ML19351D532

Responds to 800905 Ltr Re Halt of Const at Facility.Forwards Comments from Concerned Individual Regarding Suspension of Const at Facility

ML19351D532
Person / Time
Site:	River Bend
Issue date:	10/06/1980
From:	Pollard R, Weiss E UNION OF CONCERNED SCIENTISTS
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8010100353
Download: ML19351D532 (10)

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ScismTisTs October 6, 1980

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Victor Stello, Jr., Director Office of Inspection E.nd Enforcsment U.S. Nuclear Regulatory Commission i

Washington, D.C. 20555 i

Dear Mr. Stello:

This is in response to your letter cf September 5, 1980 concerning the River Bend facility which UCS received on September 10, 1980. You will recall that on July 21, 1980, UCS,' acting on behalf of an individual who wishes to remain l anonymous, requested a halt of construction at the River Bend '

facility.

As discussed by telephone with member of your staff on September 2, 1980, we sent a copy of Instiction Report 80-08 to the individual on September 12, 1980. Ths individual's ,

comments are enclosed exactly as received excipt that they H have been retyped and information that could lead to identi-fication of the individual has been deleted.

Some of the comments contain information a tsic6 NRC's jurisdiction. Therefore, we are sending a copy t) Mr. Stephen Irving of the Public Law Utilities Group in Batol Rouge, Louisiana so that he may bring these matters to tue attention of the Louisiana Public Utilities Commission if he believes such action is appropriate.

UCS wishes to add to the individual's comments the following three points:

First, your stated basis for declining to suspend construction at the River Bend facility is completely at odds with the nature of the licensing process and makes a nullity of the requirement )

that applicants demonstrate a strong-quality assurance program as a requisite to issuance of a construction permit. In your

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l letter of August 18, 1980, you state that " suspension of cor.- g l struction is not warranted at this time as this project is in 0 its very early stages of construction." " Consequently, the Yl\ t, f ,

allegations questioning the adequacy of certain construction '

practices do not presently bear on public health and safety as

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operation of'the facility is yet some-years away." Extens' ton i 4

of that " logic" would lead to the conclusion that there is i no need for any safety review by NRC at the construction permit e stage. However, the principal purpose of reviewing an applicant's quality assurance program prior to_CP issuance is to ensure that l 4

the plant will be constructed properly. i

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1 i As you are certainly aware, your inspectors cannot and do j i not attempt to verify the adequacy of each safety related part ,

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of a plant.'. Instead, you rely on the licensee's quality assurance j program during construction to ensure that the plant is properly

. constructed and does not " unduly" jeopardize public health and  :

safety when operation begins. In recognition of this, quality I i assurance is often cited as the cornerstone of reactor safety.

. Therefore, to argue as you do that an inadequate quality assurance program is not sufficient grounds to halt construction is contrary I to the Commission's reasons for requiring an acceptable quality l

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assurance program at the CP stage. Moreover, the stage at which quality assurance deficiencies are discovered is completely l irrelevant. Whether at the beginning or the end of construction, l when discovered they must be corrected.

4 Second, your investigation to date has evaded the main thrust of the individual's concerns. The original complaint

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noted explicitly that suspension of construction was needed to l remove the pressure which is contributing to the lax practices

! and the fact that, once constructed, both investigation and .

. correction of mistakes become more expensive and, hence, much  !

j less likely. Furthermore, as the individual notes in the

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attached comments, several allegations of construction deficiencies i

, have in fact been confirmed. The fact that the utility is in  !

2 the process of correcting those deficiencies confirms the

accuracy of the allegations. The remaining question, still

unanswered by your investigation, is whether the quality assurance program is adequate to assure that other construction deficiercies do not exist.

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Third, Inspection Esport 80-08 states that Regulatory Guide 1.131, dated August 1979 is only issued for comment. The fact is

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that Regulatory Guide 1.131 was first issued for comment in August 1977. Thus, the implication that-Stone & Webster promptly l accepted the guidance is not accurate.*/ Furthermore, the

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• Please note the individual's request for a copy of Stone & Webster's December 12, 1979, position statement on Regulatory Guide 1.131.

Please send UCS a copy to forward to the individual.

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important question is not whether Stone & Webster accepts the Regulatory Guide, but whether the licensee, Gulf States Utilities, accepts it. The Inspection Report states that Gulf States Utilities still has not decided; thus the allegation is shown -

to be correct.

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If you desire any further intx ution from the individual, please let us know promptly.

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Rok.s it D. Pollard

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dcluar Safety Engineer

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Ellyn R. Weiss Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 cc: w/ enc 1.

Stephen Irving Anne Plettinger commissioner John Ahearne Commissioner Peter Bradford

, Commissioner Victor Gilinsky J

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Sept. 27, 1980 4

Ms. EllynDWeiss

. Harmon & Weiss 1725 I St., N.W. .

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Suite 506 Washington, D.C. 20006 Dear Ms. Weiss w; )

Thanks for your letter of Sept.'12. I have at last had a I chance to look it over. Some of the NRC responses to the L allegations are pretty evasive. Other responses acknowledge  ;

the truth of the allegation, and then draw a conclusion that i there is no safety related result. I must disagree.

Before going into the r.pecifics of the matter, I'd draw your attsntion to tha list of GSU personnel who were present 4 at the NRC audit. Included are Jim Hudson and Ernie

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Troncilliti, both of whom were fully conversant with the problems... Thus, it is true that GSU was aware of numerous l deficiencies in their cables and cable trays, and was under-taking to find answers, but this does not change . the fact l that the deficiencies existed; the material was not in con-formance with the criteria. Therefore, it does not behoove

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the NRC to say it was.

Now, regarding the allegations:

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a) If the 600 V power cable is not to be shipped until after

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August 25,1980, ' then the schedule must have been changed.

Also, we.are told that test results will not be available

, until early in 1981. Will Okonite be permitted to ship before satisfactory test 5results are available? If not, then there is a serious impact in the construction schedule, l which shows a cut over 50 months from date of commencement. i

Are saa to believe that GSU will accept these kinds of delays?

l Also, if'the' site activities only involve splice identification, then how will they go about qualifying these splices, or are we to believe that they plan to single out those lengths of cable that contain splices for "non-Q" application only? l l

b) -We are told that S&W has issued a position statement on

, Reg Guide 1.131 on December 12, 1979. I have been unaware until now that such a statement exists. I'd te interested in seeing a copy. If S&W, indeed, accepts with no exceptions, Reg Guide 1.131, which was issued some years af ter the PSAR

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was issued, are we to believe that GSU and itt. agents accept

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with no objection ex post facto rule-making?

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c) Regarding the matter of thermocouple extension wire and 300 volt instrument cable, NRC' acknowledges that ,the vendor, i indeed, violated the spec, and that Stone & Webster subse-quently revised the spec to accommodate.the vendor. Is this procedure acceptable to the.NRC? Also, if NRC plans to take no action until the licensee can assure trace-ability through the certificate of conformance, will

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Rockbestos be permitted to ship this cable? If the cable does not have a clear pedigree, then if a failure occurs

• while the plant is in operation, how are we'to effect a correction? Surely the temperature readings carried by j the thermocouple extension wire are important enough to warrant very special efforts, beyond merely adjusting the specification for the convenience of the vendor. After

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all, we must assume that the vendor bid on the job with his eyes open, and had every opportunity to take the necessary exceptions before any contracts were signed.

d) We are told that some 17,000 pieces of cable tray have been shipped to the field, all of which is aluminum. We are further told that a number of N&D's (Ncnconformance

& Disposition Reports) have been issued against some of

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-these trays, the last of which being dated June 18, 1980.

The NRC report says that this last report has not yet

,- been dispositioned, and yet the NRC report is dated August

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19, over two months after the issuance of the NED.

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Does Stone & Webster routinely take over two months to disposition an N&D? If Stone & Webster's Engineering Assurance Procedures, and their River Bend Procedures Manual, which govern their operations on the River Bend

Project, have been approved by the NRC, do these documents

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permit a two month delay in answering an NED? Does the NRC truly believe that Stone & Webster's Operations Center kept the field waiting with nonconforming cable for over

, two months with no answer? Also, how can the licensee

' assure that these nonconforming trays will not be used as is? And how do they propose to deal with post-installation

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damage?

e) It.is true that Husky's seismic design calculations were reviewed'by the. cognizant engineers at S&W before shipment 7' took place, k'at the NRC report acknowledges that the first

, shipment of cable tray,.in December of 1979, took place

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some five months before Husky received PE signoff on their

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• r design. Thus the allegation is shown to be correct.

The relevant question is, why isn't the operation monitored closely enough to cover this kind of sloppy activity? Are there other items on the site that are similarly uncovered by PE signoff, despite spec requirements?

f) [I] must respectfully disagree with the NRC's statement that the use of two different types of cable in the same circuit at River Bend's run to the makeup water structure does not violate good engineering practice. I suggest that they will be hard pressed to find a competent cable engineer

, to endorse such a practice. For one thing: in the case in question, the ground braids used on the two cables are made of different materials, which is definitely not a recommended practice. The main rationale behind the decision to use two different sizes of cable for the run to the makeup water

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structure was to save money, and it is highly doubtful that this design had the endorsement of Stone & Webster's cable specialist.

g) We are told that Stone & Webster's electrical installation spec allows a rung to be removed to allow the necessary bending radius. This does not answer the allegation, as it does not prove that such tray is seismically qualified.

The tests that were performed on the tray did not have any rungs removed. Husky can pr6ve the seismic capabilities of their tray with a rung removed either by analysis or by test, but if they do it by analysis, then that, too, should

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be signed off by a PE. Also, if they have seismically

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proven their straight cable trays, how do we know that the fittings would meet the sama criteria? Finally, if

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Addenduni 5 to Spec 241.320 deleted the requirement that  ;

a PE sign off on the seismic design requirements in a COC i

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i prior to shipment, did the NRC approve of this deletion?

Was a change taken to the PSAR?

One more thing; we are told that cable tray began arriving

at the jobsite in December of 1979, and none has been installed '

to date (which would be August 19, 1980). Are we to believe that GSU has had cable tray in inventory at the site for eight months, without any attempt .to install it? Was any inquiry made about this waste by the Louisiana Public Utilities commission? Will GSU deny.that they paid Huskiy nearly

$10,000 in overtime to obtain early delivery of the cable

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trays?

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h) . I must regretfully state that the NRC's answer to the

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question about the spec that sizes the SkV and 15kV i

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cinsulated power cable is a lie! Any comparison between

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what in called out in Calculation E46H and what is nca '

ordered on Anaconda in the spec, and all addenda, as well as tables of reel assignments, will show that E46H is totally obsolete, and that the cables have been ordered 2 l- to conform to E120. 346H was done several years ago, and ~y ~

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was correct when it was done, but since that time, the circuit length estimates have changed, the loads have changed, and, indeed, even the cable impedance tables have changed. Thus, S&W's contention that they are using an obsolete calculation to order 5kV and 15kV power cable is totally in error. They are using the best i information they have to date, which is in E120. Which brings us back to the original contention, that S&W does not challenge, namely, Calculation E120 has not

been approved.

i i) The NRC's answer does not address to the allegation.

For starters, if there are no Category I applications for 15kV power cable at the site, then why is it ordered in i- Specification 241.232, on whose cover sheet appears the words "I Nuclear Safety Related"? Does GSU just like to spend money? Also, has the NRC actually examined the  ;=<r" table of insulated 15kV power cable sizes contained -in*""-

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Design Criteria 241.100 and found 250=MCM= copper cable?

If it does appear in that,tableffwas it r'ecently added, via the latest revisidh?~ I doubt that the 250 MCM cable that was ordered was covered in the Design criteria as of

! the time it was ordered.

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The NRC states that no fabrication of cable has been i initiated. And yet the cable tray, on which the cable is to be supported, was delivered in December of 1979, but not installed. Are we to believe that the cable vendors have accepted these delays without insisting on massive price adjustments? Also, how do they propose i to meet the 400,000 BTU /hr flame test requirement, and when? If the test must be made on a " production run of

cable"'and they are not yet into production, it would seem that they have something of a problem. And what if their cable fails the flame test. If it's in production, are we to believe that they will throw out a whole pro-duction run? or is the test itself strictly pro forma, eyewash that proves nothing? If so, then why run it?

Anaconda stated last June that they were, in fact, ' in production on the cable, and .nat they planned to deliver

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it to the jobsite shortly after the August 25 field 4

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required date. Now they .tell the.NRC that they are not

- in production. Perhaps a call to their.Marion, Indiana plant would be fruitful.

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The key to the problem would seem to be GSU's construction' schedule. They tell their vendors and others that they are on a 50 month construction schedule, and yet they tell 4 the NRC that they have not begun to install either cable or cable tray months after this activity was to be well under

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way if'their schedule was to be met.- We know that the cost

, of the plant has escalated from an estimated $400 million-at design inception to an estimated $1.7 billion now, 4 and that they are down from two units to one unit and that they have invited minority interests to share in the power plant. At current interest rates, a delay of a few months in incredibly expensive for GSU. They have a tremendous financial incentive to meet their fifty month

. construction schedule; thus - their assurances to the NRC that they have delayed construction, or that they have delayed installation of the 600 volt power cable, lacks credibility.

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Finally, I have a problem with the last statement in the

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NRC report, "No items of noncompliance or deviations have been identified." That contradi~ cts the body of their own report, to wit:  :

(1) Allegation: " Factory reworked areas of 600 volt power and control cables have not been qualified..."

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Inspection Results: . . . Qualification work...is in

- proc ress. . .a fabrication hold has been in effect. . .Eecause of c eficiencies. . . Activities at the site involve identification 4

of cable splices, not qualification..."

t (2) Allegation: " ...there will be no direct traceability (of) the (thermocouple extension wire and the 300 volt instrument cable)"

Inspection Results: " . . . traceability is made from the conductor to the reel through the resistance test reports...

No action will be taken until the-licensee can assure traceability..."

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(3) Allegation: ...the conductor tests will be performed on a bulk basis..."

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Inspection Results: "For the instrument cable, conductor testing is performed on the ccmpleted cable...

A specification revision is in process...Rockbestos has requested a change. . .to supply a (COC) in lieu of actual test reports..."

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6-G (Al Allegations- "Large amounts of cable tray have been damaged in the field..." 4 Inspection Results: ".. 82 trays nave been identified l as being damaged...N&D has not been dispositioned"

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(.5) / Allegations "

...none of the repairs proposed have met the' seismic qualification criteria."

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Inspection Results: ...the dispositioning is awaiting...

approval of Husky recommendations ~and seismic calculations...

these recommendations are in the review cycle; thus, no repairs will be initiated until it can be assured that the seismic qualification criteria will not be violated."

(61 Allegation: "Large (amounts) of cable tray have been shipped.without Husky...having complied with the... requirement that their seismic qualification criteria must be approved by a professional engineer."

Inspection Results: ."...the first shipment of cable

, tray to the (jobsite) (was) in December, 1979. The required l certificate of compliance was signed on May 20, 1980 by the responsible Husky professional engineer..."

(.7) Allegation: "Tne power run to the makeup water structure is done with two entirely different type (s) of cable...".

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Inspection Results: ...there are two types of cables -

a single conductor for cable tray and conduit applications and a three conductor cable for direct burial applications..."

NOTE: .The single conductor cable is actually being used in an underground duct bank application.

(8) Allegation: "...it is (sometimes) necessary to remove a rung (in the cable tray) . (This) has not\been proven to be seismically qualified."

" ... atone & Webster is currently Inspection Results:

reviewing the seismic acceptability of removing a rung..."

Thus, within the body of the NRC's own report we find eight items of noncompliance that they acknowledge.c And, as stated above, if.we were to examine the files, we'd find that Anaconda, indeed, stated that they had commenced pro-1

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duction,vdespite S&W's claim.that they had not. In fact,

, it would'belinatructive to review S&W's job book against S&W's Expediting Department records in this regard.

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l Indeed, the body of the NRC's report alludes to the existence i

, of "N&D's" on the job, which.are defined as "Nonconformance  !

and-Disposition Reports." Thus, mere conversance with the English language would indicate that nonconformances exist, at least in the opinion of S&W's field people. 1 I'd strongly recommend that we petition the NRC to amend "

their report to correct the concluding statement to read "Certain items of noncompliance or deviation'have, indeed,

been identified, with the following resp 6ns~e~by'the licensee;..."

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