ML20133F235
| ML20133F235 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/30/1985 |
| From: | Harris J, Lenahan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133F075 | List: |
| References | |
| OL, NUDOCS 8508080197 | |
| Download: ML20133F235 (16) | |
Text
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DCtKETEr BEFORE THE ATOMIC SAFETY AND LICENSING BOARD WC
'85 A!S -7 N0:56 In the matter of
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Georgia Power Company, et al.
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Docket Nos. 50-424 LFFICE C~ F h tar -
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50-425 00CdETu46 c. 3EPViu B m CH (Vogtle Electric Generating
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Plant Units 1 and 2)
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AFFIDAVIT OF JOHN R. HARRIS AND JOSEPH J. LENAHAN IN SUPPORT OF
SUMMARY
DISPOSITION OF PART OF JOINT INTERVENORS' CONTENTION 8 (QUALITY ASSURANCE)
John R. Harris and Joseph J. Lenahan state under oath that:
1.
We are Reactor Construction Inspectors with the Nuclear Regulatory Commis-sion Region II and have acted in that capacity since January 1977 and June 1978 respectively.
In that capacity, we have made numerous inspections of concrete and foundation construction activities at the Vogtle Electric Generating Plant.
We are personally knowledgeable of the matters set forth herein, and the statements made are correct to the best of our knowledge.
Statements of our professional qualifications are attached (Attachments A and B).
2.
The purpose of this affidavit is to respond to the Applicants' Motion for Summary Disposition of Joint Intervenors' Contention 8 (Quality Assurance).
The specific areas addressed in this affidavit are allegations regarding concrete and backfill expressed by Joint Intervenors.
Details on these allegations are discussed in the following paragraphs.
8500090197 850005 PDR ADOCK 05000424 0
Tests Were Taken At The Batch Plant Rather Than The Point of Placement 3.
This allegation, which is stated on pages 232-235 of the Teper deposition, is based on statements appearing in NRC Region II Inspection Report Nos. 50-424, 425/78-09 and 50-424, 425/79-14.
In these reports, the NRC inspector noted that sarrples for testing of slump, air, and temperature were being obtained at the concrete laboratory instead of the point of placement as required by procedure CD-T-02. The inspector identified this as contrary to procedure requirements and a Notice of Violation was issued in each instance.
4.
Followup of this item in subsequent inspections by NRC inspectors showed that the Applicants' Quality Control (QC) inspectors were retrained in procedural requirements and that testing was performed on samples taken at the point of placement.
The results of these inspections are reported in NRC Inspection Reports Nos. 50-424, 425/79-01; 50-424, 425/79-05; 50-424, 425/79-07; 50-424, 425/79-09, 50-424, 425/79-11; 50-424, 425/79-12 and 50-424, 425/80-08.
This variance from procedural requirements did not have any adverse effect on the quality of the concrete as the travel time and distance (one-fourth mile) from the concrete lab to the point of placement was too short to cause any changes in the properties of the concrete.
Fine Aggregate Test Sieves 5.
This allegation, which is stated on pages 225-227 of the Toper deposition, resulted from a Notice of Violation identified in NRC Inspection Report No. 50-424, 425/79-01.
As a result of an NRC inspection of the soils and
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concrete laboratory on January 10-12, 1979, Georgia Power Company (GPC) was cited with an item of noncompliance for failure to calibrate the sieves used in gradat-lon testing of concrete aggregate and soils as required by American Society of Testing Materials (ASTM) standards.
6.
In response to this noncompliance, GPC developed calibration instruction C-Cl-35.
The development of this procedure was discussed with NRC inspec-tors, and its implementation was reviewed by NRC inspectors during NRC inspections performed at the Vogtle site on March 26-28, 1979, June 12-14, 1979 and July 24-26, 1979. The results of these inspectio s are reported in Inspection Reports Nos. 50-424, 425/79-05; 50-424, 425/79-11; 50-424, 425/79-13 and 50-424, 425/81-09.
Review of the calibration data for the sieves showed that the sieves which had been previously used for gradation analysis met the ASTM requirements.
Thus, the quality of the concrete was not affected by failure to calibrate the sieves.
Cadweld Testino Procedure 7.
This allegation, which is stated on pages 217-220 of the Teper deposition, is based on statements appearing in NRC Inspection Report Nos. 50-424, 425/82-17 and 50-424, 425/82-26. During these inspections the NRC inspector noted that the sample frequency for cadweld testing was being based on the number of cadwelds inspected by each QC inspector.
This was contrary to position C 4 of Regulatory Guide 1.10 which requires that separate test cycles be established for cadweld splices for each cadwelder or cadweld splicing crew.
As a result of this discrepancy, the NRC issued a Notice of Deviation from a licensing commitment.
4 8.
The applicant responded to this deviation by establishing test cycles for each ca'dweld crew.
Observation of cadwelding operations and review of test data on c'adwelds by NRC inspectors during routine inspections have shown that cadwelds were being made in accordance with site requirements and for the most part, exceeded the tensile requirements specified by Regulatory Guide 1.10 and ASTM A-615.
Examination of all tensile test data for cad-welds disclosed that the rate of tensile failures has been very low at the Vogtle project (approximately 0.3 percent).
The defective cadwelds were removed and replaced with new cadwelds.
This deviation did not impact on the quality of cadwelds.
NRC inspection of the licensee's response to the original concern is reported in NRC Inspection Report No. 50-424,425/83-04.
Alleged Falsification of Concrete Records 9.
This allegation, which is stated on pages 240-242 of the Teper deposition, is based on information contained in NRC Inspection Report No. 50-424, 425/81-09.
This report summarizes the results of a detailed investigation of seven allegations performed by Region 11 personnel (a civil engineer and an investigator).
Four of the allegations were related to possible falsifi-cation of concrete quality control records. The remaining three dealt with backfill records.
Two of the four allegations pertaining to concrete records were found to be partially correct as stated. These two allegations and the findings of tne investigation were as follows:
a.
Allegation On'several occasions, testing of concrete aggregate disclosed that the aggregate did not meet the specified gradation requirements.
Findings The allegation was partially correct as stated. The applicant did have problems with the No. C7 aggregate gradation. However, the applicant's QA program had detected the problens and adequate corrective action was taken to resolve the problems.
The nonconforming aggregate was not used in concrete, but instead was removed from the batch plant area and used in Noncategory I applications, e.g., used as access road base material.
The records were found to be correct, i.e., the records had not been altered to indicate concrete aggregate that failed gradation tests met project acceptance criteria. The quality of the concrete was not affected by this problem.
b.
Allegation Concrete with slumps exceeding the specification requirements was placed in the Unit 1 Reactor Building foundation basemat. The quality records for this concrete placement were altered to reflect that the concrete placed in the basemat met requirements.
Findings The allegation as stated was partially correct in that a small quantity of high slump concrete (2 truckloads, 20 cubic yards) was apparently 1
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6-1 placed in-the basemat.
However, this was detected by the applicant's
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QA program and evaluated.
The portion of the allegation concerning placement of 60 to 70 truckloads of concrete with slumps in the range of 8 to 10 inches in the basemat and falsifying records to indicate that all concrete placed was in compliance.with project requirements was not substantiated.
The placement of the Unit 1 basement was witnessed by an NRC inspector.
The inspector was aware that a small amount of high slump concrete was intentionally placed in the basemat due to conditions encountered during the placement.
The strength of the concrete in the basemat exceeds design requirements.
- 10. Only one of the three allegations pertaining to backfill was substantiated. Th'i s allegation concerned errors in the calculation of results of approximately 200 backfill gradation tests.
The errors, which were minor in nature, were found and corrected by the Applicants.
The errors had no impact on the qualification and acceptance of the Category I backfill materials.
- 11. Based on the results of the investigation documented in NRC Inspection Report No. 50-424, 425/81-09, the inspectors concluded that the allegations had no safety significance.
The QC inspection records were found to be correct, i.e., the records had not been changed (falsified).
Failure to Correctly Prepare Test Records
- 12. This allegation, which is stated on pages 239-240 of the Teper deposition, is based on the violation cited in NRC Inspection Report No. 50-424, 425/81-09.
This violation was identified during the course of the
e.
investigation of the seven allegations discussed above. This violation was
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not associated with any of the allegations but was identified by the inspectors during review of the QA records. The violation concerned records that did not identify inspectors who performed some concrete tests / inspections. The violation was minor in nature.
It was identified to the Applicants as a Severity Level VI violation (the lowest level violation) in accordance with NRC interim enforcement criteria issued October 28, 1980, which were in effect at the time the violation was' written.
- 13. Review of the corrective action which was implemented to resolve this violation is summarized in NRC Inspection Report No. 50-424, 425/82-01.
Records documenting results of inspections of concrete were reviewed by Region II inspectors during numerous onsite inspections and during review of Module 1 of the Readiness Review Program, Structural Concrete.
These records were found to be correctly prepared and complete.
Improper Consolidation of Concrcte
- 14. This allegation, which is stated in pages 235-236 of the Teper deposition, resulted from a Notice of Violation identified in NRC Inspection Report No. 50-424, 425/79-01.
During the inspection, the NRC inspector noted that concrete was allowed to accumulate approximately two feet above finish elevation and then was moved approximately ten feet by vibrators. This was contrary to the requirements of procedure CD-T-02 which states that vibra-tors shall not be used for transporting or moving concrete.
1.
- 15. As a result of this violation, personnel were reinstructed in the use of vibrators. A similar violation was also identified in NRC Inspection Report No. 50-424/79-13. As a result of this violation a training session was held on site July 27, 1979 for concrete placement crews and QC inspectors to demonstrate the proper use of vibrators.
Examination of training records disclosed that training sessions were being held for the craftsmen on a monthly basis during which the craftsman were being instructed in proper concrete placement practices.
Observations of concrete placements during subsequent inspections indicated that proper concrete consolidation practic-es were being implemented and that the two violations were isolated occur-rences. The results of these inspections were reported in Inspection Report Nos. 50-424, 425/79-01; 50-424, 425/79-05; 50-424, 425/79-07; 50-424, 425/79-09; 50-424, 425/79-11; 50-424, 425/79-15 and 50-424, 425/80-07.
"In Place Compaction Tests Conducted on Site Could Not Meet 97 percent Compaction Criterion Established in PSAR, so the Definition of Compaction was Changed" l
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- 16. This allegation is stated on pages 236-238 of the Teper deposition.
The deposition states that the compaction criteria were related to in place compaction of concrete. This is incorrect. The compaction criteria are used t
to control placement and compaction of backfill, and is not related to placement of concrete.
The compaction criteria are used to relate in place density of compacted backfill with the density determined in controlled laboratory test performed in accordance with ASTM standards.
Standards used to control quality of concrete are not percent compaction, but rather measurements of slump and air content of plastic concrete, strength of test cylinders, control of quality and quantity of concrete materials, concrete i
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mixing time, calibration of concrete batch plants, control of methods of a
concrete placement, etc. The alleger apparently misunderstood the documents he reviewed and confused compaction criteria with concrete placement controls.
- 17. We are aware of two documents where changes to backfill compaction criteria are discussed.
The first is on page I-3 of NRC Inspection Report No.
50-424, 425/77-04 This report discusses a meeting held between Georgia Power and the NRC Office of Nuclear Regulation to establish a more detailed t
i definition of compaction based on results of a test fill program conducted l
onsite.
During the test fill program, the licensee determined that a minimum of 97 percent compaction could not be obtained 100 percent of the
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time.
Therefore, after performance of an engineering evaluation, the definition pertaining to compaction was revised to state that the average compaction shall be 97 percent with no tests below 93 percent, and not more than 10 percent below 95 percent in a series of 20 tests.
These criteria are similar to those used on other projects. The other document discussing a change in backfill compaction criteria is in a letter dated March 25, 1981 from G. Head, Georgia Power Company, to D. Eisenhut, NRC office of NRR.
This letter requested a change in compaction criteria for Noncategory I backfill placed above foundation levels north of the turbine building. This change did not affect the seismic Category I structures.
"There are Voids in the Auxiliary Building Concrete"
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- 18. The allegation is that voids occured in walls which were heavily congested with reinforcing steel, embedments, pipe sleeves and blockouts.
This
allegation, which is stated on pages 220-225 of the Teper deposition, is based tipon information contained in NRC Inspection Report No. 50-424, 425/79-19.
This report discusses a construction deficiency (50.55(e) item) reported to NRC Region II on December 20, 1979 which involved voids in the auxiliary building concrete.
- 19. Voids in concrete are referred to as " honeycomb".
Honeycomb is defined in Section 201 of the American Concrete Institute (ACI) Manual of Concrete Practices as voids left in concrete due to failure of the mortar to effec-tively fill the spaces among coarse aggregate particles, ome honeycomb and voids are expected in larg( concrete placements because of congestion caused by embedments, penetrations, reinforcing steel and because of the type of concrete mixes that are required to meet specified design strengths.
Industry practices recognize the potential for honeycomb and voids and thus methods for identification and repair of the defects are specified in ACI 201 and the Bureau of Reclamations Concrete Manual.
- 20. The voids reported by the Applicants on December 20, 1979 occurred in thin (12 inch thick) walls which were heavily congested with reinforcing steel, embedments, pipe sleeves, and blockouts.
When the problem was discovered, the applicant issued a stop work notice to stop concrete placement in the heavily congested walls.
Georgia Power modified their concrete placement methods and procedures for thin heavily congested walls so occurrence of voids would be minimized, and after notifying NRC Region II, resumed place-ment of concrete in these walls.
As a result of the corrective actions taken, the voids in the concrete at the Vogtle site have been held to a minimum.
Voids which have occurred in concrete structures have been
repaired in accordance with applicable site procedures for repair of concrete defects.
These procedures have been reviewed by Region II inspectors and were found to comply with recommended industry practices for repair of concrete defects.
The results of this review are reported in NRC -
Inspection Reports Nos. 50-424/79-19; 50-424/80-05 and 50-424, 425/80-07.
Damage to Category 1 Backfill and Possible Undermining of Class I Structure Foundations
- 21. This allegation, which 4s stated on pages 220-235 of the Teper deposition, is based on statements appearing in NRC Inspection Repodt Nos. 50-424, 425/79-17.
Upon arriving at the site on November 14, 1979, the GPC QA supervisor informed the NRC inspector that they were having a problem with Category I backfill.
He indicated a severe storm on November 2, 1979 had aggravated ongoing moisture problems and eroded part of the backfill.
Because the applicant failed to report the deficient condition to the backfill as required by 10 CFR 50.55(e) a Notice of Violation was issued.
Subsequently, a Confirmation of Action letter dated November 15, 1979 from NRC Region II to Georgia Power was issued in which it was understood that Georgia Power would not continue with backfill placement in or around the power block area or concrete placement on affected structures without concurrence of NRC.
Meetings were held with the applicant at the site and at the Office of Nuclear Reactor Regulation (NRR) in Bethesda, Maryland regarding measures to be taken to correct the backfill.
- 22. Corrective measures included testing to determine the extent of defective backfill, removal of defective backfill and foundation slabs, installation
of drainage facilities and a dewatering system, and application of gunite (sand cement mixture) on slopes to prevent additional erosion problems. The NRC inspectors observed the corrective measures taken to correct the back-fill and examined. records documenting the corrective measures during several -
onsite inspections.
Results of these inspections showed that the backfill was properly repaired and that measures were taken to prevent future erosion problems.
Details on these inspections appear in Inspection Report Nos. 50-424, 425/79-18; 50-424, 425/79-19; 50-424, 425/80-03; 50-424, 425/80-04; 50-424, 425/80-05; 50-424, 425/80-07; 50-424, 425/80-09; 50-424, 425/80-10 and 50-424, 425/81-11.
Conclusions
- 23. Based on the results of inspections conducted at the Vogtle site by NRC inspectors, we conclude that the Quality Assurance Program for control of civil construction activities at the site was properly implemented with the exception of the minor violations noted in NRC inspection reports.
These violations, which for the most part form the basis for the allegations discussed above, were corrected by Georgia Power in an expeditious manner and did not have a detrimental effect on the quality of the civil construc-tion work completed at the Vogtle site.
There is ample evidence of the effectiveness of the implementation of the Quality Assurance Program in the civil area at the site. These include:
a.
Identification and correction of nonconforming conditions by the applicant (some of the those reported as construction deficiencies to
1 NRC Region II under 10 CFR 50.55(e) form the basis for some of the allegations discussed above).
b.
Issuance of stop work notices by quality control and quality assurance personnel when craft personnel failed to follow procedural requirements or when major problems occurred until proper corrective action was implemented, c.
Preparation of procedures, specifications and drawings to control construction and inspection of civil structures.
d.
Rigid adherence to procedures, specifications and drawing requirements for civil construction work.
e.
In-depth training program for craft, quality control and other person-nel involved in construction of safety-related civil structures.
- 24. The.1 umber and type of violations cited by NRC inspectors and the number of construction deficiencies identified by the Applicants are normal for a nuclear project the size of Vogtle. These problems do not indicate that the Applicants did not implement a Quality Assurance Program for construction of plant Vogtle.
We have no concerns regarding the quality of civil construc-tion at the Vogtle site.
25.
In summary, we believe there are no outstanding significant safety or QA problems with respect to backfill and concrete construction, and that the portion of
l Contention 8 dealing with failure to implement the quality assurance program in the area bf backfill and concrete construction has not been supported by material and should be dismissed.
b
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Joh ~ R.
, rris Subscribed and sworn to before me this 30 day of July 1985 M A M Mi Akw
_ Notary P@Vid I
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My Commissica expires b/ WC 0804 8. State et late I
M Cownission Expres May 15,1538
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ATTACHMENT A JOHN R. HARRIS PROFESSIONAL QUALIFICATIONS U. S. NUCLEAR REGULATORY COMMISSION REGION II My name is John R. Harris.
My business address is 101 Marietta Street, NW, Suite 2900, Atlanta, Georgia 30323.
I am employed by the United States Nuclear Regulatory Commission, Region II, as a Civil Engineer / Geologist in the Engineering Branch, Division of Reactor Safety.
I received a Bachelor of Science Degree in Geology from Wayne State University in February 1960 and pursued graduate studies in civil engineering and geology at Wayne University's graduate school from February 1960 to June 1961.
From February 1960 to August 1961, while attending graduate school full time, I also worked full time with the U. S. Army Corps of Engineers Detroit District on the St. Lawrence Seaway Project.
I was responsible for controlling blasting operations and calculating the amount of material to be evacuated from pre-excavations surveys and the amount of material actually removed from post excavation surveys.
From February 1961 to September 1963, I worked for the U. S. Army Corps of Engineers Jacksonville, Florida District.
I was involved in foundation and concrete studies for airfields, levees, canals and missile complexes.
From September 1963 to November 1965, I worked for the U. S. Army Corps of Engineers Canaveral District at Cape Kennedy, Florida.
I was involved in geo-technical and civil design and construction of the Titan three complex, Appollo project, and underground atomic test site at Amchitka, Alaska.
From November 1965 to January 1977, I was employed by the U. S. Army Corps of Engineers Philadelphia District.
I was involved in geotecnnical and civil design and construction of dams, tunnels, levees, highways canals and hydroelectric power plants.
From January 1977 to the present I have been employed by the U. S. Nuclear Regulatory Commission, Region II, Atlanta, GA.
My duties involve inspection of nuclear power plants in civil and geotechnical areas.
I ATTACHMENT B
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STATEMENT OF PROFESSIONAL QUALIFICATION JOSEPH J. LENAHAN REGION II My none is Joseph J. Lenahan.
My business address is 101 Marietta Street, Suite 2900, Atlanta, Georgia 30323.
I am employed by the United States Nuclear Regulatory Commission, Region II, as a Civil Engineer in the Engineering Branch, Division of Reactor Safety.
I received a Bachelor of Science Degree in Civil Engineering from Drexel Univer-sity in June 1969 and a Master of Science Degree in Civil Engineering from Drexel University in June 1973.
I am registered as a professional engineer in the states of New Jersey and Pennsylvania and I am a member of the American Society of Civil Engineers.
From June 1969 through September 1970, I was employed as a Civil Engineer with the USDA Soil Conservation Service, Upper Darby, Pennsylvania.
My duties in-volved design of small earth dams.
From January 1971 through August 1971, I was employed as a Civil Engineer in the Philadelphia Naval Shipyard.
My duties involved structural design related to maintenance of shipyard structures, includ-ing' buildings, piers, drydocks and large cranes.
From September 1971 through June 1976, I was employed as a soils engineer with the Philadelphia District of the Army Corps of Engineers.
My duties included preparation of foundation designs and foundation design criteria for earth dams, powerhouses, pump stations, and various other civil works projects.
From June 1976 through June 1978, I was employed as a soil engineer with the Middle East Division of the Army Corps of Engineers in Winchester, Virginia and Saudi Arabia.
I was responsible for preparation of foundation design, foundation design criteria, and determination of construction material sources for approxi-mately five billion dollars of new construction in Saudia Arabia.
The projects included two commercial ports, two naval bases, four large military schools, and several military bases.
In June 1978, I joined the U. S. Nuclear Regulatory Commission. My responsibili-ties include planning and conducting inspection at operating reactors and at reactor construction sites. Areas I inspect at construction sites are structural concrete, structural steel, installation of post-tensioning systems, earthwork construction activities and quality assurance programs.
Areas I inspect at operating plants are surveillance of post-tensioning systems and snubbers, leak rate testing, and actions taken by licensees in response to IE Bulletins pertain-ing to snubbers and masonry wall design.
I have completed NRC's quality assur-ance, pressurized water reactor and boiling water reactor courses.
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