ML20024C994
| ML20024C994 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/15/1983 |
| From: | Rogers J DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20024C992 | List: |
| References | |
| NUDOCS 8307210274 | |
| Download: ML20024C994 (9) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY, et al.
)
Docket Nos. 50-413
)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
AFFIDAVIT OF J. C. ROGERS PALMETTO ALLIANCE'S CONTENTION NO. 6 1.
My name is J. C. Rogers.
I am employed by Duke Power Company as Project Manager for the Catawba Nuclear Station.
I have been employed in this position since 1981.
My professional qualifications are contained in an attachirent to this affidavit.
2.
In the position that I hold, I am responsible for all construction activities at the Catawba site.
3.
The purpose of this affidavit is to address Palmetto Alliance's Contention No. 6, which reads:
"Because of systematic deficiencies in plant construction and company pressure to approve faulty workmanship, no reasonable assurance exists that the plant can operate
- without endangering the health and safety of the public."
alleges that green water in UHI Building is 4.
Mr. Hoopingarner unsafe. - HD Tr. Vol. 1, p. 19; Vol. 2, pp. 66-67.
During construction, the
" green" water stands in the bottom of the blow out chambers of the UHI Building.
These two chambers are open to the atmosphere, collect rainwater and are equipped with floor drains to carry excess water to yard drainage.
This does not indicate an unsafe condition.
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9 8307210274 830715 PDR ADOCK 05000413-O PDR'
__ _ m 5.
Mr. Hoopingarner alleges that scaffold boards were improperly placed on pipes and unistruts.
HD Tr. Vol.
1, P.
19; Vol.
2, pp. 34, 63-65.
Present procedures allow scaffolding on piping greater than 3".
Scaffold boards used to support personnel may be placed on cable tray or unistrut supporting cable tray.
This is allowed by Construction Procedure 371.
Unistrut cable tray hangers are designed for a deal load of more than 600 lbs; therefore, scaffold boards used to support personnel would not affect the integrity of the design.
6.
Mr. Hoopingarner alleges the contact of carbon steel and stainless steel compromises the integrity of the materials.
HD Tr. Vol.
2,
- p. 67.
Design Engineering has no restriction on carbon steel coming into contact with I
stainless steel.
It is normal fabrication practice. to minimize contact where l
possible for cosmetic reasons only, due to rust. discoloration formation.
This in no way will decrease the integrity of the piping.
7.
Mr. Hoopingarner alleges that concrete was improperly poured into forms that were wet.
HD Tr. Vol.
1, p. 22; Vol.
2, p. 69.
ACI 347-11, Section 3.2.13 requires concrete formwork to be sufficiently tight to prevent loss of mortor from the concrete, it does not require them to be caulked or i
sealed.
QA Proce, dure M-2 requires an inspection to verity that the forms are I
free of excess water prior to concrete placement.
It does not require the j
formwork to be dry.
l l
It is unclear,as to when the water was on, the floor, pr2or to placement or after.
If before, it is acceptable because the formwork does not need to.be dry and procedurally the excess water was removed prior. to l
placement.
If it was observed after placement, it was most likely from the lc concrete " bleeding" which is normal during the placement / curing process.
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_m Mr. Hoopingarner states that he was not present during the period from formwork completion to concrete placement, therefore, he does not know what intermediate procedural steps were taken.
8.
Mr. Hoopingarner alleges that certain valves were installed backwards.
These valves have a directional arrow to indicate flow direction.
After craftmen complete erection process, each valve has three inspections that check for proper flow direction, craft post check, welding inspection and mecnanical QC inspection'."
Any errors are detected and corrections will be made as necessary.
9.
Mr. Hoopingarner alleges that the diesel generator room flooded and damaged panels in the area.
HD Tr. Vol. 1, p. 13; Vol. 2, pp 13-17. This incident was documented in accordance with QA procedure Q-1.
The matter
_ was reviewed and. corrective action was taken to assure that the equipment will be restored to an acceptable condition.
- 10. Mr. Hoopingarner alleges that pipes were misaligned.
HD Tr. Vol.
1, p. 19 ; Vol.
2, pp 19-20.
Piping passing through sleeves have staridard clearance requirements established.
A very detailed inspection is performed by QC on these clearances.
Evaluation and necessary corrective action is taken on any deviation.
11.
Mr. Hoopingarner alleges that pipe and rebar have been improperly lying on the ground in storage area., HD Tr. Vol. 2, pp 75-78..Rebar is stored ab'ove the ground for cleanliness purposes.
Prior to concrete being l
placed around the rebar, QA procedure M-2 requires the rebar to be ' inspected p
to insure that it is free of all tags, - mud, oil, or other materials that may adversely affect the bond. Storing it above ground is a preventive measure to assure that this 'M-2 inspection can be passed.
However, for rebar lying on ground, it too must pass the M-2 inspection prior to concrete. placement.
s
4 Piping is cleaned and flushed at later intervals of installation. This process assures the' piping will mket the cleanliness condition for its intended use.
- 12. Mr. Hoopingarner alleges that a welder used a wet or damp rag to quench a weld.
HD TR. Vol.1, pp.11-12; Vol.2, pp.28, 70-71.
The practice of using a wet or damp. rag to quench a weld is presently allowed by the welding program for stainless steel pipe, however, prior approval is required from technical support.
- 13. Mr. McAfee alleges that he has not seen any evidence that the concrete anchor bolt in question (i.e., the one which Mr. Allgood examined) is the length it is supposed to be.
MD Tr. 14.
An ultrasonic test (UT) was performed on the subject anchor bolt.
This test was performed by qualified
'UT personnel and the bolt was found to be acceptable.
14.
Mr. McAfee alleges that blueprints were 'mproperly changed to reflect construction errors.
Any print changes are handled in accordance with QA procedure R-3 or initiated by Design Engineering.
No print changes are incorporated without Design Engineering evlualution and approval.
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Rogers, of lawful age, being duly sworn, state that I-have reviewed the foregoing affidavit, and that the statements contained therein are true and correct to the best of my.. knowledge and behalf.
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Rogers Subscribed and sworn to before me this 15th-day of July, 1983 NOxmcET_ O.(,4nw.Jt% (ld d46'L)
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- JOHN C ROGERS 106 E. LEVIS Il0 AD.,
CLEMSON, $C 29631
. PHONE:
BUS.
l803)831-1512
.HOME
- 803)654-3544 FORMAL IDUCATION Clenson University - BCE (8acheler of Civil ' Engineering) 1949
.ACDIT10NAL TRAININC Advance P.enagoment Development - Duke Power Effective Manogemer.t Program - Harbrldge House Parformance Hanagement Program - Duke Power 2
PROFESSIONAL INVOLVEMENT Registered Professional Engineer - North Carolina (2453) south Caro. lina (2094)
WORK EXPERlJNCE FROM TO TITLE PROGRAM COMPANY
-11/66 Present Project Manager Catawba Nuclear Sta.
Duke Powe McGuire Nuclear Sta.
Oconee Nuclear Sta.
(Total.of 7 nuclear b
units) 4 Rssponsible fc r prov!dt.ng overall site direction for the construction and timely r
completion of nuclear electric senerating stations wl' thin the ' design, budget, code, and star dards required by Duke Power Company and government regulatory
- cg:ncies.
Ses ponsible for staffing the construction organtration with competent, qualificd perionne).and development of schedules and budgets to meet the project cbJcctives.
f esponsible _ for assuring that adequate construction procedures era dsveloped and followed for meeting all. construction activities and regulatory l
rcquirements.
Responsible for. ' interfacing with other Duke departments for the construction a nd completion of the proja' cts. These units'are built almost
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cntirely-with Duke' employees. The scope of the Catawba Construction workforco
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-is 180 exempt managerint, pr.ofessional, and technical empicyees and 3,970 non-j exempt employ < es.
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JOHN C A0GERI l
RESUME PAGE 2 JUNE 13, 198)
WORK EXPERIENCE _
i FROM TO TITLE PROGRAM COMPANY 11/60 11/66 Assistant Aasident Marshall Steae sta.
bukePower l
Engineer Allen Steam Sta.
(4 coal fired genera-ting untts)
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Assponsible f or the direction of all on site constructlen activities for the canstruction of large coal-fired steani electric generating stations.
Respon-
'stblities included the developme'nt of construction schedules, in eeerdination with Duke Design Engineering Department and Duke staan Generator Department.
~
These plants were const'ructed almost entirely with Duke Power construction forces. All anits were completed on or ahead of schedule with costs that were ivore than competitive in the Industry.
i 8/kg 11/60 Various Engineering Three coal fired Duke Power Titles steam electric generating stations (7 units)
Porformed various engineering functions for the construction of coal fired 4 steam electri: generating station.s.
These functions lociuded planning.
acheduling, e stimating, and technical e spport of the craf t organization for coris truction.ictivi t ies.
Received scras managerial ~e.xperience by being in fluid charge af the construction of a water treatment plant, including sarth
- dam and pumptsg station.
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.I jO K1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION f
JU(f { g N > b.
1 z
\\ h QFa:%cru,g2.p[l BEFORE THE ATOMIC SAFETY AND LICENSING BOAR tul f a \\
In the Matter of
)
)
DUKE POWER COMPANY, et al.--
)
Docket Nos.
50-413
)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
~
CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' " Motion For Partial Summary Disposition" of Palmetto Alliance Contention 6 in the above-captioned matter have been served upon the following by deposit in the United States mail this 15th day of July,1983.
James L. Kelley, Chariman Richard P. Wilson, Esq.
Atomic Safety. and Licensing Beard Assistant Attorney General Panel State of South Carolina U. S. Nuclear Regulatory Commission P. O. Box 11549 Washington, D.C.
20555 Columbia, South Carolina 29211 Dr. A. Dixon Callihan Robert Guild, Esq.
- Union Carbide Corporation Attorney-at-Law P. -O. Box Y P. O. Box 12097 Oak Ridge, Tennessee 37830 Charleston, South Carolina 29412 Dr. Richard F. Foster '
P'almetto AlUance P. O. Box 4263 4135 Devine Street Sunriver, Oregon 97702 Columbia, South Carolina 29205
. Chairman Jesse L. Riley.
Atomic. Safety and Licensing 854 Henley Place Board Panel Charlotte, North Carolina 28207 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Chairman Henry A. Presler Atomic Safety and Licensing 945.Henley Place Appeal Board Charlotte, North Carolina 28207 U. S._ Nuclear Regulatory Commission
- Washington, D.C.
20555
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George E. Johnson, Esq.
Carole F. Kagan, Attorney
. Office of the Executive Legal Atomic Safety and Licensing Board Director Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D. C.
20555 J. Michael McGarry, III, Esq.
Scott Stucky Anne W. Cottingham, Esq.
Docketing and Service Section Debeovise & Liberman U. S. Nuclear Regulatory Commission 1200 Seventeenth Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20036 Albert V. Ca Jr.
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