ML20065C140
| ML20065C140 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/20/1982 |
| From: | Sinclair M SINCLAIR, M.P. |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8209230231 | |
| Download: ML20065C140 (10) | |
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00CKETED USNRC UNITED STATES OF AMERIC A ,
NUCLEAII REGULATORY COMMISSION Before the Atomic Safety and Licensing Board M SEP22 mi:00 CFFIC" CF SEutiTnn DOCKETt'G a s w,q-In the Tlatter of: ) 13 '
, ) Docket Nos. 50-320 CONSUMFRS POWER COMPANY, ) 50-330
)
(Midland Plant, Units leand 2) ) Operating License
~ RESPONSE TO SECOND SET OF INTEItROGATORIES TO INTERVENOR MARY SINCLAIR September 20, 1982 These are responses to Consumers Power Co.'s second set of interrogatories dated August 30, 1982 Contentions 3, 5 and 7 are dealt with in the first section.
I. Interrogatory 7 (Contention 3--Accident Assessment)
- a. The FES includes a discussion of the uncertainties associated with the numerical estimates of the likelihood, as well as the consequences of severe accidents, that the DES did not carry. The FES states that the uncertainty -
bounds could be over a factor of 10 but not likely as large as a factor of 100(5-48).
The DES, (5-46-66) relying on the Ijasmussen study, came up with a factor that !
underestimates the risk by a factor of 20, according to NUREG/CR/2497, a report which was the basis of my contention.and will be a supporting document.
In the first place, the IES was seriously in error because the Lewis Report of January,1979 (NUREG-CR-D400) specifically states that the Rasmussen Report (WASH-1400) should not be relied upon for public policy determinations, as for example on p. 3, it states: "WASII-1400 is defective in many important ways. Many of the calculations are deficient when subjected to careful and probing analysis. with the result that the accuracy of many of the absolute probabilities calculated therein is not as good as claimed. One key deficiency is the use by the study team of some methodological and statistical assumptions that lack G209230231 820920 \
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credibility. Therefore, the absolute values of the risks presented by the Report should not be used uncritically either in the regulatory process or for public policy purposes. "
The documents mentioned above, all other documents obtained under discovery, as well as reports on new studies in this field will be relied upon to establish the facts for Contention 3
- b. I do not expect to have a witness of my own at the hearing. I am relying on the NHC to provide credible witnesses that will support the data in NUREG/
CR/2197, pursuant to CFR 2.720(h)(2)ti),
- c. I would expect the witnesses that the Applicant and the NRC provides to deal with with the substance of this Contention, i.e., the adequacy of the methodology of the DES for determining the possibility of severe accidents at the Midland nuclear plants, as well as the basis for the new information in the FES and NUREG/CR/
2107.
- d. Same as for c.
2 Interrogatorv 7 (Contention 5--Adequacy of Cooling Pond)
- a. My major basis for raising this contention is based on a meeting I attended on September 1,1978, when James Carson, meteorologist of the Argonne National Laboratory, came to Midland to advise city and county officials of the new pre- -
dictions about the effects and performance of the Midland nuclear plant's cooling pond based on observations of the operation of the cooling pond for the Dresden it and III plants in Illinois which had gone into operation after the Bechtel models and studies were made that was the data base in CP-FES. Acopy of my report made i
to the Attorney General at his request is enclosed.
There was no transcript of this meeting, and it was my interpretation from my notes that the original study was made from a pond in Arizona. However, I see from the data in DES and FES that the Currier and Hicks models of fogging and icing compared the air-water temperature differences between cooling ponds in the Midwest and Arizona to arrive at their conclusions that the increased fogging I
4 and icing were dependent on air-water temperature differences. Carson's discussion was not that detailed. IIIs concern was to have the County Road Commissioner and City Planning Commission prepared for more fog and Icing than was indicated in CP-FES, and to take appropriate practical measures if possible. These facts were also ultimately incorporated into DES (5-7) and FES(9-19). However, both the DES and FES continued to carry the original proved for thermal performance of the pond (and subsequently discredited and/ unreliable) tables /of the Bechtel Study,1973, which were incorporated in the CP-FES.
I had been asked by Michigan's Attorney General Kelley, who had intervened in the Midland O. P. proceeding, to attend this meeting and write a report. That report will be one of the documents I will rely on. To my knowledge, James Carson did not describe the basis of the data for the Bechtel Study, but only referred to it as inadequate, and that the Dresden data was more appropriate to the Midland situation.
- b. I would expect that the ASLB would require the presence of James Carson, meteorologist, pursuant to CFR 2.720(h)(2)(i). I would rely on this witness,
- c. The NRC witness would be expected to testify primarily on the observa-tions at the Dresden cooling pond.
- d. Same as for c.
Interrogatory 7 (Contention 7--Synergism)
- a. NUREG/CR/2156, June,1982, is a study conducted by Sandia Laboratories of the observed effect of synergistic action of low level radiation on the polymers that constitute the insulation of electrical equipment in nuclear plants. This document, as well as any other documents that will be supplied under discovery, and any new research items that deal.with the subject of synergism between I chemicals and radiation will be relied upon to establish these facts,
- b. I would expect the ASLB would require the presence of the director of the j Sandia Lab's study for NBC, NUREG/CR/2156ds a witness pursuant to CFR 2.720 l (h)(2)(i-3 I will rely on him/her? as a witness.
l c. As deacribed in a.
I d. As described in a.
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Interrogatory 8 I have described to the best of my ability the documents upon which wiknesses.
will rely in whole or in part in preparation of testimony in my responses to Interrogatory 7 for contentions.
Interrogatory 9 I am relying on the ASLB to subpoena those members of the NBC staff that have direct personal knowledge of the facts to be heard, pursuant to CFR 2.720 (h)(2)(i). I believe these persons must be the best qualified with the N'uclear Regulatory Commissioa to deal with these issues.
Interrogatory 10 s I have not as yet received the document NUREG/CR/2407 (June,1982) and -
therefore, cannot respond to this question.
Interrogatory 11 s Same as answer above for Interrogatory 10 +
Interrogatory 12 Same as answer above for Interrogatory 10.
Interrogatory 13 ,
3 (With respect to Contention 5)
- a. From the text of James Carson's discussions in TIidland on September 1978, I gathered that the fogging and icing effects were not properly assessed ,
in the models that formed the basis for the CP-Et3 report. Pe brought in observations of the Dresden pond which began operation after that study was prepared that differed significantly from the conclusions of the Ecchtel Study
.of 1973 in CP-FES.
- b. James Carson described performances at a pond in Arizona as being quite different in air-water tempers'.a from what could be expected'in the Midwest. The NBC staff conti:e s o > terate that fact in FES[etH h,
- c. Thermal performance t< ales suntd be developed based on actual oper-ation of the Dresden cooling pond and the more recent Currier and Ilicks models discussed in FES ( 5-G ) rather than relying on the Bechtel1973 Study and model l which has been proved deficient and unreliable by the thermal performance
- of the Dresden pond under actual operating conditions in the Midwest.
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- d. The 21% higher heat load of the Dresden pond as cited in FES ( 5-6 ) than thdif predicted by the model can have a significant impact on the length of time the pond can be effective as a cooling source for the reactors, the amount of evaporation and therefore, the chemistry of the pond, and the amount of fog and icing that will occur in the area and its effect on area industry, people, animals, crops and the concentration of both chemical and radioactive pollutants which can become entrapped in heavy fog and will be rained or snowed out or iced out in the area.
Interrogatory 14 I answered all of these interrogatories myself.
Response to Interrogatories for Zack Contentions 6, 8 and 16.
Interrogatory 7 - Contention 6 (Howard's Zack deficiency disclosures)
- a. Albert IIoward has voluntarily publicly disclosed the extraordinary extent of poor quality control at the Zack Co. which has been responsible for the IIVAC system at TIidland 1 and 2 This is an important safety system having grave potential consequences for workers and the public if it fails to operate properly.
IIoward's affidavit and all the exhibits he has provided will be the documents
, relied upon to establish the facts of his testimony.
- b. Albert IIoward will be asked to testify
- c. IIe will testify to the events described in his affidavit.
- d. Same as for c.
Interrogatory 8 Same as above for Interrogatory 7.
Interrogatorv 9 Albert IIoward worked in the OA division of Zack. IIe observed many serious OA problems. When he requested and received a promise of anonymity from Mr. Leonard of MPOAD, he disclosed this information to him. Subsequently, he was fired. Therefore, his qualifications stem from his personal experience with the operation of OA at Zack and the Applicant.
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Interrogatory 7 -Contention 8(dealing with the non-conformance report tiled by Zack on or about August 4,1982. )
- a. This non-conformance report deals with the fact that two sets of records--
a shop record and a OA record--which are kept to guarantee the integrity of the welds must be signed by the same person. They were, in fact, signed by two different persons. This violates the federal standards for documentation for safety-related systems in a nuclear power plant.
The non-conformance report, as well as all other documents obtained by discovery, and any newly developed information will be relied upon to determine these facts,
- b. Albert floward will testify to whatever extent he can on this. Also I expect the Nlte to provide a knowledgeable witness, pursuant to CFR 2.720(h)(2)(1)
Interrogatory 7-Contention 16( deals with Zack non-conformance report and defective Travelers 1
- a. Zack's non-conformance report filed in August,1982, disclosed that 140 Travelers showed unverified welder qualifications for fabrication welds.
- b. Same as Interrogatory 7-Contention 8-b.
- c. Same as for b.
Interrogatory 8 (Contention 6)
Albert Howard will rely on his affidavit and exhibits, all documents obtained by discovery, and any new information that is developed. Any NRC witness will rely on same.
Interrogatory 8 (Contention 8)
Same as Interrogatory 8 (Contention 6).
Interrogatory 8 (Contention 16)
Same as Interrogatory 8 (Contention 6).
Interrogatory 9 .
Albert floward's qualifications are discussed in response to Interrogatory 7a, Contention 6, p.5 The NIIC can provide qualifications on other witnesses.
Interrogatories 10,11 and 12 not applicable here.
P Interrogatory 14 The people who contributed to this last set of interrogatories for Contention G, 8 and IG are Lee Bishop, Diane liebert, Barbara Stamiris and Mary Sinclair.
Respectfully submitted, h_ ab Mary Sinclair cc: Secretary, U.'S. Nuclear Regulatory Commission Michael r. Miller, Esq.
William Paton, Esq.
Mr. Wendell Marshall Ms. Barbara Stamiris
. James E. Brunner Lee Bishop Myron Cherry
r S::ptessoor 20, 1978 Memo to Gregg. Taylor Attorney General's Offica As. you requestad on September 14, I ca writing an account of the information developed. at the fact-fNing neeting that took place between representatives of the Nuclear Regulatory Commission and the Midland County P1 =an4"r and Road. Conseissions on September 7,.1978 -
Clifford Staff of the Midland Planning Commission met with MRC people.in A.M Gordon Solberg, chief engineer of the Road Connaisalon,. and William Fortier,. his. amaistant engineer, net with them in the afternoon Observers included a Consumers 1 Power Company representative,. Ron Cook, and Mary Sinclair.
Pat Race was. present from about 1-C:C0 p.m. '
General.Information Discussed.
Growth of Midland planned for northwest direction Approx-imately 3C0 pernament workers will be operating the nuclear facilitiaa. on' round-the-clock shifts The present population of the City of Midland is 36, SOC the total County population is 67,000.
Evacuation and Rad Vaate Tr.ansportation Questions. were askad by the NEC about what routes had been.
planned for evacuation and. rad wants transportation.
Both Clifford Stoff and the road engineers said they hadn't given either of these matters much thoughY. Speculation at both meetings: indicated that the Enstman Road interchange exit to the freeway would be most likely to be used in the event of a release of radioactivity requiring evacuation. Stark and Waldo road.. exits.were also mentioned.
Gordon Solberg said that .while the East =an ex1.t would be the moet likely to be used, it la also the area at which
l most accidents occur in Midland because of the poor design of that interchange.
Willism' Olmstead, NRC attorney, asked whether 12,000 people could be evacuated in an hour. No one knew.
,Re engineer said he has not been involved in evacuation rauta p1==a4ng He: ham. not studied the evacuatice; time. for city and; county Both: Clifford Staff and the, engineers said they had not -
thou6ht about. the directions. for radioactive waste: transporta -.
tiom out of the plant site Cooling- Pond Effacts-Jamme. Carson,. meteorologist free the Argonne National.
Laboratories, stated that the people in the area. of the: cooling pond would. be subjected to hundreds of hours. of steam- for from the cooling pond. overy winter in their homes They can expect icing. one their houses,. trees and =ni-==1
- Much. additional snow will. be= geneented in the area.
(The- radioactive effluents. that are- released to the- pond
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will rise with- the for and be rained or snowed out in the-arsa This was. part of the testimony of Dr. Edward Epstein, meteorologisi at the University of Michigan, during the con--
struction license- hearings.)
These data.are based on observations in the area of the -
cooling pond for the Dresden plant in Ill.inois which has been operating for some time.. Mr Carson said that the Midland pond with its- two plants. will be much hotter.
The. Dresden pond covers 1,275 acres, while. the Midland pond' is.880 acres..
At the Dresden pond, the water is rnnning SO" hotter than the- outside temperature, according to Carson. When it is
-20" the pond is measuring 70 . Fog plumes up to five miles es e e, e 8 eye e me . mm .e m m e em . +me>+ ,e w ew me m - use e
,T-long- have been observed at Dresden Me sever, fogging that will go to zero visibility will require that roads, especially Gordonville Road, will have to be- very well. marked Gordonvd T Te Road. will have- to be- ^-
videned to allow for more maneuverability Carson suggastad.
fr,=M"g lights be installed. ta warn. motorista. that ther are- ,
going into a heavy fog area where zero. visibilitT was possible e He. askad. about the possibility of closing Gordonvilla Road where the fog is especially heavy ,
he NEC,. izr its advanca comments- and questions,.. pointed out that Bechtel. had. used. fogging data from- a pond. in Ari=ona to; calculate- for effects at tha construction. license phase Dese ars not appropriate oz comparable to fog effects in the-Midwest Ron. Cook, who- is the- resident inspector at the MiriT and n-planta, said he had visited the Dresdezr area. during fogging-and the residenta. called ~the- road. near the pond,.
- suicide road.."
Carson said that Commonwealth Edisort that operates the-Dresderr n-plants has cade un in-depth study of the- cooling pond. effecta,. but has not released it When he was asked why, he said,. "Because they could. be- sued for those- effects." .
M. Sinclair .
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