ML20064P052
| ML20064P052 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/04/1982 |
| From: | Stamiris B STAMIRIS, B. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8209130084 | |
| Download: ML20064P052 (17) | |
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C PC o. Midland Plant 30-329 OL rnits 1 E.2 50-330 OL BEFORE TrLe ATOMIC SAFETY AND LICENSING BOAPD STAMIRIS MOTION FOR PARTIAL INITIAL DECISION ON QA ADEQUACY IN SOILS REFEDIAL b'ORK PRIOR TO COMMENCEMENT OF REFEDIAL UNDERPINNING EXCAVATIONS 9/4 /82 Due to the reported voilations of established QA/QC procedures for soils reme-dial work, the failure to institute proper QA/QC procedures for that work, the reported violations of NRC/CPC agreements and of the Beards April 30, 1982 Order regarding soils remedial work; the question of Con sumer's QA adequacy with respect to soils must be resolved by this Board prior to the commencement of excavations for remedial underpinnings if public health and safety is to be protected, t
ISSUES BEFORE THE BOARD All parties in the OM-OL proceeding have addressed QA beyond soils due to the terms of the 6/5/81 QA Stipulation , since the NRC based their reasonable assurance of QA adequacy (Stipulation part 3) upon evaluation of the period from December 6,1979 to June 1,1981 during which little soils work was occuring. Yet the more narrow question of QA adequacy with respect to soils is the urgent question presently before this Board. This question, originally raised in the December 6,1979 Order Modifying Construction Permits, must now be resolved as soon as possible in order to determine "the degree to which and the manner in which soils related construc-tion activities (particularly remedial actions) will be permitted to continue"l 14 cr a A /to /so Ner , p. 9.
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if these Board considerations are to remain viable. -
The Board states in its April 30, 1982 Order (p. 7) that they have not yet completed their review of the second hearing issue "le whether and, if so, to what e.xtent the Modification Order should be sustained." This key issue is described by Consuner's as "whether the safety issues (giving rise to the facts set forth in part II of the Modification Order) have been resolved so that the QA program with respect to soils is now being properly implemented and there is reasonable assurance such implementation will continue through the construction process."2 The December 6,1979 Modification Order sought prohibition of soils activities until the question of QA adequacy with respect to soils and the related safety ques-tions were resolved. These QA adequacy / safety questions rena n unresolved in late 1982, yet the complex and difficult soils remedial work which the Order sought to prohibit has been permitted to begin in the interim due to the wording of the Order.
The unresolved safety questions associated with the issue of soils QA adequacy, of renewed concern due to the course of recent events 3, must be considered before the presently projected December 1982 QA hearing dates or they will, by that time, become moot questions as the soils renedial work in question will be irrevokably underway.4 For the imminent underpinning excavation work will certainly commit the applicant to this course of remedial actions once it is begun, in a manner unlike the other prerequisite remedial steps previously appreved by the Board.
As most recently and simply defined, the "QA" question before us is whether the soils remedial work will be properly implemented (as opposed to the " technical" question of whether that work is theoretically feasible).5 A' hearing conducted 2 CPC findings, p. 36.
3 l/ see attachment A.
4 During the 8-14-82 site tour we were informed that the excavation work was i expected to begin within a week as the baseline data measurements had been completed.
L On 9-1-82 Mr. Ross Landsman informed me the excavations had not yet begun.
Judge Bechhoefer's description in 9-1-82 conference call.
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to determine whether the soils remedial work is likely to be properly implemented can only be meaningful if conducted before that work takes place.
To await a December QA hearing and an overall (QA adequacy-technical adequacy) r ecision in 1983 as presently projected, would leave us with the untenable situa-tion of putting the answer (ie continuation of soils remedial work) before the question (whether it is likely to be performed safely). In so doing, the Applicant's scheduling needs would be placed ahead of public health and safety needs.
Although soils remedial work has been spproved prior to resolution of the related safety questions before in this proceeding, it has up till now been of a relatively minor nature and has been approved in this fashion because it did not constitute an irreversible commitment to the soils remedial work to fo11ow.6 However the very nature of the excavation work and the proportions of this underpinning job certainly qualify it as the major task of the soils remedial work at ' issue, from which there is no going back. Therefore, to allow the underpinning excavation work to go for-ward prior to the resolution of the related QA/ safety questions by this Board, would be tantamount to prejudging the entire proceeding.
Re scheduling needs of Consumer's Power Co, no matter how pressing,cannot be placed ahead of the unresolved questions affecting public health and safety.
In a case involving the Midland plant, an Appeal Board affirmed "under the Atomic Energy Act, the Commission responsibility is to protect the public health and safety, not the pocket-bocks of owners or customers of electric utility investors."7 his Board has listened to CPC and NRC witnesses discuss the technical feasa-I bility and theoretical adequacy of the underpinning remedial work, but that has no bearing upon the practical implementation of that work. Re Board, in fact, 5 found the QA aspects of the proposed underpinning work to be conspicuously lacking 8 6 ^ ' n 7/7/81 tr. 1133-1137 ,. .
7A1AB 458, 2/14/78, 7 NRC 4 p. 476, CPC Units 1 and 2, Midland, 8ASLB 2/5/82 Memo, tr. 7122-7128.
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and their underpinning QA questions remain unresolved today. To ha've assurance
_ that any plans will be carried out safely, this Board must first establish that 1
there is an effective QA program to accomplish those plans.
VARIOUS PROPOSED HEARING PIANS Unlike the af ter-the-fact December QA hearings currently envisioned, the pre-excavation QA hearings I propose would allow fair consideration of ultimate l hearing outcomes and options to all parties. I would have the Board consider the now urgent QA question of the December 6 Order, as formulated by Consumer's, "whether i
the safety issues.. . . have been resolved so that the QA program with respect to l
i soils is now being properly implemented and there is reasonable assurance such implementation will continue through the construction process," (particularly the soils remedial work at hand 1 An expedited partial initial decision in, the Applicant's 4
favor on the soils remedial aspect of QA adequacy could allow the soils remedial i work to go forward with only slight delay and with the added assurance that the I
public safety questions associated with the soils remedial work had first been
- resolved. Consumer's themselves sought this assurance for the public in their e
9/2/81 Motion for an Initial Partial QA Decision.
l The urgency of the QA question which I assert is reflected in the public state-ments of Mr. Keppler at the recent SALP meetings. Regarding the soils remedial work he said, " clearly something is wrong, its not proceeding as it should proceed."
i l At this point, he said, "I have to wonder- can Consumer's do the job?" He added i
j that FRC was "not comfortable about where we stand as an agency" and that he person-ally felt "very uneasy" about his 1981 testimony before the ASLB.9 As a result of the negative SALP rating, and the continuation of soils remedial work problems up to that day (6/21/82), Mr. Keppler announced the formation of a special inspection team to oversee Midland's work. Shortly thereafter he called 9 6/21/82 SALP meeting, statements as reported in 6/22/82 Midland Daily News.
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- 5 for a reopening of the OM-OL hearings to reconsider his QA reasonab'le assurance testimony. Fr. Keppler's testimony was expected by late August and "Mr. Paton advised that there were substantial differences of opinion between the Applicant and the Staff regarding certain factual material."10 These reopened QA hearings, as first entertained,would have properly brought the facts and evidence regardin6 the NRC-Consumer's differences before the Board for their judgement and resolution.
But by July 12, 1982 a dramatic change in the form and scope of the reopened QA hearings was announced by NRC counsel, Mr. Paton, in a conference call on the subject. "The Staff now advised that Mr. Keppler wished to confer with certain high-level NRC officials, formulate suggestions with respect to Consumer's QA/QC program, and present those suggestions to high-level Consumer's officials (Selby and Cook). According to the Staff, if Consumer's accepted the NRC suggestions (to which CPC counsel indicated there would likely be "a very quick turn-around") then the factual questions now in dispute between Consumer's and the Staff would become of lesser importance. The Staff and Consumer's could then file testimony (perhaps simultaneously) concerning the proposed QA/QC solutions.Ull In the hopes of avoiding lengthy contested hearings, and perhaps as the only way to allow construction to proceed at the plant, the NRC, Consumer's, and the Board, are willing to accept hearings based once again on subjective judgements and conclusory statements about futurc QA adequacy and " proposed QA/QC solutions."
In 1981, the hearings held to resolve the QA/ safety questions of part III of the December 6,1979 Order regarding "the adequacy of the renedial action to correct the deficiencies in the soll construction under and around safety related structures,"12 were necessarily conducted in the abstract future form, since that 10ASLB 7/7/82 memo, p. 3 II ASLB 7/13/82 memo, p. 2.
12 12/6/79 Order, p. 4.
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! work had not begun. But the question of QA adequacy with respect to soils remedial actions, which is before the Board in 1982, is in the very real present tense.
Soils work has resumed and so have the related QA problems. Once again we h, ave before us evidence of the state of QA with respect to soils. This evidence is available in the form of CFR Appendix B violations, inspection reports, noncon-i 4
f ormance reports, audit reports and findings, stop work reports,and their manner of i
resolution. We have no'need in 1982 to look to the future to answer the question of soils QA adequacy--and whether the soils remedial work is likely to procede safely and carefully according to regulations. We can consider all the relevant j evidence and nou - .
Is the soils remedial work bcingprcperly 1.'nlemented ,
.and is Consuner's QA/Qc implementation effective in maintaining the requi-i I site standards of s;fe:y and conservatism in this work?
To conduct Qt. hearings based instead upon reasonable assurance for the future according to high IcVel QA/QC' improvement plans and solutions, af ter the work in i
l question was irrevokably underway, would be to make a mockery of the serious pub-
! lic safety questions at issue in this proceeding. For there is no future lef t nor time for QA improvement when the plant is almost finished and the soils remedial
- work is underway.
l The QA deficiencies which have plagued this plant since the early seventies 1
have been repeatedly condoned and overlooked on the basis of the promise of refor-i mation, and perceived improvenents which have allowed the NRC to maintain reasonable assurance for the future time and time again.13 When the future comes to pass i
! ( as it has in this proceeding) only to disprove the assurances given in part 3 of 6/5/81 QA Stipulation, the NRC merely forgets the past and present, and moves I on to the future once more.
l l In the case before us now, the ccntinued inadequacy and deficiencies of Con-j sumer's QA as documented in the 1980-81 SALP evaluation and subsequent I & E reports:
13 history p. 9-10, !.01.L 4/30/81 crder.
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7 as addressed by the Board in their 4/30/82 Order and 7/7/82 Memorandum; as discussed in the 4/15/82 Spessard r.cmo; as addressed by Mr. Keppler as recently as 6/21/82;
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as reflected in the continuing record of NRC and audit findings regarding soils; and as discussed in the 8/20/82 Landsman memo, cannot be adequately resolved with a new QA Stipulation drawn up to reduce the importance of " factual questions now in dispute" (7/13/28 memo) by shif ting the focus from the present to the future.
The Boards directive in its 7/13/82 memo to " include prior dif terences" and their
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nanner of resolution in prepared testimony, could only be of value if the work in question awaited the consideration of those differences.
The time has cone for the NRC to follow the plan Mr. Keppler announced at the November 1980 SALP neeting--that is to lay out all the facts before the Board (leav-ing conclusions aside) and let them decide the increasingly difficult question *
'%hether QA is still defensible?" This intention similarly repeated by Mr. Keppler at the close of the 6/21/82 SALP meeting would have been met in the reopened QA hearings if they had gone forward as originally planned (contested QA proceedings between the Staff and the Applicant following August testimony). But that intent is lost in the new hearing plans (7/13/82 memo).
The events surrounding the August 12, 1982 stop work as described in the 8/20/82 Landsman memo on the violation of the ASLB April 30th Order, make a contested hearing all the more imperative now. It is the intent of this motion to seek a hearing, based on a review of all the evidence before us concerning the state of QA adequacy today, as opposed to hearing statements about expected improvements, CPC committments, or NRC suggested "QA/QC solutions" for Consumer's, as anticipated in the 7/13/82 Board Memorandum. It is the intent of this motion that hearings on the narrow question of QA adequacy with respect te sells, must precede the soils remedial work (ie. underpinning excavations) they seek to consider, if public health and safety is to be protected.
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8 RESPONSIBILITY TO DECIDE ISSUES OF THIS FROCEEDING -
LIES WITH ASLB, NOT NRC STAFF NRC regulations provide that "a Licensing Board may not delegate its obliga-tion to decide significant issues to the (NRC) Staff'.'14 It must follow then that neither should the NRC take upon'itself the decision of the key ."A/ safety question of this proceeding in the form of a reasonable assurance judgement.
Such conclusory judgements must be left to the Board. The parties are obliged to bring forward all the relevant evidence on the question of QA adequacy to the Board for their decision, upon completion of the review of that evidence. The bur-den of deciding the question of QA adequacy in this case should not and does not lie with one party (the NRC) or one person (Mr. Keppler). The burden of proof
'of QA adequacy lies with the Applicant. And the continuation of the soils remedial work,particularly the irreversible underpinning excavation steps, cannot be per-mitted (according to the terms of the December 6,1979 Order and the NRC system of regulations) in the absence of such a finding of QA adequacy by this Board.
The Board has not yet resolved "whether, and if so, to what extent the December 6 Order will be sustained" (as stated in its April 30, 1980 Order) in order to determine "the degree to which and the manner in which soils related construction activities (and particularly the renedial actions) will be permitted to continue."15 Yet the pcesent course of action regarding soils remedial work at the plant, leaves the implementation of this hearing issue, and its underlying decision, en-tirely up to the NRC staff. This becomes particularly unfair when we approach the irreversible underpinning excavations immediately' at hand, without the resolution of the essential QA safety questions related to that work. It is unfair to all parties and to the public dependent on this hearing process.
14 NRC Practice and Procedure Digest, Suppl. I to Digest 2, February 1980 p.
12; Public Serving of Indiana, Marble Hill 1 and 2, ALAB 461, 7 NRC, 313-318 (1978),
15 ASLB 4/30/80 Order, p. 7, 9.
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9 Because the NRC has met with the Applicant and progressed in their evaluation of the technical and theoretical adequacy of the soils remedial fixes (primarily an NRR responsibility), it does not mean that the NRC has simultaneously progressed in their approval of the practical implementation of the soils remedial work (pri-marily a Region III, I & E responsibility) as related to the question of QA ade-quacy. In fact, the I & E assessment of QA adequacy appears to have regressed during the course of the soils renedial work.
Implementation of the remedial underpinning excavation work cannot proceed on its theore tical feasability alone. Mr. Landsman and the other members of the I & E Staff closest to the remedial work, are attempting to do a conscientious and careful job of determining which remedial work should go forward, nevertheless they should not bear the burden of deciding the outcome of the complex and difficult QA/ safety issues of this proceeding. Yet this is the practical reality of the pre-sent situation. The flow of NRC-CPC documents, the board notifications, and memos from Region III indicate a need for Board attention and help in resolving these difficult questions.
EXPEDIENCE AND SAFETY RESULT FROM EARTIAL INITIAL DECISICN ON QA PRIOR TO EXCAVATION In seeking a partial initial decision on QA, Consumer's asserted that "an early 1
( resolution of (QA) issues will benefit the public by assuring that the remedial work, when authorized, can begin promptly in accordance with the decision...If the Board issues findings in the Applicant's favor, the applicant can confidently direct resources to maintaining and improving its QA program and its implementation.
If the decision outlines further requirements the applicant must meet, then resources l
can immediately be directed toward accomplishing them so that any authorized reme-dial work can begin promptly and in accordance with the Board's dictates."16 Thus the Applicant sought the Board's explicit prior approval for soils reme-
! dial actions in the form of a partial initial QA decision. That motion for a partial I * -
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10 initial decision on QA prior to impicmentation of the soils remedial work,which was granted by the Board in 1981, is precisely the motion I am presenting today.
Because of significant new questions concerning QA adequacy which have arisen since 1981, the motion is all the more compelling today. As cited by the Applicant in the Douglas Point Case, an early decision benefits the public by obviating
" wasteful expenditures of time and money". . . and "by alerting the Applicant promptly" of the needs which must be met to ensure plant safety.17 Consumer's adds, "Simi-larly here, a decision at a tine early enough for the parties to effectively anti-cipate and ameliorate any concerns rather than retroactively take them into account makes the resultant benefit to the public (not just the Applicant) manifest."IO 1he fact that significant safety questions arose necessitating a reopening of the record on QA, only serves to strengthen the foregoing arguments presented by the Applicant. Awaiting a full (technical adequacy-QA adequacy) decision in 1983 as discussed during the August prehearing conference would be acceptable , perhaps even preferable in terms of an integrated approach, if the remedial underpinning .
excavation work were not permitted to proceed in the interim. But in the interest t of expedience, it makes more sense to single out the narrowest QA issues (which will still protect public health and safety considerations) essential for resolu-tion prior to implementation of the remedial underpinning excavations. Other QA and technical issues can be ferestalled without compromising safety.
According to my hearing proposal, the time and effort spent working out a new QA agreement between the Staff and the Applicant would be saved. The contested hearing could then go forward sooner. The eventual QA hearings will probably be about the same length whether or not an agreement between NRC and CPC is reached as past QA problems and, differences will be considered by interyenors with or 17CPC 9/2/81 motion, h.~ 6. .
18Ibid p. 6. '
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12 cases proceeds with this work beyond their own stopwork directives) these inci-dents are termed misecmmunications or misunderstandings caused by varying inter-pretations of agreements.
Two investigations have bee.n launched by Region III on the subject of Consumer's "possible misleading statements" and "possible violations of the Board's April 30, 1982 Order" involving soils remedial work.25 At some tire we must at least consider the possibility that all these events weren't really misunderstandings at all, but were conscious violations of agree-ments and calculated risks undertaken because of pressure to push ahead and because of an expectation that nothing would be done about it anyway.
If these possibilities are not even considered, or the results of the Region III or Office of Investigation probes are not considered by this Board before the underpinning excavations are premitted to begin, then they might as well be dis-missed altogether. For once again, inaction or failure to interce'de would be inter-preted by Consumer's as approval of the status quo and the soils renedial work will continue in the same manner as it has thus far proceeded.
The concerns of the Region III staff, Mr. Keppler, and this Board (in their April 30th Order) about Consumer's ability or willingness to carry out proper QA on their own initiative in the soils recedial work must be addressed now as it becomes increasingly apparant from the course of recent events 26 that the " Staff consultation and approval" method of handling soils remedial work which the Board set forth in their April 30th Order, is not succeeding in attaining the proper care and conservatism in the soils remedial work. ,
The manner in which the soils remedial events 27 took place and whether these events do or do not constitute violations of Consumer's own, the NRC, or Board 254/15/82 Spessard memo; 3/20/82 Landsman memo.
26 see attachrent A.
27 Ibid.
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12 cases proceeds with this work beyond their own stopwork directives) these inci-dents are termed miscommunications or misunderstandings caused by varying inter-pretations of agreements.
Two investigations have been launched by Region III on the subject of Consumer's "possible misleading statements" and "possible violations of the Board's April 30, 1982 Order" involving soils remedial work.25 At some time we must at least consider the possibility that all these events weren't really misunderstandings at all, but were conscious violations of agree-ments and calculated risks undertaken because of pressure to push ahead and because of an expectation that nothing would be done about it anyway.
If these possibilities are not even considered, or the results of the Region III or Office of Investigation probes are not considered by this Board before the underpinning excavations are premitted to begin, then they might as well be dis-missed altogether. For once again, inaction or failure to interce'de would be inter-preted by Consumer's as approval of the status quo and the soils renedial work will continue in the same manner as it has thus far proceeded.
The concerns of the Region III staff, Mr. Keppler, and this Board (in their April 30th Order) about Consumer's ability or willingness to carry out proper l QA on their own initiative in the soils remedial work must be addressed now as 26 it becomes increasingly apparant from the course of recent events that the " Staff consultation and approval" method of handling soils remedial work which the Board set forth in their April 30th Order, is not succeeding in attaining the proper care and conservatism in the soils remedial work. ,
The manner in which the soils remedial events 27 took place and whether these events do or do not constitute violations of Consumers own, the NRC, or Board 254/15/82 Spessard memo; 3/20/82 Landsman memo.
26 see attachrent A.
27 Ibid. *
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, 14 a reopening of the record on QA, which have occured in the implementation of soils remedial work, cannot be put off until the remedial work in question is completed or irrevokably underway. The resolution of the December 6,1979 soils QA adequacy question is imperative now.
For these reasons, as discussed in the motion, intervenor Stamiris moves that the Board:
- 1. Place a temporary work hold on underpinning excavation work, pending Board assurance of QA adequacy with respect to soils remedial work.
- 2. Request that the office of Investigation expedite their investigation of soils remedial events and possible violations of the Board's April 30 Order, in the interest of unusual safety and scheduling needs at Midland.
3 Direct all parties to begin preparing testimony at once on the ques-tion of soils remedial QA adequacy, based upon evidence currently available.
4 Establish the earliest possible hearing dates for resolution of the soils-remedial QA adequacy issues prior to commencement of underpin-ning excavations.
Respectfully Submitted, l Barbara Stamiris 5795 North River Road cc. ASLB members Freeland, MI 48623 W. Paton, NRC M. Miller , CPC Secretary, NRC.
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ATTACHMENT A CHRONOLOGICAL LISTING OF SOILS-REFEDIAL EVENTS This listing provides the basis for my assertions about ongoing problems and violations in the soils remedial work (par.1) on which this motion is based.
In listing these events, I intend only to represent a brief showing of issues relevent to the hearings I propose--issues which represent open questions and dif-fering viewpoints ripe for adjudication.
1 As such, the following soil related QA events or reports warrant ASLB consider-ation prior to continuation of the soils remedial work.* Some of these documents reveal significant inconsistancies which must be resolved in order to afford an accurate understanding of the events they portray.
- 1. 10/13/81, QAR F120 lack of Q procedures for FVIP and control tower supports (drilling and torquing of bolts)
- 2. 12/15/81 closecut, audit justification of well fine monitoring by H01-241-02 finding 2 wrong Level inspector (CPC exh. 23)
- 3. 2/2/82, NCR M01-4-2-008 40-foot hole drilled into Q soils 4 2/26/82 incident 2 48-foot boring holes drilled into Q soils 3/8/82, NCR M01-9-2-038
- 5. 3/4/82 incident improper drilling procedures at freezewall 3/5/82 NCR M01-9-2-039 involving use of grout and hole cave-in i
6, 2/38 and 3/82 Inspection Criterion V violation: 4 instances, involv-Report 82-05 ing unapproved actions and lack of acceptance criteria in soils remedial work. Deviation:
inadequately qualified personnel in civil /
soils
- 7. 3/19/82 Inspection Criterion II and X violations: involving Report 82-06 , underpinning instrumentation
- I do not have 1981 inspection reports 81-13 thru 81-20, they should be considered to the .
extent they contain significant soils remedial information. (I will supplement later)
NCRS involving cables should be considered to the extent they involve soils remedial work (QAR F180, H01-9-2-097, -098, -099).
4/9/82 Spessard memo on QA inadequacy in
- 8. 4 /15/82 Board Notice 82-39 soils remedial work and possible mislead-ing statements
- 9. 4 /20/82 Category 3 rating in soils evaluation, 1980-81 SALP report, Keppler statements at 4/26/82 and 6/21/82 Related Keppler statements and SALP meetings, formation of Special Inspec-events tion team (6/21/82)
- 10. 4/12/23 Inspection Criterion V violation: 3 instances involv-Report 82 -03 ing outstanding FCRS, BWST undermining unauthorized field changes
- 11. 4/21/82 NCR unauthorized excavation of duct bank under-M01-9-2-051 mines BWST valvepit
- 12. 4/28/82 nonconforming drilling by Mergentime and verbal stopwork lack of Bechtel control Miller to Davis letter 13, 4/29/82 incident nonconforming drilling, hitting ductbank Bechtel NCR 4199 and damaging electrical conduit and cables, no hold tags applied until 5/10/82
- 14. 5/19/82 incident drilling of obs, well 4 encountered void Oral Communic. Record at 10:30 A.M. , resumption of drilling OCR 0168 on well la allowed till 2:40 to finish job despite stop work FSW-22
- 15. 5/19/82 issued at 1:00,1:15 or 1:30 P.M.: (accord-Stopwork Order FSW-22 ing to various times given) after Landsman and Cook inspected void, Stopwork written retroactive to 4/28/82
- 16. 5/20/82 SCRE-51 55e Safety Reportability Evaluation of (attached to 5/26/82 5/19 void: Extent of void doesn't appear Bird to Hughes letter to impact any safety related structures or utilities.
- 17. 5/21/82 Hergentime bypassed MPQAD hold points for NCR M01-4-2-062 weld inspections, no part corrective action
- 18. 5/24-27/82 conditional release to fill 5/19 void, Nonconforming material Release and related documents attached to 6/30/82 Paton to Marshall letter 19, 6/25/82 letter Inconsistancies exist between statements Brunner to Board in this letter and the referenced supporting documents. (Bechtel NCR 4199 is dated 4/29/82--it is said to have prompted a 4/28/82 Stopwork Order.) There is no record of the 4/24/82 incident mentioned. The FSW 22 Stopwork Order was actually issued
- on 5/19/82 after void incident.
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20 6/7-9/82 Audit finds civil soils group interface on soils M01-206-2 remedial work acceptable
- 21. 6/22/82 violations involving grouting of underpin-Stopwork Order FSW-23 ning brackets, MPQAD verbal stopwork at 12:15, but work continued till 2:35 when brackets were grouted
- 23. 7/8/82 . sought advice (and possible relief) on QAR F187 necessity of periodic field tests
- 24. 7/9/82 sought interpretation (and possible relief)
QAR F186 of sample point depth in well 25, 7/21/82 requests explanation of "71 individual QAR 189 deficiencies" on IFIN's (Inprocess Inspec-tion Notices) between 7/8/82 and 7/19/82
- 26. 8/17/82 letter QA organization change, J. Meisenheimer Brunner to Board as QA Supt. for Remedial Soils Work
- 27. 8/2 0/82 8/24 Landsman memo on violation of April 30 Keppler to Fitzgerald Board Order, related Stopwork (8/12/82)
Investigation Request events, new communications vehicle and and related events subsequent application, scope and purpose of investigation sought
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