ML19220B953
| ML19220B953 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/19/1973 |
| From: | John Miller Metropolitan Edison Co |
| To: | Anthony Giambusso US Atomic Energy Commission (AEC) |
| References | |
| NUDOCS 7904280002 | |
| Download: ML19220B953 (3) | |
Text
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SUBJECT:
THREE MILE ISLAND NUCLEAR STATION UNIT 2 DOCKET No. 50-320 CCNSTRUCTION PERMIT EXTENSION
Dear Mr. Gia=busso:
This letter is in a=plification and clarification of the =ajor ite=s listed as cause for delay in the construction of Three Mile Island Nuclear Station, Unit 2, in our request for an extensien of the construction co=cletic.n dates for TMI-2, dated October 26, 1973. This is the first reques t for an extension of the Construction Per=it (CPPR-66) completion dates since those dates were originally established in early 1968, when this unit was to have been located at the Oyster Creak site near To=s River, New Jers". The =ove to the Three Mile Island site itself resulted in an esti=ated s;x-conth delay in obtaining the construction permit for TMI-2; this six-month delay necessarily carried forward as a delay in cocpletion.
Ite=s 4 and 6 of the list in our letter dated October 26, 1973, relate to the fact that the early estimates for the Three Mile Island units (the basis for the esti=ated earliest and latest dates of co=pletion of construction for Three Mile Island Unit 2) substantially underestimated the quantities of =aterial, labor, supervision and funds that would be required for the units and, as a result, the projected dates for cocolecion.
(Applicants believe that this was also true of virtually all nuclear power generating units for which construction per=1ts were sought in the sa=e period as the Three Mile Island units.) The very substantial increases in the estimated cost of the units reflect to so=e degree the unexpectedly rapid rate of inflation of prices and their i= pact on the original cost esti= ate and the escalation clauses of =ajor equip =ent purchases. However, the dominant ele =ent in such increases in cost has been the unanticipated a=ount of field construction labor and =aterials which, with the necessity of sequential construction and careful super rision, required a correspondingly longer 7 9 0 4 2 8 0 00,L 84-159 5
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constructica period.
It was not possible to cf fset these f actors simply by increasing the =anpower at the site for several reasons, including the following:
(a) As noted above, construction cust proceed on a sequential basis, so that an increase in site labor and supervision (even if available) would not necessarily correspondingly shorten the construction period; (b)
The characteristics of the site and the concentrated nature of the construction activities impose a practical limit on the size of the construction force that could be utilized; (c)
There was a shortage of key supervisory skills in the area.
Not only has construction generally been active in the southeastern Pennsylvania area, but the Peach Botto= and Salem nuclear generating stations which were under construction during the same period have been drawing from the same labor pool; (d) These increases in cost and delay in completion of both units irposed a substantial financial burden and cate at the sa=e ti=e that the erosion of earnings (for these and other reasons) reduced the Applicants' coverage of fixed charges to the point that they were unable to issue normal amounts of funded debt securities. As a result, the Applicants' parent company issued extraordinary amounts of co==on stock in eacn of the years 1969-1972 and alsa obtained emergency authority from the Securities and Exchange Co= mission to issue its own debentures in order to provide funds for the Applicants in lieu of sece of the funds which they would ordinarily have raised by the sale of their own funded debt securities; (e) As a result of these factors, it became apparent that the power supply needs of the area would be best served by giving priority to allocation of limited labor, supervision, materials and funds to Unit 1, and that this would also be beneficial in =aking it possible to carry over to Unit 2 that learning and experience gained from Unit 1.
At the same time that the foregoing factors were affecting the rate of Unit 2 construction, the other items referred to in our letter of October 26, 1973 were also causing delays. Thus, with respect to Item 1 on the list stated in our letter of October 26, 1973, we had originally planned to submit the Final Safety Analysis Report (FSAR) for Unit 2 in early 1971 and had it ninety-five percent co=pleted when the revised Safety Evaluation Report guide was published in February,1971. At this same time dif ficulties were experienced in pouring the reactor building concrete on Unit 1 and, based on this experience, it was decided to modify the ring girder design for Unit 2 to facilitate its construction and avoid the proble=s experienced in Unit 1.
The engineering involved in this =odification, although not extensive in ter=s of the amount of time, did delay the final preparation of the FSAR such that we felt compelled to rewrite it co=pletely so that it would comply with the revised guidelines. This revision to comply with the Co= mission's latest guidance required =uch core detailed information and presentation than the old format. In order to prepare this =aterial, key 84~160
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engineers nad to be diverted from the project engineering problems to prepare the additional text material and additional analysis work required for the FSAR.
Th.s 2nd edition of the FSAR was nearly cocpleted when Revision 1 to the SAR guide was published in 1972. Again in order to co= ply with the up-to-date guidelines, the FSAR was revised a second time, requiring additional engineering time and effort.
The result of these delays was a total esti=ated delay ti=e of sosewhat less than a year in the project's schedule for the FSAR.
Item 3 of Applicants' request letter reflects that delays were incur:2d as a result of OA/QC requirements during construction.
It was recognized that a 20% force reduction was necessary to achieve the required level of supervision with the available supervisory persennel to assure that proper quality assurance could continue to be achieved. This reduction in work force, co=bined with an actually experienced labor productivity rate whi h was inconsistent with early overly optimistic esti=ates in 1968 when the schedule was set down, resulted in overall delays in excess of one year to the Unit 2 project echedule.
With respect to Item 5, several weeks of construction progress ti=e were lost as a result of the diverting of =anpower to accomplish cleanup operations that were required following the =ajor rainstorm and flood that occurred during June, 1972.
With respect to Ite: 10, an additional unplanned effort of sete eight months was required as a result of the AEC Interia Acceptance Criteria (IAC) for ECCS. This included the engineering tire and procurement tire for the additional caterial required to bring Applicants ' design into compliance with the IAC and thus to meet AEC's licensing requirements.
With respect to Item 11, considerable engineering effort has been expended in analyzing the effects of high energy pipe breaks outside contsinment and in designing required additional restraints to minimize these effects.
It is esti=ated that this additional work necessitated by AEC's more stringent licensing require =ents in this area required approximately seven =onths engineering effort.
Considering the composite effect of all the factors listed in our October 26, 1973 request, we have estimated a project delay of approxi=ately three and one-half years. The specific component of this overall delay attributable to each item cannot be calculated or realistically esti=ated.
While it is difficult to quantify the i= pact of developments discussed herein with the schedules of seemingly independent construction work, these i= pacts do exist. We feel that the requested extension to earliest and latest co=pletion dates of May 1,1976 and May 1,1977 is realistic and is in line with our experience to date on both Three Mile Island Units 1 and 2.
Very truly yours,
.-5 J. G. Miller Vice President ash 20: Mr W. A. 7errtchi 84 161 t