ML20137D472

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Requests Board Consider,During OL Hearings,Concerns Re Required Drainage for Excessive groundwater,micro-earthquake Indications,Earthquake Design & Deficiencies,Leakage in Westinghouse Steam Generators & Settling of Structures
ML20137D472
Person / Time
Site: North Anna, 05000000
Issue date: 05/20/1977
From: Allen J
NORTH ANNA ENVIRONMENTAL COALITION
To: Coufal F
Atomic Safety and Licensing Board Panel
Shared Package
ML20136A555 List: ... further results
References
FOIA-85-363 NUDOCS 8508220493
Download: ML20137D472 (5)
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NORTH ANNA $NVIRONMENTAL COALITION P.O. BOX 3951 Mr. Frederio J. Coufal, Chairman CHARIUPTESVILLE, VIR3 INIA 22903 Ato::11e Safety & Licensing Board (804)293-6039 U.S. Ruolear Regulatory Consniesion May 20,1977 Washington, D. C. 20555 In the Matter of Virginia Electrio and Power Company North inna 1 & 2 Operating uicense

Dear Mr. Coufal:

The North Anna Environmental Coalition (NAEC) has serious corcerns about the imminent licensing of the improperly sited and defootively constructed North Anna nuolear power station.

NAED study has led to the writing of the enolosed letter to Mr. Ernst Volgenau, NRC Director of Inspection and Enforce-ment. The letter is being sent to you and the Atomic Safety and Licensing Board with the fonnal request that the issues listed be explored formally on the record cf the upcoming Operating License Hearings

a. Remedial drainage required for excessive groundwater
b. Abnormal and differential settling of key structures into water-filled clays (sapro-N lite /halloysite)
  1. c. Micro-earthquake indications along the North s

Anna fault and Neuschel's Lineament

\ . Earthquake d design deficienotes

o. Severe leakage problems in Westinghouse steam generators Although these site-related issues are signifloant and of construction importance, they were not considered at either North Anna Construction License Hearing. They appear to have come to light after the 1974 hearing on the North Anna fault sone (with its site-approving decision) and after the installation of micro-oeismic monitoring equipnent (with its registering of faulting near the den and activity along the extrapolation of the North Anna reactor faults). Thus the necessity for consideration by your_ Board of these matters which bear heavily on "VEPCO's perfonnance in the construc-tion...of North Anna Units" and their safe operation as questioned in Contention fl.

Another consideration also appears to have grown in algnitionnoe and dubiety:

f. VEPCO's financial ability g G2 g 3 050722 G7h DELLUS-363 PDR

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Although VIPCO's financial situation was explored during the first session of the current hearing, several matters have changed since that time. Construction was stopped on Surry Units 3 & 4 on Maroh 18, 1977, a change from VIPC0's answer j to Interngstory 4.9 on November 12, 1976 that "There are no plans to abandon the construction of either North Anna 3 and 4 or Surry 3 and 4."

VIPCO's Proscootus of March 2,1977 states that " Cancel-lation of certain construction projects would result in sub-i stantial costs not being recoverable except, to the extent per-mitted, through rat % making procedures" whereas in 1975 and 1976 the Prospectus statement had been i "The Company's experience to date in connection with construction deforments indicates that these commitments can be deferred or cancelled without material penalty."

I It appears that the question of who will bear the Surry can-

! collation oosts will ultimately be decided by the Virginia

! State Corporation Commission whose deliberations would be of interest to this Board.

The Coalition also believes that this Board should con-sider certain contradictions or irregularities in the ERC j record of assessment of YEPCO's financial fitness to construct nuclear facilities.

On April 24, 1975, Mr. A. Schwencer of the Mtc wrote the Coalition that it was then the position of the 1910, as it had l

been in August aid December of 1974, that VIPC0 had " reasonable assurance of obtaining the funds necessary to design and con-struct Units 3 and 4 at North Anna and Surry as well as to com-plete Units 1 and 2 at North Anna."

It now appears that on November 19, 1974 Edwin Triner, RRC's Director of the Offloe of Program Analysis-Regulation, sent FEA a " response concerning the availability of nuoloar generation by 1980." On page 2 of Attachstent 2 of that response, under the heading FACTORS LIMITING HUCLEAR St07fH, both North Anna 3 and Surry 3 are listed in a coltaan marked " Financial Di f ficult ies ."

Which NRC information is to be believed that giving "res-sonable assurance" of funds, or that noting " financial diffi-cultles"?

s e e . (

Was the NRC Staff, along with Mr. Triner, privy to un-favorable financial information regarding VEPCO which had not been made known to the Atomic Safety and Licensing Board that made the favorable finding?

Are there today internal NRC documents, comparable to those described above, that suggest conclusions at variance with those in prepared testimony? that suggest " financial difficultied' attendant upon the operation of North Anna Units 1 and 27 How will the NRC assess VEPCO's financial capability to operate North Anna safely if the Virginia State Corporation Commiesion should fail to grant the rate increases for North Anna start-up costs and Surry 3 & 4 cancellation costs?

NAEC respectfully requests that this Board make a thor-ough examination of the foregoing financial implications.

g. Abnormal Settling at Surry NABC recognises that the Board has decided against ex-ploring the histcry of Surry construction, but the parallela

! between the handling of abnormal and differential settling at Surry during operation and the attention to abnormal and dif-forential settling at North Anna during construction are worthy of Board attention -- particularly as they reflect upcn VIPCO's "corrmitment and technical qualifications" under question in Contention #1.

The REGULATORY INVESTIGATION REPORT of Surry Settlement (Nos.50-280/75-1and50-281/75-1) is one of the most broadly revealing documents in regard to VEPC0 management and integrity.

As you probably recall, the problem of abnormal settling at Surry was finally made known to the NRC not by YEPCO but by a

" confidential informant" on May 7,1975 althcugh the problem had been known to VEPCO since 1972. The efforts of a deter-mined insurance inspector to prod an intransigent utility

! are detailed in the correspondence in the REPORT which should i certainly be a part of any record which deals with VEPCO's nuclear management and probity. We enclose it for your most l thoughtful examination as you consider North Anna monitoring.

h. The Need for Rock Anchors The NRC IJiR OUTPUT of May 20, 1976 contains the following entry on North Anna 3: DESION/PABRICATION ERROR explained as l

i

- - - - --. ....m , _ _ - , - _ _ _ _ _ . . - _ _ - - . - _ _ _ _ _ - _ . - - _ _ _ _____-,..,...m.,_ ____ . . _ _ _ _ _ _ __ _ _ m

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" DESIGN DEFICIEICY. Lack of adequate safety margin for earthquake forces and uplift forces due to water under structure. Rock anchors added to in-tegrate foundation with rock."

NAEC questioned and questions why North Anna Units 1 and 2, constructed on the same wet fault, would not also require rock anchors. It would appear to take a very credulous board to be satisfied with the explanations offered by YEPCO on April 25, echoed by the IWtc Staff on May 12 (pages 26 and 27 of enclosure with Counsel Swanson's letter of that date).

Surely the Board mast question why YEPCO chose foundation elevations and structure dimensions and foundation subgrade materials for North Anna 3 and 4 which were more vulnerable in_

an earthquake than those of Unita 1 and 2. Does it demonstrate proper " commitment and technical qualifications" to have in-creased the seismic susceptibility by " design deficiency" in Units 3 and 47 Perhaps the answer is to be found in an exhibit from the Show Cause Hearing of 1974. E13, notes from a Stone and Web-ster meeting of June 2,1973 on the Chlorite Seam Problem, con-tains the following entry:

"3. Ef fects of fault

-plane of weakness

-Por 1 & 2 bad

-Could design for 3 & 4, but don't want to.

Admit 44 prob. then."

Although it was " bad" for 1 and 2 in 1973, it was probably al-ready too late for the installation of rock anchors at that time.

To have installed them in 1970 would have " admitted a problem,"

recorded in photographs in 1970; but not formally recognized or admitted until three years later.

NAEC respectfully requests this Board to explore on the re-cord the implications of the lack of rock anchors for Units 1 and 2, and the presence of rock anchors for Units 3 and 4.

(A Note regarding Show Cause Exhibits: Many exhibits have grown in geological significance since 1974. E9, Notes of an ABC meeting of November 13, 1973 call for a " review of every possi-ble authority on the subject" of "saprolyte" but not until 1976 did the NRC request a study on saprolite by the Arny Corps of Engineers.)

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1. Justice Department Report Since 1975, the Justice Department has been studying the YEPCO situation in regard to both faulting and settling.

The original report was finished on October 28, 1975, and work has continued since that time.

NABC believes the Board, before it makes any decision on VEPCO's commitment to operational integrity, should re-quest and study all Justice Department reports.

Limited Appearances NAEC was gratified to read in the Board's Order of March 30, 1977 that at the reconvened hearing the Applicant and Staff would " respond to questions raised by those who made limited appearances." Local citizens who made limited appearances on November 30, 1976 have just recently begun to receive written replies. Since several of them have found these replies unsatisfactory, they are particularly interested in having the Board explore these significant issues on the record, raising questions to elicit complete answers.

It is possible that citizens who were unable to attend the 1976 hearing my ask to speak briefly at the 1977 segment.

It is also possible that there may be requests to speak to the new contentions under consideration. Given the holiday weekend, the number expected is small.

NAEC has continued its study of the North Anna situation since the 1976 hearing, and may ask for a few rooments to make un updated limited appearance.

We are appreciative of the Board's scheduling and other pressures upon its time. We know that your position is a dif-ficult and even an historic one.

Thank you for your professional consideration.

Sincerely, June Allen (Mrs. P. M.)

Enc. Presidont, NAEC CC: ASLB Counsel for VIPCO, NRC, Intervenor Arnold, State of Virginia ACRS NRC 1 & E

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