ML20126A097
| ML20126A097 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/31/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20126A095 | List: |
| References | |
| NUDOCS 8002140442 | |
| Download: ML20126A097 (11) | |
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O UNITED SUTES C H MERICA k gW L
, NUCLEAR REGULATORY COMMISSION C gB -
6 4 OFFICE OF INSPECTION ANJ ENFORCEMENT VICTOR STELLO, JR., DIRECTOR g g In the Matter of ) N *
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KANSAS GAS & ELECTRIC COMPANY ) Docket No. STN 50-482 (Wo1f Creek Genera.ing Station, ) (10 CFR 2.206) i Unit 1) ) '
REVISED DIRECTOR'S DENIAL OF REQUESTS UNDER 10 CFR 2.206 M I
William H. Ward, by petitions dated January 11 and June 29, 1979, on behalf of the Mid-America Coalition for Energy Alternatives (MCEA), Richard P.
Pellock, by peti-ion dated December 27, 1973, on behalf of the Critical Mass Erergy Project, and cther persons 2'/ have requested that the Commission suspend or revoke Construc;ien Permit No. CPPR-147 ' hich authorizes construction of l
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2 This decision was initially issued as 00 79-11 on July 12, 1979 (10 NRC 136) and no.icec in the Federai Recister on July 19, 1979 (44 FR 42347).
M . Ward by letter dated Augus; 11, 1979 requested further explanation of footnote 6 of the Jttly decisica concerning the ground motion values for the Wolf Creek site. The Coccission has extended the review date to permit the staff to revise the decision in response to Mr. Ward's concern and to clarify other aspects of it. See, Order Fxtending Time to Deter-mine Whether to Review Director's Decision, July 27, 1979, August 13, 1979, September"13, 1979 and November 28, 1879. In order to improve the record for review, the July 12, 1979 decision is reissued in its entirety with the clarifications incorporated.
E Wanda Christy of Eurlington, Kansas; Max McDowell of Elmdale, Kansas; David McCullough of Emporia, Kansas; Tony White of Garnett, Kansas; Kaye Yoder of McPherson, Kansas; Ferdinand and Ivonne Burmeister of Otis, Kansas; Marvin Dawson, James Mason on behalf of Kansans for Sensible Energy, Janet Skiles, and Tom Wheeler of Wichita, Kansas.
Steve A. J. Bukaty, by petition dated May 15, 1979, on behalf of the Kansas Buildir.g and Construction Trades Council, also requested that the Wolf Creek construction permit be revoked.
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. w the Wcif Creek Ger.erating Station tait Nc.1. Notices of receipt of MCEA's and Critical Mass' petitions were cutlishec in the Federal Recister, 44 Fed.
Reg. 6535,10445 (Fear;ary 1 and February 22, 1979) and all petitioners have been advised by letter that their ;etitions were being treated as requests for action under 10 CFR 2.205 cf the Cem-ission's regulations. At issue in the ,
1 petitions is the acceptability of the concrete at the Wolf Creek facility.
Specifically, the issues of concer.. are whe:her the base mat concrete is of ,
1 sufficient strength for its intended function and whether the quality l assurance system at the f acili y is adequate to assure acceptable concrete work.
These matters have been rev'.e ed and fc,r the reasons given below I have deter.-ined that the December 19,197E, Ir.T.ediate Action Letter 3/ as modified by ths March 5,1979, '.mmeciats Ac icn e:tir b/ nalting placement of concrete in the reactor concain ent bui' din; ca) be lif ted and tnat suspension of construction at the iloif Creek facility is not warranted in the interest of c
public health ar.d sa'e y. Acccrdi gly, tne a.:oce petitions are denied.:/
II The f acts surrcanding this r.a:ter are :e . ailed in Appendix C. Briefly, on December 12 and 13, 1977 the Wo f Creek Ouilding base mat was placed as a single monolitnic pour of about 66."] ctoic yards of concrete. Test cylinders S/ The Dececber 19, '978 letter :s er. closed for Appendix A.
-4/ The March 5,1979 letter is er.closec in Appendix B.
5 On the basis of tne f acts centained in his petition, Mr. Eukaty's petition on behalf of the Kansas Euilcing and Construction Trades Council is deniec by this decisicr.. -ows.er, "r. Eukaty indicated in the petition that further factual inferration ray be available. Mr. Bukaty has been contactet and has not offered ary acditicnal information.
3 were concurrently race f rom representative samples of the concrete. On March 14, 1978 the licensee notified NRC Region IV that some of the concrete cylinders wnich were tested (as specified) 90 days after the original placement did not meet the specified strength of 5000 pounds per square inch. The licensee initiated various efforts to identify the reasons for the low strength of sere of the test cylinders, and on Octooer 26, 1978 filed a final report which described tne work performec. The report concluded that the los strength cylir. der tests were n0t truly representative of the concrete in place and that the concrete in place in the containment building base mat did in fact satisfy specification req.;i re..ents.
In Decemoer,1975 the licensee reported that some problems had been experienced placing c ncrate uncer steel inserts for access hatches. As a resul;, voids existed where there sas no concrete or poorly consolidated concrete. _n ligat of this occurrence, and the continuing delay in resolution of questions on tne base r.at concrete, NRC Region IV representatives met with the licensee, and expressed the opinion that further concrete work on the l
containment building shculd be suspended until concrete placing and consolida-tion procedures were improved, cor.: rete placing crei.Is were further trained, concrete inspectors and inspection procedures were upgraded, and questions on base mat quality were resolvec. Ine licensee agreed, and the agreement was documented in a letter from Region IV dated December 19, 1978. This agreement was mocified oy the March 5,1979 Immediate Action Letter from NRC Region IV.5 A special NRC investigation was conducted under NRC Region IV direction.
during the period fro: Novetber 13 through 16, 1978, and December 6 through 8, 5' See note 4, ab:ve.
1975.E The investigation team was compcsed of inspectors from NRC Regions III and IV and Parameter, Inc. , a consul: art on concrete engaged specifically for this purpose. The team concludec that it coulc not agree with the licensee's opinion anc that the test data cust be considered to accurately reflect the strength cf the concrete in place. On the basis of the test data, it was determined tna; a caximum strength of 4450 psi could be justified.
Thi's was approximateh 10% understrer.gth from the des ign strength of 5000 psi.
The evaluation of actual 90-day moldec cylinder test data was the first step in the seque.tial prc:ess cal'ec for in the codes applicable to the Wolf Creek facility for th6 resolution cf the question of concrete strength.
It should be ncted that some cf ne 9C-cay cylinders showed lower strengths tnan companion cylinders from the sace baten of concrete tested af ter 28 days.
As with all test ca;a there is semi and:mress expected in test results, but one generally expscts the ; rends tc incicate that the concrete strength ras increased with age. Inere are, of ccurse, a variety of problems which could procu:e an effect wrica wCJ1d seem tc co-tradict this expectation. In tnis particular case the m:st plausible protism which could have caused such an ef fect on scme co, panion cylinders was that some river gravel in the vicinity of the site is known to centain an ingrecie-t which can cause loss of strength in concrete under certain circumstances. Tne NRC consultant suggested that this r.ight explair, the apparenti;. incmalcus behavior of some of the test cylinders. To test the validity of tnis hypothesis, and to independently correlate the results of scme of the tests performed by the licensee's consul-tant, the Ccnstruction Technology 'aboratories of the Portland Cement Associa-tion, NRC arranced for the U.S. Arry :crps of Engineers Waterways Experitent
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h See Inspecticn Ra;0rt 5 N 5:-232 '75-13 (February 15, 1979).
C) 1 Station to perform incependent petrographic examinations of samples of concrete from he est cylincers. The July 5,1979 Corps of Engineer's report is made 1
part of tnis decision as Appendix 0.
?.esults of the ir.depender. examination of the Corps of Engineers correlate close'y with the results of the licensee censultant's examination. Both )
results show that there is no evidence of contamination with adverse ingredients I whiEh may have caused a loss in strength of the concrete over time and that the samples are representative of sounc, relatively high strength concrete.
l However, cue to the atititude of pirameters that can affect strength, a clear l
l expla9aticn of the exact cause of .he instances of the low 90-day strengths canno; te made.
The text ste; cefined in the coce requirements was to use the determined stren;tr. (445C psi) to evaluate er rear.alyze icads while meeting all stress, i strair, ard deflection criteria. -ne licer.see concucted such a reanalysis by l two a:te rratis e methocs to deterr. ire whether the lowered strength concrete might be acceptable fc use at the Wcif Creek site. The licensee's reanalysis was s'.oritted on June 5,1979 'ndicatir; that the structure was acceptable. i Ine licensee's reanalysis and the report of the Corps of Engineers have been reviewed. The conclusion of cur revie
- is that the concrete base mat will withstand the saecified desigr. loads and all loading combinations without l impairment of its stru:tural integrity or its safety functions.8/ If the 8/ E/alustica Report Regarding the Concrete Strength of the Reactor Building !
Ease Mat Wolf Creek Generatin; Station, which is made part of this decision l and is attached as Appendix E. The evaluation report is based on the 0.12 g safe shutdesn earthquake and tne 0.05 ; operating basis earthquake approved for tne Wolf Creek site. The information concerning seismic forces contained ,
in the June 29, 1979 letter fr:r P- Wird has been previously considered by
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ine s aff and it does not alter the viLratory ground motion values for the k:lf Creek site. An evaluatica cf the seismic issues contained in Mr. Ward's letter is mace part of this de:ision and is attached as Appendix F. The j issues raised ir P.r Wa-d's istter have also been brought to the attention <
ef the Advisory Comr.ittee or. Eeact:r Safeguards.
O reanalysis had sh:wn that the design loads could not be accommodated and still teet the stress, strain, and deflection criteria, under the codes, the next step would require . hat core borin;s be taker. fro, the structure and tested.
Even though this next step was not necessary, a core boring program has been considered early in the evaluation of the strength problem. However, such a program under tne circu stances here would nct have resolved the question of
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concrete streng-h ar.d was not recormendec by the staff for the following reascas: (1) As many as 203 borings would have oeen necessary under the appli-cable codes. This nur.ber of 6:rin;s taken from the mat interior resulting in severing reinforcing steel would raise additional and perhaps more serious cJestions sin:e tre Icad bearing capacity cf the base mat is primarily governed b/ the reinforcin; steel. (2) A c:re borirg orsgran would have questionable value since it -o.lc te ur.li :eiy t. a the cores would sample the icw strength concrete which ci;n be arfene e ir the 66C) t.,:ic yards of the base mat.
(3) C re borings 'rcm t're sc til base r.a; cJe to their age (more than a year cic) -culd sh':w larger s alJes .han cylinders ta<.en af ter 90 days. The accep-Lance criteria fo- the base c,a. we e based or 93 day cylinders and no correla-tien sxis:s for relating tne care strer.gths cf concrete more than a year old to ccic ete test :ylinders 93 days old.
III In response to our cencerns a:out quality assurance resulting from the findings of tr.e ir.spection conducted dtring liovember 13-16, 1978, and C
Decetbe r 6-8, 1975,;/ NRC 0.egion IV repress.n atives met with senior c/
The findin;s are repcrted in Inspec-icn ~!e: Ort tio. STri 50-482/78-13. A Nc ice of Vi:lation was issue: cn Februa y 16, 1979, on the basis of this l inspec-icn.
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) representatives of the licensee and its construction contractor.10/
Agreenents achieved during the meeting including the licensee's commitment to suspend piacecent of safety-related concrete are documented in an Immediate Action Letter to the licensee dated December 19,1978.N Based on information obtained during follow-up inspections that were conducted to examine the licensee's implementation of these agreeraents,5! NRC Region IV concluded that the licensee had been responsive to the NRC's concerns and that modification of the Decerr.ber 19th Immediate Action I.etter to permit placement of safety-related concrete except in contain:ent appeared appropriate.
Inspection Report No. STN 50-482/79-04 describes action taken by the ;
licensee and findings of an inspection conducted on March 5-8,1979, at the l
resumption of placemen of concrete at Wolf Creek. During the inspection on March 8,1979, the licensee notified the NRC that it had again terminated ,
1 placenent of concrete. This action was consistent with NRC Region IV's modifi-cation of the Dece:iber 19th Immediate Action Letter and demonstrated the licensee's adherence to its quality assurance program.
Despite the licensee's effort to establish an effective quality assurance program, NRC Regica IV found weaknesses in the program as indicated in Inspec-tion Report No. STN 50-482/79-04 and as discussed in the related enforcement l l
letter dated April 11, 1979. NRC Region IV, in the enforcement letter accom-panying the report, 'also expressed the view that the licensee had not assigned sufficient personnel to the project to irr.plement an effective preventive 10/ The meeting is reported in Inspection Report No. STN 50-482/79-1.
M/ See note 3, above.
12/ The inspection findings are contained in Inspection Report Nos. STN 50-452/79-02 and STN 50-462/79-03.
quality assurance effcrt. As a resuit, a ranagement meeting was conducted in l l
Region :V's of fices or April 28, 1575, whic; is repcrted in Inspection Report l No. S N 50-432/79-1C.
l Since January 1973, the licensee has increased the on-site QA staff from three full tire te seven full tire and two : art time engineers of various disci-lines. Recruitment cf additional QA staf f members is continuing. As a resul; cf the increase in staffing, tne licansee's QA surveillance of construc-tion activities has in:reased significantly. DLring the period January 1, 1979 :o July 11, 1979, ar. average cf eigh: surveillance reports per month were issuec as ccm;3 rec to an aserage of tnrae ripcrts fcr a fif teen-month period endin; Cecemoer 1978. The staf f of tne licinsee's Naclear Development Depart-ment "as been reorgani:ed. A new Cor struct'on Panager has been hired. Addi-tior.a' r ec titing 'or ses eral staf f e .gir ee 3 is being ccnducted. Currently, l the results of a s ucy of t9e licersee's ;A crog am cy an outside consultant are beir.; reviewed and icolemented :y tne KGiE QJality Assurance Committee.
1 Cariel Interr.itioral (:he crimar. :entractc at the site) nas increased the or-s ite QA sta'f b) cne merber ic a totil of six. Ir. addition, the assigr:ent of a ne- C.A ana;er has visioly 'ncreased the quality of the Daniei International's QA audit pro; ram. Tre Daniel International corporate QA staf f also cond; cts quarterly on-s'te aucits. Daniel International has made crganizationa'. changes to streamline tre lines of authority and responsi-i bility cf :he site manageme,t. Tne folio ir; changes have been made.
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- a. The Administrative Assistan- to the Project lianager has been moved l
from a staff pcsition to a line p:sition of responsibility wi'th the '
3ervices Manager, Personnii Adm'nistrator, Training Coordinator and Security A:minist ator re::-tin; i: this position.
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Two positions of Assistar.t to the Construction Manager have been created and filled, both of whcm report to the Construction Manager.
This was done to permit rare mana;erent attention to quality of ccnstruction work.
- c. The position of General Concrete Superintendent has been created and filled with the following positions reporting to him: Paint Superintendent; Iron Work Superin:ar. dent; Concrete Superintendent; and Eatch ?lant Superintendent. !
- c. The positicn of CC Civil Coordina;or has been created and filled.
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- e. The osition of Technical Superin:endent, Concrete, has been l
l estaclisned and filled. l 1
- f. 3e sonnel changes have besn made il che following positions:
Ocnc e:e Superintendent; ;ersonne' Ad-iristrator, Project Mech /
deic'n; QC Er.gineer; Project Servi:es QC Engineer; Construction Mana;er; and Construction Engineerir; Manager.
53ecific :rair.ing for concrete place er: crews under the direction cf the Techni:al Suce-i.. tinder.t, Concrete, is being done for each difficult placement.
Daniel Interna.icnil has also contricted Maragement Analysis Consultants, San Diego, California, tc review the site organi:ation including the QA structure and make recemcendations for improvement.
Additions'. inspections were conducted specifically to observe concrete l'
work in progress on March 26-29, 1979,2 / Ap-il 9-12, 1979,14/ April 16-19, 13/ Inspe: tier Report No. STN 50-452/79-05.
14/ Inspection Report No. STN 50-412/79-07.
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I 4 1979,22/ April 23-26, '_97926/ and Cc ober 22-25, 1979. 7/ Other inspections conducted during May 11-17, 197}:8/ and September 17-20, 197919/ addressed the rescit:f or. cf various : pen ite:s fro earlier inspections. The results of these ir.spections indicate that Wolf Creek's quelity assurance program is effective in corre: tin; identified problems.
l Accordingly, I find reasonable assuran:e that the licensee's quality l l
1 assurance program is a: equate to permit resumed placement of containment l l
l ccacrete. Thus, f:r t.te reasons statec in this decision, the petitions to '
stsperd Or revoke -he voif Creek construction permit are denied.20/ -
Nonethe-less , t're NRC will cen;inue its inspection ef fort at the Wolf Creek facility tc ass;re hat the licinsee correctly places concrete and properly caintains i 1
1 its quelity assura .ce program 1
A co;/ of thi: ce:ermination will se placed in the Commission's Public D;:Lment F. cm at l'17 ;- Street, h.V. , 'ias hing on, D.C. 20555, and the local Puoli: Cocarent Ro.m f r the i!cif Creek Generating station at the Ccffey Cc;r ty C :t-t nc.'s e , Eur'ington, Kansas 65539. A copy of this document will 11/ Ins oe: tion Re: ort Nc. STN SC '82/79-08.
11/ Insce: tic., Re: ort Nc. STN 50-432/79-09.
17/ Insoe:tien Re: ort No. STN 50-452/79-18.
IE/ Inspe: tion Re:crt No. STN 50-432/79-12.
11/ Insoe:t'cn Re: ort No. STN 50-LB2/79-17.
~~2C/ Criti:al Mass has alsc suggested, without elaboration, that the circurs ances surrouncing construction problems at Wolf Creek indicate
sigr.ificant -eakresses" in Region IV's inspection capabilities. Since poter.:ial prc:lems with containment concrete were first identified in
. March 1973, Regio.- IV has, in conjunction with I&E Headquarters, been c:r. inucusly Eware of the licensee's actions, has guided and required veric;s a:ticas by the licensee, and has obtained specialized assistance frcr Otner NR: cf' ices and cc side parties. Thus, I find no basis for tne exp essec cen:srn about the acequacy of Region IV's inspection ef fort.
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also be filed with the Secretary cf the Commission for its review in accordance l 1
l with 10 CFR 2.205(c) of the Commission's regulations. ;
In accordarce with 10 CFR 2.206(c) of the Commission's Rules of Practice, this decision will constitute the final action of the Commission twenty (20) days after the date of issuance, unless the Commission on its own motion institutes review of this decision within that time.
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, -, / ,r l
,g Dl; Victor Stello, Jr. l Cirector !
Office of Inspection and Enforcement l
Dated at Eethesda, Maryland l this 3 '. day of January,1930.
Enclosure:
Appen:ix A - Cece:cer 19, 1978 Immediate Action Letter A;pencix E - March 5,1979 Immediate Action Letter Appen:ix C - Summary of Concrete Problems en the Wolf Creek Nuclear Flant Appencix 0 - Report of Waterways Experiment Station, U.S. Army Corps of Engi r,ee rs Appen:ix E - Staff Evaluation Report Regarding Concrete Strength of the Reactor Building Base Mat, Wolf Creek Generating Station Appencix F - Staff Response to William Ward's Letter on Seismic Issues at Volf Creek