ML20133B105
| ML20133B105 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/31/1985 |
| From: | Johnson T, Teper D CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20133B094 | List: |
| References | |
| OL, NUDOCS 8508060071 | |
| Download: ML20133B105 (9) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00;KETC3 In the Matter of N0 GEORGIA POWER CO., et al.
DocketNos.50-424ang0-g505 ll10:55 (Vogtle Electric Generating Plant, Units 1 and 2) crrice or n & 1-W
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INTERVENORS' STATEMENT OF MATERIAL FACTS IN RESPONSE TO APPLICANTOTION FOR SUPNARY DISPOSITION OF INTERVENORS' CONTENTION 8 1.
As separate intervenors, Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy filed proposed contentions concerning quality assurance.
2.
Applicants strongly objected to the proposed contentions.
3.
As requested by the Board, Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy joined their interventions and attempted to reach agreement with the Applicants on new language for a quality assurance contention. After failing to reach agreement, Intervenors proposed a quality assurance contention to the Board while Applicants attempted to eliminate most of the contention as proposed by the Intervenors.
4.
Based on the information submitted by Intervenors and the responses of Applicants, the Board, by order dated November 5,1984 adopted a quality assurance contention reading as follows:
Applicants have not and will not implement a Quality Assurance program for Plant Vogtle for welding, for properly documenting the placement of concrete, for adequately testing concrete, for the preparation of correct concrete quality test records, for procuring matortal and equipment that mcot applicable standards, for protecting equipment and for taking corrective action as required, so as to adequately provide for the safe functioning of diverse structures, systems and components, as required by 10 CFR Part 50, Appendix B, such that reasonable assurance exists that the operation of the facility will not endanger the public health and safety.
Thus, there is an accepted contention on quality assurance.
5.
By motion dated June 25, 1985 Applicants requested that the Board summarily n500060071 0507 f
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dismiss the contention without hearings or furtnet investigation.
(Atthe initiation of the Commission staf $ the Applicants eac the Intervenors agreed to extend the deadline to August 1 for respondfng to :ne Applicants' motion.) The 6.
In various filings--th0 contention as proposeo, responses to written and oral discovery questions from the Applicants and responses to written and oral discovery questions from the Commission staff--lotervenors-navo pointed to numerous examples of breakdowns in quality assu*ance at F hnc Yojtle.
Intervenors were always very clear that these breakdowns were e,ot so sauch a concern iridividually (important to the protection of the public health and safety though mary of them are) but are of utmost concern because of the patterns of evidence they present of repeated breakdowns at Plant Vogtle, 7.
Applicants have prcatnted new information (contained in the affidavits) without giving Intervenors an opporturity to cross-examine, impeach and rebut the claims trireir,.
8.
Intervenors have not yet selected their witnesses for the QA contention and are continuing to :nvestigate 1*.e issues surrounding it.
9.
Intervenors are in touch wi',1 ctrrent red former workers at the plant, some of whom are willing to testify on QA 4.cncert.
10.
At intier"enors' request, the Government Accountability Project has agreed to assist in t m ongoing investigation.
[Ihe Government AccountaMlity Project is a nonprofit law firm dich protects workers rights It han aade substantial contributinns in variout lic9nsing proceedings tround the nation.)
11.
Breakdue.s in tho' Applicants QA program have been uncovered by the NRC staff, by workers at the phot and by the Applic6nts' own Readitiess Review Program J
- 12. Numerous examples,0f breakdowns in Applicants' QA pr(gram were cited in Intervenurs' "Supplerc+nt to Petition for Leavo to Intarvine Aid Request for a Hea rir.g" ( AptH 1 11,1904). These include:
Repar' tad violatio,'s of I'RC regulations by Applicants in the construction t
methods applied to pipe-fitting and welds must be interpreted as undermining confidence in the capability of coolant and containment systems to perform their essential tasks.
... deficiencies involving welds in containment liner penetrations had been raised as an issue... April 29, 1981... problems involving the appropriate inspection of welds have occurred at least as recently as September 1983...As indicated in IR 50-424/83-15 Appednix A Applicants' construction sheet for examination of reactor coolant pressure boundary welds did not specify the penetrant examination test required by NRC.
Such a failure, not simply in the execution of a prescribed test, but the omission of the test from the required procedure, certainly reduces the confidence in the correct functioning of a vital reactor safety system.
[In another violation.] grit-blasting of the closure head weld cladding of Plant Vogtle Unit 1 (IE X78610) was performed after liquid penetrant examination of the component. This represented not only a departure from the standard procedure of performing the examination on the component in its finished condition but an unintended method of degrading a critical steam system component af ter its final installation and inspection. This is much more than a flaw in an isolated procedure; it is a basic failure in established quality assurance methodology.
Any adequate quality assurance program must take into account a broad range of
" planned and systematic actions necessary" to establish confidence in the system in question. Any quality assuran:e program predicated exclusively on the implementation of dictated procedures without regard to the exercise of critical judgment and standards of professional practice must be considered woefully inadequate.
In an examination of welding activities involving steel structures and supports in both Units 1 and 2 of Plant Vogtle, the Applicants were cited for failure to include the heat-affected zone (HAZ) of the weld in acceptance radiographs...In response to the notice of violation, the Applicants defended their practice by replying that the Code "gives no requirement for including the heat-affected zone in the area of interest" (X78610).
On November 18, 1982. welding on sections of the containment dome of Unit 2 was conducted during a "very light misty rain." The welding and site QA supervisors felt that the conditions were sutable for welding since the surfaces of the pieces were not completely covered with moisture (425/82 02).
The Applicants' responsibility for quality control extends beyond collection of individual defect notification and corresponding remedial action. By failing to make a general assessment of the suitability of the [Transamerica Delaval.
diesel generator system for such an extremely important emergency function, the Applicants have brought their own quality control capabilities into question, undermining confidence in the safe functioning of its operating plant in direct contradiction to NRC QA requirements.
The number of past and continuing failures of the Georgia Power /Bechtel QA/QC program represents a pattern which indicates an undue risk to the health and Violations involving (activities at times resulted from I
safety of the public.
For example, Report No. 50-424, 50-failure to provide documented procedures.
425/83-04 regarding concrete QC problems)
The severity of Quality Assurance performance at Plant Vogtle forced a meeting conducted 22 August 1983 at Georgia Power headquarters on the subject of 3
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Subcontractor Quality Assurance Performance Allegation by Pullman Power I
i Products quality control personnel about pipe spuport installation and piping installation as well as job intimidation of quality control workers.
Allegations had been made by a Walsh Company boilermaker that improper welding and work practice had occurred. Twenty-three concerns which dealt with twelve separate items were discussed. Defects were found during the reinspection of Pullman Power Products manufactured piping spool pieces. (Letter from James P.
O'Reilly [ sic] to Georgia Power, 28 September 1983...)
Procurement failures continue after numerous I & E Bulletins from past QA/QC I
[ Eleven specific examples are then cited in Intervenors' filing.]
inaction.
- Repeated questions have been raised about changes in the Vogtle QAP...[three examples are then cited]
Other allegations from a former employee pertain to improper QA testing of backfill materials and falsification of backfill QC test results.
Four l
allegations made by a former employee pertain to inadequate concrete QC testing and falsification of concrete QC test records. Two allegations were subsequently partially substantiated.
Four violations were also described in the Systematic Assessment of Licensee Performance Board Assessment July 1, 1981 through October 31, 1983.
Yalve mispositioning has resulted in a $40,000 civil penalty.
Testing procedures I
have identified discrepancies involving cadwell operators.
Protection of equipment procedures have been neglected.
Failure to establish adequate radiography procedures and welding procedures places the integrity of the entire plant in doubt.
13.
Intervenors cited numerous examples of the pattern of breakdowns in Applicants' I
.QA program in CPG /GANE's Response to NRC Staff's Second Set of Interrogatories,19 December 1984, including:
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Work was begun although schedules were not prepared for final release of l
construction and field procedures to assure that their development occurred l
prior to the construction activity involved.
l' In 1974, the Georgia Power QA manual did not adequately describe the QA program
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for design and procurement.
The Georgia Power QA audit planning did not include adequate visibility in that the application of all applicable QA criteria was not clear for design and I
procurement.
l-The Southern Services, Inc. QA manual did not reflect the requirements of the then current PSAR Section 17.
The QAE Office Procedures Manual's Procedure QA-04-03 did not include appropriate specification evaluation checklists. At the same time, the QA mar.ual description of organization was inconsistent with functional organization on site.
When, according to the Applicants, in-place compaction tests conducted on-site 4
could not meet the 97% compaction criteria established in the PSAR, the definition of compaction was changed; two versions of the new definition exist.
During concrete placement A-110-003 consisting of a total of 216 yards of concrete at the Unit 2 control building tendon gallery access shaf t, it was noted on two different occasions that the concrete was allowed to accumulate at the end of the conveying pipe to a height of approximately 2 feet above the finish elevation. Vibrators were then used to move the pile of concrete to the required elevation.
GPC Construction Procedure CD-T-02, Concrete Quality control, Section 6.1.9 paragraph 3 states " Vibrators shall not be used for transporting or moving concrete inside the form."
The QC inspector at the batch plant documents his surveillance in a daily log which is stored in the vault under daily inspection files. Any problems encountered at the batch plant during the day of a placement are to be entered in the daily log while the other records for the placement are filed by pour cards number.
The pour card record file and the daily inspection log files must be reviewed in order to review a completed placement record.
Consolidaitn of concrete placement files is necessary.
Slump tests, air tests and temperature measurements were being taken at the concrete lab located beside the batch plant. After testing, the concrete was transported approximately one fourth mile to the pumping equipment.
There is no further testing of the concrete.
GPC Construction Procedure CD-T-02 references ACI Standards as applicable.
The ACI Standards reference ASTM C-172 which makes provisions and requirements for taking samples at the point of placement. This is another example of failure to follow procedures during concrete placement.
There are voids in the auxiliary building concrete. The voids occur in walls which were heavily congested with reinforcing steel, embedment, pipe sleeves and blockouts. Stop work notice number SW-C-13 was issued on 20 Dec.1979 to stop concrete placement.
Fine aggregate test sieves failed to meet requirements of Criterion V of Appendix B to 10 CFR 50...
The Applicants failed to follow Rebar Procedures... Lack of inspection, improper documentation and improper identification of cut rebar appears to be in noncompliance with 10 CFR 50, Appendix B, Criterion V.
Embed assemblies in the Auxiliary Building and the Control Building suffered many defects, including: all of the plate nuts were standard hexagon nuts instead of heavy hexagon nuts; some of the bolts for a given embed plate assembly were not fully engaged with the plate nut; some of the bolts were not i
tack-welded to the plate nut; some of the bolts in a given embed plated l
assembly did not have washers; some of the bolts having washers did not have l
washers tack welded to either the bolt or the end nut; some end nuts were not tack welded to the corresponding bolt; some bolts may have been bent in excess of the design drawing specified thirty degrees; and some bolts may be cracked due to excessive bending.
Three hundred spray nozzles for the containment spray systems, 44 Fisher Control valves and 7 elbows for the reactor coolant piping system were improperly protected. Neither adequate facilities for storing the safety-5
related equipment nor approved procedures had been provided.
The inspector made further investigation and determined that a "QA program is not in operation at Vogtle." [A]n evaluation had not been made to assume that the site was prepared to receive, receipt, inspect and store safety related equipment. The inspector found that although a procedure "Nonconformance Control," GD-T-01, had been written and approved it was not used in conjunction with the " red hold tags" to prepare a nonconformance report and to provide for QA records and corrective action. In summary, the inspector determined that the QA program is not effective, audits had not been scheduled or performed on procedures and personnel in advance of activity to assure proper receipt, inspection, storage and handling of safety-related equipment.
Based on NRC inspection No. 79-17, damage to Category I backfill and possible undermining of Class I structure foundations as a result of 2 Nov. 1979 heavy rains was not reported until 14 Nov.1979 which is an infraction of 10 CFR 50.55 (e)... Backfill around the control building and Units 1 and 2 reactor building foundations will be required.
Moderate to severe erosion and slumping occurred on construction slopes in the backfill.
Backfill around the control building and Units 1 and 2 containment building had been severely eroded by washes and gullies with partial undercutting of some mud slabs. Seepage was visible along the south side of the Unit 2 tendon gallery wall, indicating that the foundatino may have been damaged by sub-surface erosion. The backfill construction slope north of the building was saturated as a result of seepage and showed evidence of partial slumping. Seepage on the backfill slope north of the auxiliary building had been ongoing since Sept.1979.
Stop Work notice SW-C-6 showed backfilling stopped as of 1 Nov.1979 because of seepage. SW-C-7 issued 9 Nov.1979. This is compounded by surprise find of limestone area under the plant which was later found to have cavities.
1 Applicants reported a potential CDR regarding the fabrication and installation of embeds to Region II on 22 Nov.1978. All concrete work involving embeds had been stopped as of 21 Nov. 1978.
However, on 29 Nov.1978... embeds were being installed.
During excavation, "GPC QA or QC personnel had no idea what acceptance criteria wsa necessary for determining the proper bearing strata until they were enlightened by this inspector.
I feel there is a definite deficiency or lack of interest on the part of GPC [ Georgia Power Company] QA-QC personnel toward projecting ahead into the construction schedule and predetermining critical checkoff points in the construction sequence where required acceptance criterion must be met."
14.
Intervenors filed more than twenty pages of written responses to Applicants second set of interrogatories (relating to QA) (excluding document production which amounted to hundreds or thousands of pages) which described many more examples of the pattern of QA breakdowns.
15.
Intervenors filed more than twenty pages in response to Applicants' fourth set of interrogatories (also excluding documentation), providing still more examples of the pattern of breakdowns in Applicants' QA program.
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16.
Douglas Teper, in a deposition for which the transcript ran 355 pages, described more examples of the pattern of breakdowns in the Applicants' QA program.
17.
Intervenors cited numerous examples of failures of the Applicants' Quality Assurance (QA) Program not as contentions in themselves, but as evidence of a pattern of failure of Applicants' QA program.
The fact that Applictnts have failed to address the failure of the QA program to identify deficiencies but rather have limited themselves to attempting to rebut the specific failures one by one, demonstrates both a failure to understand the contention and a lack of understanding of the purpose of a QA program in the first place.
Indeed, Applicants' response in itself is one more piece of evidence of Applicants' lack of an adequate QA program for Plant Vogtle.
18.
Applicants' Statement of Material Facts similarly addresses the wrong issue.
The question of whether individual problems have been solved avoidt the Intervenors' and the Board's concern about root causes and generic implications of the QA breakdowns.
Moreover, the majority of items 1 through 25 discuss written procedures which are supposed to be followed during plant construction. Unfortunately, Applicants have failed to follow the overwhelming majority of these proceedings, as evidenced by scores of documents at the Public Document Room. The simple recitation of procedures (which Applicants have failed to follow) does not relinquish Applicants from explaining the past pattern of violations, a pattern which presents a threat to the public health and safety. A QA program is more than paper, it is hardware and work.
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- 19. The NRC staff does not and cannot inspect every item of the plant to back up Applicants' program, rendering insufficient Applicants' claim that investigation should be avoided due to the lack of NRC notices of violation in certain areas.
The inadequacy of the QA program in all areas admitted by the Board has been sufficiently demonstrated that hearings on the concerns are necessary.
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20.
Applicants' motion severely mischaracterizes Intervenors' case.
The personal attack on Douglas Teper was uncalled for and unnecessary.
Mr. Teper was frank in his responses to the Applicants' questioning during deposition, a deposition which took a 355 page transcript.
In this 355 pages, Mr. Teper cited numerous examples of Applicants' violations of NRC regulations, as well as informing the Applicants that he had spoken with a former worker at the plant who might testify as to specific shortcomings in the quality assurance of welding at Plant Vogtle.
Mr. Teper's candor, rather than being praised by the Applicants, was attacked; his confirmation that he is not an engineering expert in quality assurance is cited by the Applicants as grounds for dismissing the contention, a bizarre twisting of the Intervenors' case.
Applicants failed to cite Mr. Teper's repeated citations of Applicants' violations of NRC regulations, and similarly failed to cite Mr. Teper's explanation that he is an expert on the Georgia Power Company and its management practices.
21.
Intervenors have not selected their expert witness or witnesses on QA. As Intervenors explained to Applicants, Douglas Teper is the only individual who has worked on this contention that Intervenors might use; he is not, however, the only person who has worked on this contention (nuclear physicist Marc Merlin, formerly with the Rand Corporation, and Tim Johnson have also, as the Applicants were informed), nor is he likely to be the only witness for the Intervenors in the proceeding. Additionally, Intervenors will use cross-examination to help carry their case at the hearing stage.
Respectfully submitted this, the 31st day of July,1985, Tim Johnson Douglas C. Teper Campaign for a Prosperous Georgia Georgians Against Nuclear Energy i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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00LKETED
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USNRC GEORGIA POWER CO., et al.
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Docket Nos. 50-424 and 50-4250L-
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(Vogtle Electric Generating Plant,
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'85 AllG -5 A10:55 Units 1 and 2)
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CERTIFICATE OF SERVICE
[0CNTbGNiNih BRANCH This is to certify that copies of the foregoing Response to Applicants' Motion for Summary Disposition of Intervenors' Contention 8 and the Statement of Material Facts related thereto were served by hand or by deposit with the U. S. Postal Service in the City of Atlanta with first class postage attached to be delivered to the Secretary of the Commission, the members of the Licensing Board and all others listed below, this 31st day of July,1985.
i Tim Johnson SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Comission Director Washington, D.C.
20555 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulatory Comission Southern Company Services, Inc.
Washington, D.C.
20555 P. O. Box 2625 Birmingham, Alabama 35202 Bruce Churchill, esq.
Shaw, Pittman, Potts & Trowbridge Bradley Jones, esq.
1800 M Street, N.W.
Regional Counsel, U.S. NRC Washington, D.C.
20036 101 Marietta Street, Ste. 3100 Atlanta, Georgia 30303 James Joiner, esq.
Troutman, Sanders, Potts & Trowbridge The Candler Building Atlanta, Georgia 30303