ML19323D171

Submits Questions & Comments Presented at 800325 Public Meeting in Madison,In

ML19323D171
Person / Time
Site:	Marble Hill
Issue date:	04/30/1980
From:	Eyed J SASSAFRAS AUDUBON SOCIETY
To:	James Keppler, Stello V, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML19323D130	List: ML19323D163 ML19323D171 ML19323D174 ML19323D180
References
NUDOCS 8005210202
Download: ML19323D171 (5)

Text

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l .;gy g.g'3 Mr. Ja:es G. Keppler, Direc, tor, Region II*.

'b -N Mr. Cordell C. Willia =s, Construction Pm~i-lIIEl$ bSkb kNS ff ect Section Chief, Region III !;P'.

i IIC Q Q N IR E M l II i

1. wititns 'ahd' Co'.t onts of the Sassafras Audubon Society presented at a Public Meeting held at Madison, Indiana, March 25, 1930, on the Re-sponse of Pr.blic Service Indiana, Inc. (PSI) to the IE " Order Con-fiming Surpension of Construction" at Marble Hill, August 15, 1979.

% paramount question concern 2.ng Marble Hill is not whether safety-related construc-tion should be resus d, but whether all construction should be stopped. Snould the public be subjeeted to the dangers inherent in the operation of a nuclear phnt, ir,-

cluding the storage of the plant'sJ-highly toxic wastes o_n-site, g its pov-r ,iq not mede d?

PSI has an overcapacity of more than 50% at peak power demand with Gibson 5 expected to come on lire in 1933 PSI has over-esti .ated growth in de=and for electrical en-orgy in it.s service area for many years, and is u::silling to recognize :

1) that the expected population growth and Eeneral economic activity in its area is likely to remain low, below the Nation's average, and

2) that the increasing cost of electrical energy will spur greater energy con-servation, with the potential of erergy conservation cutting erergy use 30-40% by the year 2000, and

3) that increasing availability of natural gas in the next several decades will co=;ets with and reduce dependency on electric power.

The disastrous econo ics of nuclear plants adds another di=ension to the question of whether Marble Hill should be built. The costs of constructing a nuclear phnt has been ine: easing an:r.lally at more than 3X the rate of gereral inflation, partly because of changes in design and adoption of standards to reduce the level of hazards in phnt ope ration.

PSI shculd be required by the IE, prior to consideration of resumption of construction, to identify and document all safety-related materials and systems which will have to be changed, additiorM'ly tested, or re-phced to comply with post-TMI-2 standards and criteria. The results of the DOS study of the Bymn Nuclear Plant, the prototype of Marble Hill, should also be applied to Marble Hill. Will the Westinghouse stea ge n-erators on-site havu to be replaced?

PSI has made no realistic esti=ato of what it will cost to bring Marble Hill on lira, but cost estimates of nuclear phnts of si=ilar size cade by other utilities and pub-lic service co==issions place the cost nearer $4 billion than $2 billion. And this does not include the costs of d,econtamination, dis =antling, and disposal of the " hot" S 005 u 10 hf.

parts of thrble Hin, costs which am increasing with tiec as experience is ac-quired on the effectn of aging on nuclear facilities. The prospect at this point is that it will be both expedient and necessary to let l'arble Eill stand as a

..onurent to the ruelcar energy experiment under the " perpetual care" of future cercrations because of the costs (radioactive as well as financial) of dispocal as well as the probable lack of disposal space in a Federal repository.

.i A:fother part of the disastrous economics of melear plants concefna their ageing?

L' hat is their life expectancy? Plants are aging (getting " hot" and "setivated")

faster than expected. Is Dresden I finished at age 19 or can it be decontanin- ,

ated (at considerable expense and with serious radioactive vaste disposal prob-lems) and given another decade of life? To what extent are gernric flaws such as steam Cenerator degradation affecting the viability as well as generating capacity of PWR's and adding to the costs of r:uclear po er? ~

If aH these factors are considered with the fact that Marble Hill is not needed, questions surrounding its construction are academic for it should be stopped while the investment is minor. The ques-tions and comments that follow cust be viewed in this context.

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l Can Marbla HiH be repaired sufficient 1v?  ;

Concrete placement at Marble Hin has been telow standard with nu=erous voids and horcycombs in the Unit 1 contaircent and auxiliary buildings, structures rnaring co=pletion when safety-rehted construction was stopped.

How :::ach of this huge volume of concrete can be and will be tested to in- l sure structural integrity? Will the selection and testing of selected volures of concrete on a statistical basis such as has been done by Mr.

Muenow of. the Portland Cerent Corporation be sufficient not only to " satis-f7 all applicable regulatory requinments" and " reasonably assure" the U?C, but win such testing and repair of defects where discovered, estab-lish unequivocally that Unit 1 can withstand a 28 psig pressure spike such as occurred at TIG-27 The h?.C's Regulatory Guide 155 entitled " concrete Plaeement in catero- r I Structures," notes : .

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"In particular, the presence of numerous concrete voids which have been detected at or rear the surfaces of nuclear containment build-ings raises concern about the density of portions of these and other  !

concrete structures that cannot be readily inspected. For such un-accessible areas, the only method of assuring a quality concrete

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r structure is through good planning and control of the placecent of concrete and an items e= bedded in it." '

How :::uch of the concrete cited in 25 reports to PSI as "out of slu=p con-crete" and/or included in the 91 field riports to . PSI of honeyco=bing, is in safety-related construction and inaccessible to inspection and testing but vital to structural integrity?

. II Will PSI be required to have N Certification prior to m:umption of ssfety-re-lated construction at Marble Hill?

Several confusing statements are made by PSI in their Report Tnv-i '.i n of Licensee Activities AdSt:inrr 0-der Co . fir :in* Su- a ncfoior h- .-; -

tion, concerning N Certification, but it is clear that PSI does no', er. net i

"- to have N Certification at the tire they expect the Confirming Order to be lifted:

1

.....on pace III H-1, PSI centions "An interin letter of authorication has been issued by the ASG."

.....on page III-H-5, PSI mentions that they have had their "AS'2 Quality Assurance Program reviewed by the ASE Survey' Team and as a result of their findings, expect to receive an interin letter from the ASC soon."

.....on page III-H-5, PSI also notes that " PSI will request ASE to survey its implementation of the ASG Quality assurance Progra=

within six months of resuming Code work on piping systems.",

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while in a footnote on the same pace PSI notes that " Subsequent to the January 17, 1980 letter, the decision was made to arrange for the survey to start the same date the Confirming Order is lifted with respect to Code work on piping systems."

The Indiana Boiler and Pressure Vessel Board (IB?'IB) is supposed to hold the view that Marble Hill is at a sufficiently advanced staEe of construction that PSI should have an N Certificate and should not be allo ed to proceed with only an " interim letter." Does ASE have a simnar position? The NRC?

Sassafras Audubon concurs with the IBPVB that PSI should have N Certifica-tion prior to resu=ption of safcty-related construction.

III When does Region III NP.C expect PSI to have a fully developed and functional Material Management Program?

P5I, in a .ietter to Mr. Gaston Fionlli, Region Y NIC, on February 15, 1933, concerning 19 storaSe and maintenance nonconfo::ances cited during a Nove:-

ber M-16,1979 inspe,ction of Marble Hill, centions that " Develop.ent of the PSI Material Management Program is in process. PSI will provide an up-dated status of this development by March 31, 1980."

PSI, in a subsequent letter (March 10, 1980) to Mr. Fiorelli confirred that the program is " developing" and gives no date when full co=pliance will be achieved.

PSI has had two full years + in which to institute a Materials Handling Program in conformanco with the NRC's Regulation Guide 1.38 rer,arding levels and methods of storage and maintenance of materials prior to place ent in their final location. How much time does the NRC consider " reasonable" for establishment of a Materials Management Program by the Licensec?

, -1, IV Will Recion III NIC make certain that PSI has sufficient personml sufficiently trained and experienced on-site at Marble Hill prior to termittir.c construction activitics to resure? Mr. Cordell Williams testified tefore the Moffett Subcom-mittee in November lW9 that Marble Hill had been seriously undemistaffed prior to work stoppage in terms of both capability and numbers.  ;

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• The MansCement Analysis Comparr/ (MAC) in their Diagnostic on Marble Hill ct. .e to the general conclusion that the problems that led to suspension of construction ,

af. Marble Hill were prir.arily the result of insufficient co mreial nuclear ex-perience within PSI md its contractors. .

PSI, in the section of their Report on Staffing and Qualification in areas of Project Manage: rent and Quality Assurance,is confusing as to what quality and quantity of staff they would have on hand for " installation activir.ies" and what would be requimd for full const2metion activities, stating on page III-C-7 that " Full construction activities will be supported by additional staffing as re quired."

MAC personrel, under contract to PSI en to staff key positions until PSI's counterpart in each of there positions is indoctrinated to assume project re-sponsibilities, and PSI mentions that soecific olans for implementing the tran-sition will be developed and that contract personnel vi.11 be used in other areas of the project to supplement existinE staff as needed. This seems far too in-definite and open-ended for a Project, which has suffered from a lack of suffi-cient personrel as well as sufficiently trained personnel.

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If construction is allowed to msume at Marble Hill will it be under " fixed-price contracts" between PSI and its contractors and subcontractors? '

l Marzy workers at Marble Hill, including the carpenters who went on si.rike at one point, have testified to excessive work-schedule demands, dincted to-ward reeting construction " milestones" which were not compatible with qual-ity construction. The construction pressuns have been nlated to fi.xed-price contracts where contractors will be the losers if they do not reet construc-tion schedules.

• The NRC mentioned in Item 4, Part IV of their August 15, lW9 Order of Confirmation, that PSI should review all contracts, " including conditions of such contracts that r.ay impact negatively on quality," and asks PSI to identify specific steps to be taken to assume such conditions do not re-duce the quality of safety-related work.

MAC,in their Diagnostic of Marble Hill, cer:tions (page 3), "that the original C

cost and schedule anticipations, even with the benefit of replication and fixed price contracts, were too optir.istic, and that to derive the maxir:um benefits of the fixed price construction contracts in the enviror:nent of constant change, PSI should break down the scope of existing contracts into  ;

smaller elements and aCgnssively monitor them at the site by more experi-enced personnel (nuclear experience in contract monitoring and administrp-tion).

PSI, on page III-D-1 of their Report, mentions that they have nyieved all

safety-mlated acrec=ents entered into prior to I.uyst 15,197?, ard St

" Based upon this review determired "that nora of the safety-r';lt ted E mo-exents contain conditions which i= pact regatively on the contractor's plity I obligations." i PSI dMs not Cet to the heart of the matter with recurd to d.e probic..s o' fixed-price contracts in their " Review of Safety-Related Contracts" on

!. pace III-D-1 of the Report. What further action does the h~dC inter.d to te le l on this matter? ,

VI Region III's program of inspection and enforcement at Marble Hin failed to assun the quality-construction of that facility for the protection of the public's health and safety. Mr. James Keppler, Director, Regic i III I;RC, in testimony befom the Moffett Subcor=.ittee (page 159 of the Proce lings of the two-day dear-ings) acknowledC ed that "There is no question in n;y mind that we vill have to )

have an aug:nented inspection pregram even beyond putting a resident inspector there."

l A resident inspector has been dn-site at Marble Hill for sone conths. 'What ,

specifically, am the duties of~the Resident Inspector? If construction is per-

=itted to rem at Marble Hill, how will the inspection program be augrented by Region III NRC and how will it interface and be coordinated with the duties ,

of the Resident Inspector? How much of the aug:ented program vill consist of l

" independent verification" and direct observation of construction in comparison l with examiration of PSI's construction records, ete? ,

VII Representative lee Hamilton, 9th District, Indiara, in his letter to Joseph M.

Hendrie, lhicicar Regulatory Commission, of December 20,1c779, noted that it be-came apparent during the Moffett Subco=mittee' Hearings that part of 5.he problen that caused the situation at Marble Hill "was that all =atters being handled by Public Service Indiana and the NRC vere handled privately, quietly, within the bureaucracy. No one was accountable and nothing was done in an open enough canner to allow full public scrutiny." .

!L. Keppler, under questioning by Mr. Ha=ilton at the Moffett 5ubco::ittee 1 l

Hearings on the responsibility of Region III h4C to make public the deficiencies I in construction which were found at Marble Hill, acknowledged (page 11.3) that i He also ac-he wished that knowledged thathe he had held might hahnews conferences falh*9ictim earlier to the fact thaqa"in curg ppyb" ight be at hand and Region III would be able to turn the thing around.

Whatever Region III's attitude toward the public's right to know and to questien whe:e their health and safe ~ty is involved, a public " meeting" at this time is no subst.itute for an evidentiary public proceeding on whether construction should resume at Marble Hill. The circumstances warrant such a public hearing.

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