ML19093A795
| ML19093A795 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 12/18/1977 |
| From: | Allen J North Anna Environmental Coalition |
| To: | Bradford P NRC/OCM |
| References | |
| Download: ML19093A795 (8) | |
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e N.ORTHANNA -
~.w ENVIRONM~~(CoALITIO Mr. Peter Bradford Commissioner U. S. NUCLEAR Rl!:GULA'J'ORY COMMISSION Washington, D. C.
20555 P.O. BOX 3951 CHARLOTTESVILLE, VIRGINIA 2290 (717J533-7694 or (804)29;-603 December 18, 1977
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Dear Mr. Bradford:
L;l'.,.Lf !Jlli.:!;ili f0,336 l3')0L.
PHOD. & UTIL. rne-l£o~--~ ').II.
The latest development in the North Anna case -- the NRC Staff request for re-opened Operating License hearings to further-explore VEPCO "commitment and technical qualifi-cation -- prompts this letter to you.
The Coalition believes it has a responsibility to in-form you of its past efforts to direct government attention to VEPCO's consistent pattern of concealment and careless handling of significant safety matters at both Surry and North Anna nuclear sites.
On January 16, 1976, the Coalition wrote to then NRC Chairman William Anders about the "three-year lag be-iween the discovery of four major safety problems and their reporting to the NRC. 11 Thie six-page letter of chronologi-cal description and request for redress received a reply dated February 19, 1976 (by Mr. Lee Gossick).
This reply, which appeared to respond only to page one of the Coalition's letter, was extremely superficial and unsatisfactory.
VEPCO's impro~er reporting described in the NAEC letter of January 16, 197 still needs thorough investigation, and is even more significant in December of 1977 as the NRC Staff arrests the licensing process to once again examine VEPCO's pattern of defect-discovery and reporting.
The January 16, 1976 letter is enclosed for your study.
Three of the problems it describes are still undergoing "independent review" by the Justice D..epartment, along wi t_h the "brittle fracture problem" raised by Sun Shipbuilding and Dry Dock Company.
'l'he Coalition has asked for a prompt completion of the Justice.Department investigations with the thought that their findings should be considered by any NRC Atomic Safety and Licensing Board assessing the pattern and problem of VEPCO "commitment" and integrity.
We believe the Commission can no longer turn away from repeated flagrant abuses on the part of a utility handling an ultimate technology.
Action against cumulative "material false statements" should have been, and should be, brought by the Commission, not by an unstaff;;f""citizen group.
Thank you for your interest.
Enc.
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!!r. Wlllfarn A. Andera, Ohairmm CHARLOT'I'ESV1LLB, V1i<<;HHA V'JU]
. t;. 5. NUCLEAR REGULATORY C01!?.tl3S1UN 1/16/76
( 804 )293-60}'
Washington, D. c. 20555 In the M.itter of Virginia :slectric and Po~er Co!"J_p_a.v (Surry and llorth.Anna Nuclear Power s,tations}
50-260, -281, -434,* -435 and 50..338 9 -339,...404,j05
Dear Mr. Anders:
Criteria for Determining Enforc~ent Action and Categories or r.onco:n :<3 pliance with A!iD/NRC Reg~latory ?.equira~e~ts.... Modifications, Dec. 31, 19 clea.?'ly state (p. 6) s An order 1s ordinarily issued t~.:revoke a }_icense when:
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- 2. Civil penaity proves to be ineffective as an eni'orce-ment aotio:i; or
. 6. An¥ _material false atatem.ent 1e made 1n the. ap::pllcation or in~ state~ent of taot :required under Section 182 or the !.ct.
Co::l!!lission he~ing and inspection records provide firm evidence that Vir~
ginia Electric and Power Co~pa.ny (VEPCO} is deserving of co~plete n~olear license revocation* at Surry and North Anna sites under both of the abova pro-Tbiona on the basis of repeated improper safety actions and* reporting.
N?.C docu:nents show a three-year lag between the discovery of four major s a!'ety prob le.'Ils and their reporting to the NRO:
Problet.n Fault in ?T.A excaTation Abnormal aet,tllng at Surry*
beneath reactors 1Jmorrilal pumphouse settling at :F.A P.ea.ctor design neglect ot pressure vessel supporta Known to VEPCO February, 1970 February, 1972 December, 1972 1971 -
1972 Reported to &XJ/1EC May 17, 19?3 May 6, 1975 *(by a "con-fide!lt ial informant")
April 16, 1975 liay 7, 1975 In !!.a:; of 1973, VEPCO was the first nuclear utility in t~e nation to be fined for ~proper performance and_ attention to safetyo This 1973 fine follo~ed a
~eve~ wa:-ning in !m in which the then.A3J called VEPCO's Surr;; record "an
- c*oject lesson to the industry." The 1973 C,40,000 fine and liot1ce of Violation included:
Appen:dli A, Ite?D E--
Fail ure to renort unusual safety-related events to the~.
S-;.cceeding events -- including fou..!:, ad_?.Jtional railureD to renort.:.- de!Donstrate ciTil penaltie"I to be "lncff'ective as a.n e~forcernent action".vith VEPCO.
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llr. ~illi~ Andera *...................... * * * *
- Pag-e 2
~aterial False State~enta It is a matter of record that VSPCO was convicted in April of 1975 or h:?:rbg s'.llimltted twelv-, materia.1 false sta.tementl3 to the Atomic E:-1431-g:,..- Co:n-mission regarding the fa.:.1lt zone beneath the North.Anna re~tors. Theae stat 0er..ents included instances of failure to. adduce key sa.fety inforrn:a.t ion (known to VEPCO at t2le time) at constrnct ion license hearings as well as failure to sub~it a significa."'lt.report by_Dro Pa-.u Roper, Pied::nont geologisto Now liRC inapeotion reports doc"lrJ!ent additional false ~tate~ents regard-ing settling beneath North Anna1s pumphouse, a Clasa I Str-~cture:
Inspection Report Nos. 50-338/75-:-5 a.."'1d)>03~9/75...S, page 2a
"* ** The inspect ion re?ealed that SAR predi.ct*ea: s~ttlement for the serY1ce wa:ter rei,ervo1r pumphouse *{a Clasa I Structure) f'or Units 1 and 2 was exceeded with the com.~ence~ent ot monitoring
_!!!. De~e!llber 197.2 *** " :*. (~has is added)
The p~edicted aettlement was lo44 inchea. Nevertheless, (paga I-2) " *** This value WS!i incorporated in the FSAR dated January "31 1973.
On February 12-13, 1973, measurement showed that the SWP'd (pumphouse) had settled 0.36 inches in the~ corner to 2.92_8 inoheli inchea in the NW corner ** *"
(l!ay.20, 1975)
Thus by e 1mple compar 1son or December 1972 e..'ld January 1973 figures, a.'l ad-dit 1onal material false statement is eatablished:
VEPCO repeated low figu.rei known to be false at the time of sub!llission.
Further, such a key foundation and constr~ction problem should have been brought before the Atomic Safety and Licensing Board when it convened in Hay
- or 1973 to consider constraction licenses for North..l.nna Unita :fi:3 and 4o Failure to adduce North.Anna purnEhouse infon:iation clearly*constitutes another material-false statement..According to the NRO inspection report (page I-4)
* ** The sw.FH for Unih 3 and 4 is several h".md.red feet west of the S':lPH for Units 1 a..~d 2 and ties into the sa!l!e dike *** When asked about the a.deq,u~y of the dusign and constr-.iction for Units 3 and 4,
.!!2. concern ~
e:rnressed E,Y_ th':! l.ice::i.see (.VEPCO)." (~has is added)
The inspectors fro~ :mtC at S,~~ry find the sSZ!le attitude as reported on October 16 of 1975 (page 7):
" *** Ther~ was no e?idence o{ co~cern £2. the licensee to resolve t11~ !:love:nenta of the reference datum at this t 1.'I!9 (1972) ** *"
regarding the several indication3 that abnor::nal eettlingws.
occurring bc,neath Surry*il reactors which went critical in 197.2 a."l"ld 1973.
D3~pit~ civil penalties, tr~ee altogether, intervenjng between 1972 and 1975, th~ record supports !-"'iJ.~'a ccntention~ that VEPCO e:m_ibits_cons_1stent_a.nd
.:L'l~ra~t~le _n-.1olear r.egliger.c*, with no e*,ridence of ccnceri.1."
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. I.~r. 7.'illia.'11 Andera ****.********** * * * ** * * * * * *
- 0 ?Ree; 4 Exhibit# G (cont.}
mcnt 'bt:tv~&n otructurec, ar.d in uuua ion, hLLo been ~.CT!!'~?-~-~ in some 1:notences. Thie &ettle::-,1:nt has betn e,;en more 61:..TJ.*rieine be-cause the weight of so!!":e of the stri..cturEs has beE:,n lees :t~n the weight of the material re~cved. (S9.7~1:8-12-67)
~~~~ is also made in that referEnce tc tte rcssipility of elastic rGbc...::_z:d of tho£o lighter structures. (~hceie added}
"The facility is founciE:d on sc~e 1300 feet of ove:rburde:n which puts it in a distinctive class *** "
Exhibit# 7 -- Letter frcm Henderecn and Phillips to VA;PCO'a Insurance Depertment, dated (?).A.p~_!l 21, 1974:
"RE:
??ELIA Policy l\\1F-1S(j Confirming our telephone conversation of tod83, *~
Individual A (:r.ELIA'a Engineering Cons.utant) is extremely upset over the time it 1s* taking you to get the informa-tion as outlined in his letter to you of February 4, 1974.
"It he does not receive a reply from you within the next ten 4eye, liis only alternative is to iI!~crm the lraLIA underwriters tbat he is una.ble to complete bis rer~rt due to his ina..bility to get certain infor:nation froc VEPCO *** "
{E?!li*haeia in Exhibit)
We are sure that you must agree that the Exhibits in the 1mc Investigation clearly prove VEPC01 s lmowledge of the Su.rry s&ttling proble!l from 1972 on, tr.at there ia no evidence of the ~rcblec*a denial (now the stance of both-VEPCO and the NRC).
Rather, there is firm evidence of the discussion ot "progressive" and "differential" settlement problems between VEPCO ~r.d NELIA. in Exhibit :fJ. 6 *. The settle=.ent problem ls recognized and real 0 Thus it is the position of XA.EO that VEPCO'~ failure to adduce known settlement problems b~neath Ree.ctcra fl nr.d 2 at Oonet:ruction License or Site Suitability hes.rings for Reactors 13 and 4 constitutes a ~ateriel false statement, a !nee in the ?,orth J..nna. case
" ** (The Atomic Safety and Licensing) Board properly held that failure to make tirr.ely discloeure of information which 1a significant for purposes of safety review gives rise to a
mater!~l false etate::i:ent *** "
NB.a Brie~ of 11/28/75 One must also inquire why t:h.e S-...rry Atomic Safety and Licer.sir.g Boe.rd did not question foundation cond.itio:r:s.
llA.ro ma.de a limited ai:pear&.r;ce at the I
July 1974 hearing for the precise riri.,oee or ra1eing questione on a e ite late-led **ruspect" by th~ 1':I-.C,. v.-ho ah; o cc:m,erits (pag 2-25 of SL:;':O::TY EV"J..LU-
.A'.i110rr):
- 1Th6 intt:grity of cer-tein z.ones *** iG que:stioneble, with liquefac:-
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~ posefbflitf under dynsmic conditions... "
e tr. *,'iill!a'!I Ande.r~..
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- Pore 5 R"eactor Design Nec;lect
.A.ccording to an lfilC mE!eting s'IXIl."nary of Uay 9 9 1975 by tort~ A!"ana Project l:er.acer l'.obert Ferguson *. ar.d a letter cf July 28, 1975, by XRC.'s 1... Schwencer:
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- Between 1971 and.1972, v:EPCO recc-gnized that asymn;etr_ic loads had been neglected in the* original d6s1gn or the reE..Ctcr pre::1:ure vessel (RPV) cupports for r.orth A-'llla Unite l a4d 2.
?;ot till May 1975 did VEPCO report this prcblen to the ?iRC, with llr. Ferb'U.Eon noting on li!ay 9:
" *** results to ds.te indicate the.t the existing reactor vessel supports will not withsta.~ci less of coolant accident (LOCA) loads.**"
(Emphasis added) -- -
S1r.ce Surry Onita #1 and 2 are twins of North Anna Units #1 and 2. the above is further 4oamnentation of intractable nuclear negligences VEPCO allowed Surry Units #1 and 2 to go critical with a significant reactor design neglect problem unresolved..Further, the ina.dequato Teasel supports provide dubious seismic protection for a ~le.nt that also has unr~ported 6.bnormal settling prcblems 9 foundation probl~ma that a*leo were unres:olved when the reactors went cr1t1calo Both of these situations should have figured heavily 1n VEPCO'a i:;recedent-set-
.til:lg $10,000 fine of.Ma.y, 1973 They did not. Nevertheles a, Append.ix A, Appendix l3, and Appendix C of that l!ay 1973 document deercribe a.n unfortunate pattern of incompetent and Ulltrustwortey behavior that has been consistent frc,m that t i!ne. "Am
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epection.Findings" listed in Appendix C all shew serious misrepresentation of ~afety actions., described as acco~lished by VEPCO's Vice-President,
.proven false by subsequent AEC inspectior.s.
Inspection and study of currunt OPE?.ATLirG UlHT STATUS P.EPO:C'S reveal mounting numbers of inf'ractions at Surry., proving repeatedly that with this utility a nc1vn. penalty"- is. ~il:leff'ective as an enforcement a.ction9"
- 1\\:.lfilling an NRC requirement ror 1*icense revocationo L1cen6e Revocation I! NRO Regulatory-Sequire!l"1entP, have meaning, then the *comm1a_s1on ~st, by the force of its own revocation.criteria, act to remove VEPCO's :cuclear licenses on the basis or its inability to improve integrity of performance atter repeated oivil p~altiee, end on the be.sis of previous cor.v1ct1on for material false state!Ilents, plus the following additional false state:r:ents, follor.ing the ASLl3 (inding that "failurG to mE.ke timely dfriclom.:.rc cf in-
- fc!"Zc.t.:ion wr..ich is s ienific.=.:nt for p1;rpu£:s of' t:af'ety re,iew giv~s riEe to a material false state:nent11 s
e l:r. i~: i 11 i8!Jl..1ndE:.ru * *. * * * * * * * * * * * * * * * * * * * *..
1., Failure to report abnormal set tl:in~ beneath f..~rry re&etcrs.
2o Failuro to adduce Surry settlir,g problems a.t Site S"..lita.bility a..'ld Cons-truction Licem:e 1:.ea!'h°:e;s 0 July ~d Octoter, 1974.
- 3. Failure to report excessive ?;crth Anna Pumr,hc~se settlir:g 1n Decenber, 1972.
(Repcrt =ade in April, 1975.)
4o Submission 1n Januar:, 0 1973 of pumpbouse figures known to be false at the tin:e of sui:.::dssion, a.ctt;.al mees~reICents hc..ving alrea~ exceeded th& repeated low predictions.
- s. Failure to ad.duce llorth Anr.a F...!nphcuee e.bnonr.e.l settling problems at 'J!.ay 1973 Constr~ction License hearings £or North.Anna Reactors #3 and 4, whose pumphouse ties into the same dikeo 60 Failure to report reactor design neglect problem 1n 1971-~972.
(Report made in f:fay, 19750) 7o Failure to adduce rea.ctor design neglect problem at Con.-
struct ion License hearillgs !'er Horth Anna Reactors :£L3 a:::d. 4 in YB¥. of 19730.Also at S-.lrI7 hearings in 1974.
8~
Submission of false pipe stress measurements:
2300 psi r.h~~
the actual measurement was 28,ooo psi.
Since the Coalition has no staff &nQ also has no convenient access to Surry documents, the above list may be co:r:.s iciered incomplete until a thoroueh study ls made ot submissions to the ~/1ra.c on ~he subject or Surry f'ound~
tio11s.
Given new USGS findings reg-c..:di?'.g Coe.stal Plain gecloey, f"..u-ther errlore.t ion of' the Ha:npton Roads Fa-.11 t Z!light be in order by the !\\"RC.
Vle bring this letter to a close *cy asking that the Im.clear RegulEitc:;;y Co=!ssion abide by its own regulati.::z::s and protect the publio by revcking the nuclear licenses of a utility th.st is uni'llpro.ed by frequent civil penalties and warnings, and unable to adhere to integrity and avoid ea.foty-related material false statements.
~e respectfully re~uest yo'lll" prc=:pt rear~nse ad~ising the Coalition of :,cur intended actione.
ThE:nk yc*J. for yciur professional consideration *.
~~ORTH.A!UfA E:NV IROil!ENTAL COAL IT ION
1J1TITED STATES OF AMERICA HUCLEf....,_"J:{_ REGULATORY cm-rrnss10r1 In the Natter of VIRGINIA ELECTRIC AND POHER COHPAHY (Surry Power Station, Units 1 and 2
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Docket No. 50-280 281 CERTIFICATE OF SERVICE I hereby certify that I have this da:y--.*se::-vec the foregoing docUII!ent(s) upon each person des~gnated on the offical service list compiled by the Office of the Secretary of the Commission in this proceeding in accordance with the requirements of Section 2.712 of the 10 CFR Part 2 -
Rule.s of Practice, of the Nuclear Regulatory Commission's Rules and Regulations.
Dated at Washington, D. C. this J /
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UNITED STATES OF AMERIC.A NUCLEAR REGULATORY cm[1ISSI0N In the Natter of VIRGINIA ELECTRIC AND POWER COMPANY (Surry, Units 1 and 2)
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Docket No. (s) 50-280 50-281 SERVICE LIST Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Michael W. Maupin, Esq.
Hunton and Williams P.O. Box 1535 Richmond, Virginia 23213 Anthony J. Gambardella, Esq.
Office of the Attorney General 11 South 12th Street - Suite 308 Richmond, Virginia 23219 Swem Library College of William and Mary Williamsburg, Virginia
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