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- June 4,1982 TOV!SrY C0YYiTTEE ON CE,*,CiOR SM EGUECS, t) SXR.C.
I4 Statement Before the Advisory Committee on g
eactor Safeguards, Washington, D.C. on the Midland 1 Nuclear Plants
.A hIy purpose in being here today is to bring some insights to you on the role of the Advisory Committee on Reactor Safeguards (ACRS) as the public b
perceives it, and compare s
it to what has actually been accomplished for public safety by this Committee as seen by those few of us who have a long and extensive experience with the nuclear power licensing process.
The public has lost confidence in the nuclear power plant licensing process.
Since this ACRS review is a part of that process, the reasons for this loss of confidence should be of importance to you.
Chairman Palladino has appointed a Task Force to study the nuclear licensing process. In my view, this forum for review of the bildland nuclear plants can provide much substance for studying the reasons for loss of public confidence and what is deficient in your review methods.
This loss of confidence in nuclear plant licensing has come about in spite of long and detailed licensing staff reviews and a supposedly objective overview by this prestigious ACRS.at h mk*nygg((ed 8
primarily because very serious problems have come to light /following operating license ~ ,
- approval after these extensive reviews. These problems have been the source of much pain, anxiety and high cost to the public. The ACRS must accept some respons-ibility.
Now, I was personally very impressed with the tough questions that the ACES subcommittee asked the NRC staff and the applicant in Afidland last week. I was also impressed with the range and quality of expertise that this Committee has.
Therefore, it is important to look at other factors to identify reasons why the ACRS reviews are losing their value as far as the public is concerned.
I believe I should establish my credentials for what I am to say here today.
As a science writer and editor, I was aware of the role of the ACRS from its beginnings. I have followed the patterns of its work much more closely
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- since I first became involved in the Midland nuclear plant licensing. The mis-leading propaganda with which the Midland nuclear plants, as well as all nuclear-plants, were being promoted in the late '60's, as well as the incredible record of poor quality control that was being disclosed during the Palisades operating license hearings at that time where Consumers Power Co. was also the appli-I cant, brought me into the Midland nuclear plant licensing procedure. I have been involved in nuclear plant licensing since that time--over 10 years.
In 1970, I also asked for a special graduate program at the University of Michigan which would allow me to study in any department of the University, if the department head approved, that would increase my knowledge and access 14 Adk nd n-phr>+ / cen.s sy w v% nu e emer,4s e a nd A to libraries and other resources in order to follow nuclear po;wer developm6nt @h 3
in general. The Midland project was touted as the world's largest nuclear-industrial project, tieing together as it does a huge chemical complex, The Dow Chemical Co. and two large nuclear plants. It was being built by Consumers i
4 Power Co. and Bechtel, the same utility and architect engineer who had done so poorly at the Palisades nuclear plant. I considered it a worthy commitment of my time, energy and study to follow its construction since these plants are
- two miles from my home. My Masters' thesis at the University of Michigan was on the environmental and social impact of nuclear power. It is from this background that I am making the following observations.
I have a little good news. The ACRS is good at identifying many current safety problems and potential hazards in nuclear power. I have found the Committee's data very useful on many occasions and have applied what I was able to during the Midland nuclear plant licensing. But, the Committee itself has not followed up on their own recommendations. I mentioned a number of useful suggestions that the ACRS Committee had made in 1969 that applied to the Midland nuclear plants and other installations in my statement before the Midland subcommittee on May 20. I also proved that 10 years or more later, i little or nothing had been done about many of them at nuclear installations, i
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Where citizen intervenors have taken up your ideas, however, there have been positive results. Fcr example, in 1969, the ACRS recommended that some method should be devised to control the hydrogen that would form over the reactor core under certain accident conditions. By March,1979, this had not been followed up at many plants including Three Mlle Island-2, and there it had frightening consequences. With strong citizen intervenor participation in however, the Midland licensing procedures /it was followed up and there were hydrogen '
recombiners in these plants already installed in March,1979. This demonstrates l that third party input has an important safety value.
Those of us who have a comprehensive knowledge of what has been happening
- at the construction site at Midland have followed details of what is revealed in the hearing transcripts and documents. We have listened to the summaries, especially as they have to do with QA and QC matters, that the NRC staff and ,
the applicant have provided for the review of the subcommittee on Midland. We assure you that these summaries grossly misrepresent and whitewash the extent of the problems of these nuclear plants. .
Barbara Stamiris, a citizen intervenor, who has done extensive work on the soll settlement issue, stated in her oral statement at the Midland review that she was " shocked" at the glossing over of serious problems and the omissions in these summaries. As she promised, she has written a detailed and documented review for the ACRS of the extent of QA and QC problems which were not mentioned. Her statement indicates the extent to wh'ich both the NRC staff and the applicant have covered-up the seriousness of these issues.
NRC inspectors themselves have made some significant comments which were not relayed to you.
Last August, Joseph Kane who is chief 'geotechnical engineer for the NRC staff stated that gsafety were the major considerallon that removal and re-placement of the -:esel generator building would have been the better option even with the amount of stress that building showed before preloading began, . l i Nut since costs and construction schedules are so important at Midland, that option couldn't be exercis 4Nh"4 In other words, the NRC geotechni-cal specialist had assessed the. serious problems with that building years ago
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and came to the same conclusion that our expert witness, Dr. Charles Anderson, made in his final statement to the ACRS subcommittee on May.21 of this year.
But the ACRS subcommittee was not advised of this. [
Another Region III inspector, Eugene Gallagher, said under oath, "You're r
talking about a plant 70% complete that is crippled." (p. 2466) He also said i 1-the problems at Midland were unprecedented at any other site. Ip, 2463) In I
another instance, Gallagher said he had a hard time giving quality control 4
assurance as far as Consumers Power Co. was concerned because the utility and Bechtel had obviously had a hard time moving soll from one place to another !
and doing it right, and in operating the plant they would be handling highly so-i phisticated equipment some of which had never been in use before. (p. 2441)
- Many other significant items have not been discussed. For example, underground safety piping is overstressed in at least 12 locations due to e
- uneven settlement. This piping--the cooling lifelines of the plant--will require a permanent stress monitoring system. Unusual corrosion of stainless steel piping was identified in 1979, but the combined effect of this corrosion with
- settlement stress has not been addressed. (Feb.18, '82 Testimony)
This plant will operate in an area with more chemical pollutants than is
- usual because of the proximity of The Dow Chemical Co. It is known that the
. combination of radiation and chemicals result in multiple factor interaction that can be significant due to synergistic effects. The corrosion potential of I this interaction has not been addressed. Corrosion is a serious problem for nuclear plants even in better environments.
Quality control problems have beset the Midland nuclear plants construc-tion for years. The ASLB Appeals Board found the QA so bad in the earliest AS construction of the plant, that they elicited a promi e o reform 4on this issue A
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j A.oa in 1973 4 Inbnd spite%o kh me QA-QC problems occurred. When our i
attorney brought this matter to the Appeal Board's attention, the Board finally i angrily wrote, "What we have here is a pattern of repeated, flagrant and sig-nificant QA violations of a non-routine character--coupled with an unredeemed l
promise of reformation." (Letter to L. Manning Muntzing, Nov. 26, 1973) l l
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- ( ( l This is about as adverse a characterization of management attitude as could be made. Det kd to this the fact that both Bechtel and Consumers Power Co. knew that the soll was poorly compacted sitewide in 1977 but went ahead and built safety-related and other buildings on it anyway, and you have an attitude that approaches criminal negligence.
The letter to Muntzing led to the first show cause hearing on quality control in the country. But, this did not improve matters as Ms. Stamiris has pointed out in her statement to this Committee.
Michigan's other reactors have had serious problems that should have ;
been identified before ACRS approval was given. ;
At the Palisades nuclear plant, the rad waste holding tank never was able to operate. Did the applicant's or NRC staff review disclose this to the ACRS in their summary review of that plant? The company continued to operate'the plant and not only didn't notify the NRC, but deliberately concealed the fact.
Did the staff or the company disclose the extent of the QA problems at Pali-sades ? These have resulted in one of the poorest operating records in the l nation and have been a costly burden to ratepayers and stockholders alike.
The ACRS is responsible for oversight in, proposed changes at operating facilities (p. 387, Nuclear Safety, Vol. 20, No. 4, July,1979) However,,the 4 attempt to experiment with a full loading of plutonium fuel at the Big Rock - 4 nuclear plant was approved by the Atomic Energy Commission simply with l an amendment to the original license with no public notice and no A' CRS review.
No environmental impact statement had ever been made for Dig Rock. As one of the early plants, it did not have, and still does not have, the basic safety i
systems that are required at other plants. Yet, Consumers boasted in 1972 that they were going to begin the plutonium e'conomy for the nation at Big Rock.
(Nucleonics Week, Dec. 2,1972) C Only an extraordinary and dedicated effort by a' citizens' group, the West Michigan Environmental Action Council, halted full plutonium loading at Big Rock. Partialloading of plutonium, however, has gone on at Big Rock for years. Citizens who are fighting fuel compaction at Big Rock were allowed m pas,y/,% ;
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by their Board to review the issue o(criticality o,f-compacting spent fuel storage for this reason. Without expert witnesses or funds, their ability to
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explore this issue is very limited. Some of the expertise of this ACRS Com-mittee should be there to help them. Their hearings come up this month.
Here is a major risk being forced on people since we have so much excess electrical capacity in Michigan (over 35% by Consumers Power Co. testimony) that we have no need for the Big Rock facility to operate at all. But, the ACRS remains distant from the real problems citizens face even though citizens are paying them to provide safety.
On the national scene, ACRS, of course, approved TMI-2 with all of its
$w many problems which brought it to within3hoursr of a total meltdown in March, 1979. ACRS also approved Brown's Ferry where a fire disclosed the weakness of design for electrical equipment that controls safety systems. The same problem exists at the Donald C. Cook plants in Michigan. The Union of Con-
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cerned Scientists has recommended that those plants be shut down for this and other deficiencies. But, no reviews and recommendations are made on these types of issues. The public must wait for accidents to happen to get any action.
i The ACRS has approved through their routine review process Diablo Canyon,
- Zimmer, Davis Besse, Rancho Seco, Ginna, Crystal River and TMI-l and 2 and many other nuclear plants which have subsequently had serious problems or have had serious flaws found in construction or design.
These problems are disturbing and painful for the public immediately affected.
They are costly for everyone. Is it any wonder that public confidence in nuclear power plant licensing is so low ?
I am convinced that ACRS itself is competent. But, all of these facts and examples point to the fact that the method of review which ACRS has accepted in the past is faulty. In fact, from a legal, technical and scientific point of I a c., e s Ww /-
view, the data base on which ACRS has been dependingIorittYfinalletters r/it on nuclear plants to the chairman of the NRC is and always has been untenable and unsound.
This same kind of review hadbeen planned as the routine for Midland.
But we decided at Midland to change the routine and create a third party objective view through citizen disclosure of important facts from the record that have not been revealed. I believe that Barbara Stamiris and I have dem-onstrated that without some objective probing of the summaries provided by l 1
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the NRC staff and the applicant, the ACRS has a very limited and inaccurate '
i data base for its review. (Both the Kemeny Commission and Rogovin Reports followlag the TMI accident have recommended third party review throughh%
citizen intervention). We have also provided an objective review of a critical unresolved problem,-the soil settlement issue and resulting question of the i structural integrity of at least two safety-related buildings,-with Dr. Charles Anderson as our consultant. m A / ? -2. /
It has been obvious. from all that transpired in Midland tIr%ud that Consumers Power Co. is bitterly opposed to any objective review of thatplant's construction.
But, at least this time you have some additional facts to consider beyond those of the staff and the applicant.
However, the fact remains that the ACRS meets and, on such a speedy basis, hearing only the nuclear promoters with no independent review, makes judgments of great importance to the public that affects their health, safety and economy. T'his process raises questions about the credibility of ACRS judgment. These reviews are also a costly item for citizens as part of nuclear regulation.
l The fact that eve.ry letter without exception at the operating license stage always and inevitably states after 6 or 8 paragraphs of recommendations, that the facility can be. operated without undue risk to public safety also raises questions about the credibility of your deliberations.
In the past, of course, for,the. general public, this type of letter from such illas;rr,a^dn an august body has provided an g assurance of safety. But the many serious problems now make people realize that this illusion of safety is worse than no I
review at all.
Some nuclear facilities we now know are so bad they should never have been allowed to operate. TMI-2 is one, Palisades, with'its poor quality control and negligence in management is another. Diabic Canyon and Zimmer should not be allowed to operate. With its history of QA violations and incredibly poor management decisions and attitudes, Midland should not be allowed to operate either.
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',' My conclusion is this, that to the extent that the ACRS review letter for the operating license is primarily based on the limited and carefully controlled information from the NRC staff and applicant with no objective third party review, the ACRS becomes just another part of the promotional package for the nuclear (ui/L tLe e,nce.ss rese. ve elec,4ias/ m -
industry. It raises the question, in these difficult times,r w hether the public -Nua ((e can afford promotion of a technology that cannot make it in the free market ' '# Ff *'
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concerning whether some of these things should have been ant c - j; !!'!
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II cccepting the effectiveness of the surcharge. There are studies . h, (
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'(o They have not yet been submitted to the NRC ...!
.< a 13 to which we must address ourselves. .
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, CHAIRMAN BECHHOEFER: Let me ask the followup question di i 1)j ; :
15 co we do not get too confused. I: 'U, 16 ^)8 !E' M3I A Back in '78, should problems such as -- well, problems llIl,1 jl .. g 17 i -
of additional distortion of the installed conduits and pipes and ;
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has been Consumers saying, "We want to go ahead and do this and !
h 23 make measurements and demonstrate its adequacy," and on the other ' "
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jside we have the NRC saying, "We have trouble accepting this '
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.be doing to the structure, and we would like some criteria by I
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which you are going to evaluate the acceptability of these ;'
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s t problems, the settlement and the cracking." jI I ;
i f I;: i.' ;3 y , .1 E CHAIRMAN BECEHOEFER: And your response more or less .,
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by measuring cracks and things of that nature. And your question !; ,! i p n.
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l A To be.. honest with you, I have some raa1 diffi-l culties with that phrase " reasonable assurance".
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I In what areas do you have reservations about
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i MR. PATON: Judge Decker, could I interject?
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MR. DECKER: I understand that. L f I would agree that there is certainly the ,
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lovel of confidence that the task can be accomplished. '
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The reservation that I have is that having been so close _ :
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knowing that simply the Company could not take soil material '
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from one point of the site and place it in a sufficient
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manner to support the structures on another place on the site, l N
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and then recognize that we have extremely complex sophisticated, ' ', g h M
and, in some cases, unprecedented remedial actions at a nuclear ' '
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- . I from my own shortcomings of what is technically feasib e; ,
I 2 but nevertheless, I certainly have some uneasiness abcut .
< 3 suitabilitythatthefixescanbeaccomplishedsuccessfu,,.,f w o 4 CHAIRMAN BECHHOEFER: Let me interrupt fer j L.
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What I'm simply saying is tha .
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t : 11 the complexity of the remedy itself is somewhat difficult ]
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I do have one other, I guess, provision thay 4
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16 provide a full-time geotechnical representative to observe, l
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.' 18 throughout the remedial fixes, and in doing so, provide thej o L h >
NRC with continuous confidence information, starting with -1 ti 19 l : '
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20 dewatering system installation, the monitoring of structure; I U -p,l
- 21 preloading of the borated water storage tank, valve pits, d h;jl
' ., d 22 underpinning the auxiliary building and field water valve
- b. pits, and piping systems embedded in the fill.
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sites, to a much different degree, however.'
o 2 g . i But there have been, in fact, problems on other 3
nuclear
- sites with something as simple as soils, haven't I 4 there? n' .
L 5 /. )i (h To a much lesser extent. The degree of the 6
problem is what's important here. 1
{' .'
The extent of what has _
j.
7 occurred at the Midland facility is unprecedented at any I 8 other facility. ;
i 9 4 The point remains, however, that other people .! .
10 !,
have had some problems with something as simple as soils, or 11 haven't they?
12 A Yes, of course.
13 G In fact, I a recent bulletin has been issued 1 i
14 I!
covering not only Midland but other plants as well, is that 15 right? i' .
16 A
I wrote the bulletin.
i 17 g So the answer is that, yes, a recent bulletin 1S has been issued with regard to soils for not only this plant ,
19 but others? I 20 A Excuse me.
It was a circular; Inspection and 1
21 Enforcement Circular.
22 g !
l To someone like me, they're the same. I'm
('
23 : sorry.
i 24 ' A It has a different regulatory posture.
25j g So your answer is, yes, in fact there has been !
[9
~
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E. -
( i C l1 t! 2466 4
I "31 11 bhd// gg 6, '
1 in the same kind of a way that tJe were talking about Mr. g 1 2
Salby.
3 I think you're compcring apples and oranges 4
hers.
You're talking, one, about a failure to identify an o" ;
item of non-compliance or withdrawing an item of non-compliance, 6
and on the other hand, you're talking about a $27 million-plus -
! \.i s
j fiasco.
8 There are no comparisons. You're talking about y e that is crippled. You're i c plant that's 70 percent complete, _
- IC l
I not talking about an insignificant error in an inspection
.I c l' 3
1 li raport.
i I h Q.
Actually, Mr. Gallagher, what we're talking -
chout, I think, is a reasoned business judgment, a managerial I
judgment by the chief executive officer of a large utility, G who has had years of experience in that, versus the judgment of a reactor inspector civil engineer.
7 I appreciate the fact that you note there are g .
J' differences, because in fact there are. And it seems to me i
.i that simply stating that the chief executive officer ought to I
0 ba held accountable doesn't take into account or consideration how large companies are run. And I wonder if you are really
- l ?
e fcmiliar with that?
MR. PATON: I object, Mr. Chairman. Mr.
13
- D 24 l GDllagher was asked if he had any ideas which would be helpful I
(25 ltotheBoard, and because he made a suggestion, he's now i
L 7
. W . l.M4". N RC, k E i aq,@ Aces Mit.
sua %19Bl.
E_
/YT L 39 2 FIGURE 1 l
CRITERIA FOR ASSESSING CONSTRUCTION QA/QC I
MANAGEEIR ATTITlDE 8G $ fi$gg JUN 14 gggy REGULATORY REQUIREMBES AND INDUSTRY STANDARDS ' ,9,1011,yp,y,pt y,4,Q
- A ORGANIZATION FOR QUALITY STAFFING FOR QUALITY TRAINING FOR QUALITY TIELY PROBLEi IDBRIFICATION EFFECTIVE PROBLBi RESOLUTION APPROPRIATE IFEDIATE ACTION IDBRIFICATION AND CORRECTION OF ROOT CAUSE PPEVENT REPETITIVE PROBLEN DDTIVATION FOR OlM_ITY
. W M [ Y /#2 B 76
l
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4 FIGURE 2 l-SOURCES OF INFORMATION - MIDLAND PERFORi%NCE a4
' 10 ER E ROUTINE RESIDENT YENDOR &
INSPECTION INSPECTORS INSPECTION 50.55(E)
PRCCRAM PROGRM REPORTS
/,
SPECIAL 3 alp N NON-ROUTINE INSPECTIONS NRC REGION III --
tWlAGBEIT
' CONSTRUCTION, SPECIAL PREOP, HOT TEAM , FUNCTIONAL, INSPECTIONS
/, s STARTUP TESTS e \
INDEPETOENT THIRD PARTY VERIFICATION ALLEGATIONS REVIEW NRR n
s e
e SOURCES CURREffTLY IN USE
SOURCES WHICH PAY BE USED
., i
JUE 4,1982 ,
I 'l bl '
MIDLR0 ACRS WETING INTRODUCTION BY I E STAFF o
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j .
OL REVIEW HISTORY TO' IATE to N t>o 8
/N m
OL APPLICATION DOCIETED 11/18/77 O @
F# LY 1979 PREPARATIONOFSERINPROGRESS
^
3/28/79 11i1-2 ACCIDBE - MIDlMD REVIB1 SUSPSOED EARLY 1981 OL REVIEN FULLY i
- , k RESlf
, . j. , 7..
2/5/82 DRAFT BNIR0tiBITAL. STATEIGE ISSUED i%RCH-APRIL 1982 FINAL SER OPB1 ITBi Ph@0llHION .EETINGS HEl.D WITH APP i .
9, r l'"
5/6/82 SERISSUED ' .hq 1 (I ;..
5/20-21,6/2/82 ACRS SUBC0tNITIEE WETIlES
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SER OPEN DESCRIPTION NEXT- .
APPR0X.
ITEM NO. OF ITEM . ACTION DATE
- 1. NEARBY EXPLOSIVE HAZARDS -
STAFF / APPL. MTG. JULY 82 i
- 2. TURBINE MISSILES STAFF COMPLETE REVIEW JUNE 82
- 3. TORNADO MISSILE-PROTECTION STAFF / APPL. MTG. JUNE 82
- 4. ANALYSIS OF RCS & CORE COMPONENTS APPL.-SUBMIT ANALYSIS MARCH 83
- 5. S0ILS SETTLEMENT ISSUE APPLICANT SUBMITTAL ONGOING :-
- 6. SEISMIC & ENVIRONMENTAL QUALIFICATION OF STAFF CONDUCT SITE ENV. JUNE 82 EQUIPMENT AUDITS SEISMIC Aa/8)
- 7. NATURAL CIRCULATION C00LDOWN ANALYSES APPL. SUBMIT ANALYSIS AUGUST 82
- 8. APPLICANT SUBMITTAL JULY 82 HPILINEMAKEUPN0ZZLECRACKgG, ,,
- 9. REACTOR VE5SEL HEAD VENT .; , APPLICANT SUBMITTAL JUNE 82
! 10. . SECONDARYSYSTEMC0'ITAINMENTIVALVETE8 TING STAFF COMPLETE REVIEW JUNE 82
. LEAKTESTINGOFDHRANDRBCWSUCONTAI.NMENTVALVES STAFF COMPLETE REVIEW JUNE 82
- 12. APPENDIX R (FIRE PROTECTION) ,
STAFF COMPLETE EVALU. JUNE 82 i
- 14. EMERGENCY PREPAREDNESS PLAN, b], . ,;p[, STAFF COMPLETE EVALU. JUNE 82
- 15. CONTROL ROOM DESIGN REVIEW ..b
- APPL. SUBMIT REPORT DECEMBER 82
- 16. SHUTDOWN DECAY HEAT REMOVAL REQh3 g.,,REMENTS APPL'. SUBMIT JUNE 82 l ' ^
l RELIABILITY ANALYSIS i
j ,
~
l .{. ! $ . . ,
, .s l . .
.i 6 l ; ,,, s SPECIAL REVIEW' AREAS
- QUALITY ASSURANCE
- REMEDIAL ACTIONS RELATING TO S0ILS SETTLEMENT ,
- PROCESS STEAM SYSTEM
.g , ..
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. l- '
REACTORVESSELANCHORB0llTS
, if'. ,. .
e PR0XIMITY TO DOW FACILIfiES. .
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- SEISMIC RE-EVALUATION ' 'l 1 l " .
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.$ .. ...i. . . . . .
i
..IPPROWINS TO MIDlN0 Pl#T DESIG1 e' PORV'S AND P0lW block VALVES I AFW SYSTB4 e FEEDWATEROVERFILLPROTECTIm
, e i
e ANTICIPATm Y REACTm IRIP SYSTEM - '*
, sr .
e PRESSURIZER: LEVELINDICATIMANDHEAThS
- ) i-e INADEQUATE CNE C00UNG INSTRUME!NTATim e POST-ACCIDENTIbNITWINGIN Tl 1 k .,! g g ., '
e hot LEG VENTS e F0GG LOGIC ADDEDToESFAS
, e OPERATIONALIMPROVEMENTS ,
[ b .
P l~ - . t
- 6 e
,