ML19270H274

Submits Reformulated Contentions Re Denial of Ol.Facility Has Not Been Built in Compliance W/Safety Stds,No Reasonable Assurance Exists Re Public Health & Safety & Applicant Has Violated 10CFR50 of QC Requirements

ML19270H274
Person / Time
Site:	South Texas
Issue date:	05/29/1979
From:	Sinkin L Citizens Concerned About Nuclear Power, INC.
To:
References
NUDOCS 7906260055
Download: ML19270H274 (4)

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",C NUCLEAR REGULATORY COMMISSION 97 4 $' s s ,_' \373

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In the Matter of )

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Houston Lighting and Power, et. al. ) Docket Nos. 50-498

) Nos. 50-499 (South Texas Project, )

Units 1 and 2) )

To: All parties to the Licensing Hearing for the South Texas Nuclear Project From: Citizens Concerned About Nuclear Power. Intervenor Enclosed are the refonsulated contentions of Citizens Concerned About Nuclear Power.

Lanny Alan Sinkin 2314 149 9

79062600EA

Citizens Concerned About Nuclear Power Reformulated Contentions COANE Peformulated Centention 11 Introduction

1. The South Texas Nuclear Project has not been built in a manner such that a clear showing of safety can be provided to the Nuclear Regulatory Commission and, therefore, the operating license for the South Texas Nuclear Project should be denied.

2. The South Texas Nuclear Project has not been built in compliance with designs, specifications, and procedures.

3. The manner in which the South Texas Nuclear Project has been constructed creates the very real possibility that the operation of this reactor could constitute a serious hazard to the citizens of this State.

, 4. The defects in the construction of the South Texas Nuclear Project are a result of a conspiracy which continues to this date.

5. The purposes of the conspiracy are to evade, violate, and avoid the requirements of design, specification, and procedures.

6. In the alternative, there was and continues to be gross negligence involving numerous mistakes, errors, and failures to properly comply with the designs, specifications, and procedures which have potentially serious and grave consequences in terms of the health and safety of the general public.

7. What follows are examples which comprise part but not the entirety of what the intervenor plans to present to the Licensing Board in support of its contentions.

Specific Contention There is no reasonable assurance that the activities

, authorized by the operating license for the South Texas Nuclear Project can be conducted without endangering the health and I

safety of the public in thats a; There are membrane seals in the containment structure which are damaged.

b. There are steel reinforcement bars which are missing from the concrete around the equipment doors in the containment and such bars are missing from the containment structure as well,

c. There are cadwelds which have been integrated into parts of the plant structure which are not capable of being verified with regard to compliance with 10 CFR Part 50 Appendix B.

d. There has been a surveying error which has resulted in the eastern edge of the Unit 2 Mechanical Electrical Auxiliary Building being constructed one (1) foot short (in the east-west) direction) fecm its design location (violation of 10 CFR 50 Appendix B).

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CCANp Reformulated Contentions - page 2

e. There has been field construction in error and as a result, extensive voids exist in the concrete wall enclosing the containment building (violation of 10 CFR 50).

f. In violation of Quality Assurance and Quality Control requirements applicable to the South Texas Nuclear Project with regard to document control, a field document rel& ting to cadweld inspections has been irretrievably lost (violation of 10 CFR 50 Appendix B) .

g. Nuclear Regulatory Inspection records indicate that construction records and quality centrol and quality assurance records have been falsified by employees of Houston Lighting and Power and Brown and Root (vsolation of 10 CFR 50, Appendix B, sections VI, XVLL).

The Applicants Quality Assurance plan was not effectuated l because of the following:

Quality Control as per the requirements of 10 CFR 50 Appendix B i

has not been ecmplied with.

' In particular, 10 CFR 50 Appendix 9 Section 3 was violated i

because:

a. Efforts by quality control inspectors to verify that l

design changes were executed in accordance with the purposes of the original design were repeatedly and systematically thwarted.

b. There were personnel other than the original designer

, approving design changes with no first hand knowledge of the purpose of the original design.

I c. There were design changes approved by personnel unqualified in the type of design where the change was made,

d. There were numerous pour cards that were supposed to record.'the correct execution of concrete pours which were i falsified by numerous persons.

, e. There has bcen and continues to be assaults on the I

i Applicant's quality control inspectors, continual threats of bodily harm to those inspectors, firing of inspectors, and other acts constituting a pattern of behavior designed to

' intimidate the inspectors. As a result of the intimidations, certain inspections were never done because the inspectors decided to glay cards over a period of four months rather than risk their safety on the plant grounds.

• As a result of the foregoing, the Commission cannot make the findings required by 10 CFR 50.57(a) (1) and (2) necessary j

' for issuance of an operating license for the South Texas Nuclear Project.

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CCANp Reformulated Contentions - page 3 CCANP Peformulatedr.centention #3 South Texas project Units 1 and 2 are pressurized water reactors. Such reactors have experienced about thirty reported instances (most of which occurred during startup or shutdown) in which temperature-pressure limits of the reactors vessels (as reflected in plant te.chnical specifications) in the reactor coolant-system have caused excessive pressures on reactor pressure vessels. The South Texas Nuclear project does not incorporate design features or administrative procedures which are adequate to prevent or ameliorate such pressure transients nor have any technical specifications been j proposed for this purpose. The South Texas Nuclear project will, therefore, not be inccznpliance with 10 CFR 50.

i l Closing Statement I

Intervenor contends that proof of a substantial number of j the allegations in this contention and other allegations yet to be made should result in the denial o f' the operating license i

for the South Texas Nuclear project because the Nuclear Regulatory Commission could not have unqualified confidence that this reactor has been constructed in a safe manner.

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