ML20063H019

Affidavit of B Bursey Supporting Motion to Reopen Record & Request for Stay Re Unresolved QC & safety-related Matters. Hl Jennings Allegations Proven by Applicant QC Records Substantiate Inadequate Applicant QC Program

ML20063H019
Person / Time
Site:	Summer
Issue date:	08/26/1982
From:	Bursey B BURSEY, B.
To:
References
ISSUANCES-OL, NUDOCS 8209010277
Download: ML20063H019 (4)

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7 AT0t1IC SAFETY AND LICENSING BOARGi - .

DOCKETED

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) .% 60 31 Al0:28 i SOUTH CAROLINA ELECTRIC AND GAS )

COMPANY, et al. ) Docket No. 50-395 DL 1e'

. CT! ICE OF SECRETAR f, '

00CKETING & SERVICF >

Virgil C. sumer Nuclear Station,

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a INTERIENOR'S AFFIDAVIT IN SUPPORT "

0F lt.lTION TO REOPEN THE RECORD ,

AND A REQUEST FOR A STAY _

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In going over the documents made available to me by the Applicant, I believe there are unresolved.QC and safety related matters that necessitate further hearings. The Applican't agreed to provide me the information necessary to look into the ramifications of Mr. Jennings allegations. The Applicant refused to provide me with full names or addressas of former cadwelders._

The Applicant refused to allow me to copy records which made it impossible ---

for Mr. Jennings to review them.

The problem with cadwelds is reflective of a broadar problem with QC. .

There were only two Non Compliance Notices regarding cadwelding during the .

entire construction process, both of which addressed the problem of inade-

. quate Quality Control. NCN 350 (10-26-77) dealt with below standard cadselds- resultt

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from inadequate cadwel' der training. NCN 366 CL(12-29-77) noted that bad' "  ;

cadweld; were passed by QC and pointed out deficiencies in the QC program. ,

Lt-should be noted that the only NCNs of cadwelding/,QC deficiencies were filed a year after Mr. Jennings left the job - and after a significant' (40-50d l

l portion of the cadwelds had been completed, " passed" and covered with concrete.

An earlier document regarding cadwelding was a.' Deficiency gotice l ,

l (April 3,1976) which cited QC for not properly marking rejected splices.

In that splices were either marked passed (with' white spray paint) or failed O K O!hhhhk

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4 (with red paint) one.could infer that " improperly marked" splices were I

improperly certified cadwelds.

,There was a ietter from Mr. Wielkopolski of Gilbert Associates (7-4-74) to Harold.Babb .(SCE&C) Jihich anticipated a compromise of cadweld QC when faced with production pressure: "Our experience has been that working with these three parameters make it difficult for the contractor to qualify sufficient splices to allow reasonable pouring sequences of concrete. Under

/ ' the pressure of schedule, there is a tendency to place concrete around splices for which insufficient tests have been conducted to qualify all the production splices. ' This is an extrem'ely hazardous course'c"' action which we cannot endorse." (emphasis added) --

- It is interesting to note that although Gilbert's fears about insdequately F ' tested splices being' covered with concrete have been borne out, Gilbert and Associ.ates' " Reactor Containment Building Structural Acceptance Test" (GAI Repor;t No. 2278, March 18, P 81) assumed just the opp'osite:

L " Sect. 3.2.2. Reinforcement: Rainforcement in the cylinder, dome, and the .

ma't'conforms to ASTM-A-615-72, Grade 60.' The reinforcement was soliced with s

- cadwelds cao'able of developing the ultimate' strength'of'the bars."i(emphasis added) .

Section 9.4, Concrete Cracking, of the above referenced Gilbert report cryptically not.es, " Stress cracking in the cylinder wall and dome, away from the discentinuity regions of th shell, was not predicted to occur at 65.6 s ,

psig. .Any cra.:ks which might appear were expected to be limited to discontinuity regions, and the cracks were expected to be small in non-L, prestressed reinforcement. "

The unfounded assumption that unpredicted crack'; in the containment are OK, due to the presence of the structural ' tbar - which. Gilbert assumes N

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(in spite of their previously expressed concern) to be up to code.

Gilbert's previous assertions that bad QC on cadwelds poses "an extremely hazardous course of action" (Gilbert letter 7-1-74), their asser-tion that cadwelds were performed to code (Sec. 3.2.27 containment test) '

and their reliance on the codified reinforcement to mitigate unpredicted cracking in the containment structure (Sec. 9.4 Containment Test) are

_. proven specious verbage by Gilbert's most recent submittal. on the issue, which contradicts previous assertions. A letter dated 8-16-82 from Gilbert Commonwealth ' engineers and consultants to C.A. Price,. Manager of Nuclear Engineering, SCEaG, Gilbert asserts, "Even if it is assumed'that the vertical cadwelds have no capacity...the more detailed calculations ccnfirm.... that the tendon capacity exceeds the required capacity."

Putting aiide the question of supplementing vertical rebar capacity

1. with tendon capacity, it appears the Applicant hired Gilbert to juggle their numbers around ("more detailed calculations") until the previously relied upon safety significance of the structural rebar~ vanished into some overpaid consultants' computer.

I have long maintained, and the facts of the instant proceeding substantiate that, given enough money one can hire enough experts to prove anything. It is a bit troublesome that the Applicant hires the same consultant to refute their own data. I have been unable to obtain expert testimony as to the safety significance of systematic' code violations in rebar. I contacted M.H.B. Associates in California, the Union of Concerned Scientists and Weiss and Associates. for assistance. I learned that no one knew of anyone outside the industry with qualifications in regards to faulty rebar in a containment structure.

The Applicant has long been aware of^ serious systematic QC problems and

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. the resulting b 1ow code work on rbbar. The Applicant made a decision (12-21-77 l

Lindler Surveillence Report) to accept all the cadwelds to that date. On l 1

12-29-77 a letter from Dooley to Lindler (SCE&G/QC) cited a reinspection of hil l diagonal rebar in the dome of 390 exposed splices 61, or 15.6%, were " considered rejectable". The documents do not state if these " rejectable" splices were indeed rejected and redone. perhaps they met the fate of all splices done prior to 12-21-77 and were accepted en masse.

. My examination of the cadweld records to that approximate date reflect gaps in visual inspections of cadwelds; Jennings asserts he performed over 1,000 cadwelds (he clearly remembers passing this mark as a comon moment of celebra-tion among the cadwelders) - the-company records show Jennings performed a total of 279 cadwelds. The ccmpany records reflect only 52 were visually inspected.

Jennings postulated the discrepancy in the number of cadwelds he perfonned could be attributed to (1) inadequate record keeping and haphazard OC; (2) the practice of letting other welders " sign eff" on certification, tags to help each other meet production. The certification tags I examined appeared to have

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Mr. Jennings' name in several different handwritings. ,

The Applicant would not allow me to copy the tags for Mr. Jennings' examination of his various signatures.

In summary, all of Mr. Jennings' assertions have been either borne out by the Applicant's own QC records or substantiate the Applicant's inadequate QC program.

Respectfull'y submitted, Mcaos a M FM c2wl 9 (Q, /fD .

n b w 4Ak Brett Bursey, Intervenor B /p' P-Jhc th sex we August 26, 1982 MAh .

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