ML20011A513

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Affidavit Re Contention I-D on Concrete Cover.Local Areas Where Min Concrete Cover Reduced Below Design & Code Requirements Will Not Adversely Affect Structural Integrity of Reactor Bldg.Prof Qualifications Encl
ML20011A513
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/07/1981
From: Gallagher E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20011A456 List:
References
ISSUANCES-OL, NUDOCS 8110130502
Download: ML20011A513 (7)


Text

r UNITE 9 STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNION ELECTRIC COMPANY Docket Nos. 50-483 OL (Callaway Plant, Unit 1)

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AFFIDEVIT OF EUGENE J. GALLAGHER IN SUPPORT OF iML 6 FF MOTION FOR

SUMMARY

DISPOSITION ON THE ISSt'. OF JOINT INTERVENORS'S CONTENTION I-D I, Eugene J. Gallagher, being duly sworn, depose and state:

1.

I am a civil engineer with the U.S. Nuclear Regulatory Commission.

Since February 1981, I have hean assigned to the Reactor Engineering Branch, Division of Resident and Regional Reactor Inspection, Office of Inspection and Enforcement, Prior to February 1981, I was a reactor inspector assigned to the Region III, Reactor Construction and Engineering Support Branch, Office of Inspection and Enforcement.

I was assigned to the Callaway Plant (among others) during the period of December 1977 through September 1980. A state-nent of my professional qualifications is appended hereto as Attachment No.1.

2.

As a civil engineer inspector for the Region III office of Inspection and Enforcement I conducted five inspections with respect to the Callaway Plant, Unit 1, in order to:

(1) ascertain whether adequate quality assurance plans, instructions and procedures had been established for the construction of concrete structures; (2) provide an independent evaluation of the performance, work in nrogress and completed work to

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ascertain w'stner activities relative to concrete construction were ac-complished in accordance with NRC requirements, and (3) review the quality related records to oscertain whether these records reflected work accom-plished consister.t with NRC requirements and lictase connitments. The results of these inspections are conta; rad in the following NRC inspection repcyts:

50-483/77-11, conducted December 13, 1977 through (Attachmeilt No. ?)

January 8,1978.

50-483/78-01, conducted January 10, 1978 through (Attachraent No. 3)

February 8,1978.

50-483/78-03, conducted March 29, April 18-19,1978.

50-483/80-14, conducted. April 10, 1980 through August 14, 1980.

50-483/80-16, conducted June 10-12, 1980.

3.

The purpose of this affidavit is to dddress Joint Intervenors' Contention I-D as identified in the Special Prehearing Conference Order, dated April 21, 1981.

4.

During an NRC investigation, allegations were made by an iron-worker that the concrete cover requirements of reinforcing steel had been violated. The NRC inspector observed local areas where the concrete cover was less then the mir,inum and other areas wnere the maximum permitted cover had been exceeded. A technical disagreement between the NRC Staff and Union Electric & Bechtel Power Corp. arose over an interpretation of the design and code requirements.

Prior to placement of any further concrete on the fourth lif t of the Reactor Building a meeting was held to resolve the issue. The meeting was conducted on January 23, 1978, the rer.ults are documented in Attatr. ment 3, Enclosure 1.

1 5.

Subsequent to the meeting, Union Electric submitted on February 13,1978 (attachment 4) its view which edintained that the minimum concrete cover of two inches could be reduced as a function of placement tolerances.

6.

Attachments 5 and 6 provide the NRC evaluation and position which established that the concrete cover requirement of a minimum of two inches must be Pet by the sixth lif t of the Reactor Building and that the maxinum concrete cover should be in accordance with license commitments a3 stated in BC-TOP-5A.

Union Electric accepted the NRC posit'an and took the necessary action to be in compliance by the pre-scribed sixth lift.

7. requested the NRC to permit a deviation from the maximum concrete cover for two areas in proximity of the electrical penetration banks. Attachment 8 provides the NRC review which permitted the exception.
8. provides FSAR 5 3.8.1.6.2.3 which describes the requirements for placing reinforcing sceel.

Placemert tolerances were held to minus 0, plus 1 inches on exterior walls so as to comply with the NRC position of a minimum two inch cover.

In addition, Union Electric documented that the maximum concrete cover was locally exceeded (as described earlier) around electrical penetrations.

9. 0 provides the ASME working group code interpretation on concrete cover requirements which the NRC utilized in its evaluation of the requirements.
10. The purpose of a minimum cover is to provide an adequate bond with the reinforcing bar and sufficient protection against exposure.

At no point is the minimun cover in the reactor building below one and one-t1ird inches (1/3 of two inches). This degree of cover is sufficient to provide adequate bond and protection against exposure.

11. The purpose of a maximum cover is to assure that there is not too much unreir. forced concrete.

Such concrete is susceptible to tension-related cracks. The cover maximua was exceeded in the reactor building (both above and below the sixth lif t) only in a 0 mall area situated around an electrical penetration bank.

Furthermore, the containment building is prestressed, which minimizes the possibility of cracking and serves to ensure that any cracking that does occur would be localized.

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it is the NRC Staff's view that the local areas where the minimum concrete cover was reduced below design and code requirements and the areas where the maximum cover was exceeded will not adversely sUect the structural integrity of the Reactor Building over the life of the plant.

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Subscribe (andsworntobeforeme this @

day of October,1981.

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My Comission expires:O, On 1, M 9 2-

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LIST OF ATTACHMENTS 1.

Professional Qualificatier of Eugene J. Gallagher 2.

NRC Inspection P.eport 77-11 3.

NRC Inspection Report 78-01, including Enclosure 1, Minutes of January 13, 1978 rxeting 4.

February 13, 1978: Letter from SNUPPS to E. Case, Concrete Cover Requirements for Reinforcing Steel in Reactor Containment 5.

March 6, 1978:

HRC Memorandum, I. Sihweil to 0. Parr 6.

March 13, 1978:

NRC Letter 0. Parr to SNUPPS Reinforr.ing Steel Cover Tolerances in Containment Structure for SNUPPS Plants 7.

July 12,1978:

NRC Memorandum, 0. Parr to R. Mattson, Design Criteria for SNUPPS Plants Containment Structure (Includes two enclosures Letter dated 5/3/78 from N. Petnick to B. Grier and memo dated 7/3/78 from H. Thornburg to D. B. Vassallo 8.

July 28, 1978: NRC Memorandum I. Sihweil to 0. Parr 9.

FSAR excerpt (Section 3.8.1.6.2.3) Tolerances for Placing i

Reinforcing Steel s

10. ASME working group code interpretation on concrete cover l

requirements I

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9 ATTACHMENT 1

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.s-EUGENE J. GALLAGEER 0FFICE OF IriSFECTION AtiD E!iFORCEMENT U.S. NUCLEAR REGULATORY C0t911SSI0ft PROFESS:0NAL CUALIFICATIONS I am a Civ.il Engineer in the Division of Resident and Regional Reactor Inspection, Reactu Engineering Branen, Office of Inspection and Enforcement.

I receivsd a Bachelor of Engineering Cegree in Civil Engineering fron Villanova University in 1973 and a Master of Science Degree in Civil / Structural Engineering from Polytechnical Institute of New York in 1974.

I an a registered Professional Engineer in the States of

!11inois (#37328), Florida (129114) and Louisiana (115375).

I na a cember of the American Society of Civil Engineers, American Concrete Institute e,..

Tau Beta Pi Naticnal Engineering Honor Society.

In my present work at the NRC. I provide technical assistance in the area of civil engineering to Regional offices and resident inspectors with particular enchasis on :he design and construction of reinforced and prestressed concrete structures, foundations, structural steel buildings and in structural testing and surveillance.

In addition, I provide technical input for the developcent and interpretation of industry codes, standards and regulatory requirements, relating to inspection activities.

From 1973 to 1981 I was a nenber of tne tiRC Region 3 inspection staff ressensiole for the inspections of civil engineering aspects of plants under construction and in opi*ation. This included the Inspectiot of i

laboratory and field testing of concrete, steel and soils caterials, earth emoanktents and dams, material sources, piping systens and reinforced and prestressed concrete structures.

In addition, a review of management controls and quality assurance programs were performed at plants under construction.

I participated in approxicately 90 I

inspections of reactor facilities.

Drior to joining the tiRC Staff I was employed by E3ASCO Services. Inc. in i

New York City frca 1973 to 1973.

I perfor ed casigrs of reinforced concrete and steel structures, design of hydraulic an2 water supply systems and preparation of specificMions for constrJction. From 1975 to 1973, I was the civil resident engineer at the Waterford,3 Nuclear ?lant site responsible Sr providing tecnnical assistance to construction.

Curing 1972 and 1973 I was e played by Valley Forge aaboratory in :even, OA perforaing inspection and testinc on concrete, steal and soil matariais.

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ADDIT:CNAL NRC TRAINING i

j Fundamentals of Inspecuan, NRC, February 1973 (40 nours)

.5WR Fundamentals Course, iRC, Maren 1973 ( A0 hours)

Cencrete Tecnnology and Codes, Portland Cement Assec., May 1978 (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />)

Quality Assurance Course, NRC, August 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)

Nondestructive Examination and Codes, Rockwell Int'l., August 1978 (120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />)

PWR Fundacen:als Course, NRC, November 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)

' Welding Metallurgy, Ohio State University, Septencer 1980 (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />) s d'

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E M-s ATTACHMENT 2 1

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