ML20084K872

Cross-reference to Intervenor B Stamiris Previously Filed Proposed Findings of Fact & Conclusions of Law

ML20084K872
Person / Time
Site:	Midland
Issue date:	05/11/1984
From:	Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT
To:
Shared Package
ML20084K865	List: ML20084K863 ML20084K872 ML20084K877
References
OL, OM, NUDOCS 8405140228
Download: ML20084K872 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 000hETED UNC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD T4 MAY 11 P3:22 In the Matter of CONSUMERS POWER COMPANY

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) DOC CF XLh'Nos.

50-329-OM

) 50-330-OM

) 50-329-OL (Midland Plant, Units 1 ) 50-330-OL and 2) )

CROSS-REFERENCE TO INTERVENOR BARDARA STAMIRIS' PREVIOUSLY FILED PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW All findings in Intervonor's Proposed and First Supplomontal Proposed Findings of Fact romain the same unless otherwise indi-cated below.

I. INTERVENOR BARBARA STAMIRIS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW (December 10, 1981).

13. Although accurate at the timo filed, Consumers has subsequently reorganized, as explained, infra.

14. This finding should be oliminated. Although accurato at the timo filed, the DGB Inspection has indicated that Consumers' increased involvement in contractors' activition has not lot to more timely and offectivo decision making and resource allocation.

16. This sontones should be added: The NRC inspec-tions to date, including the DGB inspection, have demonstrated that the integration of OC into Consumors' QA program has not led to more timely and thorough correctivo actions.

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-17}.The first sentence o.f this paragraph should be eliminated'in' light of the new'trendanalysis program instituted s .

7 af ter the NRC, staff found sei-ious defi*c iencies in the prior. trend I 't analysie program referenced tri: this finding. J ec xL

37. This sentence shoula'be added: The Midland team

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.y testified,tjhat the Crosby Court.'e lias not improved Consumers' QA

. s. x implementition or its idanagement attitude. Shafer, Tr. at 16880.

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42. This sentence sho'uld-be added: Mr. Gilray testified that he would defer to Region'III'c opinion as to x ,

whether prior predictions of Consurers' improved QA performance s

had come 'to ' f'hilition. 'Dr[ Landsman testified they had not.

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, i Gilray and Sandsman, Tr. at 16888.

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46,. The s5conp sentence of.this finding should be eliminated., y

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.1 s-7 2 . !, This,, sentence should be added: The 1980 reor-ganization h~an not le'd to a g{eatersmanagement commitment to quality. construction and QA principles. In fact, as explained, s

s infra, itmay have contidibuted to the QA breakdown the NRC discovered in' late 1982-in its LGB inspection and to a contentious s

relationship with the 'RC staff.

10 f;. Thi sentence sh6uld.be added to this finding:

In the DGB, inspection findings and in the initial findings of the Tera Corporati6n in the.IDVCP, we find further bases that the as-

,j ,, ,. 1 built condition of the plant. do<is not meet the design requirements.

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153. The last sentence of this finding should be i amended to read: We believe these decisions were caused by time and financial pressures and thus reflect poorly on Consumers' attitude toward safe construction of Midland.

187. This finding should be amended to read: We find example 2C above provides additional evidence that Consumers' concern with cost and scheduling adversely impacted the soils work at Midland. .

L II. INTERVENUR BARABARA STAMIRIS ' SUPPLEMENTAL FINDINGS OF FACT AND CONCLUSIONS OF LAW (March 29, 1982).

101. The first sentence of this finding should be re-placed by this sentence: The only improvement we note is Bechtel's commitment to document on-the-job training ("OJT"),

which it should have done initially.

135. The first sentence of this finding should be replaced ,

P by the following sentence: Contrary to criterion XVI cited above, we find that applicant is unable to identify deficiencies, or, once identified, correct these defiencies.

The second sentence of this finding should be amended to read: The evidentiary basis for this conclusion is set forth in Stamiris' Proposed Findings of December, 1981, repeti-tious inspection findings of the NRC staff, the DGB inspection findings, and the recent findings of the third party overviewers at Midland.

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p. 44. The first sentence, starting with " Based on the NRC's observation..." should be eliminated.  ?

III. CONCLUSIONS OF LAW The Conclusions of Law and Order sections of each set of previously filed findings should be replaced with those sections of Intervenor's Second Supplemental Proposed Findings of Fact and Conclusions of Law. F r

Respectfully submitted, +

t DATED: May 11, 1984 k /fu Lynng"Bernabei (G -

i Goverh. ment Accountability Project [

1901 Gue Street, Northwest Washipgton, D.C. 20009  !

Telt.Thone: 201/232-8550  ;

Attorney for Intervenor  ;

Barbara Stamiris i

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