ML19347D305
| ML19347D305 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/06/1981 |
| From: | Chackes K CHACKES & HOARE, COALITION FOR THE ENVIRONMENT, ST.LOUIS REGION, CRAWDAD ALLIANCE, MISSOURIANS FOR SAFE ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19347D306 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8103120386 | |
| Download: ML19347D305 (15) | |
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' usWC UNITED STATES OF AMERICA 0195 P 3
- N NUCLEAR REGULATORY COMMISSION J
BEFORE THE ATOMIC SAFETY AND LICENSING '40ARD W
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UNION ELECTRIC COMPANY
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Docket No. STN 50-483-OL
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(Callaway Plant, Unit 1)
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AMENDED AND SUPPLEMENTAL JOINT PETITION TO INTERVENE The COALITION FOR THE ENVIRONMENT, ST. LOUIS; REGION, (hereinafter " Coalition") on its own behalf and on bhalf of its members and affiliated organizations; MISSOURIANS FOR SAFE ENERGY (hereinafter "MSE") on its own behalf and on behalf of its members; the CRAWDAD ALLIANCE (hereinafter " Crawdad") on its own behalf and on behalf of its members; and KAY DREY, an individual, hereby amend and supplement their Joint Petition to Intervene filed September 25, 1980 in the following respects:
In response to the Board's suggestion of further oppor-tunity to show a sufficient cognizable interest to confer standing in this operating license proceeding (Memorandum and Order, ASLB, February 5, 1981, at 7), and pursuant to 10 CFR $2.714(a)(3), the Joint Petition is amended herein with respect to the standing of Kay Drey as an intervenor; that is, regarding,her interest "in thb pt needing, how that interest may be affected by the results of the proceeding and reasons why she should be oermitted to intervene.
An affidavit signed by Kay Drey is attached hareto to provide additional facts regardin~g the above matters.
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Pursuant to 10 CFR $2.714(b) the Joint Petition is supole-mented herein with a list of contentions petitioners seek to have litigated in this proceeding.
The Coalition, MSE and Crawdad have already been granted intervenor status in th,is proceeding, and, the re fore, allegations with respect to their standing and interest are not set forth herein.
See Memorandum and order, ASLB, February 5, 1981.
I.
_ STANDING OF KAY DREY Intervenor status should be granted to Kay Drey in this proceeding for several reasons.
First, she has been studying nuclear power for six years and has gained substantial knowledge and a substnntial library of infor-mation regarding the two contentions which Joint Intervenors seek to have litigated herein, (1) the failure of the Applicant's quality assurance program as evidenced by construction defects and the use of substandard materials at Callaway, and (2) the release of radio-active materials into the environment.
See, Affidavit of Kay Drey, attached hereto).
In addition, Mrs. Drey has had communication with at least a dozen present or former Callaway construction workers who would be potential witnesses in this proceeding. (Id.)
Based solely upon the above, the Board has the authority to allow Kay Drey's intervention because of her particular ability "to make a valuable contribution to the development of a sound record."
Public Service Co. of Oklahoma (Black Fo-Station, Units 1& 2), ALAB-397, 5 NRC 1143, 1151 n. 14 (1977);
Tennessee Valley Authority (Watts Bar Nuclear Plant, Units 1 & 2), ALAB-413, 5 NRC 1418, 1422-23 (1977); Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 & 2), CLI-76-27, 4 NRC 610 (1976).
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Furthermore, Mrs. Drey has standing in this proceeding because of the proximity of her residence to the plant--75 miles downwind--
and the fact that she receives all of her drinking water from the Missouri River, which will be contaminated by the radioactive dis-charges from the plant.
(See, Affidavit of Kay Drey). Based upon the information contained in her Affidavit regarding the potential for and consequences of planned and unplanned releases and venting of radioactive materials from the Callaway Plant, the Board snould reconsider its previous determination that a distance of 75 miles is beyond a geographical zone of potential injury for a downwind /down-river resident of a proposed plant, as Kay Drey is.
Finally, Mrs. Drey and members of her family on occasion engage in recreational activities within 10 to 60 miles of the plant.
(See Affidavit of Kay Droy).
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II.
CONTENTIONS OF JOINT INTERVENORS s
The Coalition, MSE, Crawdad and Kay Drey contend that Applicant Union Electric Company ("UE") will be unable to operate the Callaway plant without endangering the health and safety of the public and without adversely affecting the environment.
More specifically, Joint Intervenors' contentions include the following:
CONTENTION NUMBER 1 FAILURE OF THE QUALITY ASSURANCE PROGRAM Surveillance and inspection functions of Applicant Union Electric Company,.and others, including Bechtel Power Corp. (lead architect / engineer), Daniel International Corp. (construction con-tractor) and Code Authorized Nuclear Inspectors, failed to ensure the quality of safety-related material, structures, systems and components through all phases of their fabrication, construction, testing and inspection contrary to the quality assurance criteria of 10 CFR Part 50 Appendix 3.
Many vendor-supplied components were on the. construction site and were approved for installation before code-defined deficiencies and nonconformances were identified.
During construction deficiencies and nonconformances were accepted I
against code rcquirements.
Without effective surveillance and l
l inspection by the Applicant, and others, of material suppliers,
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component vendors, and construction contractors, all safety-related material, structures, systems, and components must be considered i
j of questionable integrity.
Because effective surveillance and inspection were not performed, the safe operation of the Callaway Plant is in j eopardy and should not be licensed.
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Deficiencies and nonconformances include but are not limited to the following:
I.
SUBSTANDARD REINFORCED CONCRETE CONSTRUCTION A.
Embedded Plates Embedded plates, or embeds, so called because they are embedded in concrete, are fixtures installed in concrete walls to support the ends of load-bearing steel beams, piping and other structures. The plates are made of steel with short steel studs welded to one face, like the bristles of a brush.
They are mounted flush with the wall surface, with the studs extending into the concrete.
The exposed surfaces of the plates serve as point of attachment for girders and other structural mem-bers.
If an embedded plate tears loose from a wall, the result could be the collapse of an entire floor, breakage of critical pipes in the primary and emergency core cooling systems, and even core melt-down (Class 9 accident).
When the Callaway Plant was approximately five and one-half to seven percent complete, a stop-work order was issued on June 9, 1977, when it was discovered that some of the studs were not properly l
welded to the embedded plates.
(See NRC Report No. 50-483/77-10,
- p. 8).
Prior to June 9, 1977, 480 -lates had been installed in the plant.
(See NRC Report No.. 50-483/ 80-14, p. 4).
The NRC and the Applicant do not know how many of those 480 plates contain faulty welds, they do not know where those plates are located in the plant, they do not know what loads each plate must bear, and they do not know what the consequences of plate failure would be to the safe operation of the plant and to the health and safety of the public.
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(See, e.g.,
NRC Report No. 50-483/80-14, Attachment A - item 17, pp. 4-5 and Attachment B - item 17, pp. 5-6).
The Applicant and NRC staff do know that after the June 1977 stop-work order, many unused plates had to be repaired (See NRC Report No. 50-483/ 77-10, p. 8) or were returned to the manufacturer.
There is evidence of multiple defects on some plates.
(See NRC Report No. 50-483/80-14, Attachment B,
- p. 3).
Although it is not known whether the manuf acturer inspected the plates before shipping them to Callaway (See NRC REPORT No. 50-493/80-14, Attachment B, i
- p. 2), none of the 480 installed plates were removed and reinspected, and, none were repaired or replaced.
During the process of evaluating the question whether 1e embedded plates presented a safety-significant problem, the Applicant improperly determined, with the NRC's apparent approval, that certain exceptions to structural welding code standards would be tolerated.
(See, e.g.,
NRC Report No. 50-483/80-14, pp. 7-10).
We contend that inadequate and incomplete inspection and testing were performed.
Omissions include the failure to conduct live-load tests and the failure to consider whether defective plates could withstand the effects of an earthquake as per 10 CFR Part 100, Appendix A, Section VI.
B.
Cracks in Concrete There exist several cracks in concrete structures at the Callaway Plant that affect its safe operation.
Examples include, but are not necessarily Ibnited to, the following:
1.
A crack up to 1/4 inch wide was discovered in the Reactor Building in the reactor cavity moat area in May 1977, 6
a month after the concrete mat was poured.
The crack extended approximately 270 degrees around the circumference.
Upon visiting the site in June 1977, an NRC inspector was unable to view repairs performed on this crack because work had progressed to an extent that made physical inspection of the repair impossible. (See, NRC Report No. 58-483/77-06, pp. 20-21).
2.
The NRC was notified by a Callaway plant iron-worker in January 1978 that a lift of the north wall of the Control Building had been poured above a part of the wall which contained a crack approximately 12 feet long and 8 inches deep, and which extended from the inside to the outside of the wall.
(See, NRC Report No. 50-483/78-01, p. 20).
In spite of its size and the existence of additional cracks, the NRC staff decided the crack was "an acceptable crack caused by normal concrete shrinkage."
(See, NRC Report No. 50-483/78-03, p. 3).
C.
Honeycombing Instances of air pockets or voids, known as honeycombing, have been found in concrete structures at the Callaway Plant.
As described in NRC Regulatory Guide 1.55, " Concrete Placement in Category I Structures":
[T]he presence of numerous concrete voids l
which have been detected at or near the sur-faces of nuclear containment buildings raises concern about the density of portions of these and other concrete structures that cannot readily be inspected.
For such unaccessible areas, the only method of assuring a quality con-crete structure is through good planning and control of the placement of concrete and all items embedded in it.
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The instances of honeycombing at Callaway include but ere not limited to:
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Reactor Building Base Mat, On May 31, 1977, voids described by the NRC as up to six inches, but described by a worker as big enough for a man to crawl into, were found in the tendon access gallery of the reactor base mat.
(See, NRC report No. 50-483/77-06, pp. 21-22).
Repairs were undertaken at this time, but during the NRC inspection of August 31 - September 2, a stop-work order was issued because of a discrepancy in work specifications concerning the testing of dry-pack group.
(See NRC Report No. 50-483/77-07, p. 13).
The stop-work order was lifted on December 7, 1977, after the necessary changes in specifications were made (See, NRC Report No. 50-483/78-01, j
pp. 2-3), but no information is available on whether any testing was performed on repairs done prior to the stop-work order.
A report dated August 1, 1977, by Wis s, Janey, Estner and Associated, Inc.,
described a soniscope study performed by this firm to determine the f
possibility of additional honeycombing within the 10 foot thick base slab.
The study states that, " Based upon a 25 per cent sample.
internal honeycomb probably does not occur in the base slab, except at those 19 areas where honeycomb was visible."- (See, NRC Report No. 50-483/77-07, pp. 12-13, emphasis added).
This assessment of probability is the only assurance given that no additional honey-l combing exists.
According. to a letter from James Keppler, Director, Region III, NRC, to Kay Drey dated January 3, 1979, the tendon access t
l gallery represents nineteen percent of the base mat area.
In the l
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same letter Mr. Keppler described the twenty-four large holet which were repaired, as follows:
Large voids are defined as those that require approval prior to repair.
The largest void in this category was approximately 22 square feet in surface area, and it was irregular in shape.
Its maximum depth was 17 inches, and its average depth was 8 inches.
The smallest void in this category was approximately 0.25 square feet in surface area, and its maximum depth was S 1/2 inches.
The size of the re-mainder of the voids in this category varied between thom= previously described.
2.
Reactor Building Dome Four areas of concrete imperfection in the Reactor Building dome were identified by Union Electric personnel during an inspection on August 22 and 27, 1980.
These imperfections were attributed' to "the complex nature of those portions of the dome slab where the imperfections occurred."
However, on December 12, 1980, NRC personnel noticed that blockouts for the tendon grease vents had not been removed to facilitate inspection, and after the removal of the blockouts on December 13, three additional honeycomb areas were found.
After conducting interviews with UE personnel concerning the three new void areas, the NRC concluded that, "There appeared no plausible explanation for their occurrence,,"
and that ".
there was not adequate assurance that the imper-factions' existence were limited to only those areas identified."
(See, NRC Report No.- 50-483/80-30, pp. 3-4).
D.
Concrete Cover There exist many areas where concrete coverage of reinforcing bars in concrete walls and floors at the Callaway Plant does not adhere to requirements.
Bechtel Power Corporation's inter-
, pretation of the cover requirements was that minimum cover require-ments could be reduced by one-third, but the NRC stated in a meeting 9
betwaen NRC, UE, Bechtel, and Daniel International personnel en January 23, 1978, that no reduction of the two-inch cover minimum is acceptable.
However, the NRC indicated that it would be acceptable "if the cover requirements were fully met in the area of the sixth lift, utilizing the fifth lift as a transition area."
(See, NRC Report No. 50-483/77-11, pp. 10-11).
Some examples of nonadherence to concrete cover requirements are as follows:
1.
At 340 degrees azimuth, vertical reinforcement bars and supporting bars for the horizontal tendon sheathing in the 3rd lift of the reactor containment vall had concrete cover "less than that specified by NRC requirements, but within the concrete cover requirements as interpreted by licenses and contractors."
(See, NRC Report No. 50-483/77-11, pp. 4 and 9-11).
2.
NRC inspectors observed the preplacement pre-paration of the fourth lift of the exterior wall of the Reactor Con-tainment Building, finding 14 unacceptable items, in half of which i
concrete cover was less than the 2 inch minimum required or more i
than the 9.6 inch maximum required.
These items include instances where the concrete cover is as small as 5/8 of an inch (at azimuth l
l 210 degrees) and as great as 12 inches (at azimuth 200 degrees).
Some. items were corrected, and the vest were within the range l
judged to be acceptable below the sixth lift because of the one-l third placement tolerance.
(See, NRC Report Nc. 50-483/78-01, I
l pp. 9-11).
II.
SUBSTANDARD PIPING A.
Material Manufacturing Deficiencies 10
Safety-related pipe insta ?. led at Callaway was' manufactured by a company or companies which did not have adequate control of welding parameters.
This resulted in known cases of defects which did not comply with the requirements of the American Society of Mechanical Engineers (ASME) Code.
The evaluation and acceptance of those defects and deficiencies were not done in accor-dance with the ASME Code.
The safety of pipe installed at Callaway remains in question and d #nands further investigation before an operating 11.3nse should be issued.
For example:
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In May 1979 a pipefitter discovered and reported a substandard piece of ASME Class II SA-358 piping which had been installed in the emergency core cooling system.
The pipe was substantially o'ut-of-round, was machined below the minimum wall, and had rejectable weld defects on the inside of a longitudinal seam weld.
(See, NRC Report No. 50-483/80-10).
2.
Substandard fusion welded SA-312 pipe manufactured by Youngstown Welding and Engineering Company and fabri-cated into safety-related pipe spools by Dravo Corporation has been l
installed at the Callaway Plant.
(See, NRC/IE Bulletin 79-03 and 79-03A, and Union Electric letter ULNRC-314 dated May 11, 1979, to i
NRC - Region III).
The evaluation and acceptance of this substan-dard SA-312 piping were not performed according to the requirements of Section III of the ASME Code.
B.
Piping Subassembly Deficiencies Additional evidence of deficiencies in surveillance and inspection functions include the following:
In 1979 it was 11
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discovered that pre-assembly piping formations with defective
- welds from Gulf & Western were accepted and were installed at Callaway.
i After installation it was also discovered that the vendor had used improper radiographic techniques.
(See, SNUPPS letter SLNRC-79-20 of November 29, J,7 9, to NRC - Region I, and Bechtel Final Report of November 28, 1979).
CONTENTION NUMBER 2 INADEQUATE ENVIRONMENTAL PROTECTION FROM RADIOACTIVE RELEASES The Applicant cannot provide reasonable assurance that the L
Callaway Plant will be operated in compliance with applicable environ-mental standards for radiation; in the absence of such assurance the operation of the plant would clearly be unsafe and unlawful.
Environmental Protection Agency environmental standards for the uranium fuel cycle, 40 CFR Part 190, provide in part that planned releases of radioactive materials to the general environment from l
the uranium fuel cycle, including operations of electrical generating facilities, shall not cause an annual dose equivalent in excess of l
25 millirems to the whole body to any member of the public.
-Union Electric Company plans to discharge into the environ-ment, both air and water, certain quantities of radioactive materials as part of the routine operation of the plant.
For
- example, U.E.
estimates it will discharge annually 410 curies of tritium into the Missouri River and 1000 curies of tritium into the air. (See, SNUPPS FSAR Table 11.1-2).
In addition, U.E. estimates i
the annual release of.16 curies of corrosion, activation and fission products into the Missouri River and 2330 curies of noble 12 i
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gases and more than 8 curies of halogens, carbon-14 and other'corro-sion, activation and fission products into the atmosphere.
Id.
Dissolved and entrained noble gases will also be released to the river.
Due to the following circumstances, among others, Intervenors contend that the Applicant cannot assure compliance with the 25 millirem standard.
The Applicant has not adequately assessed and cannot accurately predict the amount or discharge rate of the radioactive pollutants to be released, or. the amount of dilution to be afforded by the Missouri River, which provides drinking water for downstream commun-ities including the City of St. Charles and St. Louis City and County.
Anticipated water diversion projects in the Missouri River watershed and conditions of drought and freezing (ice-jams) would lower the amount of dilution water available and this could raise the concen-tration of radioactive material in the river to higher levels than calculated by U.S.
The Applicant completely ignores the potential impact of its l
radioactive releases on drinking water.
The Applicant's analysis of l
l the liquid pathway dosage includes only fish caught within.05 l
l miles downstream from the discharge pipe and shoreline recreation activities.
(See, FSAR Site Addendum, Table 11.2-4).
Adsorption and absorption of some radionuclides in sediment and the po*.ential resuspension of these materials in the event of dredging or flooding could lead to high levels of contamination.
Because.the Applicant cannot accurately predict radioactive t
l releases it cannot accurately predict the potential bioconcentration l
l of radionuclides in fish.
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Furthermore, Union Electric Co. is unable to predict accu-rately the dispersion of radioactive materials released into the air from the Callaway Plant or the fallout rate of such materials.
We contend there will be inadequate monitoring of the release of tritium, noble gases, alpha emitters and other radio-active materials and particularly when in quantities below the level of detection of commercial monitoring equipment or during accidental releases.
Planned releases of radioactive materials from three nuclear reactors upwind and upstream from the Callaway Plant on the Missouri River may also impact upon the local residents.
Residents of Metropolitan St. Louis may also be affected by gaseous emissions from a uranium' fuel fabrication plant in Hematite, Missouri, 32 miles south of St. Louis.
U.E.'s estimates of annual emissions do not take into account releases from the spent fuel pool, increased releases as the plant gets older and leakier (e.g.,
from steam generator tube deterioration) and releases from decontamination and decommissioning procedures.
In addition, U.E.
does not admit to the potential release of some of the major fission products, e.g.,
cerium-144 and technetium-99, and some of the major activation and corrosion products, such as neptunium-239 and nickel-63.
Unresolved safety issues, such as fuel rod cladding failures and steam generator tube and support plate failures, contribute to the Applicant's inability to assure compliance with the EPA standard.
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Finally, the health effects of low-level radiation, and of tritium in particular, are presently being reassessed by the scientific community.
Evidence suggests that the NRC's Maximum Permissible Concentrations, of 10 CFR part 20 Appendix B, would lead to greater risk to the public than previously assumed.
CONCLUSION On the basis of the above Contentions, Joint Intervenors demand that the operating license for the Callaway Plant (Unit 1) be denied.
Ap Kenneth M.
Chackes CHACKES AND HOARE Attorney for Joint Intervenors 314 N. Broadway St. Louis, Missouri 63102 314/241-7961 I
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