ML20126H720

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Handwritten Memo Re Forthcoming Facility Hearing Concerning Contention
ML20126H720
Person / Time
Site: 05000000, South Texas
Issue date: 04/09/1980
From:
NRC
To: Habacek
NRC
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ML17198A238 List: ... further results
References
FOIA-84-393 NUDOCS 8506100393
Download: ML20126H720 (1)
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UNITEDSTATESOFAMERIdA NUCLEAR REGULATORY COMMISSION e

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ATOMIC SAFETY AND LICENSING BOARD SOUTH TEXAS I

Charles Bechhoefer, Chairman Dr. James C. Lamb McGURREN/ROTHSCHILD/

Dr. Emmeth A. Luebke TREBY FF In the Matter of l

HOUSTON LIGHTING AND Docket Nos. STN 50-498 OL POWER COMPANY, ET AL.

STN 50-499 OL-i (South Texas Project,

.I Units 1 and 2)

)

MEMORANDUM (March lu, ly80)

In response to our recent inquiry, the Applicants have advised us that completion of construction and fuel loading is

' currently scheduled for September 1, 1983 for Unit 1 and i

September 1, 1985 for Unit 2.

The Staff has indicated that the FES and*SER for the' facility will be available for issuance in the fall of 1982.

If this schedule..were maintained, hearings rg '

could not be held prior to the widter of 1982-83.

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The Board believes that a hearing on issues relating to asserted construction and QA/QC deficiencies (Contentions 1 and

2) might profitably be held at a much earlier date.

(To the extent the concrete-void problem described in the Applicants' letter to the Staff dated February 18. 1980, of which we received a copy, is different from the matters raised by kb D

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Contention 1, paragraph 2., a. similar conclusion would follow.)

i Each of these issues raises questions about the adequacy of the contain=ent structure and of the building practices employed in

!l its' construction.

That structure is one of.:he important physical barriers designed to prevent radioactivity from fission products from reaching the outside world - indeed, it is the final barrier te 4

prevent leakage of radioactivity.

It is therefore critically important that this barrier be constructed properly, and special i

attention must be given to assure that deficiencies in this struc-ture do not occur or, if they: occur,- that they be corrected prop-erly and that steps be taken to prevent their recurrence.

For that reason, when issues of this type are raised, they should be '

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resolved expeditiously so that, if corrective action is required, it may be undertaken as early as possible in the construction schedule.

4 4

The parties are ' invited to comment on the feasibility of an early hearing on these issues.

(If the concrete-void issue mentioned above is different from Contention 1, paragraph 2, we also wish to hear evidence, as a Board issue, on the resolution of that problem, including steps taken to prevent its recurrence.)

We would expect that all discovery necessary for the preparation of these issues for hearing be completed prior to the hearing, that any relevant NRC or FBI investigations also be completed j

and appropriate reports prepared, and that to the extent that

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~---a an SER is required with respect to th'ese issues, it be separated from the rest of the SER and completed in advance of the remainder of that document.

We would not anticipate holding the hearing-prior to the fall of 1980 or winter of.1980-81, but this schedule would nevertheless predate the other' hearings by some two years.

We would. appreciate the views of the parties on this matter.

(A prehearing conference authorized by 10 CFR 52.752 would be held prior to any such hearing.)'

e FOR THE ATOMIC SAFETY AND LICENSING BOARD s

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Charles Bechhoefer/ Chairman Dated at Bethesda, Maryland, this 10th day of March,.1980.

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r UNAa u S3TES OF AMERICA EECDVID NUCLEAR REGL" ATORY CO.MSSION O *Y3 6 ii il gg KIDMIC SAMZ AND LICDISING 30AP3

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EDUSTON LIGHTING.AND

)

Docket Nos. STN 50-498 OL PO*a'IR COMPANY, p_ &.

)

STN 50-499 OL i

),

(South Texas ? oject,

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Units 1 and 2)

)

MEMORANDUM AND OP3ER j

(August 3, 19 79) 1.

In our April 3, 1979.Prehearing Conference Order Ruling 1

1

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Upon Intervention Patitions, LBP-79-lo, 9 NRC

, affirmed, 4

AIAB-549, 9 NRC (May 18,1979), ve admitted as parties to r

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this proceeding Citizens Concer=ed About Nuclear Power, Inc.

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(CCAEP) and Citizens for Equitable Utilities, Inc. (CEU).

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accepted two CCANP contentions and two CEU contentions (both sub-ject to further particulari=ation or rewriting;).

We also deter-mined that we needed further information to rule on.other conten-tions of CEU.

By our Manorandum and Order of June 8,1979, we note'd that the parties were attenpting to reach agreement on the wording of various contentions, and we permitted them to report '

on their efforts by July 2, 1979.

l CCANP has submitted reformulated contentions, and CED has filed a supplement to its original petition setting forth additional information concerning its. contentitms.

The Appli-(

cants and NRC Staff have each commented on all the contentions.

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i At the outset, we would note that both CCANP and Cili have expanded the scope of sone of their previously filed contentions.

As pointed out by the Applicants and' Staff, however, they have not even attempted to demonstrate good cause, as conte = plated-by 10 CFR 52.714(a), why ve. should entertain such

" untimely" contentions. 'Nonetheless, some of those contentions bring into issue potentially serious. safety questions.

Normally we would seek to ascertain the reason for the delay with respect to each contention - for example, did the information giving rise to it become available to the intervenors only after their earlier contentions had been subnitted.

Because there has already been considerable delay in the initiation of this proceeding, we

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have elected not to inquire about the causes of delay but, os

rather, to admit those late-filed contentions which raise, in our opinion,'

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_ significant safety or environmental issues.

a We-take this action on the basis of our balancing the t

five factors speci'fied in 10 CFR 52.714(a)(1):

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(i)

' We are assuning that no good cause exists for failure to file on time - although, as we pointed out, that may not actually be the case.

(ii)

CCANP and CED have no other means effectively to protect their interests.

As we pointed out in our April 3, 1979 Prehearing Conference Order, both the Commission and the 1

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Appeal Board have acknowledged that li=ited appearance state-

~ ments are not a co=plete substitute for participation as a. party.

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Tne extent to which the.intervenors' participation in the development of particular issues may reasonably be expected to assist in developing a sound record is the factor.which we-regard as most significant in the present context.

Absent our admission of the issues, no adjudicatory record at all will be -

made on them.

We have no doubt that the. Staff will attempt to '

resolve any issue which. is brought to its attention.

But to the extent that significant safety or environmental issues are involved and given th'e~ expressed intent of CCANP and'CEU to assist in resolv

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such issues, be believe that ic does'no disservice to the Staff to find that a better record vill likely be created if CCAh?

and CEU participa:elin the resoIution of such issues.

We so. find.

(iv)

CCANP and CIU are the only parties opposed to the licensing of the p.lant; their interests will not be represented by any other parties.

We note that one of CCANP's " late" issues appears to duplicate one of CEU's earlier-filed contentions.

For that issue, we are allowing the CEU contention and not that of CCANP (although we are consk.dering it to be sponsored jointly).

i (v)

Admission of the late contentions will somewhat broaden the issues, but it should not delay the proceeding.

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Staff reports that the Final Environmental Statement is not scheduled to be released until October,1980, and the Safety O

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I Evaluation Report and Supplement are not scheduled to be re-leased until September,1980 and Jariuary,1981 respectively.

rnis proceeding is therefore still in its incipiency.

As'can be seen,from the preliminary schedule which we are here adopting, sufficient time is available thoroughly to explore the " late" contentions without causing any delay in the proceeding.

2.

With these observations in mind, we turn to the partic-ular contentions:

CCANP-2:

Tnis contention puts into issue whether con-("

struction of the facility has been carried out in accordance with

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. applicable requirements.

Six deficiencies were specified in the g

_ original contention.

As revised, three subparagra,phs ((e), ( f).,

and (g)) of the original contention have been deleted, but several others have been added.

(Subparagraphs d., e., and f. of the revised contention correspond to subparagraphs (b), (c), and (d) of the original contention.)

The Applicants and Staff have no obj ection to acceptance of the contention encompassing the prac-tices specified la subparagraphs d.,

e., and f. of the revised contention.

(Tne Staff would rewrite the conten. tion by elimi-nating certain argumentative ter=s and introductory materia.by adding certain appropriate references, and by making various editorial changes.)

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We accept the contention in the form rewritten by the But we also add the practices specified in subparagr'aphs,

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1 1 a., b., and c. of the revised contention (concerning allegedly defective ne=brane seals, missing steel reinforcement bars, and unverifiable cadwelds); these are to be. renu =bered as paragraphs II

[ 4,. 5, and 6 of the contention as rewritten by the Staff.

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Subparagraph g.'of the revised contention; dealing with alleged falsification of records, appears to be the same as the-portion of CIU's Contention 9 which the Staff and Applicants would For the reason set forth earlier (p. 3), we are. accepting accept.

that portion o' the CEU Contention and rejecting CCANP subparagraph!

But we vill consider the CEU Contention as being jointly spon-g.

sored by both CEU and CCANP.

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CCANP in addition lists 5 particular quality assurance def:

.ciencies.

These apparently,are different from the falsification t

- charges appearing in subparagraph g. and in CEU Con =ention 9.

CEU '

as well as CCANP appears to be attempting to litigate some of the five particular QA. deficiencies, but CCANP's contention is more specific than CEU's contention.

The five matters appear to us to be possibly significant safety matters, and we, admit them for that The contention vill be considered to be sponsored by both reason.

CCA3? and CED and is admitted as paragraph 7. (subparagraphs a-e) of

's rewritran contention.

The rewritten contention appears as Contention 1 in the Attachment to this Memorandum and Order.-

CCANP-3:.The Applicants and Staff agree tha: this refor-I malated ce=:ention, dealins with overpressurization, is acceptable.

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We ad #: it in the form set out in the A::achment to this Me=orandu=

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and order, as Contention 3.

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he App'#-=-:s and Staff ea:h s. ate tha: -his c =:e=~1== is a=:eptable.

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' CEU 6 :

This contention raises a question as to the cow-= ilk pathway used by the Applicants in analyzing doses of radioactivityunder10CrkPart50,AppendixI.

The original contention seemed to claim that there weie cows closer to the

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plant than the 5-mile radius employed by the Applicants.in their t

analysis,, and in our April 3 Order we ruled that some greater -

l specificity must be supplied in order to create a valid contention.

No greater specificity has been provided.

Accordingly, we agree k

l vith the Applicants and Staff that this contention should now be rej ected.

CEU This contention raises a safety issue with respect j

- to the availability of nake-up, water'for the main cooling reservoir.

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l In our April 3 Order, we ruled that further particularization of

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j the information anc} data was necessary.

CEU has provided such i

_ further particularization.

The Applicants regard the particular-l ization as an untimely amendment; but, aside from untimelinesi, the have no objection to the contention.

The Staff would accept the contention.

We agree with the Staff that CEU has merely provided t

i information regarding the basis for its contention.

But even if it were untimely, we regard the contention as significant enough i

j to warrant its acceptance under the analysis provided earlier in i

this opinion.

4 We accept the contention as Contention 7, set forth in the Attachoent to this Memorandut and order.

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i CEU-8 claims that the evacuation plan does not confo:s to proposed 10 CFR Part 50, Appendix E (which the Co:=nission has direc'ted to be used as ihterim guidance) in that it fails to pro-vide for evacuation of certain areas which are outside the LPZ.

i Tne contention also raises guestions about the applicability of certain evacuation plans prepared by agencies of the State of Texas.

The Staff takes the position that information on the 1

proxid ty of a school to the facility and the limited applicability:

of state e=ergency criteria is sufficient to raise an issue as to 4

whether emergency planning measures are necessary for areas beyond the LPZ.

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We agree..We note rahat the Applicants perceive the types' "special circunstances" appropriate for invoking evacuation be i

. the LPZ under the proposed regdlations as much more limited in scope than do ve.

Cf. Pennsvivania Power and Lirht Co.

(Susquehanna Stea= Electric Station, Units 1 and 2), L3P-79-6, I

i 9 NRC (Maich 6,1979) (slip op. pp. 30-34).

We therefore I

find it unnecessary to condition the ada.ission of this contention,

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t as Applicants suggest, 3

on the outcome of the additional rulemaking en energency planning which the Commission has recently initiated.

j See 44 Ted. Reg. 41483 (July 17,1979'.1/

)

i We accept the contention in the form rewritten by the Staff.

It is set forth as Contention 8 in the Attachment to t

this m.m andu= and Order.

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That eutec=e could, of course, affect the ultimate resolutten 1

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of the issues raised by this contention.

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CEU-9:

As mentioned earlier, this contention brings into issue a number of asserted construction deficiences.

Only the first deficiency (item 9A) seems to have been raised in CEU's original contention.

The Staff would have us accept this item as rewritten, and the Applicants have no obj ection to our doin~g 1

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.We accept that iten as Contention 2, set ~forth in the Attach so.

ment to this Memorandum and Order.

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-The Applicants and Staff each oppose the remainder of i

the contention because (1) the items are beyond the scope of the original contention and hence are untimely, and (2) they fail to 3

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set forth the precise construction defects involved.'

We reject i

the untimeliness claim for reasons already set forth.

But we

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agree that the remaining items are not specific enough to con-i stitute contentions.

As we stated earlier, however, at least 1

I some of these items are covered by the rewritten Contention 1 which we are accepting.

We accordingly reject the CEU items as separate contentions but, as also stated, we will consider CEU and CCAKP co-sponsors of Contention 1.

1 I

We expect CCANP and CEU to coordinate their presentations i i

l with respect to Costentions 1 and 2 (which in effect we are treat-ing as joint contentions).

They may' engage in separate discove y efforts, as they wish, but, to the extent these issues are con-j sideredatanevidentiaryhearing,CCAhPandCEUwillbeexpected i

to plan their direct evidence and cross-examination so as to avoid j

duplication, to the extent possible.

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3.

We adop: the following preli=inary schedule for this proceeding:

1.

Discovery co:cences Issuance cf this..

Order

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2.

last day f=r sub=ission o' 1

first-round discovery reques:s Neve=ber 5, 1979 3.

Resp: ses to first-round discovery requests December 21, 1979 4.

last day for sub=ission February 22, 1980, cf supple = ental discovery er 30 days after requests service of draf:.

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environmental state-i nen or safe:y eval-

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untion report, which- !

ever is later 5.

Resp:nses to supplemental Within 30 days after discovery request,s service cf reques:

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Turther disc =very requests Within 15 days after en n,ew inferr.a:ics appear-service of yIS er ing in TES or SIR. supple-SIR supplemen:, as sentsi applicable i

7.

Responses to discovery on new infer =ation in yES==

Vithin 30 days after SIR supplements service of request t

It should be noted that supplemental discovery reques:s may

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be based only on inf===atien appearing in newly issued documents or in resp:nses to firs:-round discovery requests.

In the latter however, the request should be subnitted within 30 days of 3

case, service of the first-round response.

Motions for sus-na y disposi: ion may be filed at any time up to 45 days prior t'e a scheduled hearing da:e, with responses to r

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J be filed three weeks thereafter.

Hearing dates are not now being

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scheduled, but it is anticipated that they vill follow issuance

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of the FES.and SER supplement, respectively, by approximately 45-60 days (depending, in part, on wheth'er motions for summary disposition are p~ending).

Testimony in writing will be required to be filed 21 days prior. to the start of the evidentiary hearings during which it is to be heard.

IT IS SO ORDERED.

THE ATOMIC SAFETY AND LICENSING wm e

M.x. lLwL Charles Bechhoefer,, pairman Dated at.Bethesda, Maryland, this 3rd day of Au' gust, 1979.

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Attachment:

Contentions Accepted by Licensing Board W

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ATTAC7 MENT Contentions Accetted'bv Licensine Board:

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1 1.

(CCAKP, CIU) ~

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There is no reasonable assurance rhat the activities author-i i

ized by the operating license for the South Texas Nuclear Project can be. conducted without endangering the health and safety of the ptiblic in that:

1.

There has been a surveying e=or which has resulted i

" -he. eastern edge of the U=i 2 Mechanical Electrical Auxiliary Building b'eing constructed one (1) foot short (in the east-wes: direction) from its design location.

This error violates 10 CFR Par: 50, Appendix 3, Sections X and II.

2.

There has been field construction e=or and as a result, extensive voids exist in the concrete vall enclosing the containment building, in violation of 10 CFR Part 50, j

Appendix 3, Seetions II and X.

3.

In violation of Quality Assurance and Qcality Control requirements applicable to the South Texas Nuclear Project with:

1 regard to document control-(10 CFR Par: 50, Appendix 3, Section:

1 VI and XVII), a field document relating to cadweld inspections has been lost.

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4 There are membrane seals in the containment structure '

which are dam, aged, indicating a violation of 10 CFR Part 50, Appendix 3, Sections X, XV,and XVI.

5.

There are steel reinforcement bars which are missing fro = the concrete around the equipment doors in the contain-and such bars are missing from the containment structure nen:

i as well, indicating violations of 10 CFR Part 50, Appendix 3, t

Sections I, XY and IVI.

6.

There are cadwelds which have been integrated into parts of the plan: structure which are not capable of being verified with regard to compliance with 10 CFR Part 50, Appendix 3, in violation of Sections IX and X of Appendix B.

i 7.

Quality Control as per the requirements. of 10 CFR Part 50 not been, Appendix 3, in particular Sections III and IX, has complied with, because:

Efforts by quality control inspectors to a.

verify that design changes were executed in accord

  • i ance with the purposes of the original design were Y

.epeatedly and systena:ically thwarted.

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b.

There were personnel other than the original designer approving design changes with no first hand knowledge of the purpose of the original design.

There were design changes approved by personnal c.

unqualified in the. type of design where the change was made.

c.

d.

There were numerous pour cards that were supposed to record the correct execution of concrete pours which were falsified by numerous persons.

e.

There has been and continues to be assaults'on the Applicant's quality control inspectors, continual

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threats of bodily harm to those inspectors, firing of inspectors, and other acts constituting a pattern of

.l behavior designed to intimidate the inspectors.

As a result of the intimidations certain inspections were never done because the inspe,ctors decided to play cards i

over a period of four months rather than risk their safety on the plant grounds.

i As a result of the foregoing, the Commission.cannot make the findings required by 10 CFR 5550'.57(a)(1) and (2) necessary for

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issuance of an operating' lice:ne for the South Texas Nuclear

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?toject.

(CCANP, CIU)

I 2.

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NRC inspection records (Inspection and Enforcement Reports i

677-03, 2/77; #77-03, 4/77, and #78-08, 5/78) indicate that South Texas Project construction records have been falsified by employees of Hauston Lighting and Power Company and Brown and Root, in violatien of 10 CTR Part 50, Appendix 3, Sections VI 3

and IVII.

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i As a result, the Coc=ission cannot make the findings required by 10 CFR 5 550.57(a)(1) and (2).

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(CCANP)

South Texas Project Units 1 and 2.are pressurized water Such reactors have experienced about thirty reported reactors.

instances (most of which occurred during startup or shutdown) in which temperature-pressure li=its of the reactor vessels (as reflected in plant technical specificatier.s) in the reactor coolant-system have caused excessive pressures on reactor pressure,

vessels.

The South Texas Nucleat Project does not incorporate t

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o design fearures or administrative procedures which are adequate

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to prevent or ameliorate such pressure transients nor have any technical specifications been pro South Texas Nuclear Project will, posed. for this purpose, The I

therefore, not be in compliance 1

with 10 CTR Part 50.

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4.

(Csu) i The South Texas Project,(STP) Category I structures and equip-

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ment are inadequately designed and constructed with respect l

loadings as de=enstrated by the fact that actual wind velocities to wind, i

associated with hurricanes which have occurred along the Texas Gulf been designed and evaluated. Coast have exceeded wind loadings for Further there are non-Category 1 jeopardize the safe operation of STP. structures containing equipment These non-Category 1 build-ings are not designed to withstand winds generated by hurricanes and if damaged would provide missile type projectiles which could penetrate Category 1 structures which are inadequately protected.

5.

Cray Information is available*/ which indicates that the Staff's l

treatment Table 5.7)(of bicaccumulation of radionuclides in aquat

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organisms is inadequate or in error.

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Toonbs, George L. and Culter, Peter 3., Lower Columbia River l

l Inviron= ental Radiological Survev in Oreson, contracted oy the U.

5. Puol:Lc Healtn Service anc oregon State Board of Health.

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3ryeitong,

, The Nuclear Dilemma, Ballentine Press.

i Geoffrey, Environmental Asoects of Nuclear Po ser, Iicheltz I

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published by Ann Arbor sciences.

19/o j

Chapman, Rice and Price active Zi.nk bv Marine P1ankton.Untake and Accumulat.on of 1,adio-Fish anc She;.efish, J. 5.

i Jisa anc wilclite service Bulletin,las, vol. Ss, pp. 279-92.

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Chapman, Rice and Baptist, Ecolorical'Asoects of Radioactivitt in Tne v.arine 7.nvironment, Environmental Radiation Symposi.um, j

, Johns Hopnins Jniversity, pp.107-80.

3rown, J. Martih, Health. Safety and Social Issues of Nuclear 1

k Power, in k'.

C. Reynolds, ed. Tne California Nuclear Initiative; Analesis and Discussion of the Issues, (Institute for Energy Stucies, Stanfore university, 1976).

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6.

(CEU)

Staff and Applicant calculations of radionuclides deposition j.-

rates do not take into account the relatively high and continual humidity in the area of STP to determine c.ompliance with 10 CFR l

Part 50, Appendix 1.

7.

(CEU) i Due to soil conditions peculiar to this area inadequate water flow in the Colorado River and diminishing, groundwater i

supply cooling, Applicant will not be able to maintain the 7,000 acre

{

pond at a sufficient level to allow continued safe j

operation of STP.

I 8.

(CEU)

Proposed amendments to 10 CFR Part 50 Appendiic E (43 Fed t

are to be used as," interim guidanc 7. R,Ed 37473, August 23, 1978) i in evaluating, inter alia applications for operating licenses.

Such amendnents requ:i.re that emergency plans must, in defined circumstances, extend, as ampropriate, to areas beyond the Low Population Zone (LPZ).

Such requirements are applicable in the l

l case of STP because of the fogoving:

Matagorda Elementary School with an enrollment of a.

more than 80' students, is located approximately 8 miles from STP in a south-southeasterly direction.

Persons at the school would have to travel towards STP in order to ands in Matagorda. evacuate since the only evacuation route, State Hig i-b.

At the.and of State Highway 60 in Matagorda there begins a secondary road, 2031, which crosses the intracoas'tal, canal and continues 6.6 miles down the peninsula, ending on 4

the Gulf.

There are numerous residents in this area who have

,no other route than Highway 60 for evacuation.

j 1

i The evacuation plan formulated by the Texas De c.

L i

t ment of Public Safety is only "in case of nuclear war."part-incomplete plan by the Texas Health Department would not An i

apply to Matagorda as it only covers a 5-mile LPZ.

i Accordingly, the STP emergency plan does not conform to the t

i requirements of the above referenced proposed amendments to 10 CFR Part 50 j

guidelines., Appendix I which are currently effective as int ~eria i

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