ML20010J299
| ML20010J299 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/21/1981 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | Beechhoefer C, Eva Hill, John Lamb Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8109300277 | |
| Download: ML20010J299 (5) | |
Text
September 21, 1981 N,Q
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Charles Bechhoefer, E squire Chairman Q
I-E Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commissio ff 8
Washington, D.C.
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h 'e Dr. James C.
Lamb q
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[q 313 Woodhaven Road SEP2 41981 a q Chapel Hill, North Carolina 27514 4/jgp r p4f7 Ernest E. Hill Lawrence Livermore Laboratory Eryh g
University of California P.
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Box 808, L-46
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Livernmore, California 94550 RE: Houston Lighting and Power Co. ( Scu th Texas Project, Unites 1 and 2) Docket Nos. 50-498 and 50-499 Gentlemen:
On September 18, 1981, in the above referenced proceedings, the Board set forth eleven questions regarding Citizens for Equitable Utilities Motion to File Additional Contentions Based on New Informa tion and to Establish Discovery and Hearing Schedule with Respect to the a
New Contentions.
Citizens Concer,/ned About Nuclear Power, Inc. hereby submits the following response corresponding in number to the Board questions.
- 1. Apparently number 1 is only a request for responses from all parties except CEU with no specific response required.
2.
The question of HL&P's compliance with all NRC reporting requirements regarding the American Bridge steil defects is really two questions. Firse, did HL&P notify the NRC. about the defects. CCANP believes HL&P did no tify the NRC in a report pursuant to 10 CPR 50 55 but the only such report reviewed by CCANP to date is so vague it is hard to tell whether the full extent of the American Bridge problem was indeed reported. The second question is whether HL&P notified the NRC in a timely fashion as required under 10 55 CCANP believes this question is still open, depending on the date the problem was discovered and the da te the problem was reported. Discovery is necessary to r'ea ch an ultima te determina tion on both questions.
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Members of the Board September 21, 1981 Page 2
- 3. CCANP believes the NRC knew of the American Bridge problem prior to the submission of newspaper articles by CEU. C CANP, however, notes tha t when Mrs. Peggy Buchorn of CEU went to Arlington, Texa s and a sked Deputy Director John Collins for all correspondence on the American Bridge incident a s of la te August or early September, Mr. Collins denied any knowledge of any such correspondence and denied knowledge of the events themselves. The precise details of HL&P/
NRC communication on this Quality Control breakdown awaits the discovery process.
- 4. Whether HL&P and Brown and Root allowed use of defective structural steel in STNP is really three questions. The first is how the welding codes are interpreted when deciding steel is defective. At one time, according to the newspaper repo rts, B&R QC inspectors were rejecting 90% of the steel beams.
B&R then changed the procedures for inspection and the reject rate dropped to 6%.
The second guestion is whether the inspection of the steel not installed reveals a level of defects sufficient to conclude the installed steel clso has defects.
The third question is whether production of the steel was carried out in a uniform manner such tha t the level of defects in the steel no t installed is an adequate indicator of the level of defects in the installed steel. CCANP is informed tha t 3 ate 11e' Corpora tion is doing an engineering analysis on the steel to estimate the level of defects in the installed steel.
A gain, full discovery is the ouit means for CCANP to a sses s this questi on.
- 5. The precise location of the steel in another matter for discovery. CCANP is informed that m2 ch steel is installed in safety related structures.
- 6. This question calls for a conclusion which CCANP cannot reach until full discovery is held. Of importance to/ CCANP, however, is a proper perception of this question a s really two que s tio ns. The octual defects and their safety impact raise ono question, i.e.
the potential public health or sa fe ty threat raised in the Board question. At the same time,-there is a generic question which CCANP would formula te a s follows: Does the Imerican Bridge event indicate an unacceptable breakdown l
in the vendor surveillance program, an unacceptable breakdown in on-site inspection processes, inappropriate changes in quality control procedures once the problem was discovered, and inappropriate management responses complaints from quality control inspectors?
to
j Members of the Board September 21, 196 Pa ce Three
- 7. CCANP believes that definitive answers can be given to the previous three questions through a co mbina tion of discovery conducted by intervenors and an investigation by the NRC. By letter of September 2, 1981, CCANP requested the Arlington, Texas office of the NRC to inve stiga t e the American Bridge question and included in that letter seven specific questions CCANP hoped the NRC investiga tion could answe r.
These questions are in some instances similar to the questions posed by this Board on September 18.
- 8. CCANP is not certain tha t HL&P did issue a press release on this problem. CCANP believes that calls to reporters from intervenor representatives produced the newspaper articles submitted by CEU.
- 9. CCANP participated in the initial investigation of the American Bridge breakdown and continues to be inter-ested in the questions raised by these events. Further-more, since its formation in 1978, CCANP has been interested in all questions about STNP that raise doubts about the quality of work at STNP. The contentions forming the original core of this expedited proceeding were initially raised primarily by CCANP. As a party to these proceeding s, CCANP is vito11y interested in all such issues and intends to participate fully and, hopefully, without Board obstruction in their resolution. OCANP perceives the que stion raised by the Board, or at least by one of the Board members, as implacitly co nta ining the suggestion that CCANP should be limited in its involvement in the American Bridge question. As a full party, CCANP sees no justifica tion for any diminution of CCANP's role in addressing this question.
Since CCANP also perceives this problem to be primarily a problemi of managerial character and technical competence, particularly in the area of quality control, the full participation of the intervenor who raised this contention in the fir s t pla c e is certainly mandated.
- 10. CCANP joins in sponsoring the contentions.
l
- 11. HL&P is the construction permit holder and license applicant. As such HL&P is responsible for the manner in which STNP is constructed. But Brown and Root is clearly responsible for actually carrying out the bulk of work, including th e QC func tions. At Comanche Peak, Brown and Rott failed to adequa tely exercise its function of vendor surveillance. In particular, the welding done l
Members of the Board September 21, 1981 Page Four i
for Comanche Peak by a subcontractor to Brown and Root wa s deficient, and Brown and Root failed to detect these deficiencies. The same failure appears to have occurred in the American Bridge breakdown. There is the possibility that the same personnel at sc level were involved in both breakdowns. If Brown and..oot is not technically competent to build a nuclear power plant, then HL&P is responsible for knowing that fact and taking appropria te action. A failure on HL&P's part to discern Brown and Root's failures and/or a fa ilure on HL&P's part to adequately address Brown and Root failures reflects on HL&P's managerial character, j
While CCANP ha s med s a response to the questions presented by the Board, CCANP expresses its concern that in its questions the Board is going well beyond the level of inquiry and certainly beyond the limits on findings of fact and merits normally considered in a decision on admitting new contentions. In fa c t, CCANP would view a decision by the Board no t to admit the contentions af ter reviewing the answers of all parties to these questions as clear error.
For CCANP,
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b Lanny Alan Sinkin 2207 D Nueces Austin, Texas 78705 i
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING AND POWER CO.
(
Docket Nos. 50-498 (South Texas Project, Units 1
)
50-499 and 2)
(
CERTIFICATE OF SERVICE I hereby certify that the September 21, 198'. letter to the Mec.bers of the Board wer e uailed first cla ss postage prepaid to the following:
Charles Bechhoeffer, Esquire Atomic Safety and Chairman Licensing Appeal Board U.S.
Nuclear Regulatory Commission U.
S.
NRC Wa shing to n,
D.C.
20555 Washington, D.C.
20555 Dr. James C-Lamb, III Atomic Safety and 313 Woodhaven Road Licensing Board Chapel Hill, North Carolina 27514 U.
S.
NRC Washington, D.C.
20555 Mr. Ernest Hill Lawrence Liv ermore Labora tory Docketing and Service University of California Section P.
O.
Box 808, L-123 Office of the Secretary Livermore Ca lifo rnia 94550 U.S.
NRC Washington, D.C.
20555 Jack Newman, Esquire Lowenstein, Axelrad, et al 1025 Connecticut Ave.,
N.W.
Weshington, D.C.
20036 hjffiw jorA Brian Berwick, Esq.
h(ve k 55 Assistant Attorney General 1727 [ bY"J g'Q' Environmental Pro teMion d(,^)g g,C, 2.000(
Division P.
O.
Box 12548, Cepitol Station i
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Pat Coy
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5106 Casa Oro Doe::rma 3
San Antonio, Texa s 78223 WNna
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@t SEP 3 4198t'.
T4 Jay Gutierrez, Esq.
3][ $,Q,y"y,7 Office of the Executive Legal g
i Director
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8 U.
S.
Nuclear Regulatory Commission I
Washington, D.C.
20555 Lanny[Sinkin
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