ML20009C649
| ML20009C649 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 07/17/1981 |
| From: | Lynch M, Schwencer A Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20009C648 | List: |
| References | |
| NUDOCS 8107210315 | |
| Download: ML20009C649 (16) | |
Text
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-o NDC STAFF EVALUATION OF THE BAILLY CONSTRUCTION PERMIT EXTENSION REQUEST _
The NRC staff has performed an evaluation of the request by the Northern Indiana Public Service Company (NIPSCO) to extend the latest completion date of the construction oermit (CP) for the Bailly Generating Station, Nuclear-1, from September 1,1979, to December 1,1989.
This evaluation (1) the NRC staff evaluation of good cause for consists of three parts:
failure to complete the Bailly facility by the latest date specified in the CP and a reasonable time for the extension of the CP in accordance with Section 50.55(b) of 10 CFR Part 50; (2) a Negative Declaration recardinq the issuance of an Environmental Impact Statement; and (3) an Environmental Impact Appraisal.
The NRC Proiect Manaaer assioned to the review of NIPSCO's request for David Lynch.
Mr. Lynch may be an extension of the Bailly(CP is Mr. 9 contacted by telephone at 301) 492-6413 or by writing him at:
Mr. navid Lynch Division of Licensing U.S. Nuclear Regulatory Commission Washincton, D.C.
20555 The followino NRC staff members contributed to the three sections of this evaluation:
NRC Staff Evaluation of Good Cause Mr. navid Lynch "ecative Declaration _
Mr. David Lynch Environmental Imoact Acoraisal L. G. Hulman L. M. Bykoski M. David Lynch D107210315 810717 PDR ADOCK 05000367 C
/
t c
NRC STAFF EVALUATION OF THE REQUEST FOR AN EXTENSION OF CONSTRUCTION PERMIT NO. CPPR-104 FOR THE SAILLY GENERATING S,*ATION, NUCLEAR-1 DOCKET NO. 50-367 A.
INTRODUCTION Northern Indiana Public Service Company (NIPSCO or the permittee) is the holder of Construction Permit No. CPPR-104 issued by the Atomic Energy Commission on 1/
May 1,1974, for construction of the Bailly Generating Station, Nuclear 1 (Bailly).-
The plant is presently under construction at the permittee's site located in Porter County, Indiana, about 12 miles east-northeast of Gary, Indiana. In accordance with Section 185 of the Atomic Energy Act of 1954, as amended, 42 U.S.C. Section 2235, and in accordance with Section 50.55(a) of the Nuclear Regulatory Commission's (NRC) regulations, a construction permit (CP) states
-the earliest and latest dates of construction. By letter dated February 7,1979, the penaittee adviseo the NRC staff that construction could not be completed oy the latest date presently specified, namely September 1,1979, and, therefore, requested that the construction permit be extended to September 1,1985. In
, two subsequent letters dated August 31, 1979, and Novemoer 26, 1980, NIPSCO successively amended its estimate of the construction completion date to December 1,1987, and thence to Decemoer 1,1989. In accordance with Section 50.55(b) of 10 CFR Part 50, tne NRC staff, having found good cause shown, and for the reasons stated below, concludes that the latest caapletion date snould be extended as requested to December 1, 1989, pending submittal of acceptable cocifications to tne construction dewatering program.
This evaluation contains the following sections: Section 3, tne NRC staff avaluation of the specification of " good cause" shown by the permittee for "an extension" (i.e., the specific delays which the permittee nas cited in support of its request for an extension); Section C, an NRC staff assessment of tne reasonableness of NIPSCO's estimate of the time to complete the Sailly facilicy; anc Section 0, the NRC staff's conclusion.
Tl
-The cuties of tne Regulatory staff of the Atemic Energy Ccamission were subse-quentlj assumed by ne Nuclear Regulatory Commission in January 1975.
e B.
NRC STAFF EVALUATION OF THE SPECIFIED DELAYS In its letter of February 7,1979, the permittee set forth five factors to which it attributed the delay in completing construction of the Bailly facility beyond Septemoer 1,1979, tne latest canpletion date stated in its constraction permit (CP). Four of these five factors occurred after issuance of the CP. The total delay due to these factors accounts for 57 months; these five factors are dis-cussed in Sections 1 through 5 below.
In its two subsequent letters on this matter, NIPSCO specified certain additional matters wnich delayed the construction of the dailly facility. Basically, these subsequent letters cited the continuing slip in the staff's evaluation of the shorter pile proposal and reflected the actual construction experience of other nuclear power plants.
1.
Assumption Regarding The Issuance Gate of the Construction Permit NIPSCO's estimate iaade in 1973 regarding the issuance date of the Bailly CP assumed that tne Atomic Safety and Licensing Board would issue a f avorable initial decision in December 1973 and that the NRC staff would issue a CP by January 1,1974. The actual coorse of events demonstrated that these assumptions were optimistic. Hovever, it was reasonable to anticipate in 1973 that the CP hearings would end in August of that year based on their start in early April 1973.
Instead, the nearing record did not close until November 1973. The Board issued its favorable initial decision in April 1974.
Normally, the NRC staff would have been required to issue the CP a.vitnin a few days. However, the. Appeal Board ordered a stay in the staff's issuance of the CP which was finally issued on May 1,1974.
Wnile none of these individual delays (e.g., the protracted hearings or the nppeal Soard Ceder staying issuance of the CP) were predictable, the penaittee could have mocified its estimated construction canpletion date as events unfolded. However, tnis.relatively small slip of four months did not lead NIPSCO to alter its original estimate of the construction completion date.
It is the NRC staff's finaing that the original estimate made by NIPSCO in
-1973 tnat tne CP could ce issued by January 1,1974, was reasonaole based on tne CP hearings starting in early April 1973. The NRC staff also finds that the time period between the original date assumed for issuance of the CP (January 1,1974) and the actual issuance (May 1,1974) was the direct consequence of the length of the CP hearings and, accordingly, was beyond the control of tne permittee.
Accoraingly, the IRC staff finds that the first factor stated by tne permittee rapresents good cause for tne delay as cefined in Section 50.55(o) cf 10 CFR Part 50.
2.
Celays Attributable to The Judicial Stay This particular facte,r is cited by NIPSCO in its letter of February 7,1979, for 25 conths of :ne delay in completing the Bailly facility.
Ho wev er,
NIPSCC nas stated at a later-date in reponse to an interrogatory that it enose not to resume construction follo'.dng a decision of the 7th Circ it -
of the U.S. Court of Appeals ( April 13, 1976) denying petitions for review. -2/
This would, therefore, account for an 18 month delay beyond the control of the permittee.
With respect to the time between April 1976 (the Court of Appeals decision) and November 1976 when the U.S. Supreme Court denied petitions for certiorari, we fi.nd it unnecessary to make any judgment as to whetner NIPSCO's delay in resuming construction in the period from April 1976 to November 1976 is attributable to any reason which would constitute good cause inasmuch as NIPSCO made no such claim in its response to the cited interrogatory. The maximum period of time for which we reserve our judgment is seven months.
As discussed in Section 6 of this evaluation, this interval is too short to affect our overall assessment.
Based on the foregoing discussion, we find that an 18 month delay attributable to the court ordered stay of construction was a matter beyond the control of the permittee and represents good cause for the specific delay cited. We make no judgment regarding the following seven month period.
3.
Mobilization of Contractors The permittee also stated in its letter of February 7,1979, that it experienced a two month delay in mobilizing its contractors.
It should be noted that most of the contractors and subcontractors involved in building a nuclear power plant in the first half of the construction pnase, which is predominately heavy construction, are highly specialized, capital intensive companies. Moreover, at all stages in tne construction process, contractors on a nuclear power plant must establish and maintain highly specialized quality assurance / quality control procedures and highly skilled personnel. Under the rules and practice of the NRC, they must comply with the requirements of Appendi 3 to 10 CFR part 50 and are subject to a continuing review process by the Office of Inspection and Enforcement. Accordingly, compared to the total number of contrac-tors and subcontractors in heavy construction, tnere are relatively few who fulfill these requirements and are thus qualiffed to be employed by a utility in constructing a nuclear power plant.
Since NIPSCO was unable to predict with any precision when the court ordered stay of construction would be lif ted, it was unable to schedule the required contractors who could initiate construction immediately following the lif ting of the stay on construction. To have kept specialized, capital intensive contractors "on call" for either an 18 month or a 25 month period attributable to the judicial stay of construction would have resulted in inordinately large economic penalties.
2/ Northern Indiana Public Service Co. response to Porter County Chapter Intervenors' second set of Interrogatories (6/8/81); answer to Interrogatory 1. _
We conclude that the two month interval for NIPSCO to mobilize its con-tractors following the judicial stay was beyond the control of the pemittee
'and that good cause has been shown for this specific delay.
4.
Installation of the Slurry Wall The installation of a slurry wall around the perimeter of the excavation prior to starting excavation of the site was cited by the pemittee as another factor contributing to the delay in completing construction. The installation of the slurry wall was intended to minimize the flow of groundwater through the relatively porous upper layer of unconsolidated sands (i.e., beach sand) into tne excavation from the surrounding area, thereby.ainimizing the drawcown of the adjacent water table. The :aC staff's position when HIPSCO originally proposed to install the slurry wall was that it was a good approach
)
but that it was not required by the IRC. The staff position at this time is that the slurry wall will expedite the early stages of construction and, ac.:ordingly, that the time expended in constructing this wall was time well-spent. Basically, a passive barrier to grounowater flow suppleaented as required by puraps, is inherently more reliable than depending on active components such as pumps. As installed at the Bailly site, the only major q
infiltration experienced through this relatively impenetrable barrier is.in a limited area at the southeast corner of the excavation.
in this corner, the underlying clay layer into wnich the slurry wall is driven apparently thins out to a negligible thickness or is nonexistent, thereby not providing a positive bottom seal at this point. Cn balance, the slurry wall has-accomplished most of its intended function.
l The slurry wall is an improvement over the original i4IPSCO proposal which b
was to perform the construction dewatering using only pumps. This improvement is attributable to the fact that the slurry wall minimi:es the drawcown of the groundwater levels in tne adjacent Indiana Dunes flational Lakeshore.
On this basis, the NRC staff believes that the' peruittee acted responsibly in proposing tnis alternate engineering approach to the matter of construction dewatering. Furthermore, the slurry wall was installed only after this approach was thorougnly ventilated in a hearing and authorized by an, amendment to the CP.
On the basis of the foregoing ciscussion, we conclude that the permittee nas show good cause for the two month celay associated with ir.stallation of the O 'rry wall.
- 6. Review of he Shorter Pile Procosal The final factor cited oy the permittae for its failure to complete tne Sailly facility oy Septemoer 1979 is the time which tne staff took to conouct a review
[
of the shorter pile proposal. The :RC staff review of ilIPSCO's presently proposed anc conditionally accepted program began in Maren 1978 wnen ilIPSCO submitted sufficient information to permit our review to start. Prior to that, I
ilIPSCO had suggested a number cf methods for pile placement in the saaner of ~ 1974 but did not pursue any particular proposal after the matter of the l
CP issuance nad been brought to the federal courts. Following the lifting of the court ordered stay of construction in November 1976, tilPSCO made a one-sentence reference to the use of jetting as part of its pile placement program in a letter submitted in December 1976.
While the September 1977 submittal provided some information on the jetting proposal, the NRC staff felt the need to obtain more data regarding the engineering and environmental aspects of this proposal and, therefore, arranged to observe in late September 1977 the first installation of a pile using jetting as a major feature of the placement program. At that time, and in its subsequent review effort, the NRC staff expressed its concerns that the jetting process proposed by NIPSCO as an integral feature of its pile placement program might adversely affect the 3 situ soil properties of the uncerlying interbedded glacial sands and clays, and might also adversely affect the adjacuat Indiana Dunes National Lakesnore. 31PSCO's position on the matter of adversely affecting the soil properties was that although the jetting process mignt disturb the underlying soil, the suosequent conventional driving prce?ss would redensify the interbedded sands and clays. Existing conventiona! techniques would then be used to recensify the soil near the.
top of the piles. The NRC staff did not accept NIPSCO's ' position on this matter inasmuch as tne soil disturbance would have to be incurred through Jetting of the piles before it could be determined whether conventional pile criving after the jetting process would actually redensify the disturbed soils as claimed by NIPSCO.
Accordingly, lacking any definitive demonstration of nIPSCO's claims, tne NRC staff chose on a conservative basis not to accept the September 1977 proposal for pile placement. This was formally statec in a letter from the,lRC staff to NIPSCO in February 1978. The NRC staff's position was also based on the consideration that the potentially adverse impact on tne' adjacent National Park would be avoided if the proposed method of jetting was not implemented.
The differences between the permittee and the NRC staff views on this particular matter can be cnaracterized as an optimistic technical approacn by.4IPSCO and its consultants and a conservative judgment by the staff and our consultants. This is typical of many sucn divergent technical views of proposals mace oy utilities.
In most, if not all, post-CP case; wnere the NRC staff view prevailed, suosequent delays have occurred in the cesign and construction phases.
The NRC staff finds that NIPSCO acted in good faith in proposing an innovative engineering metnod for pile placement in Septemoer 1977. On this basis, we find that the six monta delay attributable to the review and subsequent rejection oy tne NRC staff of the September 1977 proposal represents good cause for the delay from Septemcer 1977 to :taren 1978.
dIPSCO thereafter succitted what is now called the shorter pile proposal in March 1973. The NRC staff initiated a prompt review of the shorter pile proposal leacing to a meeting in May 1973 in the office; of Sargent & Luncy in Chicago. At this meeting, detailed tecnnical discussions of the March 1973 proposal ensued leading to tne issuance of NRC staff questions seeking additional information. As part of this process, the NRC staff required the pecaittee to conduct an indicator pile program and to submit an evaluation of tnis program as part of its response. Tne final report in response to tnis -
e, e
requirement was submitted by NIPSCO in December 1978.
We find that NIPSCO initiated the indicator pile program in an expeditious manner recognizing toe specialized equipment requireo to drive the indicator piles. We also find that the December 1978 NIPSCO report incorporating all the field experience accumulated in driving the indicator piles was submitted within a reasonable time period.
For tne reasons discussed aNve, we find that the delay attributed to this por-tion of the review process (i.e., from March 1978 to December 1978) represents good cause for celay.
The hRC staff wview of the shortcr pile proposal continued from January 1979 until March 5,1981. The length of this NRC staff review was primarily attribu-table to internal considerations regarding the NRC's various responsibilities rather than to any significant ceficiency in NIPSCO's proposal. Accordingly, we find that permittee had no control over tae length of this NRC staff review and, therefore, we find that good cause exists for tnis period of delay.
6.
Second Mobilization of Contractors In our letter of February 1978, we aavised NIPSCO not to place safety-related piles at the 3ailly site whose design differeo significantly from that described in the CP application until we had reviewed and approved any ucn proposal.
In its letter of November 26, 1980,- NIPSCO asserted that following lifting of tne NRC staff acmonition of February 1978, it needed six montns in which to perform a corporate reassessment and to moeilize its contractors prior.
to initiating tne production phase of placing the snorter piles. 3/
In this instance, we interpret the phrase " mobilize its contractors" to 17iclude the engineering work force at its arenitect/ engineer, Sargent & Lundy, and its pile placement contractor. Lacking any detailed justification for this six month mobilization period, we cannot accept tne full amount of this stated delay, particularly that portion related to a corporate decision-making process.
Recognizing that NIPSCO was able in November 1976 to mobilize its contractors witnin two months following the lifting of the judicial stay of construction, we believe that a, second mobilization of NIPSCO's work force could reasonaoly be accomplished within a period of three to four morths. This leaves about two months of this particular delay for which good cause has not been shown. However our assessment of a reasonable time within which to. complete the Bailly facility is not a precise process (Refer to Section C of this evaluation) whicn can account fe' small, individual construction phases sucn as mobilization of contracte 3.
Moreover, a two contn dif ferential between HIPSCO's estimate of the '.ne to concuct a corporate reassessment and to mobilize its contractors and th. time estimatea by tne NRC staff for the secona mooilization of contractors 3/Tince we stated our acceptance of tne shorter pile proposal in our letter dated March 5,1981, construction of the Bailly facility could be expected to resume in early September 1981.
o
's too small when conpared to the 107 month tota! tonstruction time estimated i
oy IIIPSCO, co be of significance in our overall assessment of either good cause or of a reasonable time to complete construction of the Bailly facility. 4/
On the basis of the foregoing discussion, we find good cause for the delay incurred in mobilizing NIPSCO's contractors a second time.
Summary of Delays in Comoletinc the Bailly Facility The delays in-completing construction at the Bailly facility by the latest date specified in the CP resulting from the causative factors discussed in Sections 1 through 5 are summarized in Table 1.
Of the total 68 month construction period estimated.Dy the pennittee in 1973 in arriving at its estimated construc-tion completion date, 50 months were lost due to factors which we find represent good cause. Accordingly, we find that the permittee has identified in its letter of February 7,1979, factors which represent good cause for the delay in cotpleting construction of the Sailly facility within the time period (i.e.,
f' rom May 1974 to September 1979) specified in the Bailly CP.
The permittee has also identified in its letters of August 31,19/9, and November 26, 1980, additional factors which we find represent good cause for the delay in c:apleting construction of the Bailly facility in the time period froa Septe. ber 1979 until September 1981.
In the follovnng section, we evaluate whether MIPSCO has specified a reason-able time within which to caaplete the Sailly facility.
4/
-In its letter of Hovemoer 25, 1930, MIPSCO estimated that it would need a total Of 107 months, including an allowance for uncertainties, to complete tne bailly facility following the lifting of the NRC staff's holc imposed in February 1973.
7 4
s TABLE 1 CHRON0 LOGY OF MAJCR MILESTONES DURING THE TENURE OF THE SAILLY CP (1by 1,1974 to :eptember 1,1979)
TIME INTERVAL cELAY DATE EVENT (months)
(months)
C0t@ENT
~
JAN 1974 HIPSCO estimate for CP issuance 4
4*
Protracted hearings MAY 1974 CP issuance 5
none
~
~
- 0CT 1974 Lourt ordered stay 18 18 U.S. Court of Appeals APRIL 1976 Denial of petitions.
U.S. Court of Appeals 7
NOV.1976' Denial of certiorari 2
2 Mobilize contractors
-JAd 1977 Start slurry wall 2
2 Construct slurry wall MAR'1977' Complete wall 6
ncne SEP. 1977 Jetting proposed by NIPSCO 5
5 Review of pile place-ment using jetting-FE3 1978 NRC letter rejecting pile placenent using jetting 1
1 XAR 1973 Snorter piles proposed 9
9' Raview of shorter pile program CdC1973
' HIPSCO suamits final report 3
3 Staff review-MR 1979 :
' TAI accident-
.6 6
Ad hoc reorganization of HRR P
SEP 1979 Latest CP conpletion.
Totals including Pre-CP factors 63 50
'Uelay incurrec prior -to CP issuance
- "No jucgenent made regarding good'cause
s
^w a
C.
[EASONASLENESS OF NIPSCO'S ESTIMATE OF THE TIE TO C0ffLETE THE BAILLY FACILITY
- n ab:ordance with Section.50.55 (b) of our regulations, the Comission 'will extend the.campletion date of a CP for a reasonable period of time upon a tiowing of. good cause.
The previous section addressed the matter of good cause. This sectic:
presents the rRC staff evaluation of a reasonable time for the extension of i.he
. Sailly CP.
In NIPSCO's letter.of February 7,1979, the permittee stated that it concluded, based on the construction experience of other' utilities buildinc nuclear power plants, that the time to complete the Bailly facility would be longer than the 68 months estimate it :aade' in.1973. This longer construction period was attributed by NIPSCO
,to the additional engineering effort required to complete the final design due to mere numerous and detailed regulatory guides. NIPSCO estimated in this letter that
= cased on its observations, a construction period of 80 months was required from initial ground breaking to fuel loading. Although we do not share NIPSCO's views on the particular cause of lengthier. construction, we agree that experience indicates that 68 months from issuance of a CP to completion of construction was optimistic.
We also consider HIPSCO's February 7,1979, estimate of $0 months to have been optimistic, an opinion wnich NIPSCO came to share, as indicited in its letters of August 1979 and Govember 1980.
Based on its further evaluation of construction experience with respect to schedules and other factors, NIPSCO submitted on August 31, 1979, a revision of its previously estimatec construction completion date. Basically, NIPSCO reevaluated its estimate of the construction period for the Bailly facility based on an NRC.
staff study entitled, "lRC Caseload',- Planning Projections for Fiscal Years 1981-85,"
Maren - 1979. This HRC study presented a relationsnip between the percentage of
. co.apleted construction ana the construction time elapsea since placement of t.'e first structural concrete (typically, the reactor builaing base mat).
This rel e e
tionship establisned three types -of plant construction schedules; i.e., those facil-ities built faster tnan the median, a median construction pace and facilities 511 more slowly than the median. Based on a sample of 18 piants completed in Ge time frame of 1977 througn 1978, the construction period estimated by thc NRC staff from first structural concrete to fuel loading is 65 montns for an "early"
- plant, 77 months for a median plant and 37 months for a " late" plant. These values
~
were considered in early 1979 to be representative of industry averages. A plot of the ' construction curves representing these three schecular modes is 'shown in Figt.re l. Tne corresponaing intervals from ground breaking to first concrete are 5,10, and -15 montns for tne "early", median and " late" mocels, respectively.
In its -letter of August 31, 1979, NIPSCO estimated the conscruction period from first concrete to fuel loading as 74 months ana from beginning of pile placement to first concrete as 9 months. NIPSCO then included an additional 15 months in
'its. estimated construction time to account for various uncertainties.
The result-ing total construction perica was estimated to be 93 ~ months. Starting in October 1379, tnis yielded the permittee's estimate of Decencer 1,1937, as tne construction
.ccmpletion aate.
~~-
Due to' delays in the NRC staff's review of the shorter pile proposal, NIPSCO amenced 1ts estimate.1 construction completion date from December 1987 to December 1989 in its letter dated l4ovember 26, 1980.
This latest NIPSCO estimate was based on:
(1) completion of the NRC staff review on the shorter pile proposal by Janua5 !?81; (2) a six month period to mobilize its major contractors following completion of Item (1); (3) pile placement in nine months; (4) a 74 month construction period from first structural concrete; and (5) an 18 month uncertainty allowance added to Item (4) to provide conservatism in its estimate. The significant differences between NIPSCO's August 1979 and i4ovenber 1980 estimates were the addition of the six montn mobilization period and the addition of three more months to the uncertainty estimate.
The hRC staff has made an independent assessment of the time it will most probably take NIPSCO to complete ccnstruction of the Bailly facility. We nave evaluatad tne construction progress of plants similar to Bailly for wnich CP's were issued in tne same time frame (late 1972 through mid-1974) and for wnicn construction is now expected to be completed in the early 1980's. Table 2 lists seven facilities (not counting the Bailly facility) which like dailly have boiling water reactors (BWR's) and Mark II containments.
We have focused on the construction experience of Zimmer, Wi4P-2, Shoreham, LaSalle-1 and Susquehanna-1 since these five facilities are sufficiently close to completion to provide a reasonably firm estimate of the duration of construction for the Bailly facility. Start of construction for tnese plants ranged from June 1971 througn November 1973 and the most likely comple-tion for these facilities is September 1981 through September 1983. The Limerick-1 and Nine Mile Point-2 f acilities were not considered in this assessment since they are still four to five years from completion.
The time from issuance of the CP to the construction completion date for these selected facilities estimated oy the NRC staff varies from a low of 96 months (LaSalle-1) to a nigh of 126 months (WhP-2). These construction periocs are sornewnat misleacing,-however, since some of the five selected facilities initiated limited construction activities prior to issuance of the CP.
This was possiole in the time fram under consideration ti.e.,1971 througn 1973) since tne tnen Atomic Energy Commission granted exemptions for a number of facilities to allow site preparation and excavation to take place prior to issuance of a CP. The construction time estimated by the ARC staff ranges from 95 renths (LaSalle-1) to 134 months (Zimer and WNP-2).
In early 1975, the Advisory Committee on Reactor Safeguarcs ( ACRS) and the iiRC staff icentified a significant new concern for a sp:cific type of containment; i.e.,
hydrodynamic loads imposed on the structures and components of BWR's with vapor suppression containments. These are tne General Electric Mark I, Mark II and Mark III containment designs. The basic concern of the ACRS and tne NRC staff in early 1975 was that the pool dynamic loads mignt ce significantly higher than the design casis loacs ahich were then being used. After extensiva analytical and ex;erimental investigations, tne NRC staff estaolisned a rec,uirement in late 1973 that utilities building SWR's using Mark II containments adopt a bounding set of cool dynamic ioads whicn are significantly higher than those previously used.
These larger, conservative bounding loads led to a redesign by the affected utilities of those structures anc comoonents subject to these bounding loads resulting in a delay
_. ~
-IAh!L 2
[511MAIID CON 51RUCillW PER1005 Of MARK 11 SWR'S IMO[R CON 51RUCTitm e
DALE Ol' CP.
SIARI 0F CONSIRUCIION COMPIIll0N CONSTPUCTION PERIOD (M05.)**
CP ISSilANCC 00HSIRUC110N PIRilliitC SI Al f BASEL OA CF tem
'--8ASED~ N AC1UAl STARI IAttillY lin in r utR-mt 10/12 06/11 11/88 (3/82 118 1 34 uuP '- 2 CitR-93 03/13 06/12 09/84 09/83 126 1 34
%wehani
-CPPR-95 04/13
~11/12 05/82-09/82 113 118 e
I.aSalle - 1 CPPR-99 09/13 10/13 09/81 09/81 95 5uuluchanna - I CPPR-lui 11/13 11/13 04/82 04/82 101 101 Itailly CPPR-104 05/14
't I inserid - l CPPR-106 06/14 08/10 01/84 03/85 129 Nine Mile Pt. - 2 CPI'R-l l?
06/14 06/15 03/86 03/86 141 When unaltiple units 'are under (onstruction, only the first unit is listed Based on the NRC staff's estiukstes l
4 1
in completing the five facilities cited above by a period we estimate to be 12 to 24 months.
Additionally, the accident at TMI in Maren 1979 resulted in a delay in construction as did other factors including enhanced NRC staff requirements for the environmental qualification of equipment, fire orotection and security and safeguards measures. The delays resulting from the use of larger pool dynamic loads, the impact of the accident at TMI and the other cited factors are not necessarily additive. We estimate a nominal combined delay of about 24 conths for all these factors.
Subtracting 24 months from the NRC staff's estimated 95 months to complete LaSalle-1 to account for the delays resulting from both the impact of the THI accident and the larger pool dynamic loads indicates that the plant mignt have been ouilt in 71 months. This is in close agreement with a 70 month construction period that is predicted by the early 1979 ilRC model for a plant being built faster than average (5 montns from initial ground breaking to first concrete and 65 months from there to completion). Figure 1 illustrates this in that LaSalle-1 followed tne "early" plant model for 20 months after first concrete. The time unen the construction schedule of LaSalle-1 diverged from the "early" schedule corresponas to early 1976 wnen the NRC staff concerns regarding tne pool dynamic loads caused those utilities building SWR's to redesign and reinforce the basic structures and components of the reactor cuildings. Following this, LaSalle-1 tracked tne mecian construction schedule of the 1979 flRC model. The apparent slowdown in LaSalle-1 during tne last 13 montns of construction is most likely attributable to the impact of the TMI requirements now being implementec on all plants coth under construction and in operation.
A similar reasoning process applied to the WNP-2 facility incicates that the plant
.aignt nave been built in 110 months (134 less 24) while tne " lace" model of the 1979 MRC methodology would predict 102 montns (15 months from ground breaking to first concrete plus 87 montns from there to completion). Figure 1 supports this reasoning process since the %P-2 facility closely tracked tne " late" construction schedule for aoout the first five years of its constr'.ction.
It should be noted that Commonwealth Edison has succafully built and operated a numcer of plants prior to starting construction cf La: alle-1 unereas the Wasning cn Puolic Power Supply System (WHP-2) has yet to c1...plete its fir,t facility.
The construction schecules of :nese facilities appear to correlate with the relative experience of their permittees in building nuclear power plants.
We concluce, then, that the longer schedules presently being experienced in con-structing LR f acilities using Mark II vapor suppression containment designs reflect the acverse impact of two separate matters (the TMI accident and :ne larger pool cynamic loads).,hicn snould not adversely affect a similar plant sucn as tne dailly facility, starting construction now.
On :nis casi., we conclude tha: the models developed by the :4RC in 1979 to estimate construction scnedules are still valid. We further conclude that a utility wnicn 1s exoerienced in ouilding and operating nuclear power plants can be reasonably expectec to build a plant f aster than the necian senedule wnile a utility without prior nuclear power plant construc-tien experience such as ilIPSCO, can be reasonably expected to complete construction of the dailly facility on a scnecule si:,iilar to that cf the LP-2 and Zimer facilities (i.e., the 1979 iRC " late" model.)
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dita respect to WIPSCO'S estimate of nine conths to drive the safety-related piles, we find tnis time int 7tval to ce coth reasonable and prudently conservative.
On tne casis of tne foregoing discussion, the.EC staff position is that NIPSCO snould be acle to ccmplete the 3ailly facility witnin acout a 96 monta period from re-sumption of construction (9 conths from start of pile placement to first structu-ral concreta plus a7 montns from there to conpletion). Se 74 montns whien NIPSCO estimates from first structural concrete to completion plus its uncertainty estimate of 16 months ' adds up to 92 months to complete tne Bailly facility after pile placement.
mis 92 renth construction perioo astimated by NIPSCO is not significantly different from tre d7 month periou precicted by tne 1979 NRC construction schedule models.
Inasatcn as tne !EC construction schedule " late" model reflects cata for nuclear poser plants of all types (i.e., Bia's and P.iR's) and since the statistically cerived model yields estimates wnich are not significantly different from NIPSCO's estimate, we consider tne permittee's estimate of 92 rcnths for tne total construction period to ce both reasonaole anu prudently conservative. Se two month differential cetween tne time wnen HIPSCO assumed the NRC would issue a favoracle evaluation of tne snorter pile propsal (January 1931) and the actual issuance (:1aren 1981) can ce readily accor.vodatea within MIPSCO's is contn period for uncertainties..doreover, tne relatively wide spread in taa time to construct a nuclear power plant predicted oy tne 1979 JAC statistical models (70 rentns to 102 rcntas) and the 18 month uncertainty estimated oy NIPSCO botn illustrate that tne construe:. ion period of a nuclear ;cver plant cannot ce predicted in a precise manner. Accordingly, we find tnat NIP 3CO's estimated conoletion date of Cecemoer 1,1939, is reasonable.
D.
CCJCLUSICH for tne reasons stated nerein, the JRC staff concludes tnat good cause has seen snown for extencing tne latast construction cc:pletion date for construction of tne Sailly Generating Station, Nuclear-1, Construction Permit No. CPPR-104, to Ceca:cer 1,1969, and, accordingly, tne NIPSCO recuest-snould ce granted after JI?3C0 sucaits acceptable modifications to its monitoring and mitigation program for construction dewatering.
(Pafer to our D}v ntal 2 pact isal.)
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M. Cavid Lynch, Project danager Licensing 3ranen Jo. 2 Division of Licensing hgv
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A. Schwencer, Chief Licensing Branen uo. 2 Division of Licensing Cated : July 17,1331 -
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NEGATIVE DECLARATIOd SUPPORTIGG THE E(TENSICN OF IME C(PIRATICN DATE FOR CCUSTRCCTIOd PERIIIT NO. CPPR-104 BAILLY GENERATING STATI0d, WCLEAR-1 IC C ET No. 50-367 The U.S. duclear segulatory Cor: mission (the Cor: mission) has reviewed tne dorthern Indiana Eublic Sarvice Company (NIP 3C0 or permittee) requests dated Fectuary 7, August 31, 1979, and November 26, 1980, to extend the expiration date of the construction permit for the dailly Generating Station, Nuclear-1 (CPPR-104) wnica is located near Gary in Porter County, Indiana, ne permittee in its.rost recent letter of.evember 26, 1930, requested an extension of the permit to Decemoer 1, 1989, as a reasonacle period for cccpletion of construction of the sailly facility, including an allowance for contingencies.
2e Corr.cission's Division of Licensing (tne GRC staff) has prepared an environmental mpact appraisal relative to this amendment to CP?n-104. Based upon this apprai-sal, tne MRC staff nas concluced tnat an environmental impact statement for this particular action is not warranted. 'Ihis decision was made pursuant to tne Cor.nis-sion's regulations in 10 CFR Part 51. Specifically, the Oct: mission nas determined tnat tais enange to the construction permit (extending tne latest date of construction completion) is not a major federal action significantly affecting ene quality of tne nr.an environment.
ae environmental impact aopraisal is available for puolic inspection at the Cc:=ission's Puolic Document Rocm,1717 d Street, N.J.,.;ashington, D.C.
20555 and at the aest Chester Townenip Puolic Liccary,125 So. 2nd 5treet, Cnesterton, Indiana 4o304.
Dated at 3etnesca, Aaryland, tais day of 1381.
FCR THE NUCLEAR REGUIATCRY CC(MI53ICN A. Senwencer, Chlef Licensing 3ranen No. 2 Division of Licensing I