ML20235H567
| ML20235H567 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/07/1987 |
| From: | Steele W AFFILIATION NOT ASSIGNED |
| To: | Murley T NRC |
| References | |
| NUDOCS 8707150181 | |
| Download: ML20235H567 (5) | |
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1 7 July 1987 Nuclear Regulatory Commission Attn: Mr. Thomas Murley Washington D.C.
20555 j
Dear Mr. Murley:
1 Thank you for responding to my letter dated April 20, '1987. The last sentence in your response dated July 2 Such changes require considerable prior review within the NRC to ensure that the changes do in fact improve safety and that the costs of such changes are commensurate with the safety improvement." must mean that you made an astimate of the cost of the requirements changes q
as detailed in my letter. If nothing else, when I asked you to comment on the PSNH independent audit concerning the increase in cost of constructing the Seabrook Plant which resulted from NRC requirements changes, why didn' t you give me the costs you l
estimated while approving the changes versus what it has actually cost to implement those changes! Please forward a copy of the f
cost / benefit analyses used in your decision-making process.
l Secondly, do you consider how much the rate payers are willing to 1
I pay for electricity when you do the cost
/ benefit of a
requirements change or do you believe the shareholders should forfeit the difference between what the costs of changes are versus what the state Public Utility Commissions are willing to allow utility companies to recover in rate base?
Why doesn' t-the commission give the consumers in each state the facts and via referendum decide whether to implement a change? As it stands today my investment dollars in PSNH have in effect been
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expropriated by a combination of goverment agencies (NRC and PUC j
with the refusal of a
state government to participate in i
evacuation planning thrown in for good measure.)
Thirdly, I would like to know when the NRC expects to make.a n
decision relative to a rule change which would allow the NRC to license a
plant despite the refusal of state and local N
RfC authorities to cooperate in the evacuation planning process. The oo comment period was scheduled to end May 5 but was extended to Jun oo 5.
ff Finally, why did the NRC refuse to grant a low power license to op the Seabrook owners back in March 1987 as recommended by the
$T Atomic Safety and Licensing Board (ASLB)?
How many plants have A
been refused a
low power license when given a
favorable k$
recommendation by the ASLB?
Is the NRC caving in to political 042 pressure from
- senators, congressmen and governors from the Northeast? I thought the commission's job was to make decisions based upon facts and not political expediency.
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I certainly would appreciate a prompt reply to this letter.
Sincerely,h b
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PIPING AND SUPPORT CHANGES Between 1973 and 1979 the N RC imposed many regulatory changes which aff ected the design and installa-tion of piping and other equipment supports. Requirements for pipe supports at the beginning of the project were covered under the power piping code and took only five pages to list. By 1974 regulatory requirements for supports were so numerous that they filled an entire volume of the Boiler and Prassure Vessel Code. The impact of these voluminous changes could not be realized until installation of the supports began in the early 1980s.
Other NRC changes affecting supports included extensive documentation and reanalysis requirements, many more quality assurance procedures. revised earthquake vibratory frequencies, and requirements for seismic design of non safety components. As a result, larger and more complex supports nad to be made to ht l
within the structures at much higher costs in engineenng and erection.
PLG found that the additional work on piping and supports from these several events is an impact on the pro-ject schedule of 7 months and a cost of $405 million. PLG found that PSNH took prudent steps to minimize change and applied resources to overcome the schedule extensions resulting from the new requirements.
44 % months 7 months OUALITY ASSURANCE EFFECTS Quality assurance is a fundamental aspect of nuclear power plant design and construction, ensuring that the plant's structures, systems and components will perform satisf actorily in service A strong quality assurance program is essential to the success of a nuclear power plant project. Several nuclear power plant projects were cancelled hrgely because of quality assurance-related problems. Others have been substantially delayed. P LG evaluated the Seabrook Station quality assurance program in detail and found that this program was managed prudently. However, the Seabrook project incurred significantly increased costs in implement-ing its stringent quality assurance program. These costs may be considered as an " insurance premium" for the entire Seabrook project because they were incurred to protect the likelihood that Seabrook Station would ultimately provide service to customers.
Quality assurance costs for nuclear power plants that were completed in the early 1970s represented about four percent of the direct craft hours. Thus,it was reasonable for PSNH to assume in 1972 that quality assurance costs would remain low. However, a large increase in quality assurance requirements occurred after 1972 and greatly increased costs and adversely affected construction worker productivity. Quality assurance programs are very extensive, encompassing many volumes of procedures. The rrograms are audited on an ongoing basis by outside organizations such as the NRC as well by the utility constructing the plant.
PLG has determined that the evolution of more stringent interpretations of N RC regulations and the issuance of hundreds of associated new standards since 1971 accounted for 6% months in the project schedule and
$445 million of the project cost.
l 50w months 6% months Msb 2 PicKARD, LOWE AND GARRICK,lNC.
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..c FINANCIAL CONSTRAINTS The project schedule and cost have been severely affected by financial constraints.
- 1980/1981 Financial Constraint - This restraint on the project resulted from the legislature reversing a decision by the New Hampshire PUC to permit Construction Work in Process to be included in the rate base. Cash flow restraints caused PSN H to reduce its ownership share. The pace of project construction was slowed for a period of about 13 months. between March 1980 and April 1981. Project activities in engineering, procurement and construction were slowed significantly by the financial constraint which was aggravated by Massachusetts regulatory delays.
61984 Work Stoppage - Following the announcement of an increase in the estimated cost of the unit in March 1984 PS N H's banks were unwilling to extend their revolving eredit agreement.
This bankers' decision and the resulting financial problems caused work to be suspended from April 18 to J uly 23,1984. The work stoppage occurred during an advanced stage of construction when piping, pipe supports, electrical, instrumentation and control, heating, ventilating and air-1 conditioning systems and equipment were allin critical stages of installation and startup testing activities were becoming critical for many systems.
9 1984/1985 Financial / Regulatory Constraint - The same external banking financial problems that stopped work in April 1984 led to commitment limitations u ntil October 1985 when full fu nd-ing was restored Orders of the New Hampshire Public Utilities Commission' limited"expen-ditures between April and July 1985.
The total effect on the project f rom these actions by the legislature, regulators and the banks was found to be 18 months of schedule and a cost of $744 milliott PLG found that in each instance PSN H was effective in implementing manpower reductions while protecting sunk costs. Management minimized adverse effects, maximized the benefits of the available cash flow and began planning for construction restarts.
68% months 18% months OTHER SUPERVENING EVENTS Other events were analyzed and their ripple effects quantified. In total, these add 11 months to the schedule and a cost of $ 771 million. PLG investigated the results of 12 other events which became known after the pro-ject was planned and determined that they had no effect on the project schedule. However, these events did account for $456 million of the project cost.
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79% months 11 months i
PICKARD, LOWE AND GARRICK,INC.
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SUPERVENING EVENT: An un3xpected occurtsnce subsequent to project start that was beyond the control of project manangement.
CONSTRUCTION PERMIT DELAYS The initial project schedule was based upon receipt of the construction permit for Unit 1 by December 30, 1974. The permit was received on July 7,1976, over 39 months after the application was filed with the N RC d
and 18% months beyond the expected start of construction. The uncertainty of the licensing process caused an additional month of mobilization time after the permit was issued. Examination of the record indicates a major contributing f actor of the delay was the protracted N RC review and hearing process which was exten-ded by intervenor activity during the licensing proceedings. PSN H aggressively expedited the licensing pro-cess and resolution of contested issues during the entire period. There is no indication that PS N H, Yankee or UE&C contributed to any portion of the licensing delay.
The effect of the unforeseen delay in issuing the construction permit was a project extension of 19% months and a cost increase of $315 million.
- ' 19% months CONSTRUCTION PERMIT SUSPENSIONS Two separate suspensions of the construction pertrit delayed the project. On November 9,1976 the EPA Regional Administrator,without warning, reversed his prior approval of the once-through cooling system. The construction permit was suspended by the NRC unt:e the EPA again approved the once-through design. In 1978 delay recurred when the U.S. Court of Appeals,in response to intervenor activity, found that the EPA Administrator had violated proper procedures in reversing the' Regional Administrator's decision. The N RC suspended construction for three weeks while re-examination of the issue took place. On these occasions PSNH actively pursued every avenue to expedite the resolution of the inter agency disagreement and res-ponded prudently in managing the effects of the suspensions.-
The two constnJction permit suspensions contributed 9 months to the project schedule and cost $198 million.
28% months 9 months 4
4 PICKARD, LOWE AND GARRICK,INC.
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gRREGy o
UNITED STATES n
NUCLEAR REGULATORY COMMISSION
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W ASHINGTON, D. C. 20555 JUL 0 21987 Mr. William D. Steele 4951 Santiago Way Colorado Springs, CO 80917
Dear Mr. Steele:
Your letter of April 20, 1987 to the Office of Inspection, King of Prussia, Pennsylvania was referred to me for response.
Regarding the information you presented, the U.S. Nuclear Regulatory 1
Commission (NRC) has not investigated the basis for any of the reported claims by the independent consultant. Therefore, I am not in a position to dispute the factuality of the claims.
i However, you should be aware that the NRC has a responsibility to protect the health and safety of the public. That responsibility carries with it, during each phase of a nuclear plant's licensing review, the requirement to make certain that design, construction and operation will provide the required public protection.
Plant design changes during construction may be required by the NRC as a result of additional information that could affect safety.
Such changes require considerable prior review within the NRC to ensure that the changes do in fact improve safety and that the costs of such changes are commensurate with the safety improvement.
l Sincerely, Thomas E. Mur:cy, virector Office of Nuclear Reactor Regulation O L -,. o a ? n /l.
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