ML20108D681
| ML20108D681 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/30/1983 |
| From: | Brew J NEW YORK, STATE OF |
| To: | Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20105B503 | List:
|
| References | |
| FOIA-84-250 NUDOCS 8412130351 | |
| Download: ML20108D681 (11) | |
Text
!
7-STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE
,1.c /c u we
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THREE EMPIRE STATE PLAZA, ALBANY 12223
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i PUBUC SERVICE COMMISSION P",'jg0'^
' h oAvioE.eLAsed EDWARO F. LARMIN JOHN J. MELLtH*'
CAKMEL CARRINGTON MARR HA ROLD A. JER RY. JR.
I ANNE F. MEAD I
]
CICHARD E. SCHULER CCSEM ARY S. POOLE R August 30, 1983 D~r t $o r, e ^ '*
p adIO ~
l\\8[gg Bernard Bordenick, Esq.
I qd Office of the Executive U.S. Nuclear Regulatory h(MO ", h Legal Director jpg Commission N
Washington, D. C. 20555 Re:. New York Public Service Commission Shoreham Prudence Investication.
Dear Mr. Bordenick:
Enclosed are the pertinent pages of LILCO witness Cordaro's testimony which claim that LILCO was unable to maintain normal communications with the AEC during the Shoreham licensing hearings.
I would be happy to send other excerpte, or complete copies of this testimony, if you are interested.
I would like to discuss the so-called " black out" with you at your convenience.
I can be reached at (51S) 474-4535.
I appreciate your assistance in this matter.
Very truly yours,
%hM JAMES W. BREW Staff Counsel Enclosure
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8412130351 840521 PDR FOIA BELAIR84-250 PDR N
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I 1
CORDARO DIRECT 2
In 1973 alone, 32 Regulatory Guides were issued by the f
3 C.
While regulatory guides identify what is required, 4
they do not identify the procedures or analysis necessary 1
5 for the implementation of the - requirement.
The AE must 6
determine the appropriate procedures and analysis.
In some 7
cases, such as Regulatory Guide 1.46, concerning the effects P Pebreak, and Regulatory Guide 1.75, concerning i
8 of i
9 electrical separation, the full impact took years to 10 determine.
11 12 Q.
Why couldn't the Shoreham project team anticipate some of ' '
13 these regulatory changes during the licensing hearings?
14 A.
LILCO was unable to anticipate fully these changes due to i 15 certain AEC procedures, which resulted in reduced AEC
{
16 technical consultations relating to Shoreham.
In order to i
17 avoid the appearance of collusion and impropriety, as well i i
18 as any last minute changes in a plant's safety Evaluation 19 Report, the AEC, during the licensing hearing, traditionally l 1
to j 20 communicated with a utility onl'y through counsel.
Due 21 the highly publicized and unusually contentious nature of l
22 the 3horeham proceedings, the ABC adhered more strictly to 23 traditional procedures.
At all times, other than during 24 the hearing period, informal technical dialogues were held '
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CO N O D 1
at which utilities and their AE's were informed of potential,
2
- or imminent regulatory changes and oth ; AEC technical and
)
, iengineering concerns.
During Shoreham's licensing hearing 4
nly the most important licensing issues outstanding at the 5
"I 8 ""
6 discussed.
The vital informal day-to-day technical 7
dialogues, particularly regarding regulatory guides, were 8
impeded. at an extremely important time in the project's 9
history' These circumstances had little or no effect on the 10 i
11 engineering of most nuclear facilities because their 12 licensing hearingu were very short.
At Shoreham, however, 13 LILCO was unable to maintain continual informal technical i contact with the AEC during its lengthy three-year licensing 14 15 hearings.
[
16 17 Q.
Would you please explain the impact of the reduced AEC i i
18 technical consultation on the Shoreham project?
19 A.
To construct a facility as complex as a nuclear power plant, 20 engineering must be sequenced to ensure that necessary -
1 21 information is available when needed by construction.
This; 22 engineering offort is called engineering support to 23 construction.
Similarly, engineering must be available to 24 allow the timely procurement of equipment.
The result of.
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1 CORDARO DIRECT 2
not exactly knowing what the AEC would require caused s
~fhoreham'sengineeringtobelesssupportivetoconstruction 3
4 and procurement than engineering on other nuclear projects.
5 Shoreham's engineering consistently was less advanced than 6
planned and not always available when required.
As a 7
result, construction was rescheduled and equipment was 8
delivered late.
9 When the Shoreham project was restarted in the Fall of 10 1972, Shoreham's engineering appears in retrospect to have 11 been less advanced than the engineering of other plants when 12 they received their CP.
Shoreham's less advanced 13 engineering began to become apparent only in late 1973 after 14 saw engineering activities had progressed.
15 The shoreham project engineering had difficulty 16 supporting construction throughout the project because of 17 the continuous promulgation of new regulations by the AECj i
18 and NRC during Shoreham's construction.
As engineeringi i
19 attempted to implement regulations, new regulations werel 20 issued that had to be simultaneously evaluated.
At the si=e 21 time, engineering was attempting to support construction by.,
22 issuing a continuous series of engineering information to '
23 construction forces.
24 l
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l CORDARO DIRECT y
Q.
Did LILCO experience any difficulty in implementing the new 2
fegulatrycodesandrequire=entsontheShorehamproject?
3 A.
Yes.
Part of the problem resulted from the fact that regu-4 latory requirements were and are found not only in officia4 5
regulations such as 10 CFR 50, but also in Regulatory 6
- Guides, AEC branch technical positions, standard review 7
g plans, NUReg documents, etc.
While these quasi-of ficial re-9 quirements do not have the force of regulations, they are lo difficult to integrate into plant design since they may not 11 necessarily be required and.may or may not enhance plant 12 safety.
Moreover, in many instances, regula, tory guides and 13 other similar guides do not provide specific information 14 needed for their implementatio,n.
The utility is left to i
15 l
determine the method of compliance.
16 The difficulty og implementation of regulations and re-I 17 quirements to Shortham was co= pounded by the extraordinar I 18 ily long time needed to obtain a construction permit, the l
restricted flow of inf ormation f rom the AEC during the 19 l
20 licensing hearing, and the project curtailment resulting 21 l
f rom Calvert cliffs.
Because of these unforseeable delays, {
22 c'
the Shoreham project was forced to comply with many new
I 23 regulations, and the applicability of many regulations could:l, i
l 24 t
t ;-
t.
e I
i j
.tl
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8 CORDARO DIR M 1
i not be fully determined until af ter LILCO flied its Final 2
i afety Analysis Report in 1975.
3 4
5 Q.
Did compliance with regulatory requirements result in increases of Shoreham's cost?
6 7
A.
Absolutely.
LILCO's compliance with regulatory changes and 8
supplements contributed to cost increases.
Design changes 9
necessitsted by new regulatory requirements resulted in 10 changes on numerous systems with an accompanying increase in 11 cost.
12 Whenever feasible, LILCO took steps to minimize the 13 impact of regulatory changes.
For example, af ter the Mark 14 II Hydrodynamic Load r equirements were issued, LILCO 15 recognized the possible impact on Shoreham's piping and 16 equipment systems.
As a result, LILCO worked with stone &
i 17 Webster to increase substantially the design margins on all!
I 18 pipe supports not yet designed and released for construction' 19 even though the exact magnitude of the loads and final NRC 20 interpretation of the requirements were not av ailable.
I 21 Because.of LILCO's action, over one thousand large bore pipe-,
i 22 supports were upgraded.
Four years later, when the finale 23 design assessment was made, over ninety percent of these i pipe supports did not require additional modifications.
24
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2 1
CORDARO DIRECT 2
In 1973 alone, 32 Regulatory Guides were issued by the 3
While regulatory guides identify what is required,
- fC.
3 4
they do not identify the procedures or analysis necessary j
5 for the implementation of the r equirement.
The AE must 1
6 determine the appropriate procedures and analysis.
In some 7
cases, such as Regulatory Guide 1.46, concerning the effects 8
of PiPeb r ealt,
and Regulatory Guide 1.75, concerning 9
electrical separation, the full impact took year's to 10 determine.
11 12 Q.
Why couldn't the Shoreham project team anticipate some of 13 these regulatory changes during the licensing hearings?
14 A.
LILCo was unable to anticipate f'ully these changes due to 15 certain AEC procedures, which resultaa in reduced AEC 16 technical consultations relating to Shoreham.
In order to I I
l 17 avoid the appearance of collusion and impropriety, as well i l
l 18 as any last minute changes in a plant's Safety Evaluation l 9
19 Report, the AEC, during the licensing hearing, traditionally to) 20 communicated with a utility only through counsel.
Due of l 21 the highly publicized and unusually contentious nature 22 the Shoreham proceedings, the AEC adhered more strictly to 23 traditional procedures.
At all times, other than during 24 the hearing period, informal technical dialogues were held
~
-8 2-0 l
e l
u
. :- :- - - L.
i CORDARO DIRECT y
at which utilities and their AE's were informed of potencial 2
. or imminent regulatory changes and other AEC. technical and
)
s ngineering concerns.
During Shoreham's licensing hearing 4
on1y the most 1m ortane menmg iss.es ouest-mg at ee "I
8 ""
6 discussed.
The vical informal day-to-iay technical 7
~
(
dialogues, particularly regarding regulatory guides, vera-8 1
impeded at an extremely important time int the project's.
9 10 history.
These circumstances had little or no effect on the engineering of most nucle ar'. f acilities because 'thair 11 licensing hearingu were very short.
At Shoreham, however, 12 13,
LILCO was unable to' ' maintain continual informal technical 14 contact with the AEC during its lengthy three-year licensing 15 hearings.
16 17 Q.
would y explain the impuct of tne reduced AEC i 18 technic cion on the Shoreham project?
I I
ilit'y as complax as a-nuclear power plant, '
19 A.
To cant 20 engine-mt sequenced to ensure that necessary i I
21 informt ts ole when needed by construction.
This 22 engineering et is called engineering supporf.
to '
23 construction.
Similarly, engineering must ba available to f j
e 24 allow the timely procurement of equipment.
The resul.t of ;
i e
I 1
i li
.- ~.
~,
1
$0RDARO DIRECT 1/1 '
2 not exactly knowing what the AIC would r equi re caused 4t
- fhoreham'sengineeringtobelesssupportivetoconstruction 3
4 and procurement than engineering on other nuclear projects.
5 Shoreham's engineering consistently was less advanced than 6
planned and not always available when required.
As a 7
result,. construction was rescheduled and equipment was 8
, delivered late.
\\
When the Shoreham project was restarted in the Fall of 9
g.3 10 i
1972, Shoreham's engineering appears in retrospect to have 11 been less advanced than the engineering of other plants when.
12 they received their CP.
Shoreham's less advanced i
13 engineering began to become apparent only in late 1973 after t.
14 S&W engineering activities had progressed.
I 15 The Shoreham project engineering had difficulty 16 supporting construction throughout the project because of 17 the continuous promulgation of new regulations by the AEC l l
18 and NRC during Shoreham's construction.
As engineering' 19 attempted to implement regulations, new regulations were 20 issued that had to be si=ultaneously evaluated.
At the sime 21 time, engineering was attempting to support construction by ;
r.
22 issuing a continuous series of engineering information to 23 construction forces.
24 I
i
'O.
l I
t.
i e
y -
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i CORDARO DIR M 1
e
~
2 Q.
Did LILCO experience any difficulty in implementing the new e
- [egulatrycdesandrequirementsontheShorehamproject?
3 4
A.
Yes.
Part of the problem resulted from the fact that regu-latory requirements were and are found not only in official 5
regulations such as 10 CFR 50, but also in Regulatory 6
7
- Guides, AEC branch technical positions, standard review g
plans, NUReg documents, etc.
While these quasi-official re-9 quirements do not have the force of regulations, they are 10 difficult to integrate into plant design since they may not 11 necessarily be required and may or may not enhance plant 12 safety.
Moreover, in many instances, regula, tory guides and 13 other similar guides do not provide specific information 14 needed for their implementation.
The utility is left to 15 determine the method of compliance.
16 The difficulty of implementation of regulaticas and re-17 quirements to Shorgham was compounded by the extraordinar-18 ily long time needed to obtain a construction permit, the 19 restricted flow of inf ormation f rom the AEC during the 20 licensing hearing, and the project curtailment resulting i
21 from Calvert cliffs.
Because of these unforseeable delays, j 22 the Shoreham project was forced to comply with many new '
I regulations, and the applicability of many regulations could:
23 8
I i
24 I
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e ;
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e E
e 1
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1 CORDARO DIRECT s
2 not be fully determined until after LILCO filed its Final 4
3 iafety Analysis Report in 1975.
h 4
5 Q.
Did compliance with regulatory requirements result in 6
increases of Shoreham's cost?
7 A.
Absolutely.
LILCO's compliance with regulatory changes and 8
supplements contributed to cost increases.
Design changes,
9 necessitated by new regulatory requirements resulted in 10 changes on numerous systems with an accompanying increase in 11 cost.
12 Whenever feasible, LILCO took steps to minimize the 13 impact of regulatory ch'anges.
For example, af ter the Mark 14 II Hydrodynamic Load r equirements were
- issued, LILCO 15 recognized the possible impact on Shoreham's piping and 16 equipment systems.
As a result, LILCO worked with Stone &
17 Webster to increase substantially the design margins on all!
i 18 pipe supports not yet designed and released for construction; i
19 even though the exact magnitude of the loads and final NRCt 20 interpretation of the r equi rements were not available.
21 Eecause.of LILCO's action, over one thousand large bore pipe,
22 supports were upgraded.
Four years later, when the final 1
1 23 design assessment was made, over ninety percent of thesel 1
24 pipe supports did not require additional modifications.
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e 0
9
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- e w e -%em +=eme u.
- _ _. _ -. _. _ _ _. _. _ _. _ _. _., _ _ _. _.. _ _. _. _ _ _. _ _ _ _ _. _. _... _ _ _ _ _.