ML20079R225

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Suppl to 830218 Petition to Intervene,Consisting of Proposed Contentions.Certificate of Svc Encl
ML20079R225
Person / Time
Site: Satsop
Issue date: 06/15/1983
From: Bell N
NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8306220129
Download: ML20079R225 (41)
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UNITED STATES OF AMERICA y7 NUCLEAR REGULATORY COMMISSION oh.ct oruwsse, g&sur.

x--------------FETY AND L!CENS!NG BCaR2 CL BEFORT THE ATOMIC SA 4

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM

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Dock No. 50-508 CL i

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(WPPSS Nuclear Project No. 3)

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-SUoPLEMENT OF COALITION FOR SAFE POWER TO RCCUEST EOE~EEEE555~55D PET 5Y56u---------------------------- 5~E65~L55U5~56~5E ERVINE

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Pursuant to an Order dated April 21, 983 of the At nic Safety and Licensing Bosrd in the above-esptioned pr::seding Petitioner Oos11ticn for Safe ?:wer hereby cuenits the Supplenent to its Pequest for Mesring and Petit.:n f:r

'__:ve t'o' Intervene filed Februsry ~_ 3, 1983.

The contentt:n:

. ; ;h the Coalitich. for Safe Power seeks to have ai-itted

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proceeding are as Eclicws:

072P 1 Petiti:ner contends that there is no rasc_nati2 assurance that WNP-3 will be "substantially cenpleted,'cn a timely basis" as required by 10 CFR part 2, Appendix A,

Section V!!!(b) (1).

l Construction of VNP-3 was halted on May 27, 1093 l

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'following a decision by the WPPSS. Board of Directors.

This construction " deferral" is intended to last anywhere fren 30 t

l days to a termination of the project. See " Analysis of l

Alternatives Related to UNP-3" May 26, 1983, Sonneville l

l Power Administration at 23, 24, 25, and S2.

l In a December 2, 1982 press conference, then Managing Director of WPPSS, R.

Ferguson predicted that WPFES would default on its debt for units 4 snd 5. making centinued 8306220129 830615 PDR ADOCK 05000508 PDR G

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construction of WNP-2 and WNP-3 " impossible".

See Pasco

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.g.v Spring",. December 2, 1982.

Applicant cannot currently sell

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'i g-arrket'to finance continued construction of WNP-3.;-See

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' Litter to Honorable Jim Weaver, Chairman, Subcommittee on Mining, Forest Management and Bonneville Power o

Adminstration, U.S.

House of Representatives, from D.W.

%zur, Managing Director, WPPSS, June 8, 1983, Attachment 2

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Any alternative financing of the pro]ect would not be r btained without the approval of the Bonneville Power o

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'. dninistration, which is not likely. Testicony of Peter

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t, UA yJohnson, BPA Adminstrator, and Alexander Squires, WPPSS QM

  • Deputy Managing Director before the Subcommitte on Mining,

' Forest Management and Bonneville Power Adminstration of the H

on Interior and Insular Affairs, Portland,

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Petitioner contends that Applicant has neither adequately nor correctly assessed the potential releases of radionucleides from WNP-3 during normal, transient and 7

accident conditions, nor the somatic, teratogenic and genetic effects of the ionizing radiation.

Applicant thus fails to meet the requirements of 10 CFR 50.34, 50.36, z.

20.103, 20.203, and Appendix I of Part 50 and, further, I

p6 underestimates the human cost of the pro]ect in the

, cost-benefit analysis required by 10 CFR 51.21, 51.2O(b)&(c) 3 4-fu 4f land 51.23(c).

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l Applicant is required to quantify, to the fullest 4

extent practicable, the factors considered in calculating

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i the environmental effects of the pro]ect.

It is well known i M,

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that the effects of low-level radiation on living organisms.

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is cumulative.

R g g i g t i g n _ g g g,H u_ m a n _ H e g i t h, John Gofman,

'M.D., San Francisco: Sierre'. Club Books,I 1981 at 47.'

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M Applicant should be required to provide a x

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complete and,

.eccurate analysis of the xisting. radiological burden of the -

site but does not.. ' Environmental; Report.5.2.

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.g fails to discuss the results of innumerable studies done' since the 1950's on aquatic life of the Pacific Ocean (into which the Chehalis River and WNP-3 effluents empty) which s.how that radiation from the Hanford Nuclear Reservation exists in fish, oysters, birds, and sediment. @gg_g2gz Columbia River Studies, Allen Seymour (Washington University, Seattle) Laboratory of Radiation Ecology, Contract AT(45-1)2225, Project 1.

The Environmental Report (ER) does-not discuss the entire scope of artificial radiation in the Pacific Ocean and food substances found therein including biota such as salmon which return to the 1

vicinity of WNP-3.

Existing radiological and health burdens of people residing within the redius of WNP-3 should be taken into l

account in the assessment of the effect of operation of the i

project on human health.

Dr. Rosolie Berte11 states that radiation has an enhancing effect on existing health burdens and that such information is necessary to correctly Notermine t.he-impact of'the roject's operation.

Egg

" Radioactive Effluents: Pebble Springs Nuclear Plants",

Testimony Before the Oregon Energy Facility Siting Council, April 3, 1978.

geg_glgg "X-Ray Exposure and Premature Aging", Journal of Surgical Oncology, 1977 at 379.

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The findings of the "Heidleberg Study".'should be -

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incorporated into th_e models-used to~ estimate theidoses.4cf:

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radiation released from WNP-3:

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C'omparisons of, official regulatory. guides'of the'.

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USA and the Federal Republic of Germany TF.R.G.)

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.for, calculating annual -human doses. with.:the results: reported in thajint'ernational literature:;g *7 q j.3 9.,,.,;gg. y 7; g.

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shows that the recommende'd factors for essential ~

' FE radionucleides (Cobalt 60, Strontium 90, Iodine

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131, Cesium 137, plutonium 239, etc.) for the transfer from soil into plants, from fodder into animal products and from the gastro-intestinal tract into the blood are determined in some cases in a scientifically questionable way and the factors are often located at the lower end of the range of realistic values.

Thus the potential radiation dose is substantially underestimated...

"Radioecological Assessment of the Whyl Nuclear Power Plants", 1978, Department of Environmental Protection of the Un'iversity of Heidleberg, University of Heidleberg, NRC Translation.520, U.S.

N.R.C.

The effect of radiation releases to children in_gtegg has not been assessed by the Applicant.

The age of irradiation is all important with in_ utero doses having tbe most lethal consequences.

Gg{mgn, su2rg at 26, 48, and 729.

Populations of in_ utero children are not provided by the Applicant nor are doses and effects to them pro]ected.

The effect of projected doses of low-level ionizing radiation are underestimated by Applicant in Environmental Report Section 5.3. Ggfagg, aggra at 532.

Additionally, new research has surfaced which indicates that the Japanese bomb data, upon which Applicant relies, requires reevaluation.

ggienge, May 22, 1981 at 900.

gee _Alag gglegge_ News, June 19, 1982 at 405.

Applicant has failed to address the potential

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~ radiological consequences'fol' lowing a, fuel handling accident Y 4.end a'p'ostulated loss-of-coolant. accident'(LOCA).

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Novick, Assistant Director.for Licensing,.NRC to m

3 R' L...Ferguson, WPPSS, April,12, 1983 at'450.8.

Applicant hes/not provided<en adequate description of the

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u safety-related and non-safety related portions of the Fuel

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Handling Ventilation System and their interaction during normal operation, LOCA and fuel handling accidents.

Letter, gu2ra, 450.5.

Recirculation and exhaust flow rates for the Shield Building Ventilation System are not used in FSAR Table Table 15-1.

' Applicant has underestimated the doses of radiation to workers at WNP-3 over the life of the project. Applicant has

. failed to-adopt a management policy related to ensuring that occupational exposures conform to the ALAPA principle.

Letter, su2re, 471.13.

Applicant has not provided a requirement for maintaining " positive controls over each individual entry" to a high radiation =one.

In addition, forty-three areas have airborne concentrations greater than the maximum permissible.

FSAR Table 12.2.2-3.

Applicant has not used additional process or engineering controls to lower these concentrations.

Letter, guarg, 471.12.

-Applicant does not Justify projected subaverage annual doses for workers at WNP-3.' ' Applicant may have also underestimated the effect of low-level neutron radiation.

EElenER_EREE, July 17, 1982 at 39.

Occupational exposures from WNP-3 will impact on the overall genetic pool and should be considered in the cost-benefit analysis of the 1} Q [,;' ' ' ' . i.' 5 - L}~:[Q f. ~ '"

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'~ ;T project. ggimag, ggggg at 584. Applicant's projected total annual dose of 440 man-REM / year would result in n approximately 1.7 cancer deaths annually. FSAR 12.4.1.3 and Qgimen, sugga 534. Applicant does not adequately delineate between temporary and permannent workers at the plant thus ..c.- : w. .s.Ah making impossible an accurate calculation of potential lifetime doses to permanent workers and true lifetime doses to temporary workers. Applicant further underestimates the effects of low-level radiation emissions on the health of the population near facilities related the nuclear fuel cycle which provides the fuel to be used at WNp-3. For example, Applicant does not include the chemical and radiation hazards of the zirconium cladding production in Albany, Oregon which includes 6,000 lbs of ammonia, 1-2 tons of sulferdioxides, 1 ton MIBK and 2,000 lbs. of radioactive residue (containing Radium-226) released per day. "2irconium Hacards and Nuclear Profits: A Report on Teledyne l Wah Chang Albany", Pacific Northwest Research Center, 1979. CEge_g l Petitioner contends that Applicant has not shown that safety-related electrical and mechnical equipment and components will be environmentally qualified at the onset of operation and throughout the life of the plant such that .the,re is adequate assurance that the requirements of General l Design Criteria 1, 2'and 4'of 10 CFR 50, Appendix A are satisfied. i t Applicant has not demonstrated that the present testing l methods used to meet applicable criteria are adequate. Dr. ( A. Clough of the Sandia National Laboratories has stated l that "The present testing methods underestiret+ the 1

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'y 2?7 -. g.p s;, M s- .J.~ 2. ~yp, long-term effects of radiation exposure on polymers by not .taking into account dose rate effects and synergisms that 1 r, /.S display themselves only.in a longer. test." Industrial Research and Development, June 1982 at 55-56. The polymers. i ere found;in cable insulation,and: Jackets, seals, rings,.and ...a,. .+-: .tr - gasket's at WNP-3. Current methods of testing have used high levels of radiation over short periods of time which underestimates the effects of the total dose, which in the typical real situation would be applied in low levels over long periods of time. NUREG/CR-2157. "Occurance and Implications of Radiation Dose-Rate Effects for Material Aging Studies", June 18, 1981. The effects of synergisms referred to by Dr. Clough involve the exposure of equipment to radiation and heat. The greatest degradation was found when exposure to heat was followed by exposure to redietion which is the most'likely accident scenario. NUREG/CR-2156, "Radiction-Thermal Desredation of PE and PVC: Mechanism of. Synergism and Dese-Rate Effects", June 1981. The results of these reports have not been applied to the environmental qualification testing performed and referenced by Applicant to demonstrate compliance of safety-related equipment and components with applicable standards. Applicant has not accurately defined the parameters of an' accident ~which would effect the operability of safety-related equipment. Furthermore, Applicant has underestimated the period of time safety-related equipment will be required to operate. S.H. Hanauer, NRC, perceived this issue as a problem shortly following the accident at

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Three Mile Island Unit 2: I believe that as a result of the TMI accident 1we ~ have to rethinkl . f. -. 47 1. Environmental Qualification Envelope

2. Things which have~to be' qualified

~ Changes in my thinking include; 1.. Core-dr. mage is credible

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2. Long-term plant operation is essential,

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3. LOCA and SLB may not give en envelope that includes TMI experieince.

Note from S.H. Hanauer, NRC Assistant Director for Plant Systems, Divisison of Systems Safety, April 6, 1979. Such thinking was reiterated by Robert Pollard, Nuclear Safety Engineer of the Union of Concerned Scientists: I think it is clear that what is needed is essentially a reassessment of the environmentel qualification of safety related equipment in light of the Lessons Learned from the accident. Special Prehearing Conference, Three Mile Island-1 Restart Hearing, Docket No. 50-289, November 8, 1979, TR at 236. Applicant has not met the criteria of Regulatory Guide Nos. 1.70 and 1.89 (or en acceptable alternative) end IE Bulletin 79-01B in failing to provide the required information for each item of safety-related equipment. For example, the exact location of each item is necessary to determine the environmental conditions which may impact upon it, such as flooding. FSAR Tables 3.11.1 and 3.11.2 do not provide complete information on this matter. See Letter to G.W. Kinghton, Chief, Licensing Branch 3, NRC from G.D. Bouchey,WPPSS, January 17, 1983, Attachment 1 (Question No.100.2, Response) and 1, Enclosure 4 (Item 1). Much of the equipment and components important to

'N @ I' h(Eh$ hhh f ff. [ f [9 _, Q,n, - l~ .i' '^ ';l.'G ' +: safety are not environmentally qualified at~WNP-3. Examples of such equipment includeilNAMCO limit Switches, Diesel 1- ~ _2 Generator Control Panel,' containment isolation and safety.~ injection systems. FSAR. Tables 3.1.1. and 3.11.2. e _ u z;..: CESP 4 V"? ~ ' ~ ' Petitioner contends that the CESSAR design utilized at WNP-3 is inadequate to provide rapid depressurization, decay heat removal and the capability for natural circulation and thus violates the requirements of 10 CFR 50 Appendix A, General Design Criteria 34, 35, 38 and 44 and the provisions of NUREG-0737. Natural circulation is considered to be the normal means of providing core cooling when all reactor pumps are inoperative, and thus will be relied upon by Applicant to meet the requirements for decay heat remeval. With main feedwater-assumed to be inoperative, natural circulation depends upon the operability of the emergency feedwater system. To meet applicable criteria, Applicant must show that reliance on the emergency feedwater system (EFS) is Justified, based on (1) whether or not the EFS is fully safety-grade ar;d (2) what the consequences of, steam voiding (steam bubbles in primary system high points) would be. Applicant cannot place reliance on emergency feedwater at WNP-3 because this systen is not safety grade. Reactor coolant pumps cannot be relied upon to remove the steam bubbles because this system is not safety grade and thu~s fails to satisfy the requirements of GDC 34 and 35. Additionally, Applicant has not committed to other improvements such as upgrading the emergency diesel generator and High Pressure In3ection systems, as proposed

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.,~2 ~; f y :. y. ~ ' ' _:.. p p _,g y:. r-t a.us;:.e... ac -a ~... by NRC. Memorandum from'F. Rowsome and J. Murphy, huc' lear. .0 ' Regulatory Research, NRC to R. Tedeaco, O f f i c e o f N R R,.i.' 7 r w ~ ~.. ~, ~ January 29, 1982. 3 ~, ~The Auxiliary Feedwater System (AFW) normally operates '- during.startup and shutdown of the reactor and also. served a;. :g.e; < dual function as an emergency sistem for the removal.of . k. decay heat through the steam generators in certain accident 'e situations, such as Small Break LOCAs. The AFW unavailability analysis for WNP-3 provided by Applicant does not meet the recommendations of NUREC-3611 and NUREG-0635. Letter to G.W. Knighton, NRC from G.D. Bouchey, WPPSS, April 20, 1983. Applicant has not provided an AFW flow analysis as required by NUREG-0737 (II.K.2.19). See FSAR Table j 1.8.2. The AFW system is not environmentally qualified. FSAR Table 3.11-2. Endurance tests have not been. performed on all AFW system pumps. Letter from G.W. Knighton, NRC to WPPSS, June 1, 1983 at 640.7. The C-E primary system is similar to that of the Babcock and Wilcox design used at Three Mile Island No. 2. In the C-E design, however, if emergency cooling and depressurization are required, instead of the use of pilot-operated relief valves (PORVs), water is drawn from the cold leg loop and sprayed into the pressurizer. If the reactor coolant ptimps necessary for this operat' ion are not available, an auxiliary spray system must be used. Such a system is not fully safety-grade at WNP-3. Thus the requirements of GDC 38 are not met at WNP-3. The installation of fully safety-grade PORVs should be required

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because it has not been shown that the auxiliary pressurizer .~ spray is as effective:es PORVs;for rapid depressurization.- '.(:. n' Inside N.R.C. April 18, 1983 at 8..

Furthermore,,the auxiliary pressurizer' spray cannot effectively'functioniinHe low temperature.overpressurization-event.

v., c,- r, gg, a-- y,, 3 .-.. v... Applicant has not shown that'the reliability of the WNP-3 EFS negates the need for a backup system. In the C-E design there is no capability for core cooling via high pressure insection or so-called " feed-and-bleed" if feedwater is absent. Inside NRC, April 18, 1983 at 8.

Thus, WNP-3 is vulnerable to loss-of-all-feedwater accidents, failure of the high pressure in]ection system, loss of offsite power necessitating reliance on the motor-driven auxiliary-feedwater pumps (requires only a diesel failure to remove from service)'or a very small loss of coolant accident.

Inside'NRC, April 5, 1982 et 11. Applicant has not committed to upgrading any of these vulnerable systeg.s. The NRC has suggested that the answer lies in installation of FORVs to allow for " feed-and-bleed" capability. Inside NRC, April 18, 1983 at 8. Such feed-and-bleed will not work to provide for decay heat removal; it is a theoretical method of cooling which has been shown not to be effective by the Semiscale tests S-SR-1 and S-SR-2. Personal communication with R. Pollard,JNuclear' Safety ~ Engineer. POKVs chould be fully safety grade as they are the sole method of providing aganist overpressurization when the plant is cold and because they are a part of the reactor coolant pressure boundry. NUREG-0578 "TMI Lessons Learned

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+ _., a.~ Task Force Status Report:a.nd Short Term'RecommendationsT,,i_ ~ c . ~? v ~~ %, ~ '.,' ';s July 1979 at A-4. _.e.. q; %. - ~ .hy.. ~ 1 -5 g::,3.; ..a ,._,.,.;.~ ll s.e;; -r ' ye The C-E design relies upon use of the steam; generators,.:y,.. l-K c; iM-T, 25; of which there are two 'at -WNP-3, forTdecay heat removal.~' ~2q ~ - Steam generators have. generally beenjshown to'.be unreliable; v g,7, 3 ..,., s -._n }, g.,, .due to corrosion-and other elements which cause steam generator tube deterioration. They are subject to many ~ problems, including the destruction caused by loose parts inside the generators found in many plants. Eee IE Bulletin .83-24. In the event of multiple failures of the steam generator tubes, it is essential to isolate the steam generators to decrease offsite radiation doses thereby removing them from service for decay heat removal. koreover, the steam generators as-built at WNP-3 are of questionable quality.~ NRC inspections revealed document discrepancies related to welding of supports, exterior damage, and possible weld shrinkage. Inspection Reports 81-12, 81-14, 82-02. The base plate upon which the No. 2 steam generator rests was found to have been inadequately documented to suuport a finding that the surface finish was adequate. Upon Applicant's inability to Justify the finish, the plates were replaced; subsequent analysis indicated that the plates as installed would have affected the safety of the plant.' Inspection Report 81-17 at 2. CEEE_2 Petitioner contends that methods proposed by Applicant to meet the requirements for instrumentation for detection of inadequate core cooling (ICC), NUREG-0737, NUREG 0578 and GDC 13 of Part 50 to 10 CFR are inadequate. 1

13 ) Applicant should be required to provide a reactor coolant meter capable of measuring coolant inventory from .3 zero to 1002 Metropolitan Edison Co., Docket 50-289-SP, 1 Atomic Safety and Licensing Board, Partial Initial Decision, December 14, 1981 at 665. Level indication would provide a faster and more reliable diagnosis of conditions in the cass

  • of an accident.

Applicant has not shown that ICC instrumentation proposed for WNP-3, which includes a subcooled margin monitor, a vessel water level monitor and the use of in-plant instrumentation, will meet the requirenents of Reg. Guide 1.89 or an accepteble alternative. In particular, tecting for C-E plants wh ch hac been completed has shown that when reactor coolant pumps are on, existing methods of measurement and proposed designs such as the HJ1C Cheated 3 unction and unheated thermocouples in the water level mescurement system) ere not. accurate I indicaters of vessel level and core coverage. EPR1 Section 6.2. The Applicant has not yet resolved the issue of ICC t ( instrumentetion, which remains an "open item". Response to r NRC Cuestion 100.2 at 2. l CEsE_g l Petitioner contends that the Emergency Diesel Generators as designed and installed are unreliable as a source of on-site emergency power necessary for safety. Fai' lure of the diesel generators should be considered a l design basis accident; the existing design of WNP-3 does not j meet the requirements of GDC 17 of 10 CFR Part 50, Appendix A. Loss of off-site power at WNP-3, an Anticipated Abnormal Occurance, would present an undue risk to the j health and safety of the public due te energency diece:

14 generator unreliability and the questionable as-built equipment at WNP-3. Failure of the generators - should be n considered a design basis event. Diesel generators have not been proven uniformly reliable. "The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400 CNUREG-75/0142", Union of Concerned Scientists, 1977 at 205. Because many safety-related systems need AC power to operate end because offsite power is lost occaissionally, poor diesel generator reliability is an imp'ortant sefety concern. Menorandum from D. Eisenhut to F. Schroeder, Dec. 12, 1980. In E19Eige_ Egger _&_*ight_ggs (St. Lucie, Unit 2), ALAS-603, e

  • 2 NRC 30 (19803 the Appeel Board Scund that diesel generaters are reletively unreliable pieres cf equipment, compared to other equipment to which the single failure criterion is ccnmenly applied. For exerple, on June 2, 1982 all three diesel s'enerators at the Calvert Cliffs Nuclear Power. Station (a C-E plant 5 were sinultane ucly incperatie resulting in a situation where nc energency power s :.u r c e s 9

were available for eleven minutes. At WNP-3 several errors have occured with the procurenent and installation of the Energency Diesel Generators. The generators were originally ordered in the wrong cless of equipnent. Inspection Report 80-09. The Applicant and its contractors failed to ensure the operability of the generators as evidenced by the findings of an NRC insepetor who noted that water had been allowed to enter the generators, electrical panels and couplings which were not waterproofed. Upon questioning, a werker 1

informed him that Ebasco had specificel?.y told.him not to rectify the situation. Inspection E p.+ i 82-16. Applicant has not shown the Emergency Diesel Generators and associated controls are environmentally qualified. FSAR Table 3.11-1 at 3.11-91. CEgp z Petitioner contends that there is no reasonable assurance that the Seismic Category ! structures, systems, compenents and equipment at WNp-3 would continue to operete during a seismic event in the vicinity of the site, thereby violating GDC 2 of Appendix A to part 50, 10 CFR and Jeopardizing the public health and safety. Con: rete structures irportant to safety have not been prcperly instelled, ner adequate quality assurance actions 4 taken, tc ensure ccnformance with applicable codes. Quelity assuranco personnci have repeatedly accepte,d feulty cencrete placenent and i r.p r e ; e r reber placenent. Inspecticn Repcrts SI-OS at 52, end 79-07. This has resulted in quertiens about the seisn.ic capatility of walls in the North tiesel Generster Rocn (Nos.-4~ and 42) and the Reacter Au:4iliery Building. gee Inspection Report 82-06. Repairs to the Reacter Auxiliary Building have allegedly been corpleted, however adequate documentation of such repairs does not exist: Attachrent No. 6 to Construction Engineering Consultants Inc. Final Report dated February 22, 1982 (Appendix to Inspection Report 82-06) has the words " Areas of Repair Very Inaccurete" written over the diagran with the initials "WA", presumably W.G. Albert, Senior Reactor I'nspector responsible for the inspectien. Wall No. 41 was built to Class G instead of Class I requirenents despite the

16 - fact that it must function as a Class I structure. Inspection Report 82-16. The Applicant and NRC have n identified numerous instances of improper quality classification of structures and compenents. See Attachment 2 to Letter GO3-82-1240, December 2, 1982. Applicant rey net ensure that adequate drainage under and alongside the foundation walls of the Resetor Auxiliary Building occurs on a regular basis. This drainage is ir:portant to the seismic capability of the plant. Inspection Report 82-15 at 4. Inadequate attentien to care and naintenance of the Grcund Water Dreinage System has been identified. nspection Repcrt e?-05 at C. Centrols applied ~ to excavati:n ncer the Reactor Auxiliary Building have been substandard. SALF, Decenber 6, 19E2 at 9. Applican'. has cr.nitted te but net yet cenpleted a cherh cf all seisric r:nitcring equipment which has been shown to be deficient. Inspection Repcrt 82-03 ec 7. Adequate OA '. a not taken place to ensure the seisrie cepability cf cable tray supports. Inspection Repcrt 82 ~ 4, and 81-04 at 2. Inspection, upgrading and seismic enelyses cf containment attachnent equipment has not been completed.

SALp, s 2ra at 17. Applicant has not completed a reenalysis d

of piping supperts, restraints and snubbers. Inspection Report 82-23 at 4. Applicant has not shown that the seismic design of liquid end gaseous redweste systems, structures and equipnent conferr to the guidelines of Reguletery Guide 1.143 or er. acceptable alternative. Table 1.8-3, Letter to G.W. Knighton, Chief, Licensing Branch 2, NRC from G.D.

17 - Bouchey, WPPSS, No. GO3-83-08. Applicant has not shown compliance with Standard Review Plan Acceptance Criteria 2 3.8.4(6) "Meterials, Quality Control and Special Construction Techniques." Letter, su2re at 1.8-168. The acceptability of seismic and dynamic qualification of safety-relate,d equipment has not been shown. Attachment 13, Enclosure 4 (item 11) from Knighton, NRC, April 4, 1983. The design of UNP-3 may not be adequate to withstand the forces of a seisric event. Certain theories resulting fror, studies resulting from the 1980 volcanic activity of Mt. St. Helens volcane have the potential to inpset on the adequacy cf the WN?-? design. Analysis ef Altctnatives Polated to WNP-?, May 2G, 1983, 3PA et 42. The L'r.ited States Gelogice! Survey (U.S.G.S.) has suggested that the petentie for an earthquake in the vicinity ef the plant r. y be effected by the subduction of the Juen de Fucs piste. The Ap;21 car- 'as r. : t yet shcwn that the plant's de ign i.e. edequate tc%ing these new scsunptions into acccunt. Conversation with Bill.Hobert, Bonneville Power Adninstratien, June 13, 1983. EEse_g Petitioner contends that the emergency response plans proposed by the Applicent are inadequete to assure that protective neesures can and will be taken in the event of a radiologica: emergency as required by 10 CFR 50.33, 50.47, 50.54 and Appendix E to Part 50. Applicant's Emergency Plan (EP) relies heavily upon the plans and actions of the responsible state and local authorities. Applicant's EP does not yet include the plans fer Greys Herbeur C :.u n t y, Mason Cour.ty c: the State c f

19 - required to evaluate " mayor portions of emercency response capabilities" and to identify deficiencies "as e result of n exercise or drills". The NRC Staff has concluded that a successful full-scale exercise is "at the core" of the finding of adequate protection for the public. SECY-82-185, " Final Amendment to O CFR Part 50 and the Appendix E: Modifications te Energency Prer aredness Regulations Relatine to Low-Power Operations", May 1, 1982. The G e v e r n r.e r.t A.c c o u n t i n e. Office has concluded that: Testing emergency procedures with offsite participatier weuld impreve State end Ices; erergency preparedness...T'.e typec cf defi:ier.: es identified du r i r.g t hes + ! '.* ? ' - : l ee n s c e' facilitic:: drills included: --inade uate corseniest:cn between the var:cus eger.cie partici,rs.:n; i r. the drill, - - c : r.f u s i e r. regard ng respencib ;ity a r. i auchcr t> icr c e c.r d i r.e. n.: cr.c a r.c l e r e n t : n c. ererger.=y essur+s, anc --:nad+r.uste effs:tc rad::1; rs'. 1:n tr:r.:. pr:ceru:ce. w .....w..: .: e....,.....,...- e..... .m. ..,.n..., s.. ~.. ...... v. a. u:... ... -....... a. u-ac ual ever.t c.rrure. t.12 : ty h: : d: r.;

r. a c l e s -

e r e r e. t n r v. dril:s, N ^-::re.eed s :.wer ,r : t -a t er: lecal e orgency servlee a;+ncies '. e v e te:n at:- recelvc scre cf the probierc that were i d e r.t i f i e d. - GAO Report to Cengress, "Arees Around Nuclear Facilities Should be Better Prepared for Radiologica: Eregencies", EMS 76 110, March 30, 1979. Applicant has not shown hcw the entire population l within the ten-mile EPZ will be notified of an accident and evacuated, if necessary. The sirens which will allegedly be I installed have not been shown to be unifermly reliable. i These sirens do not cover the entire zone, particularly the l 1 wilderness area WSU, SW, SSW, S end SSE of the plent, which are prirerily populated wath a transient p r p u l.s t i : n. EP i

Figures 7.1-and 12-2, Table 12-4. Members of the public who hear a siren may not known where to evacuate, r Based on the sensitivity of children-(in_ utero through preschool particularly) the-plume exposure pathway EPZ should be larger for pregnant women and chiiren. The TMI accident caused e statistically significant rise in the rate of infant mortality within ten miles of the plant. i " Management of Radiological Emergencies", Gordon McCleod, i M.D., Text of Lecture, May 2, 1980. Dr. McCleod, formerly j l i Secretary of Health for the State of Pennsylvania has said: Any radiolegical emergency plan and responce in Pennsylvania rust not overlook populatien density for at least 20 r.iles around existing er proposed nuclear reactors. 1 Applicant has. net shown, pursuant to 10 CFR part 50 Appendix E, IV D.2 end 50.47(b)(6)&C7) thet edequete education and notification procedures will be felicwed during normal plant operaticn and in the event cf en accident et UNP-3. These requirements include "besi emergency planning information", " general infcreaticn so te i the neture end effects of radiation", " signs or ether 1 reecures...hcipful if en accident occurs." 10 CFR Appendix E, IV, D.2. Applicant should be required to utilice such 1 methods as billing or home distribution of public information brochures as suggested by the GAO. GAO Report, supra et 28. Applicent has not shown compliance with Appendix E, IV, D.3 which states that a licensee shall dera strete the means to alert end instruct the public within the plune exposure pathway EPZ "within about fifteen rinutet." Furt,orncre, the plan does net describc e

> 21 - radiological crientation training progran for personnel, including the media, as required by Appendix E, IV, F. Applicant's EP fails to meet the requirements of 10 CFR Part 50, Appendix E, IV which establishes the need for an " analysis of the time required to evacuate end for taking other protective actions for verious sectors and distances within the plur.e exposure pathway EP2 for transient end pernanent populations." Applicant's estinctec de not c,atisfy the full spectrum of this requirerent. Furthermore, Applicent does not provide a " range of protective actions fer thic conc" es required by *O CFR 50.47(b)(~0). Neither d:es A;;;icent nahe e chowing that each pri.. iple res; nse or g an i=a t i c r. wil have the staff "tc resp:nd ar.d t: eugnent ...'ona c ::.t i n.: us b a s i s. " 10 CFF 50.47(t)(*.1 Ap;11 cant d:.e s n:: ier:nttrete in itt E? the difference in recp:nst tire, :rgsnicst:en, rethcd et c. ) for different tire: ef dcy which car. te rees:nebly ersured tc exist. The ET doc: net. discuss the effect of regions r.e t e c r c i o g i c a l ::nditi:ns cr everustien snd prctect ive acticns. Due t :- the lack of evecuetion plans with the requisite specificity, Applicer.t has not shown that in the event of an NF -3 that adequete no'ification, corrunication, accident et education, evecuation, and relocation can take place fer pernenent, transient and special populations within the EPZe. C_ TSP __9_ Petitier.er centends that NEO inspection end er.fercement het not toen adequete to ensure that cor.ctruction of Np- ? cer.forre

NT' criteria and applicable industry ::de s r.

22 that, ac.a censequence, operation of the plant will endanger the public health and safety. NRC inspectors generally review only 1-58s of zafety-related plant activities. "Looking But Not Seeing: The Federal Nuclear. Power Plant Inspection Pr o g r a r. ", Lawrence Tye, Unicn of Concerned Scientists, 1979. E */ 1981, the NFC hed fcund that WNF-3 had more then the average nonconpliances per inspecticn hcur then plants in Regior. V cr the natien. WFPSS :n~,uiry, su re et 45. Ncvertheles:, --u-- t'he plant received fewer inspection hours f r c r. the I:FC then the everage ;1ent i r. Regicn V er the netion. WN7-?/5 eA' F, Februery

  • e ': :
p. g...

.7.,.w.....,. e.. y . s ef.ct y.- r e l :: er e.' e r t r : ce ; work beger., eithcugh cuch ,,..4,..c.. ...y, . c. r.=.v..d..' .. e.,.,,. -.,.. - I n ct c l. e. ; c :- e r. t env:10n :nte; ect.c :: enc. Fein e r. -. ether .w ~....,

e. n..
o..
s..

u...,.. ... - e. e.r e. ~....,.... _. e... t. e. s,. t,.. s.. ...-..a .g .c =_ izg ' r. ; c : '. ; ; r Fopcri E. 0 * ?, and EC

  • C..

NFC inspert:ra enf review boards hev+ n:ted Applicent's ecntinuing ine,h:1:ty to ensure irpreverents to contractcr Cf./OO progranc, ir.cluding .' n. s_ ~ e c '..., v e.-..' ".'..' "., e..' c "..- n. ~ '..' v e e ~ '..' c.. 'F.* =., = w. - ~. y Such systerstic dicrescrd on the pert of the Applicant, however, has never met with effective enforcenent action by the NRO, eithough it he'c been threetened regularly. Inspection Rep:.rt 82-2* at 1. The NPO has been hesitent to reke the violations of codes, procedures end construction practices noncor.fermances c-p '. o c e '. '. '. s. e. '. ". e - '.-. ..c o.' e i. c v. . u.. e.. w c.a, + g

l \\ g. 1 l 1 1 .!nspection Report 82-18 at 4 (lack of moisture control for 4 four months and the direct violation of CB&! proceedures on September 26, 1982). The implications of the discovery that the une of Project Change Proposal (PCP) instead of a Nonconformance Report (NCR) for a safety-related ayaten, which ellowed CA/CO procedures to be bypassed was not thoroughly investigated. Inspection Repcrt 82-15 at 4. The NRC Inspection and Enforcement Division failed to ensure

t. hat the Applicant carried out conmittrents nade in response to nonconfermances.

See Inspection Report 81-02 regarding Nonconformence 80 ~?-O". NFC inspection of WNp-? wil; be lirited in scope d a r i r.g the period cf "preservetien". The inspections done en WNp-5 efter "rothbe: ling" were linited primarily to the veriffentio.. ef inert at-osphere in heavy e rui; n er.t e$d sore i westher;ro:fing. NR7 ir.?pections were sh::t a r..d infro uent. l I While al:escdly see'-:Ing t: ensure that certain eyete t r c.c t irportent t: safety were preserved, ins;cr;::c ign: red ther areas which would be of irportance in e plant under t l construction. cEge_;g petitioner contends that Applicant will not adequately i maintain the structures, systems and components of WNp-3 which are important to safety, during the period of time l l during which it is held in a " preservation state" pending i completion resulting in violations of Appendix B to part 50, 10 CFR. I Section !! cf Appendix B, 10 C.rR part 50, establishes the requirenents for a quality assurance program. Such a progren shal; "take inte account the need for special f y-

24 contrcls to attain the requirec quality." Section XI!! establishes the handling, storage and shipping measures necessary to preserve " material and equipnent in accordance with work and inspection instructions to prevent damage or deterioration," including, "special protective environments, such as inert gas ateosphere, specific moisture content levels, and terperature levels," which shall be beth specified and provided. A plan Scr the meintenance of the structures, syste..s - and components necessary te safety during the "precervation state" et WNp-? does nt yet exist. Thus there is no rceconetic ecrurance ths; the quality of werk end reter s1: w 11 te pre served ac:ording to NFO reguistic.s and spflicable inductry codcr. The Applicant was cent. sten-ly understaffed during derral construction hanpering the ir;1erentati n Of its OA/OO progrer.. Egi Insperticn Ec;;rt F*-0? at 10, 50 end inspertzen Re;;rt Si

  • 7 et
  • 1.
Now, with all but ~27 cf ite ranuel w:-rkers having been terrinated, and the disrissel of the me;erity of its

,000 ncn-ranual workers in-inent, Cond cf June, ~ 9 8 3.3 ncintenence w:11 be greetly curteiled. See "WppSS Layc Off ",072 Workere at plant 3", Oregonian, June 1, 1983. The Applicant has had a history of failure to maintein cleanliness and quality preservation at WNp-3, documented in NRC inspection Reports from October 1979 through the present. Housekeeping and cleanliness have repeatedly been substandard and NRC surveillance has shown corrective action in this area to be "inadequete". Inspection Reports 82*C,

81-17 at.-9, 10 and 83-01 at 2. NRC inspection of WNP-3 will be limited in scope during the preservation state. The NRC inspections done on WNP-5 after it was " mothballed" were limited primarily to verification of inert atmosphere in heavy equipment and some weather proofing. NRC inspections were short and infrequent. While ellegedly seeking to ensure that the syster.s most important to safety were preserved, inspectors ignored other areas which would be of importence in e plent under construction. These inspections did find, however, problens with the weter contrcl rie a s u r e s which were taken. Inspecticn Repert 62-02 and 82-07..A;;11:ent has prev::ualy i been cited-for failure to edequetely pretect electrical penetration terrinal boxes; and NRC inspecticn revealed the rs ority cf sue.' be::es senpled lecked the necessary inert gas pressuriceticn. Inspecticn Rep rt $2-19 st 4. Pue t: financi:1 difficulties it ic uncieer if the App;ican-will have the rescurces, during the preserv;-ir.n state er-thereafter, to adequetely reintain the site in l accordence with the requirerents of Appendix 3. l l l C_usu_A reo ** Petitioner centends that the App *icent is not technically qualified nor exhibited the renegement capability necessary to operate UNP-3 as required by 10 CFR SO.40(e) and.that operatfion will therefore endanger the public hesith and safety. Applicent's construction of UNP-3 has reveeled the systematic leck of manegenent responsibility required by Section I of Appendix 3 to 1C CFR Part 50. Applicant has a history of managerent problems at a13 five of its nucleer prolects including WNP-? which have

26 - resulted in cignificant construction defici encies. A Washington State Energy and Utiliti Committee, in a report es to the Washington State Senate and th March 1, 1981 titled the. e 47th Legislature on "WPPSS Inquiry" examined the causes of costs overruns and schedule delays at th concluded that: e pro 3ects and WPPSS Management has been the Ecst WPPSS pre 3ects.cause of cost overruns end schedule deleys significant on the Executive Summary, WPPSS :nquiry, gygra. The Applicant a for WNP-3 is the sene as thet rated as one cf seven below of WNP-2, everage construction sites by the NRO. NUEEO-OE?4. Acccrding te this S A _' P, WNP-2 " displayed evider. e of weaknesses i n s i:. fur. - i onel Tmete eretc" crees then any other below everese plant) these of "qua:ity assuranc.e'Cincluding nensge~.ent s n -! r e. i n i r g ', safety-re:eted structurer, piping and hangcr.[, e l c e t r i r s.' equi; r en t, electries; (tray and wire) enf inciru ent tiir." et E-4. Many of the top renegerent of WPPSS allegedly responsible for inprovements in the nenegement of their nuclear prcsects, have left the company, including Ett Ferguson, Meneging Director. The Bonneville Power Adminstration of the U.S. Department of Energy stetes thet voluntary resignations from WPPSS in 1983 have reached en annual rate of 25% on a company wide basis, with the expectation that a deferral in'WNP-3 (which has since occured) wo41d even impact on the WNP-2 pro 3ect on the order of a 15 to 202.' icss in generetien and technical support

'27 - organizations. Analysis of Alternatives Related to WNP-3, Bonneville Power Administration, May 26, 1983. Thus, the actual deferrel of WNP-3 will have a correspondingly poor-effect on its technical support. Most of the craft workers at WNP-3 have been terminated and within a week, the na;ority of then had actually left the area. According to the NRC, many of the welding probier.s experienced et WNP-3 were directly attributable to newer welders. Inspection Report 80-17 WPPSS, which is losing 25% of its personnel due to its uncertain financial future, will have difficulty attrecting experienced workers. Upon re-cennence.ent cf ecnctruc-icn, the Applicant will experience the sane, and perhape increased, need tc retrain workers after discovering the resulte cf their inexperienec. WPPSS has, i r-the past, had difficulty in adequete steffing. Sgg sig. Incpsetion Reperts S2-07 at ?, 4 and 81-08 et 1C,

e. _.

The Applicant'c nanage.ent '. a c f:iled to rertify continuing failures in construction practices end quality assurance. The NRO and the *.'ashington State Senate ner y end Utilitiec Conrittee, have found that the excessive number of contractors (e.g. 65 instead of 3) have diluted the effectiveness of WPPSS management. SALP-1, and WPPSS Inquiry at 26. The NRC found that Ebesco, the Construction Meneger, was reluctant to exert nenegement control over significent weaknesses which affect Quality Class I work. Incpection Report 81-14 et 13. The App l i c a r.t 's e t t er.p t to inprove managenent of WNF-2 L

- 2D - by adopting " integrated management" in 1978 (which then reverted to the original scheme in 1980) failed. WPPSS Inquiry, supra at 10. 'In fact, during the three years of integrated man &gement "the primary ir. pact ...was on the ability of the organi=ation to act -- on any decision, in any office, at any time." "!!t: interfered with meterial and engineering support of construction, contributed to -unnecessary rewerk and added to access and interference prcblens en the ob site, and confused inspectien." Inquiry, EMEra at 34. Si r.ce deintegretion cf management, the Applicant hes, despite the prcvisi:ns cf 10 CTF 50, Appendir P, Ee:tien 2, become " excessively detached free the day to day prchlems at the nite." FALF, Decerber E, 1932 at 5. his review of Applicant's perfertsnee at WNF-2 points repe tedly to the indiffercnco :S UFFFS rensge.ont as the bacis f'e r centinuins e.. a ,,,s r _ i c. e_...,.. .e ..se

s. c n.

... o.- e p.,i n..,,c '..' e...c, '.'ahu pr: pt and effective ccrrective ectiene end to provide sufficient infernation and analyses when requested.

SALP,

_s u _r e_ at E, 7, S. Ar.licent has censistently failed to c _s exercise authcrity over centractors uho heve repeatedly fa:1en short of the minimun requirements established by Appendix 3. Applicant has demonstrated inedequate attentien to IE Circulars and lessons learned et other of its project sites.

SALP, s_ u_ a>r a at 9, 10.

C_ Y_ S_ P _ _1 _2 Petitioner contends that Applicant has failed te centtruct VNP-? in ecccrdance with N?C relos and re;u; a-ic ns, cpplicable industry standards and codes a r. d

with a quality assurance program which meets the criteria of 10 C.rR Part 50, Appendix B and GDC 1 of Appendix A and thus there is no reascnebfe assurance that operation of the plant will not endanger the public health and safety as required by 10 50.40. Applicant's construction of WNP-3 has consistently. feiled to meet the standards set forth in Appendix B and the overall requirenents of GDC 1. A. review of NRC inspection reports shews that Applicant h-s repeatedly failed to utill:e prcper codes and standards, perforn necessary analyses, prcvide and implenent en adequate QA/CO progran and maintain appropriate records. While the findings cf the those inspection repcrts are thenselves of safety s ; ; r.f i c a r.c e, tcre i ; ; r t ar.- l y, they are synptersti: cf syste.,stic vi:letiens of NPO and industry criteric. The use.of

f. pre;erly trained persor.r.el for censtructic.n and inspectien

'O A /OC) prrredures has beer e

r.s i s t e r.t prcbler since 1972.

Requircrents arc routinely we:ved in lieu ef trtir.ing end tests whic.' ther are nct teken. Egg 2 g _insr+:ticr Ee;;rts 75-OE, 7?-11, E0-09,. ani 81 ~4. Instances of fergery cf qualificati:ns exist. Egg e.e. Ins ection Report 7S-06. Cuality assurance inspectors = r who ere vital to the essurance of safe construction, have repeatedly found to be ignerent of the construction practices, recording procedures and require.ments which they are intended to oversee. See Inspection Reports 79-03, 81-14, and 81-01. The failure of Applicant to overcome these violationa at en early stage places in question the quality of construction throughout the plant. Moreover, A;;11 cant has actively dicr:.uraged e.m;1oyee inv:1verent in

quality assurance by allowing its contractors to use the threat of disnissal against workers who voiced concerns about construction and procedure violations. See Inspection Report 79-09 and 81-10. Workers who cane forwerd to testify before the Washington State Senate. Energy and Utilities Corrittee were ternineted thereafter. WPPSS Inquiry, sugte

ntroduetery.Renarks.

I The quality assurance progran has repeatedly failed te identify and report construction errors, found subcequently by.NRO inspectors. Ege Inspection Report 79-03, 79

  • O end SALF, surra at 1*.
n some cases, quality assurer.ce precedures have beer. ty-passed a:together.

Inspecticn Ecycrte 60-17 st and'80-19 at 4. When the OA pregrsi fe: piping ~was four.d to net support Ouality Cics: ! w:rk, Sbarre relceced the c:ntract'er to continue despite the finding:. SALp, gggna c: 1~,

  • 7.

The que:ity assurar.c+ prcgrar and its inplerentati n at

  • 'NT-3 f cund tc. be "no effcet:ve" 17 the SA* C c' rebrunry 19

-c sir.s se tofey. SALP, surrs \\ at 7, 8. A centir.uing problen, the Applicant had represented in 1978 that improvenents would be nade, but i l they were not, ggg g.g Inspection Report e2-19 et 4. ' 'h e n l significant deficiencies in the inplementation cf CA were identified, eften no restriction s on work were placed. Inspection Report 81-14. And the failure to incorporate relevant inductry codes into the work hes been the subject of repeated NRC findings. See Inspection Report 81-08 at =,w. Applicant has systenatically failed te ensure en

1 32 - adequate and consistent vendor surveillance program. S_ee Inspection Reports 80-04, 81-14, 81-08 at 10 and 82-25 at 2. Thus there is no assurance that vendor supplied equipment materiale and components have been constructed to appliable s NRC standards and industry codes. Applicant's audit procedures are inadequate, and at times, non-existent.

n 1979 the NRC found Ebasce audits to be

" superficial". Inspection Report 76-09. No audits, despite a requirement of the Preliminary Safety Analysis Report (PSAR), were being done of "proyect orcenizations" or "important Appendix 3 criteria". Inspection Repcrt S*-CS at "O, "?. Trent analyse ' ave never been perfereci et 'JN p - ? i with tf.e Ap-licant sinply weiting fer failures to occur. -m !nsport n Report 8*-08 at ~1,

  • 6.

Centrol of ensate design s j, changes (which occur at appr ::inately 800 per rcnth) has 1 centinued t: b s-e prevalent weekness. SALP, eing; at 17. ~'s A;;;icant tr. warned that the rc;etitivo naturc cf e d e a.i g n p r : t l e.a s -ight require an enfcrcetent cenierenre.,

.spe ct i on Repert 82-2" et ".

The end-of-the yeer SALp confirred nc improvements had been ecde. L e Structures at WNP-3 have been improperly constructed.

~

W rkers'have systenatically utiliti=ed vibraters improperly sa .-t

1

'or failed to use them entirely in the placement of concrete resulting in voids and therefore weakened structures. Inspection Reports 78-06, 80-08 and 83-01 at 3. Allegations of voids in sheer walls have been confirmed. Inspection Ropert 61-18. Allegations of equipment left in concrete structures have not been preven wrong. Inspection Repcrt f a i

} 32 - 79-06. Coner .e placement records have been inadequate to assure other espects of quality construction. Grout n application and testing have been inadequate. Inspection R6 ports 79-01, 79-04. Uncertified technicians have been used to place concrete and procedures have not net applicable codes. Egg Incpection Reports 78-08, 78-09. ~ Failures to install or insta!! properly steel reinfereing bara freber) have repeatedly eccured et WN?-?. !nedequcte preservation and quclity contr:1 receures have been in;1enented to assure quality of stec reber used in the plant. Ins;ection Reports 79-04, 79-07. rkers have inproperly pieced, left out entirely er tent reter; quelity assursrec perscnnc! have failed te catch these err rs due to ler; due dilegence end bacic Agnerance of pre;cr ernetructio-er.d cedsc. !r.spection Repert 79-07, 77

  • 0, and 8*-O*.

The quality of welding, quel:ty assurenec : f w c i d i n g. and re erde cf welding hevo routinely feiled tr cct epplicable codes and OA requirenente. The qualification cf welders has repeatedly been questioned. !nspection Reports 80-17, 8*.-06, 81

  • 4 and 82-12.

Quality esaurence personnel have reutinely eccepted bad weldc. Incpection Peperts 79-10, 80-06, 81-01, 81-14 and 82-19. "Significent deficiencies" have been found in the welding of reactor vessel and et.am generator supports. Inspection Report 81-14 et 9. Welding OA recorde and radiographs have been forged for unknown periods of time. Inspection Report 81-17 notes that radiograph "teuch-upc" begen "er ectly es

33 - December 1980." Inspection Report 81-17 at 13. Imprcper welding procedures noted by NRC inspectors have gone n unchanged inspection after inspection. See Inspection Reports 80-03, 04, 06, 07, 81-08, 10 and 83-05. procedures to ensure proper torque of bolts have repeatedly been violated. Applicant has never taken steps to acsure werker and quality assurance personnel 4 understanding of bolt r.arking which has, as a result, been conducted i r.a r e,me r !)' frer 1979 te the 'rresent. SALp, s u a r_ _s __c at

  • 1.

Ne procedures have been in ;1ece te er.rure boite are prcperly terqued, i r. s:re :esec *eading tc the exceeding :f Fc:t ' r t r e. : e + v. nr;cct :- Fe, : r. ?.

c t s
r. r..:- : '. s v c r:-

beer. ;reperly treined in gging procedures end have r+;kakefly beer. found tc r. understar.d the tags, when they a..cule ba,;ated er.i when rc.eved. S_ e_ e ins s ti:n Fe crts c -f

c.....
e.,.

c.. A;.; ; ; r e r : h e.? n:. ::.1g;;+: e:-: :s. s t. :r s r. f r a : M i. '.. ;. r., eye:st.ons ;n a : :c r d t n r. '. i t - s p;- ' _ r.t A ; ; c r. : : :- E cr:teria. 1 :ur.entat:

r. cr. the quel:.y of :schf1;l end density teets ere 1 e r k : r.c.
SALF,

_s u r _r _a at 9, ! r.s m e c t : c n c Rc;;rt 82-CO ct 7. Beckf!!!!ng operat:ene for safety-related piping have nct been classified as s Ouality Clanc I activity. SALp, supra at 9. Applicent has not ensured that other safety-related work has been properly executed. Support for electrieel cables has been deficient. Inspection Report 83-C5 et 5. Cleanliness her been e continuing and unresolved deficiency in the reactor pit erec. Incpection Repert 83-O~ st 2.

34 c_usE_xzso es Petitioner centinds that Applicant has not adequately or eccurately assessed the seisnic capability of the WNP-3 site as required by GDC 2 of Appendix A, 10 CFR 50 and Appendix A te 10 CFR 100 thereby underestimating the risk to public health and safety from a seismic event. Applicant.has net taken into eccount in its seismic snalyses, the works of Ruff and Kanameri (1980; and others which suppert the view that the subduction of the Juan de Tuca plate createn the p:tential f:r large nagnitude certhquakes in the. subduction =one beneath UNF-3. Letter to R.E. Jackson, Chief, Geosciences Branch, Oivisien of Enginscring, U.S. N?? fr:r S.T. Algorriscen, U.S.G.E., April 21, 19??, Entleaure at 1. The Ap;;icant has not justified tho=accurptiens us+d in deter.~.ining the locatien er intentity cf ths !??4 earthquake er e>:plained the si o f the "randon carthquake" censidered to occur within a 32-kr radius cf VNF-2 in A;;;icant's analysis. Letter, gggts at 2. A; plicant *: FSAF cu b.- i t t a l s roves; ine:ncistencies cr? lack cf adequate ;ustificatien for disgrens, earthquake

  • placements, earthquake sizes and other assurptione.
Letter, suerg at 2.

Applicant fails to adequately ;ustify the annual exceedance prchability for the SSE, taking inte account all sources for the random earthquake, subduction zone earthquakes, and earthquakes on significant, capable lineers. Letter, gyptg at ?. Applicant has net considered the capability of a na;or northwest-trendir.g fault in the Hu ptulips River area for WNp-? which may be in;criant tc the site in light cf offchere stu n e:_perft: ci by Fi;ver ( ??2' and Snevely enf

.p:,. ~,p .., ~.. s .mm-. ,w a n. , Wagher (1982) which " indicate a subduction tectonic style characterizedbyeasgward (landward) dipping thrust faults [that generally steepen westward (upwards) and that have offset sediments as young as Quaternary." Letter, gu2rg at ~ 4. Furthermore, Applicant has dimissed offset magnetic anc alles KK and HH on the Juan de Fuca plate as probably due t'o episodic unping of short transform faults connecting ^ effset segnents of the spreading ridge a in Hey (*977). FE/.R 2.5-44. In so dcing, Applicent har chosen net to regard HH as a fault or the source of a deep-seeted na or earthquake, a significant errer in its analyse:.

Lotter, EMILE st 4.

-. EL=q _ss Petitien'er centends that the fire pr: tecti:.. prograr et W.'.*T - ? d r e : net rett the require cr.tr of

  • O CFF 50.49, Appendix R and Gen. oral Decign Criterie ?.

l.;; 1 * :ent her n:t 0:nducted er eva:u=tien cf the V?:r ~ design assindt the requirerer.tc cf "O OFR 5".45 an:..; ; en di:. I R. Ege FSAR Table ".9-2 and *_etter t: C. V. Knighter., i Chief, Licensing Brar.ch 2, NSC frer 3.0. 3:uchey, UFPSS, ,s Jenuary 27,1983. _C_S __1_5 F_uD Pe'iticner contends that Applicant's Emergency Core Cooling System (ECCS) calculations do net meet the requirerents of 10 CFR 50.46 and the criteria of Appendit: K, 10 CFR Part 50. Applicant has not performed plant specific Er.ergency Core Cooling System celculations required by 10 CFR 50.40. S22 FSAR Table .8-2. Applicant has not used the revised e.... e. e ;......n. ,,s..- ._...,_s. _r... .f

.
. r e - r. 7 +. - <.. c..

, w., ,.m 4. .<.,i.-

g. <:m..:. -

n., mvy.. .in w..~. .._e.. m- & --- - e. - 33 1 a m,a,c(.;. 4. .p.~.. .~ m,-. ' M,..~v.. 6

.K.3.30) to show compliance with A pendix K..

P ,.CFSP 16 ..es, ~ se., 2- - ...y...

,,,,c

.n, -w .' Petitioner contends that the Applicant has .- - (.. underestinated the effects of WNP-3 oWeration on the acuatic m <p e J; J biota of the Chehalis River in violation of 10 CFR 51.20 and the' National Environmental Policy Act. n l . App icant has miscalculated and disguised the effects nn ' o f h e' r. .=, .r n. Y* avy metal diceharges to the Chehalie River by usine., .t.. O, averaged data from unknown flews. The er bient ccncentrations r .,3. u w. retaic would increase in in low flow ( v s.. a v e r a c.,e ) s...

c..

of heav"i .0-measi.trements; averages are not an accurate basis fror which

2. '

to assest the quality it'pset of '.lNP-? diccharges. ..s...m. ...~ A;;11 car.t'e ba selir.e study is i r.a ie q u r.t t-te:sure sc: : :. i t l e watei que'.ity data ht: teor :: ' '. e e t e d. U.0 E!E at C-4. Applicar.t's ;ter: sed dir.:harge to the Chche;;c w : ; '. i.: in ex er: c f c i t h e -- evcrage :r r. xir.ur cencentre. len: ei t h.s Enviren enta; F r : t e r t i e r. Ager.cy's re::rre.-+d tvo: t p r r a:cir ur c : n r g r.'. r s t : : r. irr e;; '.e svy rc c;e. F *~ " i e e.,. e...

e...

....s. e......, r. cencultant. EPA criter e ar+ : r.t e n c e d te e r.s.: r e t h -: 'h -~ pretNti:n cf rea;1ra.acn, grow.h anc r epre ciuct i ve-succese of equat e erger.:sr.r. " Water Cuelity Criteria",

  • l. S. ETA "972 at ~~'.

In fact, the Envirent. ental Irpact Statement cf the NRC esteblishes that sono loss of fish can be expected. but""ees not quantify the effect. NRC EIS at 2-10. d Applicant has not considered the physical state (i.e. free ion or bound in complex) of the metals which is believed to effect tcxicity. "Toxicciogical Consideratiens of Heavy . Meta's in the Aquati: Envirocre.t", Che;rsn, ~978. m v

<,_~Ysjr 37 - ...; _ v. m. n_. . o. c .o., s,. . u .w. n. Generally,.the. dissolved fo:m of retals is theught to be the r.ost toxic. Applicant's use of sufuric acid to reduce and control pH would result in a thousand-fold increase in the free ion species of r.etal constituents in the discharge, as opposed to bound forms. Egg " Toxicity to Biota of Metal Forr.s in Natural Water", Andrew, Hodson, and Kenasewich, 1976 at 129. The additivo and synergisti effects of the cortined r.,e t a 1 ' d i s c h a r g e s f r e.n WNP-? have not tieen concidered. It has been shown, for example, that a mixture of ecpper, cadmium and =inc car. cause lethel efferts with individus; i i concentratienz e f 4 0*. e r ;es.

Eatcn,
  • 'a t or iet.

7:1722 *7?6 (197?7. Further cre, Applicent faile en;1rcly ,~. -. i.. to consider the sub;eths1 effects on fish and cther equatic life including chrer.de cenditicn:. App 2 cer.t a c s u r. + a a e x i r.u r chlcrir.o : : r. r t r.t r a t. : n Of .05 rg /11 ter. 7e *:? ' E'aff '.es .t : a *. s-d t '. a t c h : c r i r.e ;4vels ug g. .. s.s a. e..e.. c.

s.... r.

e .., 7 s .a. I J l lower esiculatien, hewever, the d'e '- gor v e+* exceet EPA recontended !!rits (.000: by two and cne half tires, thus eopardizing the aquatic life of the river. T '. c chlorine will not be reduced to a:lowchie levels unt:; 400 feet downstream and 22 r.inutes, en area well outside the six'ing zone, personal communication with J.D. Srith, PhD, consultant. Moreover, Applicant proposes to use sulferdioxide to saticfy the criteria CEF at 5.3-41 but fails te consider the toxic effects of sulferdioxice, on the the uncupp:rtat;e assur.;tior, thct it will te entiro:y

'T v .2'yhR,P.rg*C*P. 0;@SM,, h, @%.. !.ts.7-h.J.".M %.%,i.d.5'WA,%..'e?b? "'h:'.t.,?.^.?. W W W* M *'

%. Y:.,v,.R;p,;

T T* li s .,, %,,. g..,;... r .+.e e. ,.? w'- -..w...'.....~. ...v o;- -+ . n a. *y . u,. : ..,.., w,u.or -; :. s.. T~ .W, p .,..r.z. ,.,.~. n. .~ e- . :. 7.m.<,.p...r. - w.-.e,_.. v.m -w. 9.?cr..,. -? ; 7 ? w; ' . v ~; m -.. w,,. . w r~ .<..s.. .m ~ .. ~~.;

:. "- q( f,.K..r,5.;. (_.,.; y w.n.
z..c a :~. g.v. 3

..y _ ., s .z.. . q,, .g, ~. - consumed. m. n _L :~~ 5;:.. 1 r_ , P:n a-

-r.

3 <_

7. yx::

.' g~

C -:,. -

...'t m .. n.v., m < ~.w. my.~

e g.fm"24.. u.

.n.. .. -w 1 : w. = s m c.v.~ <=t*:

g ;.;...

.d.~..e . ac:.w q:: : i n x ;--' ... n.JW:v@..f3 Applicant' states"tihat%re'~wi1Qbe /.1.u..,leTor',.no.liWi-fMGq M,;Yl. .;;ff 1tt . s.. ... w.v.,. 4 mm,. z.u ....:,, c y,m.r:u. c* v. - w.,.. .. x;,.y q will causet. 3 r p: x -Q,W (p, -. sm.; 7:., zag :.x c,7. y.: g.?~ g..::,b,~,. : Q. 3..< s ' y ~

.t d

.d;.n.:discha..rge 'of phosphate,.T.:E.R c5,.3. Er WNP-3,n;.:h owe ve r[ :,4 .;t . m -+yp] ~

. > ~.s. w..

. m.. - - " A.a ~ ~n ..,..~ .w ., x.. .m~. . v. -. 7y v. .,.,.....: 4 3:..,.,.

n. ;.n.

%.4 -g m c -- -m .a 3 . w,,.m... >w .w.h.u m.. -=

q. t mx.*

..,..:+.. > <6., ,a c., ~ a D'. an.~i,ncrease*in the level'.gf.. phosphate.in the Cheha11s..lw+ &.,f. ' ;7.9:3+y o

p.,,q,& X..~:.?w.. :..e

=. _ o. .. ;.. t .a. .n, p,'q~:'(M.? Appli' cant

  • pas
  • not dassessed 4

,the feffectJofz the. < increased.?.ug.':,%.s= ';i'.Q;Llb1@. q

n n ~ >,
y.,. /..y 9: s ;.

y~ ..v s>;f n.m W.:.;. M '. "phoshh' ate leve1~on'the occ'urance of blue'-green algae whi6' ~.N [d?.? 7 I ~

&.W

.s '1Q-,..] can~'ffect the~ heat absorption and storage capabilit'y of the'- W,~~..:U a L. 3.. river.~ The indirect effects of increased temperature upon -7/ a ;:

s...

fish' include swimming speed, metabolic rate, accelerated ~ ll e_ & w-m <o.;- chronological aging, growth and contributions to the .,. ; u. outbreak of disease. " Factors Affecting the Columbia River h,D f, Chinook and Coho Resources in Fresh Water", October 13. 1977. CEsg_12 . Petitioner contends that Applicant does not have and will not ir.ple. ment a CA/QC program which will functicn as required by GCO 1 of Appendix A to 10 CFR Part 50, 10 CFR 50.40, Section VI!!(2)C(?) of Appendix A to Part 2 to assure the protection of the public health and safety. In Dusguene_ Light _Com2any (Beaver Valley Power Stat' ion, Unit,2) A1.AB-240, AEC 829, 1974, the Appeal Board held that m.- ' J. 1.,, a a licensing board needs "more than hope" when deciding if a licensee would implement an adequate QA/QC program for plant r:_... operation. The Appeal Board also held that it was not ' : 6. : '.., ..~. : :.s j'A.' 10 CFR Part .K.f+.n . 'eno, ugh.,. f.or a lice.n.see -tci c.omply with Appe. idix B, l-W~-R r. ~ ., -sq..~ %w - s -- JO'; ' ' 50, by.merely alleging that it had an adequate QA/QC program . M.2: : w.~

M.

f4,. particularly when its history in this area case doubt on its t ,, 7, c. ability to perform. m. Applicant will not be able to retain sufficient numbers of trained personnel to operate and maintain WNP-3. l l

s.: c.,.. n- ..: g' [~: ; 3. F .q.v.:9f7,59.g.,;;; g ; y p

p.,. ~~

- g ;::.. .Inspectii.on ' Report 81-17 fat.dlD.BPA AnalysiaWagggg 'at 417, T V ~'~ 9 ~ .n. : 2 C'A..JA..- .,;. w. s., ~.. * . _. J 5_.- licant has repeatedly allowed -QA/QC.. procedures ~to' be.n'0 3,/ c/ .,.1;1,u.

t.. 7 W~.C.. pp
m.....r.yw." -F...

. -i e ..m..#. g. mq,.;p. 5;iy y 7m; 3.. n -; 4. y. ~,,,, See e g,J, Inspection4. Report 82-15 ~ at 4,. ' ?.$. .g.... c-- .,,.s wy. g.2 .~ ,. f.c',' .~ ,.a; ...x n. n C.;g.- . c <C gentirely bypassed. z 2;e.,.. ,..g.. , ~;, :., = .:.wp. :.

  • u. * : !% 5~1%* y; f* Y n., ^. !:* l'~".

., + ,. f,* "7.. ' . % A 7. y'....

  • .e-,

': -d - ? ~ n ^ '"^o~ Applicant has f ailed 'to ' carry:J.out":com.mittments' made to ' the e'- .... e.,..NRC for corrective actionsq;ygee 3.,g.-Inspection Reporty,,l+.;; -9 A . 5 py,e. N ..;:; r.. } k;jn-q.,

s.. # _ '. ;.-:$

.: [} y,.. .?:yf,Q Qg. 7. V;. . _'m ~ 7 ~^ ' '81.02. Applicant has repeatedly failed to take prompt, ~~ corrective action with sufficient analysis to resolve and prevent reoccurance of errors. SALP, December 6, 1982. 2 Applicant's management has remained aloof from the day to day plant activities, only becoming involved if absolutely necessary, a matter the NRC attributes to systematic management failures at WNP-3. SALP, supra. Applicant, on its nuclear project most nearing the ' operational stage, has been subject to strong enforcement action, yet has failed to adequetely implement a quelity assurance program: The inspection findings indicate that regulatory requirements were violated.... Additionally, it appears that several of your activities were not conducted in full compliance with your committments to the NRC or fail to conform to the provisions of accepted industry practices which

you have been encourage to fellow.

The NRC is particularly concerned with the two violations...because of the very essential role they plsy in the execution of an effective Quality . Assurance Program for construction. Letter from_J.L.. Crews, Director,' Division of Resident, t..... .w y.t Reactor Projects and Engineering Programs to Dr. R.G. Matlock, Program Director, WPPSS, October 25, 1982. 'The systematic failure to conform to quality essurance requirements and the lack of management oversite are revealed in the NRC inspection records and SALP Boerd

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  • ".[9 '

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s. m Applicant's perfor.manc. e :idoes $o.. N-.-- ...%:.yJ,44,.y ' y 1 ' '.,s... : v. a.5e. neraE.e,l. nT'f aj 3?'i?.I/f.s.%. * - + s'js - ut. M.*.g gp.t.s ' ?.M.cl

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  • -. s 5 *.:..

.r:9.',1 *; :. - 3 yr -.-t Me a. vll?.o:.n :y. ;.. a..,.',,..* of hope for ' compliance with;y, applicable 3a. andards -;durinig,1.the$g.N., s._,. t . -y.,m: .h y - u.y.;y.,yq d.9;w = .w 1,%.v.m :a n,.g. y:sg:g y:;.- m;,,%g.;,_1;y(.;,,yg s .. r.. _.;,qp4;qp.m . cn ;,4 v e c -: ~ '.v. 7. 3 ~ <.. a .. m ~.. .g g_,.q9 y @f,Qc@

  1. 4..-b()DPerationa1.. phase.

. ;.';,e, . WTg,n l 49.;'. -T*'L*.'t~.2.~,;&.:; : :.:x:,x.'.' ' :, <.Q~.-??qqh W,T:lgg. g i-Jy;j,g2,f D k s yp;yd 5% y- ..-y: g ? g m.>,ip.-3 2.;.sy',Q y q.; u.: y. .Q, g- ::g. yyp. ..,.-m,..,,7. a...g :r. - n,....s g.3..s.,r +.....&. Q. ..y--. ~ z.+,g3.y:7.. ~.. ~. M., p.n. : - o ..ita... .... p, ~s,.

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..s p;.. m.- .u .n.c -,.;.:..,, .. 4.,.. .. p,.... ..n. .n ^1.,1. F;7,. y--? '-. ; - 3 g ;r-g; V.~.o.. e;,'7.%<,,,'p Re spe. ctf ully.. submitted, S.,..ig M,..- y.. - m*, hw ,s-..? c.-,~.;,._........>.g.y.e.. ,g., s ;..>.,R;;.n. n gg r.pm...p~.. ,m,m...%... ;.;-, v + . t.-. u-:3 s ~?.? '.? ~ _-;a - ' ~' .[ e Dated this day, the 15th Nina Bell of June, 1983. Coalition for Safe Power 4 - e qr .b a. = - ~*.. a. O e 1 m e.- .'k ~ ,t4, p 8 u p sh-, ,+I-- g g .w g j ;,_.*, .}' M.'..i ~ .,g. .sa i. .._'7"~ ..!I ,/,^"' 's

  • iA A -

4 9 1

n g -* -.y, n [I, ?? UNITED STATES OF APERICA NUCLEAR REGULATORY C00 MISSION p g C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD [ My ' = 1 p g,0 -11 In the Matter of ) O g@oL%$ ~ ) c t- 'in-WASHINGTON PUBLIC POWER SUPPLY SYSTEM ) Docket No. 50-508 et. al.- _) ) m (WPPSS Nuclear Project No. 3) ) CERTIFICATE OF SERVICE I hereby certify that copies of the " SUPPLEMENT OF C0ALITION FOR SAFE POWER TO REQUEST FOR HEARING AND PETITION FOR LEAVE TO INTERVENE" in the above captioned matter were served upon the following persons by deposit in the United States mail,first class, postage prepaid, and (*) by hand deliv,ery Federal Express this 15th day of June,1983: Morton Margulies, Chairman

  • Nicholas Reynolds Atomic Safety & Licensing Board Debevoise & Lieberman U.S. Nuclear Regulatory Comission 1200 17th Street, NW Washington D.C. 20555 Washington D.C. 20036 Dr. James Carpenter

. Frederick J. Shon Adminstrative Judge Administrative Judge Atomic Safety & Licensing Board Atomic Safety & Licensing Board 'U.S; N0 clear Regulatory Comission U.S. Nuclear Regulatory Comission Washington D.C.,20555 Washington D.C. 20555 Stuart A..-Treby Gerald Sorenson, Manager Counsel for NRC Staff. Licensing Program Office of Exec. Legal Director WPPSS U.S. Nuclear Regulatory Comission 300 G. Washington Way Washington D.C. 20555 Richland, WA 99352 State of Washington Atomic Safety & Licensing Energy Facility Site Evaluation Appeal Board Panel -Council Mail Stop PY-ll U.S. Nuclear Regulatory Comission Olympia, WA 98504 Washington D.C. 20555 .y Docketing & Service U.S. Nuclear Regulatory Comission Washington D.C. 20555 A Nina Bell, Staff Intervenor Coalition for Safe Power 1}}

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