ML20105C982
| ML20105C982 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/29/1982 |
| From: | Stamiris B STAMIRIS, B. |
| To: | Okrent Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20105C399 | List: |
| References | |
| FOIA-84-96 NUDOCS 8502090562 | |
| Download: ML20105C982 (7) | |
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nr 5795 N. River Road
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Freeland, MI 48623 F RTJu.cTV L May 29, 1982 t
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--- e Chairman Okrent (b
Members ACRS 7
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Dear Chairman Okrent:
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Re:
Midland Plant 1 am unable to attend the ACRS meetings in Washington this week, but I wish to submit the following statement regarding statements made at the May 20, 21st ACRS meeting in Midland, Michigan.
Upon reviewing the Quality Assurance and outstanding soils issues in prepar-ing this statement, I am struck by the illogic and basic unfairness of dealing with operat ohs license issues while such major questions as the soils issues remain unresolved.
'the. ASLB hearing the soils case for the past year has not even heard the 7
vast majority of the technical issues dealing with the soils remedial fixes, let alone offer their decision in this case.
The one major area which has been covered in the hearing, quality assurance, is now about to be reopened as Mr. Keppler reconsiders his previous testimony on QA adequacy in the wake of the recent SALP report.
In light of these facts, and considering Consumer's pattern of continuing inability or unwillingness to properly execute the sensitive soils work at hand, I urge this board to withhold any ciecisions leading toward the operators license until all the facts are in and the ASLB has had an opportunity to complete its soil settlement decision.
Consumer's 1984 Dow steam contract deadline and Congressional pressures such as "the Bevill dates" for NRC licensing review have played a substantial role in bringing the operator's license review to this committee at this time.
But Consumer's pressing licensing needs cannot be placed above the more important health and safety quent ions which must be resolved first.
This committee's efforts to ascertain the underlying criteria on which the NRC has based their safety review, as pursued at the May 20 and 21st meeting are essential to the protection of public health and safety. The NRC's failure to demand rigorous adherence to objective criteria as seen in Quality Assurance, if repeated in technical areas, cannot provide assurance of a safe iluelear plant.
The NRC summary of quality assuranc,e isives,unounted to a Ehitewash of a seriously deficient QA history as documented in public' records.
From the QA review
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May 29, 1982
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pYesented Nay 20th, the ACRS could not begin to understand or critique QA adequacy.
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I fear that the technical review summaries are similarly flawed, leaving the ACRS without the necessary data base for their assessment of NRC regulation.
The ACRS is to audit and evaluate the NRC review, but is relying on the NRC's own presenta-tions of the facts--or those of the applicant, rather than objective sources.
I hope this committee is able to overcome the obvious shortcomings of this system, and somehow achieve an objective and critical analysis of this nuclear plant.
The public deserves no less.
Thank you for your consideration of these important matters.
Sincerely, W
Barbara Stamiris 9
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INTERVENOR RESPONSE TO NRC QUALITY ASSURANCE ASSESSNENT AT 5/20/82 ACRS MEETING At the May 20, 1982 ACRS meeting on Midland, and in the SER, the NRC has con-cluded that Consumer's QA program has been and will be acceptable.
I wish to i
document the public criticism I made of that assessment.
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'The QA history of this plant reveals major QA problems in virtually every construction area undertaken.
Consumer's 54Fq.23 response -lists the major construc-4 tion activities prior to 1977 as " soils, rebar and embeds, concrete. cadwelding, structural steel erection and liner plate erection." The NRC's October,1979, Chronological Listing of Major Events identifies problems in rebar and embeds in 1975-76, concrete and cadwelding in 1970 and 1974 (ALAB 106,. LBP 74-71), and in
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tenden sheath omissions and liner plate bulge in 1977, and containment post ten-
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sioning errors in 1979.
Since that time, electrical and piping have been the major construction areas in addition to soils remedial work. The NRC's recent 1980-81 SALP evaluation rates these three areas negatively today.
As early as 1972, the ALAB 106, Board found that "neither the applicant nor the architect-engineer has provided reasonable assurance that the QA program will l
be implemented properly." Suspension of the construction permits was considered then,.and again in 1974 as a result of QA deficiencies.
Yet the NRC and Consumer's have repeatedly defended inadequacies, cited imporvements, and given
- heir reason-able assurance to licensing boards that proper. QA would ensue in the future.
Most recently a " reasonable assurance" conclusion was given by the }mC prior to the commencement of the soil settlement heari.gg intended to dFeide that very -
question. It was based on the May 1981 team, inspection and seiv'ed as a condition I
for a stipulation agreement between the NRC and Consumers that the soils QA break-
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down would not be litigated.. As a result of the stipulation, the NRC drew a line between their consideration of pre and post December 6,1979 QA problems", as
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an NRC witness admitted (p. 3869). I found that'QA problems occurring after Decem-u be'r 6,1979, were minimized, defended, or overlooked by the NRC, while previous problems were addressed straightforward 1y in the soil settlement hearing.
During the May 1981 team inspection, NRC inspectors actually had copies of the proposed QA Stipulation with them during the inspection. The May 81-12 inspec-tion served as the basis for Mr. Keppler's reasonatie assurance judgement and
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the subsequent QA Stipulation.
This inspection and personal visit by Mr. Keppler, at the March 13,' 1981, invitation of Consumer's James Cook represented Consumer's best QA effort. It is a significant inspection because, stripped of its summary judgements and conclusary statements, it reveals surprisingly inadequate construc-
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tion and QA implementatien on the part of Consumer's. Noncompliances and deviations i
were identified in eight of the eighteen areas inspected, particularly in the
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ongoing construction areas of soils, electrical, and piping, and an I.A.L. was i
issued.
The body of the May 81-12 inspection findings, as well as the two negative
. SALP reports for 1980 and 1981, contravene the NRC's prepared testimony of QA ade-quacy for that same time period.,Yet even if-we were to accept the NRC?c June
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1981 position that "as a result of revisions, improved implementation, and cther factors
.. (there is) reasonable assurance that QA and QC will be appropriately implemented with respect to future soils construction activities, including reme-dial actions," we once again have the passage of time to prove this assurance wrong.
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For as the most recent I&E reports (82-05 & 82-06) document, the soils reme-dial work has not been properly implemented.
QA deviations, and misleading infor-mation in the remedial work have led to a consideration of escalated enforcement.
And Director Keppler is currently reconsidering his QA testimony in light of these 231.:: ticr..
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3 Yet in presenting the NRC assessment of QA to the ACRS the RC minimized Mid-O land's poor QA history saying "following each major problem. period the licensee has been responsive." Mr. Little of Region III'went on to define the NRC criteria hr judging the QA program adequate as being that the licensee identifies his pro-blems. However, the records of audits and inspections reveal that once problems are identified, adequate corrective or preventative actions do not ' follow.
Mr. Little said that when the NRC conducted its follow-up soil settlement investigations in December 1980, that the licensee-had met its soils commitments, aside from some minor FSAR review and documentation problems.~ This statement overlooks and: avoids the reality of Consumer's inadequate soil settlement responses.
Specifically the December follow up inspection, 80-32, indicates that 40%
of Consumer's soil settlement commitments from questions 1 & 23 "either have not been completed by CP Co. or the action taken was considered insufficient." The 80-32 FSAR re review problems were extensive, and particularly significant because Consumer's own audits had revealed the problems several months earlier, but failed to correct them. The problems with relaxations of procedures or failure to fol-low approved procedures were paralled to the original FSAR review problems which are cited in the December 6th order.
Yet only at NRC 'insistance were proper prece-I dures implemented in what was termed the re re review. The 80-32 inspection resulted in three noncompliances involving inadequate design Aontrol, one involving inade-quate corrective actions,(the same criteria cited in the December 6 order), and numerous unresolved items.
The second soils follow up inspection, 81-01, involving onsite implementation ofsoilscommitmentsresultedinfournonco$pliancesandadeviation. Again the
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significance of these soils problems comes from their remarkable similarity to the original soils errors of.1975-78, and also from the fact that once, again they repre-sented a continuation of problems which Consumer's own audit findings had identified I
six months earlier.
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W-Six CPC audit findings (M-01-11-0-01 to 06) of July 1980 involved soils test-d ing errors ins (1) relative density; (2) test elevations; (3) inadequate.inspec-e
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tions; (4) ','Q" placement of soils; (5) equipmentsverifications; and (6) inadequate geotechnical review. Consumer's considered, but did not initiate a soils stop-work at this time (3167-70). And the soils testing errors of January 1981 (81-01) which were taking place under the direction of an unqualified geotechnical engineer, contrary to their NRC commitment, indicate that corrective actions again did not follow the earlier identification of the problems m
Regarding this series of July 1980 audit findings, I blieve the NRC was remiss in not considering them in their post-December 6,1979 testimony, despite the fact that I had personally presented these findings informally to NRC members in Jan-uary 1981 and thereafter.
In cross examining witnesses about the apparant contra-dictions between these audit findings and their testimony that soils problems were resolved in.1980, the significant similiarity of these problems to past prob-lems was denied (p. 2590).
The.May 81-12 inspection revealed similar audit deficiencies and failures to correct identified problems as in.dicated in,the noncompliances cited. Also NRC inspectors identified five unresolved items regarding dewatering well plans (the only ongoing. soils work) and.found soils QA to be inadequately staffed (a repeat of the 81-01 deviation). As noted 'in the April 82 SALP report, "every inspec-
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tion involving regional based inspectors and addressing soils settlement issues
. has resulted in at least one significant item of noncompliance" despite the tremen-dous attention focused on soils.
In other statement's before the ACRS, the NRC has credited Consumer's with undertaking a voluntary soils work-stop during the course of the hearing, since legally the soils prohibitions of the December 6 order were notjinding.
- However, the evidentiary record of the soils hearing, and the ASLB April.30,1982 memoran-(
' dum (p.13), confirms that certain soils work continued beyond this agreement with-(
out NRC concurrence.
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.1 The NRC also granted specific concurrence for portions of the soils remedial
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In fact, the initial NRQ testimony of the hearing (5uly 5,1981) was a complete reversal of
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the licensing board's question and concern regarding the impact of ongoing soils work. At the January 1981 prehearing conference, the board asked if there was any. soils work that needed tohn stopped at. the outset of the hearing because it threatened the soils problem remediation.
1he NRC "re-interpreted" this question
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to bei Was there any soils work which needed to go forward because it threatened Consumer's construction schedule needs. The NRC answered this new question affirma-tively-and proceeded to grant concurrence for 12 permanent dewatering wells on those grounds.
The overwhelming preponderence of evidence represented in CPC and NRC reports for 1980 and 1981 indicates that despite the programatic QA improvements, actual QA improvements, actual QA implementation has remained sorely deficient.
The Midland QA organization does not provide the required independence from cost / schedule responsibility because Vice president James Cook retains ultimate authority for the Midland project in both areas (p. 2054). This issue of QA cost /
schedule independence *was criticized in Midland's AIAB 147 decision of September l-18, 1973 yet is openly repeated in 1980-82 This summary of rece.nt events just begins to tell the story of QA inadequacy 1
and NRC leniance at the Midland plant. The extent of design and construction defi-ciencies which has resulted at Midland over the years tends to be overshadowed by the predominant soil ' settlement problems, but is just as serious.
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u, wce O&f0f Vice President - Projects, Engineenng and Construction a
m oener'et offices: 1945 West Pernell Road, Jeckson, MI 49201 e (517) 78&O453 June 25, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND PROJECT MIDLAND DOCKET NO 50-329, 50-330 AMENDMENT NO 105 FILE: 0485.11, 0485.16 SERIAL:
17916 Enclosed herewith is Amendment 105 (Revision 13 to the Responses to NRC Requests Regarding Plant Fill) to the Company's Application for Construction Permits and Operating Licenses containing three (3) signed originals and sixty (60) copies of the following:
1.
Addition of a new Appendix D formed, in part, from existing information previously published in either che Midland FSAR, the 50.54 (f) Responses to NRC Requests Regarding Plant Fill, or attached to separate correspondence.
2.
Addition of a new Appendix D formed, in part, by new information not previously published, such as, well logs, boring logs and sample extrusion logs, and grain size distribution graphs.
Proof of service upon the parties listed in the Service List is being provided under separate cover.
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JWC/RLT/mkh CC RJCook, Midland Resident Inspector, w/o f b "7 W 9 l
oc0682-0134a100 l
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CONSUMERS POWER COMPANY APPLICATION FOR REACTOR CONSTRUCTION PERMIT AND OPERATING LICENSE
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'D3CKET NO 50-329 DOCKET NO 50-330 AMENDMENT No 105 Enclosed herewith, revising and supplementing the above-entitled application, are revised and new pages for incorporation in the Responses to NRC Requests Regarding Plant Fill. The Responses to NRC Requests Regarding Plant Fill was referenced by Amendment 72 to the above dockets on December 19, 1979. The enclosed material consists of the following:
1.
Addition of a new Appendix D formed, in part, from the following existing information previously published in either the Midland FSAR, the 50.54 (f)
Responses to NRC Requests Regarding Plant Fill, or attached to separate correspondence:
a.
Boring logs b.
Laboratory test results c.
Geophysical survey report and results of crosshole seismic tests d.
Test pit laboratory data and plate load test data Diesel generator building piezometer plots e.
f.
Report on test fill program g.
Selected laboratory data evaluation reports.
h.
Observation well and pumping well construction summaries.
2.
Addition of a new Appendix D formed, in part, from the following information not previously forwarded to the NRC:
a.
Well logs b.
Boring logs and sample extrusion logs c.
Crain size distribution graphs miO682-0134b100
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These new and revised pages bear the notation " Revision 13, 6/82" and are marked in the margin to indicate where changes or new material is submitted.
Additional pages and figures have been added as rellected on the revised " List of Effective Pages."
i Consumers Power Company j _
L Dated June 25, 1982 By a es W Cook, Vice President Sworn and subscribed to before me on th-25 day of June 1982.
n Notary Public, Jackson County, M' igan My Commission Expires September 8, 1984 l
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miO682-0134b100
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