ML20212N247
| ML20212N247 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/03/1986 |
| From: | Arum J, Kelley E, Marbet L FORELAWS ON BOARD |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20212M998 | List: |
| References | |
| 2.206, NUDOCS 8703120414 | |
| Download: ML20212N247 (9) | |
Text
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Pn D . A y c,b0~3 Y f E*E BEFORE THE "0t p[:t :
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U.S. NUCLEAR REGULATORY COMMISSICN In the Matter of: )
Seismic Risk at the )
REQUEST FOR IbTK6ffb#1:53 Trojan Nuclear Power Plant )
OF PROCEEDING TO SUSPEND OPERATING LICERSE
) 00CoU,. ., ;
) November 3, 1986'd* '
Petitioners Forelaws on Board, Elaine Kelley, and Lloyd K.
Marbet, pursuant to 10 CFR $ 2.206(a), hereby petition the Director of Nuclear Reactor Regulation and the Director of Inspection and Enforcement to suspend immediately the operating license of the Trojan nuclear power plant, operated by Portland General Electric Company (PGE), due to PGE's failure to disclose to the NRC and other appropriate authorities conditions that undermine the safety of the reactor in case of seismic event.
I.
PARTIES Petitioner Forelavs on Board is a nonprofit organization dedicated to environmental protection, duly incorporated under the laws of Oregon, with members who live or work in the vicinity of the Trojan nuclear power plant and who are endangered by its continued operation.
Elaine Kelley and Lloyd Marbet are members of Forelaws on Board who are individually threatened by Trojan defects.
8611070119 861103 PDR
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ADOCK 05000344 4NHb II.
VIOLATIONS OF THE ATOMIC ENERGY ACT AND NRC REGULATIONS BY PORTLAND GENERAL ELECTRIC COMPANY PGE has violated the Atomic Energy Act and numerous NRC regulations by failing to disclose the magnitude and extent of the design deficiencies at the Trojan nuclear power plant. These PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 1 350 3 e703120414 87030, PDR p
ADOCK 05000344 PDR EoO - oo23,6
deficiencies became known to Forelaws on Board in October 1986, i
when petitioner obtained parts of some documents associated with litigation between PGE and the Bechtel Corporation on errors in the design and construction of the Trojan plant. PGE and Bechtel settled their litigation and agreed not to disclose these documents.
A.
PARTIAL DISCLOSURE OF DOCUMENTS HAS REVIALED SHOCKING DEFICIENCIES IN THE DESIGN AND CONSTRUCTION OF TROJAN i Representatives of Bechtel Corporation, in conversations with PGE officials, described the structural defects at Trojan as "the worst mistake we have ever seen in a construction project of this size." (Documents Appendix, p. 1)
The design defects at Trojan stemmed from a shortage of qualified manpower available to Bechtel at the time Trojan was built.
i Bechtel was building many other reactors at the time and was spread too thin.
As a result, Bechtel turned to " job shops" to obtain engineering personnel.
One of the Bechtel supervisors referred to these job shoppers as "the engineering equivalent of a Kelly Girl."
Bechtel deliberately concealed this shortage of experienced personnel from PGE and the-public. (Documents j
Appendix, pp. 2-3)
The engineer assigned to design the earthquake-resistant shear walls for the control building complex (Mohammed Ali) grossly underdesigned the shear walls by using a single wythe
(
masonry block construction instead of the conventional poured concrete.
Before Ali designed the shear walls, he made no preliminary calculations to determine whether such a wall could withstand earthquakes. In addition to the control building, Ali PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 2
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a
- 6 was also in charge of building the turbine building. When the i
extent of Ali's errors was discovered by his supervisors, he was fired.
(Documents Appendix, pp. 4-6)
Despite the obvious flaws in Ali's design, Bechtel did not fundamentally redesign the plant but instead attempted an engineering patch job involving the addition of another wythe of ~
masonry on the inside of the existing wythe.
- The void between the two wythes was then to be filled with reinforced concrete .
Unfortunately, this design prevented the reinforcing steel rebar from being continuous around the building, considerably weakenin g the structure.
This fatal mistake stemmed from pressure from PGE management to avoid construction delays and cost overruns.
(Documents Appendix, pp. 7-8)
Assistant group supervisor Leslie Arvai recommended the conservative approach of redesigning the entire plant.
Arvai was over-ruled by project engineer Peter Karpa, who i stated, "Well, as I explained, if you jeopardize the construction i
schedule, then you cause a great loss of money to the client."
(Documents Appendix, p. 7)
In its zeal to avoid cost-overruns, Bechtel sacrificed safety.
. The man brought in to replace Ali, James Edmunds, was woefully unqualified to attempt such a complex patch job. In fact, Edmunds had never designed a wall of any kind before working on Trojan. (Documents Appendix, p. 9)
Edmunds made numerous errors.
He made calculations using the wrong arithmetic factors.
His mistakes were compounded by Bechtel's failure to follow NRC-mandated quality control
{ procedures.
Amazingly, due to understaffing, Bechtel never i PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 3
l checked any of his calculations until after the reactor was '
built.-(Documents Appendix, p. 12) What checking was'done was performed by his subordinates, who were naturally reluctant to expose the incompetence of their boss after the plant was built.
(Documents Appendix, p. 13)
The safety implications of Bechtel's procedures were discussed in a highly critical report by PGE's 1
expert witness, Morris Shupack. (Documents Appendix, pp. 14-16) i After completion of the plant, Bechtel attempted to hide the design deficiencies from PGE. On January 27, 1977, Bechtel refused PGE's request for seismic design calculations. Bechtel tried to perpetuate the cover-up by warning PGE:
We are unsure whether the transmittal of raw seismic calculations Appendix, p. 17) is in our mutual self-interest. (Documents s
Bechtel also made serious errors in the design of the
, internal block walls and the walls of the diesel generator enclosure. (Documents Appendix, p. 18)
Bechtel built double l wythe walls which left too little space between the wythes for grouting, which resulted in voids within the walls that left them structurally unsound.
(Documents Appendix, pp. 19-22) According to Edmunds, this technique was applied to all the partition walls of a similar size, compounding the effect of the error.
(Documents Appendix, p. 23)
An undisclosed study, commissioned by PGE and performed by Preece/Goudie & Associates, left no doubt that there are gross design deficiencies at Trojan. Dr. F. Robert Preece wrote:
This concept of selecting walls willynilly and calling them shear walls and totally ignoring other nearly identical walls clearly demonstrates the design team did not comprehend basic concepts in earthquake resistant design. (Documents Appendix, p. 26)
PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 4 l
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The report indicates that the block walls constructed at Trojan did not even comply with the Uniform Building code for masonry. j (Documents Appendix, p. 27) The report stated that "the entire l design concept is in error" and concluded that the designers of I i
. Trojan were "either naively ignorant or intellectually l dishonest." (Documents Appendix, pp. 36, 34).
B.
PGE HAS VIDIATED THE ATOMIC ENERGY ACT AND NRC REGULATI BY FAILING TO DISCLOSE THE EXTENT OF TROJAN'S FLAWS.
PGE.has violated 42 U.S.C. 5 103 by failing to abide by its -
agreements to " observe such safety standards to protect health and to minimize danger to life or property as the commission may by rule establish" and to "make available to the Commission such technical information and data concerning activities under such licenses as the commission may determine necessary~to promote the common defense and security and to protect the health and safety
'I of the public."
l-PGE has also violated numerous NRC regulations, including the 10 CFR 5 21.1, which requires any individual director or responsible officer of a firm constructing, owning, operating or supplying the components of any facility or activity which is licensedAct Energy orofotherwise 19954, as regulated pursuant to the Atomic amended, or the Energy Reorganization Act of 1974, who obtains information indicating: (a) That the facility activity or basic component supplied to such facility or activity fails to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order, or license safety hazards of the commission or (b) that relating to substantial the facility, activity, or basic component supplied to such facility or activity contains defects, which could create a substantial safety hazard, to immediately notify the commission of such failure to comply or such defect, unless he has actual knowledge that the commission has been PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 5
adequately' informed of such defect or failure to comply.
PGE has also violated 10 0FR Part 50, Appendix A, which specifies General Design Criteria for Nuclear Power Plants. Among the criteria are these pertaining to design bases for protection against natural phenomena:
Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, to perform their safety functions. floods, tsunami, and seiches.without loss The design bases for these reflect: structures, systems, and components shall (1) Appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated, (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena and (3) the importance of the safety functions to be performed.
PGE has also violated 10 CFR Part 100, Appendix A, which sets forth Seismic and Geologic Siting Criteria for Nuclear Power Plants. Part V(a) of Appendix A states:
The design of each nuclear power plant shall take.into account the potential effects of vibratory ground motion caused by earthquakes. . . . The earthquake which could cause the maximum vibratory ground motion at the site should be designated the Safe Shutdown Earthquake.
Part VI(a) states:
The nuclear power plant shall be designed so that, if the Safe Shutdown Earthquake occurs, certain structures, functional. systems, and components will remain These structures, systems, and components are those necessary to assure (i) reactor coolant pressure boundary,(ii) the integrity of the to shut down the reactor and maintain it in a safethe capability condition, or (iii the capability to prevent or mitigate the conseq)uences of accidents which could result in potential offsite exposures comparable to the guideline exposures of this part. . . . The design of the nuclear power plant shall also take into account PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 6
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the possible effects of the safe Shutdown. Earthquake on the facility foundations by ground disruption, such as fissuring, differential consolidation cratering, liquefaction, (d) of section'and V. landsliding, as requ, ired in paragraph The documents disclosed to date show that Trojan was not property designed to withstand the Safe Shutdown Earthquake.
- ~ III.
REQUESTED ACTION Petitioners request that the Director of Nuclear Reactor Regula, tion or the Director of Inspection and Enforcement institute a proceeding pursuant to 10 CFR Part 2 Subpart B to i
suspend the operating license of the Trojan nuclear power plant.
This proceeding should include public hearings in Portland, Oregon, or other location in the vicinity of the Trojan plant.
We also request that the Directors issue an order under 10 CFR I 2.202 to show cause why the Trojan operating license should !
! not be suspended pending completion of the proceeding, based upon a finding under 10 CFR I 2.202(f) that PGE's violation of the
! Atomic Energy Act or NRC regulations has been willful or that the public health, safety, or interest so requires that the license suspension be temporarily effective pending further order.
i We also request an order requiring PGE to provide.to petitioners immediately copies of all documents associated with its litigation with Bechtel over deficiencies or potential deficiencies in the design, engineering, construction, or repair of the Trojan plant.
Petitioners should also have opportunity to 4
conduct discovery (by means of interrogatories, depositions and otherwise) pertaining to the Trojan plant against PGE, Bechtel, i
l PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 7
and their present and former employees, contractors, and consultants.
Dated: November 3, 1986 Respectfully submitted, A /)
A is -
ELAINE KELLEY / -
YJV/K. 'M GKF#
3609 S.E. Rockwo6d Milwaukie, OR 97222 1 142/ S. Bsk Ws Ferry Road oring, OR 97009 J 'Arui, Co-Director LAWS ON BOARD 320 S.W. Stark Street Suite 202 Portland, OR 97204 I
l PETITION FOR PROCEEDING TO SUSPEND TROJAN LICENSE Page 8
i l
.i 1
e
)
~ BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION In the Matter of: )
~ Seismic Risk at the )
REQUEST FOR INSTITUTION Trojan Nuclear Power Plant )
OF PROCEEDING TO SUSPEND OPERATING LICENSE .
)
) November 3, 1986 DOCUMENTS APPENDIX MARCH C,19 f7 j EcorNo ra 2., fon- OtecNTb AVA iL AB l'i T Y.
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