ML20072P958
| ML20072P958 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/29/1983 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8304040428 | |
| Download: ML20072P958 (4) | |
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UNITED STATES OF AMERICA
'83 iM 31 P1 :27 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD n;,,5 r n M.CH In the Matter of HOUSTON LIGHTING AND POWER Docket Nos. 50-498 OL COMPANY, ET AL.
50-499 OL (South,_ Texas Project, Units 1 and 2)
CORRECTIONS TO CITIZENS CONCERNED ABOUT NUCLEAR POWER (CCANP)
MOTION FOR NEW CONTENTION On March 22, 1983, Citizens Concerned About Nuclear Power (OCANP) filed its Citizens Concerned About Nuclear Power (CCANP) Motion for New Contention.
Unfortunatey, there were two errors in that motion. This filing is to correct those errors.
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On page six, the fourth. full paragraph should
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read " Exhibit 2 a t 33-34," not " Exhibit 2 at 31."
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Pages 33 and 34 of the hearing examiner's report k
are a ttached hereto as Attachment 1.
On page seven, the fourth full paragraph should read " Exhibit 2 at 37," not Exhibit 2 at 31."
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[E Respectfully submitted,
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D Lenny/Sinkin Counsel for Intervenor
,{5 E
Citizens Concerned About h
Nuclear Power, Inc.
f.g 2207 D Nueces Austin, Texas 78705
[;i (512) 478-3290 5.?
Dated: March 29, 1983
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8304040428 830329 E
PDR ADDCK 05000490 O
PDR H
ATTA!DfENT 1 Docket N2. 4540 Paga 33 laid at mar q-ent's door step, the time for NL&P to "put-up or shut-up" has arrived; i
Dow feels we now have a " final, final honest-to-gosh" dollar estimate on STP, and a
' fire estimate for time of completion, and concludes that HL&P needs to IN monitored more closely, that the Commission should improve its regulatory control over contruction of these massive units, and that any more delays or cost overruns should be assessed against the stockholders.
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HL&P ML&P focused its primary defense in this issue on the lack of management or engineering expertise of Ms. Blaenthal.
ML&P's position that discussion of poor management practices can be undertaken only by one with an academic degree in maNment or engineering, and extensive management experience, should be rejected. It does not require an expert in the area of management to conclude from the evidence in this case, (which consisted of government and in-house documents outlining problems. at the project in plain, understandable language, and Dr. Goldberg's candid testimony at
' deposition, also in plain English) that, indeed, HL&P cannot escape from all blame i
associated with this project.
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Discussion e
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h Because HL&P attacked Ms. Blumenthal's credentials, and because many of the doceents concerning STP were adnitted into the record with little or no discussion j
about their contents, (to the examiner's dismay) the examiner has attempted as thorough h
a review of them as possible within the time allowed. The following is a discussion of f
problems at STP which indisputably appear in the record.
k Evidence shows that data existed in 1973 indicating that the 55 month construction schedule promised by B&R (a firm with no prior experience in engineering design for j
nuclear plants) was optimistic then, and increasingly so as time went on.
Available g
information which indicated that 55 months might be unreasonable was contained in the g
Nuclear Regulatory Corsnission (NRC) " Yellow Book' NUREG-0030, which is a compilation of l
statistical data which profiles construction durations of nuclear plants in general and h
is available to all utilities.
Prior to 1970, the Yellow Book showed construction k
81 durations of approximately 46 months; in 1971, 52.9 months. For the years 1972 and
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1973, the months of duration skyrocket to approximately 59.9 to 70.1.
Again, in 1974, the duration period for larger units is 75.9 months; in 1975, 68.6.
In 1976 the duration for 1000 MW units and larger rose to 92.6 months. The year 1977 shows 67.8 months and 1978 approximately 87.7 months.
Gibbs and Hill, Inc., which authored a j
" Performance Evaluation" of the project, dated April 1980, stated:
fire In sumary, there were clear indications during the period 1973 to 1978,
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from available information on completed projects, contemporary projects reid Q
other projects under construction trat pointed to a need to reevaluate the B
(STP) schedule.
However, there appears to have been no attempt to f actor E
into the (STP) management and decision process this industry data, even y
though much was available. (Final draft, p. 44)
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Docket 4. 4540 Page 34 The evidence also shows that the magnitude by' which this project was growing was not appreciated by HL&P.
The Gibbs - Hill study shows that by 1976 most bulk quantities and manhours for construction had increased over 50 percent.
0 However, the schedule was not analyzed to determine the realism of maintaining the original fuel leading dates.
Gibbs - Hill also comented on the absence of prior nuclear project experience on this project:
The lack of identification of cause or effect for over 4,000,000 manhours of increases on STPEGS (STP) can be attributed, in our opinion the absense of prior nuclear project experience and the la,ckprimarily to 1
of project control systems sophisticated anot.gh to monitor progress and successfully anticipate current and future problems on a project of such size and complexity. (Final report, p. 44)
In fact, HL&P's Dr. Goldberg stated:
I hadn't found too many people that I would have had that confidence that they would have realized it (problems with S&R) sooner.
HL&P's staff, which had remarkable basic technical qualifications, a lot of fellows with post-graduate degrees, unfortunately, 'had very litle prior design experience. (Deposition, Cities Ex. 2, p. 60)
In summary, the most conservative statement which can be made concerning HL&P's management of this project is that the overall plant operation, (until the recent past), was definitely not integrated by the strong hand of an overall project managsr in total control of the project.
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Possible Regulatory Treatment of STP HL&P refers to Ms. Blumenthal's suggestions for treatment of STP as " draconian."
However, Ms. Blumenthal's suggestions might be considered very moderate in light of alternative regulatory treatment which might be recomended if mismanagement i
is found to exist.
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l For example, a penalty on return could be imposed similar to that adopted in l
Docket No. 3094, General Telechene Comoany of the Southwest, (June S.
1980).
Management itself could be penalized by refusing raises in officers' salary levels in cost of service.
See, e.g. Docket No. E-2, Application of Carolina Power and Light Comoany, (September 24, 1982). In this case. CPL was also penalized by a decrease of l
one percent on return on equity capital because of poor management of already existing nuclear plants.
However, the Commission s.taff conducted a four month on-site 3
{
evaluation of project management and intervenors also contributed substantial independent evaluation of CPL management of the plants in question.
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Another regulatory alternative is an incentive / penalty progras similar to that L
adopted by the New York Public Service Comission in Case 28059 Inouiry. Nine Mile Point No. 2 Nuclear Station, (April 16, 1982). In that case, the Comission adopted
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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Dy:n.g.
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
INS 31 p7,.y REBIIEIG8IE DE SEBy1GE I hereby certify that~ copies of CORRECTIONS TO
-CITIZENSCONCERNEDABOUTNUCLEARPOWER(CCANP)'it.;".h"....
9 5
TPf
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MOTION FOR NEW CONTENTION was served by deposit thC the United States Mail, first cla ss postage paid to the following individuals and entities on the 29th day of March-1983 1
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0 Charles Bechhoefer, Esq.
William S. Jordan, Esq.
j Chief Administrative Judge Harmon and W'eiss Atomic Safety and Licensing 1725 I Street, NW Board Panel Suite 506 U. S. Nuclear Regulatory Commission Washington, D.C. 20006 Washington, D.C. 20555 Jack R. Newman, Esq.
Dr. James C. Lamb, III Lowenstein, Newman, Reis &
Administrative Judge Axelrad 313 Woodhaven Road 1025 Connecticut Avenue, NW Chapel Hill, NC 27514 Washington, D.C. 20036 Ernest E. Hill Robert G. Perlis '
Administrative Judge office of the Executive Lawrence Livermore Laboratory Legal Director University of California U.S. Nuclear Regulatory Commission P. O. Box 808, L-123 Washington, D.C.
20555 Livermore, CA 94550 Mrs. Peggy Buchorn Atomic Safety and Licensing Board Executive Director U. S. Nuclear Regulatory Comm.
Citizens for Equitable Washington, D.C. 10555 Utilities Route 1, Box 1684 Atomic Safety and Licensing Brazoria, Texas 77411 Appeal Board l
U. S. Nuclear Regul atory Comm.
t Brian Berwick, Esq.
Washington, D.C. 20555 Assistant Attorney General for the State of Texas Docketing and Service Section Environmental Protection Office of the Secretary Division U. S. Nuclear Regulatory Comm.
P.O. Box 12548 Capitol Station Washington, D.C.
20555 l
Tom Hudson, Esquire dA*any Baker and Botts L a nng/ Si nki n j
One Shell Plaza j
Houston, Texas 77002 g
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