianents, cable, endor ecaposents, etc.

I Actual and proposed craft work fome (by major craft), craft availability, 5

L productivity, potential labor negotiations and problems.

6.

Detailed review and current status of all large and ama11 bore pipe hangers, nstraints, snubbers, etc. including 6esign, rework, procurement, fabrication, delivery and installation, broken down for Uktit Eo 2 and needed common j,

facilities and Unit No 1.

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7. Detailed review and current status of buit quantities including ourant i

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total estimated quantities, quantities installed to date, quantitica scheduled to date, carrent percemit complete fbr each, actual vs forecast installation rates an0 basis for these figures broken down separately l

for (1) Unit No 2 with needed common facilities and (2) Unit No 1.

f Concrete (CT - Cubie Yards) a.

b.

Pacess Pipe (LF - Linear Fleet) l

- farge Bare Pipe (2-1/2" and larger) h11 Bore Pipe (2" and Sha11er)

Yard Pipe (LY)

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Large Bore Pipe Hangers, Restraints, Snubbers, Mc (Esch) d.

fkall Bore Pipe Hanger, Bestraints, Et.c (Ench) e.

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cableTray(11)

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Total conduit (LF) g.

"I h. Total Itrposed Metal Conduit (LF)

  • i. Electric Cable (LF)

- Power

- Control

- Instr uentation

- Plant Lighting

- Soeurity J.

Electrical Terminations (Esch)

- Pbwer

- Control

- Instraneatation

- Plant Lighting

- security k.

Electrical Circuits (Each) 1.

3hatnsmentation (Ehch)

Ccaparison of Pbrecast Six (baantities With Previous Fbrecasts n.

t 8.

Detailed review and current str,tua of preoperation of preop test procedures, imtegration of preop test activities with constnnetion schedules, rystems turnover schedule,' preop test schedule, current and proposed preop test progran manpower; broken down separutely for (1) Unit No 2 with needed ecaumon facilities and (2) Unit No 1.

a.

Total Number of Procedures Required for Puel Icad b.

Number of Draft Procedures Eat Started c.

Nimber of Draft Procedures Being Written

4. ' Neber of Procedures Approved c.

Number of Procedures in Review, f.

Total Eisaber of Preop Test-Beguired for Peel Imad l

g.

Etamber of Preop 14sta Campleted h.

Number of Preop Tests Currently in Progress 1.

Rimber of systems Turned Over to CP Co J. Preop Tests Planned or in Frag /ess for Unit No 1 After Puel load of Unit No 2 9.

Detailed discussion of 5% atn construction influence due to changes attributed to NUREG-0, y at,4er recent licensing requirements.

10. Discussion of schedular impact, ir arg, regarding potential deficiencies reported in accordance with 10 CFR 50.55(e).

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11. Overview of current const,ruction manasceent organization and activities.
12. Site tour and observation of ecastruction activitN.

13 Basis for coupletion ante extension.

j IRB 8/3/81

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NUCLEAR REGULATORY COMMISSION g *-

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'+,*... *,o SEP 3 1991 Docket'Nos: 50-329/330 Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201

Dear'Mr. Cook:

Subject:

Results of 1981 Caseload Forecast Panel Visit - Mitiland Plant, Units 1 and 2 This will confirm the findings of the NRC's Caseload Forecast Panel resulting from the visit of August 25-27, 1981 com'pletion schedules for Midland Plant, Units 1 and 2.to assess construction As reported at the conclusion of that visit, the Panel's finding reaffirms its 1980 projection of an October 1983 completion date for Unit 2 and April 1984 for Unit 1.

July 1983 for Unit 2 and December 1983 for Unit 1.This agrees reasonably wel Since the staff establishes the schedule on the applicant's completion date, the schedule for review of the Midland Plant application for operating licenses remains as reported in Mr. Denton's letter to Mr. Selby on August 21, 1981.

for issuance of the Midland Safety Evaluation Report.This includes a recently Sincerely, Robert L. Tedesco, Assistant Director for Licensing Divist(sn of Licensing cc: See next page 7-y'/,f 1 1

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MIDLAND Mr. J. W. Cook s

Vice President Consiimers Power Company 1945 Dest' Parnall Road Jackson, Michigan 49201 cc: Michael I. Miller, Esq.

Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.

Division of Radiological Health Alan S. Farnell, Esq.

Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Suite 4200 Lansing, Michigan 48909 1 First National Plaza

Chicago, Illinois 60603 William J. Scanlon, Esq.

2034 Pauline Boulevard

. James E. Brunner, Esq.

Ann Arbor, Michigan 48103 -

Consumers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Myron M. Cherry, Esq.

Midland, Michigan 48640 il IBM Plaza Chicago, Illinois 60611 Ms. Barbara Stamiris 5795 N. River Ms. Mary Sinclair Freeland, Michigan 48623 5711 Summerset Drive Midland, Michigan 48640 Mr. Paul A. Perry, Secretary Consumers Power Company Stewart H. Freeman 212 W. Michigan Avenue Assistant Attorney General Jackson, Michigan 49201 State of Michigan Environmental Protection Division Mr. Walt Apley 720 Law Building c/o Mr. Max Clausen Lansing, Michigan 48913 B'attelle Pacific North West Labs (PNWL)

Battelle Blvd.

Mr. Wendell Marshall SIGMA IV Bldg.

Route 10 Richland, Washington 99352 Midland, Michigan 48640 Mr. Steve Gadler 2120 Carter Avenue St. Paul, Minnesota 55108 O

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O Consumers Power James W Cook h

hhf Vice President - Projects, Engineering and Construction oenere: Offices: 1945 West Parnell Road, Jackson, MI 49201 + (517) 788-0453 Jaruary 25, 1982 l

Harold R Denton, Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND PROJECT MIDLAND DOCKET NOS 50-329, 50-330 CONFORMANCE TO REGULATIONS RESPONSE FILE 0505.6 SERIAL 15495

REFERENCES:

(A) NRC,(EGADENSAM) LETTER DATED OCTOBER 27, 1981 (B) CONSUMERS POWER COMPANY (JWC00K)

LETTER DATED NOVEMBER 20, 1981 Reference (A) requested (Question No 400.8) an evaluation which would demonstrate that the Midland Plant meets the pertinent regulatory requirements of Title 10 of the Code of Federal Regulations. Reference (B) provided an interim response. The attachment to this letter provides the final response to the question and any exceptions to the pertinent regulations are noted therein. This information will also be incorporated into the Midland FSAR in a revision to be issued in February 1982.

JWC/JNL/dsb CC RJCook, Midland Resident Inspector, w/a RHernan, USNRC, w/a RWHuston, w/a DBMiller, Midland, w/a

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UNITED STATES NUCLEAR REGULATORY COMMISSION 3

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E REGION lli P

799 ROOSEVELT ROAD j

%*****o CLEN ELLYN,ILLINolS 60137 April 9, 1982 s

MEMORANDUM FOR: Darrell Eisenhut, Director, Division of Licensing, NRR FROM:

R. L. Spessard, Director, Division of Project and Resident Programs

SUBJECT:

RECOMMENDATION OF BOARD NOTIFICATION (MIDLAND)

Recognizing the Atomic Safety and Licensing Board's keen interest in matters impacting on Consumers Power Company's quality assurance activities in connection with Midland, Region III believes that the Board should be made aware of two issues being pursued by Region III relative to the remedial soils work. These are:

1.

Members of the Region III staff who participated in recent meetings with the applicant concerning the application of quality assurance in the underpinning activities have expressed concern that information provided by the applicant's staff regarding the status of instrumenta-tion work completion was misleading. While the technical issues related to this matter are being resolved to our satisfaction, I plan to initiate a more in-depth look into the concerns expressed by the NRC staff members.

2.

The applicant is experiencing problems with QA program implementation as they restart work in the underpinning area. While our experience tells us that some problems will occur in the restart of any activity that has been suspended for a long period of time, we believe certain problems should not have occurred (e.g., performing work without adequate implementing procedures; selective application of QA program requirements to work activties). We are continuing to. monitor closely the licensee's activities in this area. If we concIude that the program is not being well managed, we will not hesitate to stop the work and take appropriate enforcement action.

The results of our investigation fato the possible misleading statements and any continuance of problems with the implementation of the qualiry assurance program will be brought to the Board's attention promptly.

f?.t &

R. L. Spe6sard, Director Division of Project and Resident Programs cc:

V. Stello, DEDROGR ' -

R. C. DeYoung, IE H. R. Denton, NRR J. G. Keppler, RIII I:. L. Jordan, IE W. Paton, ELD J. Lieberman, IE E. G. Adensam, NRR W. P.,Haass, NRR R. Cook, SRI, Midland v,,i/nr h w MY#} '

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vomr Company Midland Project: PO Box 1963, Midland, MI 48640. (517) 631-8650 May 14, 1982 Mr. L. E. Davis Bechtel Power Corporation F.O. Box 2167 Midland, MI 48640 MIDLAND PROJECT GhD 7020 REMEDIAL SOILS ACTIVITIES File: 0458.16 UFI:

00234(S) Serial: CSC-6083

REFERENCES:

(1) CPCo letter CSC-6067 dated May 5,1982 (2) CPCo Letter CSC-6073 dated May 6, 1982 (3) CPCo Letter CSC-6076 dated May 7, 1982 (4) Atomic Safety and Licensing Board (ASLB) Memorandum Order, dated April 30, 1982 ThisletterisintendedtoclearlyidentifythecurrentscopeoftherbentASLB Memorandum and Order relating to remedial soils work (Reference 4). Also, this letter supercedes all previous correspondence on this subject as provided by References (1), (2), and (3).

1 The current scope of the ASLB stopwork scope is defined as follows:

1) TE4PORARY h' ELLS a) A stopwork has been placed on drilling, installation and developing of temporary dewatering wells except for dewatering the area around the 72" diameter line that is to be repaired.

b) Work can proceed on the header system, pumps and hook-up for any temporary wells.

Pumping can proceed on any temporary wells which have been previous-ly developed. Work can proceed on the dewatering system for the service water pump structure at the appropriate time.

l 2)

PER\\1ANENT hTLLS i

a) A stopwork is being placed on installation of the header system, pumps, and electrical system for the permanent wells which are being installed by Kelly Dewatering.

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b) Work can proceed on the drilling, installation, and developing being per-formed by Kelly Dewatering. The Loughney wells can be reactivated.

3) UTILITY !!ONITORING PITS a) All work related to utility monitoring pits other than that specifically referenced in item #1 in this letter can proceed as scheduled.

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May 14,.1982 RBIEDIAL SOILS ACTIVITIES

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4) TANK FARM a) No work is to proceed in the tank farm area. The exception to this is the epoxy injection grouting of cracks in the borated water storage. tank ring wall.
5) EXCAVATION AND BACKFILLING a) A stopwork has been placed on any excavation and backfilling in Q designated areas as defined by Bechtel drawing C-45 (Q) Rev. 6 other then the utility monitoring pits.

b) Excavation and backfilling can proceed in Non-Q designated areas.

If any

' questions arise if specific work is in Q or non-Q areas or it is close to Q areas (within 10 ft) consider it Q until receiving further guidance from CPCo Construction Department.

6) FREEZEWALL a) Work can proceed on drill work for freezewall elements, b) Work can proceed on all installation including header systems, refrigeration plant, and testing of the freezewall system.

Activation can proceed after Region III approval.

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7) DEEP-SEATED BENCSIARKS No work can proceed on drilling or installation of the deep-seated benchmark.
8) INSTRINENTATION a) /. stopwork has been placed on installation of monitoring system instruments and mounting.

There are other instrumentation restraints which are not specifically addressed in this letter.

By virtue of this letter, these restraints are not voided and remain in effect, b) Work can proceed on the installation of the monitoring system cable.

We intend to continue utilizing "stopwork" letters and u3 dates as a vehicle to con-trol the release and execution of the work affected by the ASL3 stopwork onier.

This memorandum only applies to recent ASLB order (Reference 4) and does not void nor alter any non ASBL related stopwork orders.

If there are any questions Construction Depart r clarifications necded, please address them to CPCo

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D. B. Miller Site Manager DBM/GM/dmw cc: Dehorn-JMeisenheimer ABoos DRonk JFFisher JA\\ looney MCurland JSchaub DLVanDoorne e

SteveJ.badler,P.E.

2120 Cart:r Avenue, St. Paul, Minnesota 55108 Telcph;ne: 646-5005 s

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March 26, 1982 Wendell H. Marshall, President Mapleton Intervenors RFD 10 Midland, MI 43640

Dear Mr. Marshall:

Submitted herewith are the concents and questions on the above referenced MRC Findings of Fact and Conclusions of Law prepared by Dr. Edward Pry ina, PhD.

From the list of questions that nest be answered I have concluded that NRC has glossed over the nuclear plant's deficiencies and shortcomings, the threat to the public safety and health, the pollu-tion of air and water environments by radioactive dunping, the un-tenable location on the flood plain, cracked and sinking buildings, soil and compaction probleus, and unresolved safety problems includ-ing the EMP threat.

In ny humble opinion based on the above referenced docunent, it ap-pears that URC is still continuing to promote nuclear power plants for the industry instead of carrying out its nandated duties - that is, to regulate.

As an exanple, enforcement of all safety and health rules must be strict and the URC connission is'the cop on the nuclear beat and therefore, cannot close its eyes to the above mentioned de-ficiencies, and certainly cannot pass out a pernit under these cir-cunstances.

Sincerely, g.

dcA! '

Steve J. Gadler, P.E.

SJG/lk e

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DRAFT E!!VIRONIETAL STATEMEIT (!AIREG-0537) - Related to the Operation of Midland Plant, Units 1 and 2.

Docket Nos. 50-329 and 50-330; Consumers Power Ccmpany.

U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Re5ulation, Feb. 1982.

CC CCT3 PREPARED BY DR. EDWARD A. FRY 2I:!A Page 1-1 Introduction Par. 2 ( Paragraph 2)

Waste heat will be dissipated to the atmosphere from a 360ha (880 acre) cooling pond.

Question: How much heat (in BTU's) will be dissipated into the atmosphere?

How much water will be lost to the atmosphere and what effect will this have on the flow of the Tittabawassee River 4

(referred to as T. River) during a 12 month period, but especially during low flow.

At what temperature will the cooling pond wastewater be dischar-ged into the T. River?

How will temperature standards in Michigan be monitored for compliance?

' dill the temperature of the cooling pond wastewater being discharged into the T. River be measured at the end of a pipe or in a " mixing zone".

If a mixing zone is involved, how vill it be defined and monitored for compliance.

Par. 4 (Administrative History)

'Jere there any environmental assenssments concerning environmental impacts during the construction phase?

Page 1-2 par. 1 question: Does the NPDES permit have any control over radioactivity in wastewater?

Have 401 certification permit conditions been met?

O

Page 2-1 Purpose and Need for Action Par. 2 (Point # 3) Line 3

-;uestion: Specifically what costs went into the " Projected Economic ndvantage" ecuation? Was decommissioning cost included ? If not, how would incorporatin; it alter the above?

Page 2-2 Par. 2. Production Costs Line 2 Statement made that " Environmental costs associated with construction have already been incurred".

Question: Identify these costs (environmental) during construction also, include any construction permits, pre-opera-s tional studies which had to be done.

Par. 3 Line 2 " Economic-Dispatch logic" (assumed that least costly units would be on line for the longest time)

Question: Re: The projected average savings of $202 million dollars / year between 1984-1988.

Do these savings include amount of money excluded as part of decommissioning costs of the plant?

Have any calculations been done on savings from alternative electric generating facilities and if Midland Plant 1 ard 2 were not completed?

Page 2-5 Par. 1 Line 1 Re: " Estimated savings for 1984 = S124 million" Question: How are these savings calculated? What values, costs, etc.

are included?

question: How is capacity factor defined?

Question: What evidence is used to justify a capacity [$f 865 avernged over the life of the plant?

Question: How does the above estimated capacity factor compare with capacity factor for other PWR's in existence today?

What happens to the capacity factor as the plant gets older?

- ' ow is the 5124 million savings (estimated) affected if Question:

d the capacity factor drops to 30E?

15,5.

j question: At what capacity factor are esticated savin 5s down to zero?

Par.3hhisisaratherinterestingplacetoinsertthedecommissioningcost.

Question: '4ould it not be more appropriate to include the decommissioning cost befor" alculating the " savings"?

Far. 4 Line 1

"...In conclusion...."

Question: On what basis does the (NRC) staff agree with applicant's assessment of potential savings? especially since applicant has not factored in the decommissioning cost, nor has the method of decommissioning been determined at this time.

Will~the plant be dismantled after 40 years or simply buried?, i.e. paved over with concrete?

Par. 5 Line 16 " Diversity of Supply" question: Fromthestandpointofthecostfbenefitratioistheaddition of Midland 1 and 2 to increase diversity of fuel supply for the service ar'ea justified in view of the eno rmous cost of a nuclear electricity generating plant?

By the same token, this nuclear facility can also be considered to be a significant financial liability to the rate payers.

Page 2-7 Par. 4 Line 7

".. Substitution of nuclear-generated electricity for coal, oil and gas.."

Question: Yhat differences in radionuclide caicsions (total) would be expected between nuclear power plants and fohsil fuel plants?

O

. 4._.

Page 2-7 (continued)

Comment: It seems to be a serious waste of technology to use nuelear energy to boil waler to produce' steam, especially,

,Lf one considers the risk due to radiation exposure and accumulation of radioactive wastes with no place to store or bury them.

Question: What weight towards justifying Midland 1 and 2 construction, did NRC staff assign to cogeneration capability.

'dhat is the justification for such an assessment?

Tage 3-1

" Alternatives to Proposed Action "

Far. 1 Lines 7, 8, 9,10.

Comment:

In the statement " Since the plant has been substantially constructed.... most economic and environmental costs have already been realised and must be viewed as sunken costs in any prospective assessment"

'suestion: What are sunken costs? Why have such alternatives not been explored before construction of the plant began?

P:.r. 3

".... Environmental costs associated with any alternatives that were considered and foreclosed at the construction permit stage would now be prohibitive"?

.iuestion: But what if current assessment and knowled 0 indicate that 6

serious environmental damage might result from poor design / construction cf the existing partially completed facility (73% completed). Also, note the soil testing concerning the settling of the storage facility related to the cooling core system.

Par. 4 Line 1 "...only logical alternative to permitting operation of the plant is to deny its operation. (until the problems are resolved) rather than issuing the permit because the plant is 73% completed and any retrofitting, etc.

would be prohibitive.

. Comment: The entire emphasis is on the 5200,, savings per year for the j

first five years. Note,' however, these savings do not reflect all costs involved and so are not true and accukat e.

g.

Question: Have all unresolved safety issues been resolved at this time? Have all of those identified which were determined to have generic implications beer resolved? As an example, what is the status of the soi:

tests, misrouted ripes for cables, water pipes which have become "cvalized" due to settling of constructed units?

Page 4-1 Project Description and Affected Environment Par. 1 Line 4 question: 'ihy was the cooling tower eliminated?

Question: How much did the peoposed cooling tower cost?

Page 4-3 Par. 3, Line 11

+

)

Question:. ~4 hat are the requirements of Part 50 34a of Title 10 of Code of Federal Regulations?

Par. 4 uestion: What will be the kinds and quantities of each specific s

radienuclides which will be expected to be released annually into unrestrticted areas? (include gases solids and liquids).

Par. 5 question: Why has not the NRC's detailed evaluation of radwaste systems-and their capability to meet recuirements of Appendix 1, Chapter II of Staff's Safety Ivaluation j

Report, been provided at this time?

Jhy must it be 4

postponed until May, 1982?

]

i Par 6 Question:

'ihere will solid radioactive wastes ce-disposed of?-

.iuestion: What will be the calculated cost of disposal?

question: Have you looked into any potential synergistic effects between any radioactive nuclides?

4.

1 4

f O

_o,.

. Face L-3 (continued)

Par. 7 Question:

ihat specific information will the Padiation-dese-design objectives of Anpendix centain? J.< hat.will be the format? '4hy have these objectives not been provided 1

at this time?

Page 4 4 Par. 1 Lines 1-6 Question: hhich specific non-radioactive (chemical and physical) wastes are being referred to here?

z. hat is the waste manaEement system based on?

Par. 2 Question: 'dhat specific radioactive and non-radioactive wastes will comprise the Cooling Pond blowdown?

'ihat specific biocides will be used at this point? In what concentrations?

Par. 5 Questions: How much heat will be lost into the atmosphere through evaporation?

(In BTU's)?

What will be the temperature of the Cooling Pond blowdown at the point at which it is discharged into the T. River?

Does the State of Michigan have thermal standards? If so, how will the Midland P1nnt 1 and 2 affect those standards How will such thermal standards be enforced, especially if a mixing zone is involved?

'Jhat will the specific water quality of the cooling pond blowdown (discharge) at the point of discharge into the T. hiver? (Including TDS,pH, B.O.D., C.O.D., D.O.)?

In view of the fact that Midland 1 and 2 are downstream from the Dow'. Chemical Ccmpany Plant, will the anticipated combined (Dow Chemical and Midland 1 and 2) discharge meet Michigan water quality standards?

How will the anticipated decreased dissolved oxygen levels by adjusted to meet state water quality standards?

'4 hat impacts will the lowered D.O. levels have on biota?

'Jhat effect will be anticipated concerning the fluctuating T. River levels on downstream water quality? Biota?

and riverine aninals living along the banks?

r

Tage 4-5 Cooling ' dater Treatment Par. 1 s

'.' uestion : Uhat effect will sulfuric acid have on the pH of the

.q.

cooling pond wastewater? The T. River?

Question: 'that effect will the lowered pH have on re-dissolving toxic heavy metals found in the sediments.

Par. 2 Question: 'ihat is the potential for. having the discharged chlorine combine with organic wastes in the T. River forming toxic organochlorines such as PCB's etc.

'ihat will be the significance and impact of the presence of 135 metric tons of sodium in the T. River?

Par. 5 question:

'that is the chemical composition of the referenced evaporator blowdown?

Page 4-9 Par. 1 Question: What was the basis for the satement indicating full vertical mixing in the T. River?

question:

dhat specific segment of the T. River does this apply to?

Question: 'dhat are the depths of the T. River below point of discharge?

Question:

4 hat are the temperatures of the T. River and the effluent from the cooling pond (wastewater) at the point of discharge into the T. River?

Page 4-11 Par. 2, Line 3

~

Question:

'4 hat is the history and specific composition of Dow Chemical waste discharges into the T. River?

uestion: 'dhat is the annual thermal loadin; of the Dow Chemical Company s

to the T. River?

Question: What is the B.O.D., C.O.D. loading of the Dow Chemical Company to the T. River?

e Questicn: What '4 of the time will Midland 1 and 2 have to shut down because of being unable to withdraw enkeup water from the T. River and/or discharge pond wastewater into the T. River because of low flow of the T. liver er because of excessive temperatures cf the pond wastewater?

Far. 5 iuestion: What method will be used to mitigate fugitive dust during plant construction and operation?

Page 4-13 Par. 7, Line 10 question: Specifically which radioactive elements are being referred to here?

(Reference to Regulatory Guide 1.111).

Page 4-15 Ecology Far. 1 Terrestrial question: Specfically, what flora and fauna inhabit this area? What surveys have been made and are being relied on at this point? How often will such surveys be made?

Par. 2 Question: Have potential impacts resulting frem the use of 345 kV.

transmission lines been evaluated? If so, what are they? If not, when will this be done?

How much right of way will there be on either side of the transmission lines?

How will the right of way be cleared and maintained?

How near will the 345 kV lines be to the nearest living receptor (Human or Animal)?

Par. 4.

Question: What is the ficral and faunal species composition along the right of way?

Par.

(4.3.4.2) Aquatic question:

'4 hat is the biotic species composition of the T. River in the vicinity of the plant site, on an annual basis, mon?.h by month?

-9

,uestion:

'! hat is the biotic ccmposition of the T. River in the vicinity of the plant site? elithin the Cooling Pond? That is the pctential for oder problems in the Cooling Pond ?

question:

Yhat species cceprise the I' Mere diverse species. assemblage" in the vicinity of the plant cite? Is species diversity an indication of pollutien or lack of pollution?

'(uestion: Enumerate all other generators of wastes upstream of Midland 1 and 2 list specific thermal and waste load to the T. River for each waste generator.

Question: How will the thermal and waste load of upstream waste and heat generators affect Midland Plant 1 and 2 ? How will it affect communities and plants downstream frem Dow Chemical and Midland Plant 1 and 2?

Page 5-1 Environmental Consequences and Mitigating Actions Par. 2, Line 7 uestion: To what use can the pri=e farmland inundated by the cooling s

pond wastewater be returned tc af ter the plant is decommissioned? Will method of decommissioning have any influence or effect on what will happen to this prime farmland which is becoming a scarces commodity?

Page 5-2 (Par.2)

Question: How much right of way will the 345 kV. transmission line require?

Page 5-3 Par 2 question: Does the state of Michigan have anti water quality degredation regulations? If they have, then how will the Midland proposed activity mesh with it?

PaSe 5 4 Par. 2 question: Wodd these standards apply to both the Dow Chemical Company Plant and the Midland Plant cischarges?

Question: What is the thermal and waste (total) contribution of both Dow Chemical Company and Midland Plant (Consumers) to the T. River? Any synergistic effects between chemical c mp nentn?

Pa-3.

Question: How is the " mining zone" defined, measured and enforced? Does it include horizontal as well as vertical mixing? How will this be determined? Have any model studies been done on this?

Page 5-9 Par. 1 luestion: What measures are being taken to mitigate fugitive dust during construction and operation?

. Fage 5-9 (Continued)

Par. 2 Site question: *' hat is the statement based on which indicates that the Staff (NRC) forsees no significant adverse impact of plant oper ation en terrestrial biota?

.! hat surve'ys and inventory

.,I.

of bicta is being referred to? Nhich specific bicta are referred to by the above statement?

Par. 3 Quer, tion:

In reference to landscaping program in relation to mitigatien of the construction phase impacts, what measures (land-scaping, etc) are contemplated in connection with decommissioning of the plant after 40 years?

Pa6e 5-10 Par. (last) question: Other than by an ongoing monitoring progran, how else can NRC staff detect whether or not any significant impacts are occurring? Should this therefore not be a part of the condition for MRC licensing?

page 5-12 Par. 2 " Based on comparison of average kmperature expected in the F.idland plant...."

question: Do fish in these waters die at srecific temperatures or at average kmperatures?

Par. 5 Question: What will be the upper or the highest temperature attained in the cooling pond.eastewater to be discharged into the T. River?

Page 5-13 Question: What levels of low dissolved oxygen are anticipated? What impacts are contemplated on biota?

Par. 2 question:

Is there an inventory of the flora and fauna of the transmission line corridors?

Par. 3 uestion: What happened to the results of the evaluation of potential s

hazards of collision, electrocution and exposure to herbicides on birds, which was conducted by the NRC staff?

i 1

1 I

l

)

Page 5-13 (continued)

Par. 74uestion: Is there an inventory of aquatic organisms in' the referenced T. River ? If not, then on what statement is this comment made?

Page 5-15 Par. 1

4uestion: how will the losses due to migrating waterfowl be mitigated?
  • lho will repay the farmers for their losses?

PaEe 5-18 Par. 5 Cuestion: In reference to airborne effluents and their diffusi6n in the atmosphere being dependent on meteorological conditions, what measures will be taken during temperature inversions, or when rather than 360 degree dispersion, air will travel in a plume likened to a " river of air", preventing airborne radionuclides from dispersing and thereby pctentially exposing receptors (amimals, humans, vegetation ) to high levels of these radionuclides.

Page 5-21 Par. 2 question:

It is very important that baseline data be collected and current levels of anticipated radionuclides be esta-blished in air, water, crops, meat (including hogs, cows, chickens goats, deer, etc.) so that meaningful results can be obtained when comparisons are subse-quently made.

Page 5-23 Par. 2 Comment: There is a great deal of controversy among scientists as to the biological effects of low level radiation. This matter has b: no means been settled at this time. It is best not to err at all regarding a cafe concentratic or dose of exposure, however, next best it is better to err on the side of safety and to permit only the smallest body exposure and only if absolutely necessary Page 5-29 Par. 5 (last) It is not possible to say that no lethal effects have occurred at

the radioactivity concentrations found in the area surrounding the plant. Lethal effects are difficult te detect and in order to find them, if they do in fact exist, one must lock for them in the existing population before the populatien is exposed to a given suspected toxic substance.

Fage 5-38 Far. 2 'suestion: "Jere samples taken at Three Mile Island during the time when releases were actually taking picce er afterwards when no other ceasurable radioactive fission products could have been detected?

Fage 5-70 Par. 1 qu stion: 'q:ere and how will high level and low level radicactive wastes be disposed of? What is the anticipated cost of such disposal?

Fage 6-5 question: Specifically what kind of deccmmissioning is being contemplated and planned for in cennection with ::idland 1 and 2? hat measures will be taken to control the niobium and radioactive elements with long half lives?

How will they be removed and where will they be disposed of7 3

4 4

J i

O

-O e

4 Wendell H. Marshall MAPLETON INTERVENORS RFD 10 Midland, Michigan 48640 March 25, 1982

' Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, D.C.

20555 Attn:

Charles Bechhoefer, Esq.

Mr. Ralph S. Decker Dr. Frederick P. Cowan Jerry Harbor, Esq.

Ref:

Consumer Power Plants Units 1 & 2, 50-329, 50-330 Gentlemen:

The Mapleton Intervenors letter to the ASLB dated 16th of December, 1981, on the unresolved safety issue of the Electro Magnetic Pulse (EMP) has become a matter of concern to the Consumers Power Company as evidenced by their letter to the ASLB dated the 28th of December 1981.

Consumers Power Company states that the matter should not be addressed at this time because it is not properly before the board -

however, since this is a safety issue and effects the public health and safety, it must be addressed at this time because retrofitting of plant against EMP would be financially impossible.

Therefore, we again petition the ASLB board to stop construction of the plant until the EMP question has been properly resolved.

Sincerel,

hf k Y//

i Wenaell H. Matsha 1,'Presi ent Mapleton Intervenors cc:

Michael I. Miller, Esq.

Mr. Myron M. Cherry, Esq.

Ronald G. Zamarin, Esq.

Mr. R. B. Eorsum Alan S. Farnell, Esq.

Mr. Don van Farrowe, Chief James E. Brunner, Esq.

Mr. Walt Apley Ms. Mary Sinclair Mr. James G. Keppler, Reg. Admin.

Stewart H. Freeman P. McCallister, P.E.

Mr. Steve J. Gadler, P.E.

Frank J. Kelly Zane M. Goodwin, P.E.

Mr. Robert W. Huston Dr. Charles H. Carson, PhD.

U.S. Nuclear Regulatory Commission Ms.. Barbara Stamiris l

  • > Steve J. Gadler, P.E.

2120 Cart r Av:nue, St. Paul, Minnesota 55108 Telephon2: 646-5005 1

lQ)Yl/.

I March.30,.1982 Mr. Wendell H. Marshall Mapleton Interveners RFD 10 Midland, MI 48640

Dear Wendell:

k Please find enclosed questions prepared from enclosures 1 and 2 attached to a letter from Ms. Elinor G. Adensam, Chief Licensing i

Branch #4, Division of Licensing, U. S. Nuclear Regulatory Commission, Docket numbers 50-329 and 50-330, dated November 30, 1981.

This letter and attachments were sent to Mr. J. W. Cook, j

Vice President, Consumers Power Company by Ms. Adensam of the NRC.

The two enclosures mentioned in the above paragraph address the matter of a request for additional information on generic "un-resolved safety issues" at Consumers Power Midland Plants 1 and 2, as well as other nuclear power plants in the United States.

It behooves the NRC to address the questions contained herein because so many of them concern the public health and safety, and especially the people living in the Midland area.

I am certain that the NRC will not attempt to gloss over the serious-ness of the plant's defects.

Certainly the NRC, the regulating federal agency, cannot give a license to the Midland plant, for as Dr. Edward Pryzina says, you would not send an astronaut into space in a space vehicle with a deficient nose cone.

I suggest that you send this list of questions to the Nuclear Regulatory Commission to the attention of Mr. Ronald W.

Hernan, Licensing Project Manager, Office of Nuclear Regulatory Regula-j tion, United States Nuclear Regulatory Commission, Washington, D. C.

20555.

Sincerely, Steve J. Gadler SJG/ sit i

I e

1

_z

+

Wendell H. Marshall MAPLETON INTERVENERS RFD 10 Midland, Michigan 48640 s

.g.

A'pril 1, 1982 Mr. Ronald W. Hernan l

Licensing Project Manager i

Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Hernan:

Enclosed are additional questions from the Mapleton Interveners relative to the Consumers Power Company Midland plants 1 and2, Dockets number 50-329 and 50-330.

These additional questions are sent to obtain answers because of the safety and health implications.

We request that the United States Nuclear Regulatory Commission review these questions and provide us with complete answers, for we feel that the job is not being well done.

4 Yours very truly, a

4 h'l M

-~

Wendell H. Mar tall (

President, Mapleton Interveners WHM/ sit cc:

Sec'y, Nuclear Regulatory Comm.

Mr. Steve J. Gadler, P.E.

Docketing & Service Sec., NRC Zane M. Goodwin, P.E.

Charles Bechhoefer, Esq.

Mr. Robert H. Carson, Ph.D.

Mr. Ralph S. Decker N U.

S. Nuclear Regulatory Comm.

Dr. Frederick P. Cowan Resident Inspectors Office Jerry Harbour, Esq.

Ms. Barbara Stamiris Michael I. Miller, Esq.

Mr. Myron M. Cherry, Esq.

Ronald G.

Zamarin, Esq.

Mr.

R.

B.

Borsum Alan S.

Farnell, Esq.

Mr. Don van Farrowe James E. Brunner, Esq.

Mr. Walt Apley Ms. Mary Sinclair Mr. James G.

Keppler Stewart H. Freeman P. McCallister, P.E.

Mr. Robert W. Huston Frank J. Kelly I

O

ENCLOSURE 1 - REQUE3T FOR ADDITIONAL IN'ORnATION.

I (Enclosures 1 and 2 are attachments to a letter from Ms. Elinor G..idensam Chief Licensing Branch No. 4, Division of Licensing, U.S. Nuclear Regulatory Commission (Dockets Nos. 50-329/330) dated Nqvember 30, 1981), to Mr. J.W. Cock.

%'ENCLbSURE1 Page 1.

Paragraph 1 (Par.1)

Question: Where can we obtain a copy of NUREG-0606 " Unresolved Safety Issues" (Also c lled the " Aqua Book"). Also, a

earlier documents such as NUREG -0510 and NUREG - 0410.

Par. 2.

Question: How many " Unresolved Safety Issues " have been identified to date in the United States? In the rest of the world?

How many have been resolved to date? (both generic and non-generic? ).

How many nuclear power plants in the United States are operating today with serious " Unresolved Safety Issues or problems" ? How many of these plants have received construction and/or operating licenses from the Nuclear i

Regulatory Agency (NRC)?

1 Question: Has the Midland FSAR been updated as requested by NRC?

4 If so, Where can we obtain this material?

ENCLOSURE 2 Page C-1 Par. 1, 2, & 3 Questions: What is the basis for the decision (by NRC) as to whether i

a newly identified safety issue or problem should be treated as one having generic implications? Who makes this decision and what kind of empirical evidence is used?

Question: What is the justification for allowing any nuclear power i

plant construction / operation in the face of identified serious " Unresolved Safety Issues"?

i Question: What magnitude must an "Unredolved Safety Issue" reach before it triggers a shutdown of construction or operation?

Who makes this decision? What empirical evidence is used?

question: What actually triggers the decision that the " safety" significance of a given problem does not prohibit continued operation or construction of the plant while the longer term generic review is under way?

{

Page C-2 Par. 1.

Question: How does the NRC define " undue risk" How are unresolved generic and non-generic safety problems factored into i

this decision? Who makes this decision and what empirical evidence is used?

j

~

question: To what extent will generic safety evaluations be allowed to dictate specific requiremen'ta or needs of individual plant fadilities?

w

g,,

  • Page C-2 (continued)

Question:

Who makes the deter =ination concerning the relevance of a particular generic or non-generic problem with respect to a specific nuclear plant?

s Par. 3 question:

Has a Task Action Plan been prepared by Consumers Power for Midland 1 and 27 d

Question: If a Task Action Plan has been prepared by Consumers Power for Midland 1 and 2, has it incorporated the following:

a.

Have they described the investigative program which must be undertaken with regard to the problem (safety) ?

b.

How long will the program take?

c.

Will any interim measures be necessary pending completion of the investigation by NRC?

d.

Will the suggested program plan produce effective results'.

s Have alternative courses of action been suggested by e.

Consumers Power, in the event the program plan does not produce the anticipated results?

Par. 4

".. In short, the board (and the public as well) should be in a position to ascertain from the SER itself-without need to resort to extrinsic documents % the staff perception of the nature and extent of the relationship between each significant unresolved generic safety question and the eventu-al operation of the reactor under scrutiny" j

' Question: What specifically is the (NRC) staffs perception of the nature and extent.of the relationship between each signifi-cant unresolved generic safety question? What empirical evidence is required?

Question:

On what basis did licensing board make the decision to permit continuation of construction in the face of the i

serious unrecolved, safety questions, both generic and non-generic?

3 In view of the many unresolved safety questions identified to date; a.

Have any of these safety problems been resolved for any U.S. reactor to date? If so, Please. specify and describe.

- s, b.

Was there a reasonable basis for concluding that a satisfactory solution will have been found before a given reactor was to be put into operation?

c.

Will the safety problem have immediate or eventual safety implications? If so, what alternatives have been identified now, at this time, before the reactor is allowed to operate?

j Question: What is the basis for allowing the reactor to operate even though it is now known that a safety problem will or might be found in the future? How is " undue risk" defined in this situation by the NRC? Please describe in detail.

+.

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,m e.w,

=

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Page C-3

" Unresolved Safety Issues" Question: Pursuant to Section 210 (PL 95-209), has the NRC developed a plan to implement all identified corrective measures relative to unresolved safety issues (generic and non-generic) for the Consumers Power Midland 1 and 2 plant?

~

'lhere can we obtain a copy of this plan? (For each unre-solved safety issue? )

Question:

... In reference to Section 3 on page C-3.... House amendment which required development of a plan to resolve Eeneric safety issues, including priorities cssigned to each issue.."

l Has the NRC developed such a plan (if different from the above plan) for Consumers Power FEdland 1 and 2 plant?

If so, please indidate where we can obtain a copy of this plan?

1 Question: How many unresolved Section 210 safety issues have been identified to date (March, 1982) for all U.S. nuclear plants including Midland 1 and 2?

Question: Is the NRC Program for Resolution of Generic Issued Related to Nuclear Power Plants designed to focus on only broad safety issues or can it focus on specific narrow unresolved safety j

issues as well? Give an example using the Midland 1 and 2 plant.

Question: Since the NRC generic issues program in effect pre-empted the U.S. Congress's enactment of PL 95-209, does the NRC program I

ine:ude all requirements mandated by Congress? If not, which ones have been left out and why?

Page C-4 Par. 2 Question: What was the basis on which the NRC determined which nuclear power plant issues qualify as " Unresolved Safety Issues" and are reported to Congress? Are there any other kinds of safety. issues which have not been designated as such by the NRC and not reported to Congress? Please describe and use examples to clarify this point.

Par.4 Question: " Reference here is to the section in quotes beginning with "An unresolved Safety Issue is a matter...."

Question: Does " matter" have to affect a number of nuclear power plants to qualify under this definition?

Question: How'does the NRC determine if it is dealin5 with an "important" question concerning " adequacy"? Who determines if the question is "important caough"?

l Question: How is adequate defined by the NRC? (as it relates to existing safety requirements?)

Question: How does 'the NRC evaluate if a proposed unresolved safety issue involves conditions "not likely" sto be acceptable?

O 4

- ~,.

Page C-6 (continued)

Question: Where can we obtain answers to the above questions?

Question: Where can we get a copy of the " Office of Nuclear Reactor Regulation Unresolved Safety Issues Summary, Aqua Book"?

Does this book contain any information on Midland 1 and 2?

If yes, please describe and list this information.

Question:

If, during the course of a given year, certain " Unresolved Safety Issues become " Resolved", how is such information disseminated? How can we get on a mailing list to assure that we obtain current information?

Page C-7 Question: How current is this list of "New Unresolved Safety Issues?"

(i.e. since 1979?)

Question: Where can we obtain a copy of NURIG - 07057 Question: Where can we get a copy of Section 10.4.3 SER discussing (Page C-8) effect of water hammer on steam generator feedrings?

Could not such problems (i.e. water hammer effects) have been anticipated by the design engineers? Could they not have been uncovered by the manufacturer before a packaged nuclear power plant was sold to Consumers Power, for example?

Question:

(Re: A-3) Could not this corrosion been forseen by metallurgical engineers and prevented?

Does the United States send astronauts into space in a space vehicle which has a nose cone which will melt when exposed to the sun?

Page C-9 Question: Is it really ethical for the NRC to allow the nuclear power industry to use the people as guinea pigs by allowing the industry to experiment and do research at such great cost to the public (health and safety), ie. major decretse in degree of protection of public health and safety and then try to compensate for the public health and safety loss?

Par. 2 Question: What specific sections are being referred to here? SER cited but incomplete.

Question: How much of the basic research on such items as steam generator tubes does the nuclear industry actually do on their own?

Question: How much of such research is conducted at university laboratories-At public expense?

Question: Why is the nuclear industry not forced to werk out technical and engineering problems in their own laboratories and work out the bugs before they are allowed to build nuclear power plants which the NRC knows will have " Unresolved Safety Problems which will predictably impact the public health and safety?

U

,' Page C-9 (continued)

Par. 3 Question: Who decides what appropriate action will be thken in the event of steam generator tube degredation NRC? Manufacturer?

Owner / Operator of the Plant?

. Question: Who decides how " appropriate' actions " is defined? Is such decision made on a case by case basis or does' it become generic? If so, who makes that decision?

Page C-10 Par. 2 Question:

Where can we obtain a copy of SER Section 15 3 57 Question: Where can we obtain a copy of the 1980,81 ATWS issue which was scheduled for rule making in midsummer 1981?

Par. 4 Question: What assurance at this late date can NRC give that in the event of ATWS malfunctions, that the Emergency Core Cooling System will operate?

Question: How does this generic problem relate to and affect the Midland 1 and 2 plant?

Question: What specific unresolved safety problems have been identified at Midland 1 and 2 by the NRC7 By Consumers Power?

and how are they related to A-9 and A-11?

C-11 Par 4 Question: How is fracture toughness evaluated to assure that the nuclear power plant can be operated without " undue risk "to the health and safety of the public?

Par. 5.

Question:

(Re: A-12) Why could not the toughness of the different steels have been determined by the manufacturer under simulated conditions of temperature, pressure, etc.?

Question: Why has it taken this long for the NRC and the manufacturers of nuclear power plants to discover the problem with reassessment of fracture todghness?

Are there perhaps other problems whinh the NRC and the manufactureres of nuclear power plants are aware, but have not yet revealed to the public relative to additional i

decrease in protection of health and safety for the public?

If the answer to the above is yes, please let us know all additional newly discovered " Unresolved Safety Problems "

connected with reactors.

Par. 7 Question:

Is Midland 1 and 2 included in NUREG -0577? Where can we obtain copies of this document?

O o

Page C-12 Par. 1 Question: Has the final implementation plan for NUREG 0577 been completed?

If so, where can we obtain a copy?

. Par.[3 i

Question: -(Re: A-17) Are NRC conclusions sensitive to the c'ertainty of an unresolved safety problem which is expected to occur in the future and cause a " Major reduction in protection of health and safety of the public. for which public must somehow be compensated? If not, then why not? Please explain Page C-13 Par. 4 Question:

On specifichily what basis other than sheer speculation can the NRC give the public " reasonable assurance" that the l

effects of potential system interaction on plant safety will_be within the effects on plant safety previously l

evaluated? (evaluated by whom?).

j Question: How does the NRC define " reasonable assurance" in this instance?

]

Question: Hou does the NRC finding on A-17 impact on operating license for Midland 1 and 27 Par. 6 I

Question:

Is M,dland 1 and 2 one of the plants being re-evaluated re-garding seismic desing criteria? If so, what information is currently available to us?

Page C-14 3

Par. 3 l

Question: (Re: A 43) How does Containment Emergency Sump Reliability as an unresolved safety problem impact on Midland 1 and 2 construction and operating license?

C-15 i

Par. 4 Question:

(Re: A 44) WiM the Station Blackout unresolved safety problem i

impact the Midland 1 and 2 plants? How did Consumers Power propose to resolve this problem?

I Question: Where will Midland 1 and 2 obtain offsite electrical power?

Under what circumstances? Is there a written committment?

I Question: Where can we obtain a copy of SER Section 8.2? 8 37 l

C-16 Par 3 Question: How will the fact that Midland 1 and 2 is a cogeneration plant and will supply the Dow Chemical Company with steam, affect I

its ability to participate during an emergency to utilize' i

steam to drive a steam turbine utilizing auxiliary feed-I water system in the event of total on-site and off-site.

electrical failure?

Question: Where is NRC review of auxiliary feedwater system design described?

r

. *.,.a

' Page C-17 Par. 3 Question: Where is the NRC review of Decay heat removal (i.e. Section of SER?

)

Question: What problems regarding heat decay removal are anticipated at Midland 'l and 2?

Far 7 Question:

(Re: A-46) Does Midland 1 and 2 anticipate having any problems with seismic qualification of equipment? If so, please explain? Is Midland 1 and 2 on a fault zone?

C-18 Par. 1 Question: Will Midland 1 and 2 be able to be brought to a safe shutdown condition in the event of a seismic accident?

Par. 3 Question:

(Re: A-47) What does the NRC mean when it states that "It is generally believed " by the NRC staff that such control system failures would not lead to serious events or result in conditions that safety systems could not handle"?

Are there times when NRC does not generally believe this?

If so, under what circumstances? Please cite example.

Page C-19 Par. 2 Question: Why has NRC chosen to permit nuclear power plant operation, especially in view of their statement:

"A systematic evaluation of the control system design, as contemplated for this (serious, significant) unresolved safety issue, has not been performed to determine whether postulated accident could cause'significant control system i

failures which would make the accident consequences More severe than presently analyzed" Question: What consequences will this decision have on people from Midland?

Par. 3 Question: On what basis can NRC give " reasonable assurance" that the Summer Unit can be operated? (safely? ).

Question: What impact will the NRC decision have on Midland 1 and 2 and the health and safety of the public living in Midland Michigan?

Page C-20 Question: On what basis can NRC issue an operating license to Consumers Power in view of this serious, significant, unresolved safety problem, thereby jeopardizing the health safety of the people in Midland, Michigan?

9

=

R J Cook, Midirnd Razident Insprctor James W Cook Vice President - Projects, Engineering and Construction

+w General offices: 1945 West Pernall Road, Jackson, MI 49201 e (517) 78&O453 February 11, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND PROJECT REQUESTED INFORMATION ON LICENSEE QUALIFICATION FILE: 0505.813/0505.16 SERIAL: 15506 The intent of this letter is to provide additional information requested by your reviewer for Chapter 13. The licensee has applied for operating licenses for both units and expects to receive them simultanteously. This expectation is based on the present construction schedule which indicates construction and testing will be completed on both units prior to loading fuel on the lead unit. In this context, Consumers Power Company was asked to address seven issues, several of which dealt with contingency plans should the operating licenses not be issued simultaneously. The seven areas of interested are detailed below.

Area 1.

SITE AUTHORITY AFTER LICENSE IS RECEIVED: Upon receipt of an operating license for either unit at the Midland Plant the Vice President of Nuclear Operations will become responsible for the site.

Any remaining construction work (which is defined as all work on equipment which has not been turned over to Consumers Power Company) on either unit will proceed in accordance with the Quality Assurance Program now in effect, Topical Report CPC-1A. All modifications and warranty work will be performed as described in Consumers Power Company's Topical Report CPC-2A which was accepted by the NRC on January 12, 1982. All remaining preoperational testing, if any, will proceed in accordance with Topical Report CPC-1A which is implemented by the Midland Nuclear Plant Testing Program Manual. Administrative control of all-construction activities will be treated as modifica-tions under CPC-2A.

Area 2.

UNITS 1 AND 2 STAFFING, OPERATING QUALIFICATION, AND CONTINGENCY PLANS: It is our intent to have Senior Reactor Operator license holders (Plant Supervisors, Shift Supervisors and Shift Engineers) fill their respective positions on both units simultaneously and be fully qualified on both units. The bases for this approach includes:

oc1281-0543a131, y~

s t'

2 A.

Most major systems are virtually identical on both units from an operating standpoint. These systemi include:

~

reactor coolant nuclear instrumentation containment heat removal incore monitoring 4

containment isolation offsite power combustible gas control onsite power emergency core cooling fuel transfer and handling containment spray and service water i

fission product control component cooling water i

reactor protection desineralized water ESFAS and ECCAS borated water safe shutdown outside the control room chilled water safety-related display fire protection instrumentation emergency diesel generators non-safety control-and auxiliaries (ICS, CRDCS, turbine control, computer, atmospheric main steam steam dump, pressurizer control, loose parts feedwater monitoring, boron monitoring) condensate' auxiliary feedwater i

It may be noted that in the FSAR these systems have a single description which is applicable to both units. The only major systems that are significantly different are the main turbine-generator and transformer, but the controls operate similarly.

Au appropriate, operating procedures are designated for the applicable unit.

B.

The on-going training the operators receive is applicable to both units and' includes differences, similarities, and common'or l

-shared features.

l C.

The present s.. Jule provides a relatively short time of approxi-mately five months between the startup of the two units.

Licensing individuals on both units simultaneously will allow us to have all of these individuals involved in the startup of the first unit rather than in a classroom training program. This j

experience will be invaluable in starting up the second unit.

I oc1281-0543a131

3 D.

The design of the plant includes some shared or common features, where appropriate, such as the auxiliary building including the control room, spent fuel pool including cooling and purification, services such as HVAC, and systems like service air and auxiliary steam supply.

It would create an unjustified complex administrative burden for the Shift Supervisor to assign responsibility for control of these common or shared features to the operators of one unit or the other.

E.

The attached meeting summary, dated November 17, 1980, signed by K N Jabbour and B A Wilson, indicated agreement to simultaneous examinations for both units. This has been the basis for plan-ning and training since then.

If the staff cannot be licensed on both units simultaneously, a contingency plan would call for operators to' attend a special class to emphasize similarities and differences between the units just prior to taking the license exams on the second unit. As indicated above, the main core of training on the second unit is conducted l

simultaneously with the first unit. This alternative would decrease l

the number of licensed individuals per shift during startup of the first unit since some of the individuals would be in classroom training at all times. This would also lessen each individual's involvement in the startup program due to the time spent in the classroom during significant operating events.

Area 3.

NUMBER AND SIZE OF SHIFTS, ATTRITION, AND EXAM FAILURE RATES: The l

following table and Attachment A describe our plans for providing an adequate number of licensed operators. Five licensed personnel are required per shift (2 SRO's and 3 RO's) and five shift staffing is required. Our goal is.to establish six shifts consisting of eight i

licensed personnel (3 SRO's, 4 RO's, and a Shift. Engineer) per shift.

A 75% NRC exam passing rate and a 15%/ year attrition rate were used after careful consideration of available industry and company data.

This data is presented in Attachment A to illustrate the relationship between the requirements, our objectives and actual etaffing to date.

The minimum required and enticipated shift crew staffing are addressed above and in the following list:

i l

Minimum Required Anticipated 1

1.

SRO's:

2 3

I 2.

RO's:

3 4

3.

Auxiliary Operators:

3 10 4.

STA (Shift Engineer):

1 1*

5.

Chemistry Technician:

1 5

6.

Health Physics Technician 1

2 i

oc1281-0543a131 i

\\

l

4 h

7.

I&C Technicia'ns 1

8-42 (depending upon shift)

  • SRO license desirable In addition, we are currently investigating the availability of. contract personnel with previous initial startup experience on a B&W unit. Our. intent is to have these personnel on shift to be available to control room personnel during startup of the first unit.

Area 4.

SIMULATOR TRAINING OF NON-LICENSED PERSONNEL: Phase E of the Cold License Training Program is described in Subsection 13.2.1.1.1.2 of the FSAR. This subsection specifically outlines simulator training requirements. Attachment "B" provides informat; ion on plant personnel who have completed this phase of the training and our present plans for future training.

Area 5.

PROCESS STEAM INTERFACE BETWEEN DOW CHEMICAL COMPANY AND PLANT STAFF:

The interface between the plant staff and Dow will be via the process steam control room, which will be manned by one or two Consumers Power Auxiliary operators who will maintain communications with the main control room and Dow.

The process steam control room will normally be manned at all times and the operators will receive sufficient class room and on-the-job training to qualify at that station. Fifteen Chemistry / Health Physics Technicians will normally be available as needed to support operations of the process steam system.

Area 6.

CONSUMERS POWER COMPANY PLANS FOR OFF-SITE TECHNICAL SUPPORT: Fol-

~

lowing is a table containing the prelimininary estimated. manpower requirements for the Nuclear Operations Department Technical Support Staff located in Jacksca, Michigan. These numbers thru 1985 do not include available resources in other departments.

Pm.: MART tmmm NUCLEAR OPERAMONS CEPARTMINT = S-YEAg praw_ FORICUT 1981 1982 1983 1984 1985 MMMMMMMiklfMM ncetzAR ACMVTTIES RadiolossesA services 14 3

13 6

21 8

23 11. 23 11 suclear Licanetag 11 4

12 6

18 8

21 8

21 8

Plant Projects 4

1 4

1 9

1 9

1 9

1 Plant Support 26 3

43 10 36 11 61 12 61 13 Reactor Engineering 24 4

30 6

40 7

40 8

42 9

TOTAL NUCLEAR ACTITITIES 79 19 104 29 144 33 134 40 136 42 QUALITY 438t%ANCE*

67 14 80 13 98 13 106 14 107 14 TRAINDG*

30 14 66 20 93 21 92 11 92 21 P1 ANN DG 4 4DMDI5? RATION 3

4 10 6

14 9

16 10 16 10 jgtTT & AUDI* R17tB ""

1 1

3 1

9 3

9 3

9 3

l TOTAL C D ERAL CITICE 202 32 263 71 360 81 377 33 33o 90

  • Includes personnel located at plant sites.

I oc1281-0543a131 l

l

5 The heading "EA&P" includes engineers, supervisors, and managers while "SE-W" is in general clerical and' technicians.

Area 7.

TRAINING OF NON-LICENSED PERSONNEL: The Training Department has recently increased its staff significanly to assure that all licensed and non-licensed personnel are trained such that they can perform their work competently and with an understanding of how their actions impact the plant. To assure that this objective is met, a $40 million training center is being built which includes plant-specific simulators for both Midland units.

Generic training will be conducted at this center. Site specific training will be prepared at the plant. These facilities and personnel will be used to train non-licensed personnel such as I&C technicians, engineers, radiation protection technicians, and chemistry technicians as well as licensed operators. Some of the training personnel will be dedicated to training only I&C technicians, radiation protection technicians or chemistry technicians thus assuring both specific and general training in their field of interest.

It is also the intent of the Company to provide training for electrical and mechanical repairmen as well as auxiliary operators. The formalized training programs for these last three groups will be completed after INPO guidelines are finalized. As a minimum the program will consist of learning systems fundamentals and on-the-job training.

JWC/BLH jm i

CC: RJCook, Midland Resident Inspector RCHernan, US NRC DBMiller (3), Midland RWHuston, Washington l

oc1281-0'543a131

ATTACHMENT A Licensed Operator Candidate Resource - Objective s

Number operator candidates needed for 5 shifts 25 Post fuel load objective - six shift schedule (7 licensed operators / shift)(6 shifts) 42 (1 Shift Engineer / shift)(6 shifts) 6 Subtotal 48 Assume 25% NRC license failure rate

+0.75 Subtotal 60 Attrition (.85)(.925)

+0.79 (1.5 years of attrition)

Required number of license candidates 81 Licensed Operator Candidate Resource - Actual Number SRO certified candidates 7

Number RO certified candidates 11 Number candidates in certification training 50 Total operator candidates 68 Number Operator candidates to be hired 13 Required number of license candidates 81 A

mil 281-O'03a-131 0

l

AttcchmentB i

's

~

B&W S1HULATOR TRAINING POSITION 77 78 79 80 81 82 83 Note 8 Gescrol Manager 1(40) Note 5 Plcnt Supt Oparctions Supt 1(120) Note 6 Maintenance Supt 1(40) Note 5 1

Technical Supt Plent/ Shift Supy

/

1, 4(120) 6 Note 2 10, 2(120) Note 7 Ccatrol Operators 1, 3(120) 9 Note 3 4

Auxiliary Operators 29 Shift Engineers 2(60) Note 4 2

4 Technical Engineer 1(120) 1 Note 1 Esgin:ers (Technical Dept) 1(120) 1, 3(40) Note 5 1 SR T2chnical Analyst 1(120) 1 Note 1 Nucleer Training Instructors 1

4, 1(120)

Operctions Coordinator 1

NOTE 1

Same~ individual who attended 1979 course 2

Three of these individuals attended 1979 course 3

One of these individuals attended 1979 course 4

Course for non-operators 5

Course for Management personnel 6

Held previous license 7

Held previous license and attended 1979 course 8

Approximately 15 personnel will attend simulator training in 1983.

It is expected that the group will consist primarily of Plant / Shift Supervisors and back-up Shift Engineers.

General - All periods of instruction are for 320 hrs unless indicated otherwise as (XX).

cil281-000lb131-27

fbcdL N

[ pay hycl[(wd o

UNITED STATES 8"

NUCLEAR REGULATORY COMMISSION n

,E REGION ill

%*****,g*['

7MB ROOSEVELT ROAD g

GLEN ELLYN, ILLINOIS 60137 April 9, 1982 u

,4 i

s MEMORANDUM FOR: Darrell Eisenhut, Director, Division of Licensing, NRR FROM:

R. L. Spessard, Director, Division of Project and Resident Programs

SUBJECT:

RECOMMENDATION OF BOARD NOTIFICATION (MIDLAND)

Recognizing the Atomic Safety and Licensing Board's keen interest in matters impacting on Consumers Power Company's quality assurance activities in connection with Midland, Region III believes that the Board should be made aware of two issues being pursued by Region III relative to the remedial soils work. These are:

1.

Members of the Region III staff who participated in recent meetings with the applicant concerning the application of quality assurance in the underpinning activities have expressed concern that information provided by the applicant's staff regarding the status of instrumenta-tion work completion was misleading. While the technical issues related to this matter are being resolved to our satisfaction, I plan, to initiate a more in-depth look into the concerns expressed by the NRC staff members.

2.

The applicant is experiencing problems with QA program implementation as they restart work in the underpinning area. While our experience tells us that some problems will occur in the restart of any activity that has been suspended for a long period of time, we believe certain problems should not have occurred (e.g., performing work without adequate implementing procedures; selective application of QA program requirements to work activties). We are continuing to. monitor closely the licensea's cetivities in this area. If we conclude that the program is not being well managed, we will not hesitate to stop the work and take appropriate enforcement action.

The results of our investigation into the possible misleading statements and any continuance of problems with the implementation of the quality assurance program will be brought to the Board's attention promptly.

-/h. oh -rC_

R. L. Spessard, Director '

Division of Project and Resident Programs

~~

cc:

V. Stello, DEDROGR R. C. DeYoung, IE H. R. Denton, NRR J. G. Keppler, RIII E. L. Jordan, IE W. Paton, ELD J. Lieberman, IE E. G. Adensam, NRR W. P..Haass, NRR R. Cook, SRI, Midland

,, J / ~ L d m f, _

~~'

O os * '

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