ML20028C785

Suppl to Request for Hearing & Petition for Leave to Intervene,Listing Contentions.Certificate of Svc Encl

ML20028C785
Person / Time
Site:	Columbia, Washington Public Power Supply System
Issue date:	01/10/1983
From:	Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-CPA, NUDOCS 8301140106
Download: ML20028C785 (7)

Text

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. 6** UNITED STATES OF AMERICA 003ETED-

'"!W NUCLEAR REGULATORY COMISSION -

~ BEFORE THE ATOMIC SAFETY AND LICENSING BOARDg 313 @ M3

'In the Matter of )

) ym: i,.Dif-WASHINGTON PUBLIC. POWER SUPPLY SYSTEM, -) Docket Nos t50960 CpAin.'b..'-

et. al.

) 50-397 'CP'A -

) .

(WPPSS Nuclear Projects Nos. I and 2) )-

C0ALITION FOR SAFE POWER SUPPLEMENT TO REQUEST FOR HEARING AND PETITION FOR LEAVE TO INTERVENE-Pursuant to an Order dated December ~ 15, 1982 of the Atomic Safety and Licensing Board in the.above-captioned proceeding..the Coalition for Safe Power hereby submits its Supplement to Recuest for Hearing and Petition for Leave to Intervene. -The contentions the Coalition for Safe Power seeks to have admitted in this proceeding .

as follows:

CFSP 1

-Petitioner contends that delays in the construction of WNP-1 and 2 have been under the full control of the WPPSS management.

The Applicant was responsible for the delays and the delays were dilatory and thus Applicant has not shown the " good cause" as -

required by 10 CFR 50.55 (b).

WPPSS cites the following reasons for requesting an extension on WNP-1 and 2:

1)-changes in proiect scope due to regulatory actions (pri-marily improvements as a result from the lessons learned l from the TMI-2 incident), -

2) construction delays and low productivity; '

3) labor strikes;

14) design changes; and

5) delays in delivery of eculpment and met.epials.

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8301140106 830110 PDR ADOCK 05000397 O PDR _

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7 House Report No.. 96-1452. " Evaluating Nuclear Utilities

performance: Nuclear Regulatory Commission' Oversight",.0ct.

t 2,1980 summaries the . management problems that have effec ted the -WPPSS.

plants:. '

t Region V has in recent months . sharply escalated _its enforce-ment activities relatin6 to - the Washington Public Pov.er Supply. '

System construction of. a major system of nuclear reactors.' At present, the utility hasLno nuclear reactors in operation.

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Five are under construction by WPPSS.. however, and its first.

unit is meant to be operational.in two years.- As. Region V enforcement documents disclose, the construction of-that unit  :

has been plagued with severe quality assurance problems. .Those

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problems have resulted in repeated NRC enforcement .mae tings with '

the WPPSS management-and recently with Washington State officials-  :

concerned about the utility's apparent oroblems, p.44 '

Once again, the absence of an acceptable quality.assurarce  ;

program has significantly contributed to the emergence of  ;

these problems. In several. cases the faulty work was dis-covered so la te that there is some question about how or even i whether adequate corrective work can be done. p. 44 _

~ r Moreover, the quality assurance program at the site nas been I so deficient over the past four years that records that w,uld  :

have disclosed the results of tests on some other construction  !

work have been lost outright. requiring 100 percent reinspection of some work and "re-qualification" of. procedures. This apparent  !

massive confusion at the WPPSS site ha's been partly attributed i by an NRC inspector to WPPSS' difficulties in managing a large array of contractors doing construction work, including safe ty- j i

related work...The inspector observed that the,7 Licensee i management had not been effective in requiring contractor -

l compliance with specification requirements, p.46 Corroboration of the WPPSS difficulty in overseeing its contractors is found in the early 1978 falsification of certain welding ' records by lower level personnel in the  !

' mechanical contractor's organization. Despite the sertousness  ;

- of those findin.us of falsification, they did not appear to be --

l as significant as the far more widespread quality assurance problems of lost records and inadequate testing data, p.46 i The problems expertenced by WPPSS in attempting to construct its first nuclear reactor heighten the Committee conaern over the need for NRC identification of major management pr,blems at utilities prior to the issuance of an operation license. p.47 l

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The Washin6 ton State Senate _ Energy A' Utilities Committae "WPPSS Incuire,"a report to the _ Washington State Senate 'c the 47th Legislature, March _1, 1981. examined - the "causes of. cos t 7ver.

runs and schedule delays on the five WPPSS: Nuclear Power Plants."

The Committee identified a number of areas of management.

failure, each of which:significantly contributed to the cost and schedule problems on the projects...The cumulative impact of these deficiencies leads the Committee to conclude:

WPPSS mismanagement has been the most significant cause of cost overruns and scheoule dalays on the WPPSS pro'ects.-

(emphasis added) WPPSS Inquire supra, Executive Summary.

Specially, the Committee concluded that evidence was lacking

+c to show:

that the officially adopted completion dates for the plants are used by WPPSS management to monitor or control the

. progress of work at the plant site. Supra, p.22 The report further states:

this finding is consistent with the findings of the Administ-rative Auditor's team of experts. As stated in the S-1 Report:

'The team was told of four or five levels of schedules which were said to be in use on the Supply System projects. How many of these are useful and used was not clears , There was -

evidence that all are waiting for the next one ,which will ,

show everything. ' Supra, 7 Applicant has had full control over the labor difficulties .

upon which it blames construction delay. Labor disputes hsve been tied to WPPSS management:

l Because contractors, continue to receive full payment of profit and overhead during a labor dispute, their incentive to bargain in good faith and reach an early settlement is reduced... Additionally, the projects schedules

- are potentially delayed because contractors have less economic incentive to reach early settlement of labor disputes. Supra, p. 28-29.

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JLabor . representatives . told' the Committee - th'a't' WPPSSE management' problems reduced' labors' productivity in fiv~e general categories:

POOR CONSTRUCTION MANAGEMENT PRACTICES POOR ENGINEERING POOR COORDINATION OF SCHEDULES LOW WORKER MORALE

, POOR SAFETY PRACTICES AM

D. PROCEDURE

S. Supra, p.45.

The Committee requested WPPSS' response but did not receive it.

However, the report quotes a Mr. Mc Elwee of WPPSS mana ement:

We have never claimed and we do not claim that low a productivity is the fault of labor. Low productivity j

is generally our fault, management. Either the. material is not available when and where it should be or the engineering is not available when and where it should be, or the equipment or we've gotten interferences or  :

our planning .is incomplete or what have you. ' Supra, p. 45 46.  :

The Committee determined that WPPSS 's claim that on half of the cost overruns (including the cost of delay) were caused by regulatory

-- requirements to be unconvincir.g. It was (based on a limited stud 7  ;

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of WNP 1,2, and 4) that chan6e orders caused by reghlatory require-  !

ments fell in the range of 5 to 11 %. Supra, p. 45. The Committee j 4

] concluded that .

I WPPSS does not have nor has it ever had, an effective change ,

management system. The failure of WPPSS management to  !

institute such a system is a direct and principal cause of project schedule delays. Supra, p. 38 i and the Administrative Auditor found that-  ;

I Changes directed by the Nuclear Regulatory Commission  !

were found to be significant but not necessarily  !

controlling and never more important than the lack of I lack of timely engineering and procurement. (emphasis added)  !

! S -1.,Re por t, p.2-6.  !

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The comittee also concluded that this' matter had been brougth to' the tihe attention of WPPSS management numerous times to no apparent i

avail. Supra, p. 39. .

Applicant states that " changes in project scope due to regulatory actions" and " design changes" caused delay in construction. It:is, however,

is difficult to see how just such a conclusion was made give the findings of tte WPPSS Inquire

WPPSS does not record the added cost or time of rework done as the result of regulatory changes or any other causes...Mr. L.E.

Buchant, the director of a Boeing consultatn team examining WPPSS change management system, testified Sept. 19, 1980,.that WPPSS.

was incapable of accurately measuring the effect of regulatory changes. Supra, The Comittee concluded that WPPSS management directly affected the procurment of materials:

Integrated management [ adopted by WPPSS at all sites by 19793 affected all aspects of project administration'and construction.

It slowed pecurement and design, interferred with material and engineering support of construction, contributed to unnecessary rework, added to acess and interferred with problems on the job

__ site, and confused inspection.

Particularly harmful [conseque'n'ces] were restrictions' on employment in materials inspection. Inadequate quality inspection capa-bility has created an extensive back-log of uninspected high priority materials stockpiled on site, which cannot be released for construction.

WPPSS Inquiry, supra, at 34.

Thus, it is concluded all Applicant's alleged reasons for con-struction delay have been attributable, directly or indirectly, to WPPSS management and thus do not constitute a showing of " good cause."

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• CFSPT2 .

l Petitioner contends tha t the pending rcouest for an extension for the construction ner. wit for WNP-), pursuant to 10 CFR So.55(b), is invalid due to the " deferral" of continued con-structien for up to five years. More ove r, the request is n-t a "reasonsable period of time" as required for the Commission to grant such an extension.

By January, 1981 Applicant had already gone 65 months over an original expect'ed construction schedule of 60 months. Suora,

p. 20 On April 29, 1982 the WPPSS Board of Directors decided to.

" defer" construction for up to five years. The Washington State Senate Energy & Utilities Committee concluded that evidence was.

lacking to show that "the officially adopted completion dates for the plants are used by WPPSS manaEement to monitor or control the progress of work at the plant sites." Supra, p.22, Furthermore, WPPSS management has taken responsibility for construction delays:

Low productivity is generally our fault, management. Supre, p.45 Petitioner submits that the time necessary to comple te

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WNP-1 given its prior manaEement and schedule history in combination with a delay of up to five years constitutes an unreasonable Seriod of time.

CONCLUSION The above stated contention met the requirements of 10 C.R 2.714(b) and should be admitted as issues in the above-captioned proceeding l

i Respectfully submitted hjew- PM Eug ne Rosolie Coalition For Safe ??wer Qg *

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UNITED STATES OF. AMERCIA .

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NUCLEAR REGULAT07Y C0?*'ISSION .

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 83 3113 NOM 4 In the Matter of )

) Docket No. 50-397CP,gs'h7tCEg WASHINGTON PUBLIC POWER SUPPLY SYSTEM ) 50i460Cfr;ANCH (WNP-l&2) )

)

CERTIFICATE OF SERVIC E I hereby certify that coales of COALITION FOR SAFE POWER SUPPLEMENT TO REQUEST FOR HEARING AND ?ETITION FOR LEAVE TO INTERV in the above

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captioned proceeding have been served on the following y deposit in the or call U.S. Mail, first Federal class,10th Express, day of. January,orasindicatedbyast8rskbyexpress this 19 3:

Herbert GRossman, Chairman

• Nicholas S, Reynolds ASLB Debevoise & Lieberman USNRC 1200 Seventeenth St. N.W.

Washington, D.C. 20555 s Suite 700 Washington, D.C. 20036 Glen 0, Bright Administrative Judge ASLAB Panel ASLB USNRC USNRC Washington, D.C. 20555 Washington, d,c. 20555 State of Washington Dr. Jerry Harbour Energy Facility Site Evaluation Administrative Judge Couno 11 ASLB Mail Stop PY-11 USNRC Olympia, Wa, 98504

~~ Washington, D.C. 20555 D6cketing and Service Section A Elaine I. Ch n USNRC Council for NRC Staff Washington, D.C. 20555 Office of Executive Legal Director Gerald C. Sorensen ~ USNRC Manager, Licens ing Program Washington D.C. 20555 WPPSS 300 George Washington Way Richland, Wa, 99352 46  % e-M ina Bell -

Intervenor for CFSP i

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