ML19331D313

Amended Petition to Intervene Alleging That Inability of Soil to Support Plant Structure W/O Compaction Procedures Violates Requirements.Claims That FSAR Statements Are False & Evasive

ML19331D313
Person / Time
Site:	Midland
Issue date:	08/25/1980
From:	Stamiris B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OM, NUDOCS 8008280668
Download: ML19331D313 (4)

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';sY U.S. NUCLEAR REGUIATORY C0'.24ISSION b #

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. .fo In the matter of Docket No. 50-329 O N * .,I

• Consu=srs Power Co. 50-330 CE Midland Plant Units 1 and 2 AENDED PETITION TO INTERVENE Barbara Stamiria petitions to intervene in support of the Order of Modification of Construction Permits in order that continued work on,and unsatisfactor r resolution of soil settlement problems do not threaten her health and safety intrests.

AENDED SUPPIMNT TO PETITION TO INTERVENE j Barbara Stamiris is representing herself with the following list of ,

cententions :

1. That the soil conditions of the Midland reactor site, their potential i for subsidence identified in the 1970 S.E.R., and-their inability to support plant structures without the extensive use of fill soils and compaction proceedures, represent insdequate attention to health and safety requirements l in that design specifications have not allowed

• appropriate and adequate l

j compensatory safeguards"(10 CFR-100.10).

l 2. That C.P. Co. statements and responses to the NRC have been at times l

l a) false - in FSAR statements regarding fill soils (table 2.5-14) ,

l l b) evasive - regarding geologie classification and seismic characteristics '

l of the region as separate from the Central Stable Region (responses to NRC questions 361-362) c) and reveal an overall pattern of reluctance in complisnee with NRC questions and testing proceedures regarding soil settlement problems (responses to NRC 50-54f requests and the August 4,1980 Ar=y Corp of Engineers Report) which show that C.P.Co. isn't fully divulging and attending to these i=portant safety is sues.

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3. That C.P.Co. is placing their own financial and ti=e schedule intrests above their ecacern fer safety issues involved with the soil settle =ent

• as de=c=strated by :

a) The new ec=pletion schedule pressure as a result of the Dew stet = centract deadline b) The pressure on NRC to reschedule the priority of their Operator's License review because of "enor:ncus rescurees already invested by the NEC and C.P.

Co. " as outlined at the July 29,19S0 Eidland =ceting.

c) The conti=uation of work on Deisel Generator Building while u= resolved safety issues existed d) The apparant concern for expediency in the choice of re=edial actiens as noted i R.3. Peck's censultart state =ent 6-lC-79s and the rejectice of Option 2 Removal and Replace =ent Plan e) The ad=issien that "the Midland FSAR was sub=itted to the NRC at a= earlier point in the project than would have nor= ally cceured in order to provide additional ti=e for the operati=g license hearings due to the forcasted intervention.*(response to 3-21-79 EC-54f request Q.1)

4. That C.P.Co. has not i=ple=ented its Quality Assura:ec Progra= in eceplia ee with 10 CFR-50 Appendix 3 rsgulatic=s as was "rearo2 ably assured" to occur in the conclusions of the 1973 Shew Cause Heari gs on past Q.A. deficie=cies as noted ins a) Oesign and eccstructien deviations and inadequacies in the use of ra dc=

fill under safety related structures b) In the ec=paction of these soils e) In the is i=spection of a and b above d) In the corrective actiens tr. ken (as these deficient proceedures ec=tinued about 15 years beycnd official cotificatics) a=d these repeated breakdow=s in quality assura:ce threaten health and safety of the publie.

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5. That the perfor=ed and proposed re=edial actions of C.P.Co. regarding soil settle =e=t under safety related structures do not =eet health and safety standards in thats l Preloading in and around Deisel Generator Building i

a) does not charge the composition of the i= proper soils to meet the original PSAR specifications

. b) does not preolude all future settle =ent of this or other safety related structures or stability of cooling pond slopes where the sa=e inadequate

=aterials and proceedures were used c) =ay have adversely affected surrou= ding soils 3e per asent dewateri=g system a) would change the water table y soil,and seis=ic characteristics of the whole plant site fro = their ori inally 6 approvd specifications as set forth in the PSAR and Construction Per=it - specifications on which the safety and

[ integrity of the operating p'. ant were based b) could shorten the safe shutdown ti=e c) =ay cause additional settlement

s. That the additional i=for 4 tion snd testing requested of C.P.Co. by the NRC and its consultant the Ar=y Corp of F.ngineers August 4,1980 is essential for the staff- to perfor= its evaluation of health and safety intrests and

=ust therefore be responded to fully and co= plied with totally.

7. That the practice of e= ploying Quality Assurance Staff and cc=struction 3

engineers and workers, frc= t a sa=e co=pany (Sechtel) represents a ec=flict of intrest that has interfered with satisfactory perfor=ance regarding soil settle =ent issues (10 CFR-50 Appendix 3) -as de=enstrated by the pattern of quality control deficiencies regarding fill soils fro = 1974 through 1979 (nonconfor=ance reports- and Q.A. recuests referenced. in Appendix A of the Dec.61979 Order of Modification)

Wherefore petitioner requests that she be permitted to continue to intervene in the preseeding for the Order of Modifiention of Construction Permits. Dec. 6 1979.

Respectfully Submitted r

Barbara Stamiris 5795 N. River Freeland Mich. 48623 August 25,1980 YLl%W Y f)1.4 m

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