ML20030C367
| ML20030C367 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/21/1981 |
| From: | Blake E ARKANSAS POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20030C353 | List: |
| References | |
| NUDOCS 8108260029 | |
| Download: ML20030C367 (7) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LOUISIANA POWER & LIGHT COMPANY )
Docke t No. 50-38 2 l
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(Waterford Steam Electric
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Station, Unit 3)
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APPLICANT'S STATEMENT OF MATERIAL FACTS RELATING TO JOINT INTERVENORS' CONTENTION 22 (SAFETY-RELATED CONCRETE)
Pursuant to 10 C.F.R.
S 2.749 (a), Louisiana Power & Light Company ("LP&L") states that there is no genuine issue to be heard with respect to the following facts material to Joint Intervenors' Contention 22:
1.
LP&L's architect-engineer for the Waterford 3 project is Ebasco Services, Inc., which has general supervisory responsi-bility for construction, including the, placement of all safety-related concrete.
Most of the concrete was actually placed by an Ebasco subcontractor, J. A. Jones Construction ' Company.
Scme of the specialized concrete placements were performed by anothe.r sub-contractor, Fegles Power Service.
At present, more than 99%
of safety-related concrete construction at Waterford 3 has been completed.
8100260029 810821
PDR ADOCK 05000382; G
PDR'
2.
LP&L has implemented a Quality Assurance ("QA") and Quality Control ("QC") program for Waterford 3 in compliance with 10 C.F.R. Part 50, Appendix B.
LP&L's OA/QC program is described in Section 1.8 of the Waterford 3 Preliminary Safety Analysis Report and in Chapter 17 of the Waterford 3 Final Safety Analysis Report.
In addition, Ebasco independently implements its own QA/QC program, which has been generically approved by the Nuclear Regulatory Commission ("NRC").
Both concrete construction subcontractors also have detailed QA/QC programs, which have been reviewed and approved by Ebasco.
3.
The cement, aggregate, admixtures and other materials used in batching concrete for Waterford 3 are all obtained from supply sources with QA programs that have been reviewed and approved by Ebasco.
The concrete batch contractor, an affiliate of QA Corporation, performs a receiving inspection on the concrete constituent materials to ensure that the materials conform to the specification requirements established by Ebasco.
In addition, an independent testing laboratory, Peabody Testing Services, Inc., performs physical and chemical tests on the cement, aggregates and water.
l 4.
All concrete is batched in accordance with mix designs that meet industry standards and have been approved'by Ebasco.
After batching, both Ebasco and Peabody Testing Service perform appropriate tests and inspections to ensure that the concrete has been properly mixed and is acceptable before it leaves the batch plant....
I 5.
When the first concrete truck of the day reaches the 1
j placement location, and before any safety-related placement begins, Peabody Testing Services tests for air content, slump, unit weight, i
ambient temperature and concrete temperature.
These tests are repeated approximately every 50 cubic yards of concrete after the first batch of the day and every batch is checked for proper water /
cement ratio and the number of drum revolutions on the delivery trJck.
Additionally, Peabody Testing Services makes a set of four compression cylinders from the first batch of the day and every 150 cubic yards thereafter.
If a concrete placement is less than 150 cubic yards, but more than 50 cubic yards, a minimum of two i
sets of cylinders must be molded.
The cylinders are then tested f
for compressive strength at the Peabody Concrete Testing Laboratory i
with one cylinder being broken at 7 days of age; two at 28 days and one which is used as a spare shculd problems be encountered with the 28-day breaks.
Cylinders tc? molded, cured and broken in accordance with ASTM C-31.
6.
Before each concrete placement, the placement location is subjected to a pre-placement inspection by representatives of Ebasco and the concrete subcontractor.
This inspection is designed to ensure proper preparation of the placement location for receipt of concrete, including proper surface preparation and form place-ment, proper placement of reinforcing steel, and adequate cleanli-ness.
7.
The actual placement of concrete is performed in strict compliance with Ebasco's Detailed Specifications for Concrete Placement, Curing and Finishing.
The placement must also be carried..
out in accordance with the detailed concrete placement procedures of the concrete subcontractor.
All concrete placements are observed and inspected by QC inspectors of the concrete subcontractor to ensure that the concrete is properly placed and cured in accordance j
with the established procedures and specifications.
In addition, most of the concrete placements have been independently observed and inspected by Ebasco QC inspectore.
i 8.
All inspections and QA/QC functions concerning safety-related concrete are documented in accordance with 10 C.F.R. Part 50, Appendix B, and the documentation is retained by LP&L.
In addi-tion, LP&L QA auditors periodically observe the work at Waterford 3 and audit the QA/QC programs of Ebasco and the concrete subcon-tractors to ensure that proper QA/QC procedures are followed.
Ebasco also independently audits the concrete subcontractors' QA/QC procedures, and Ebasco's QA/QC program at the Waterford 3 site is in turn audited by representatives from Ebasco's headquarters in New York.
LP&L's QA/QC program is audited by Middle South Services, Inc., a subsidiary of the holding company that owns LP&L.
- Finally, the NRC performs its own on-site inspections of the construction at Waterford 3 and audits of the QA/QC program.
9.
An important aspect of the Waterford 3 QA/QC program is the system of documenting, reporting and resolving problems that are identified during the process of construction.
Minor problems are documented on Discrepancy Notices and corrected, usually l
at the site.
Nonconformance Reports are used to document more serious problems, such as those requiring design engineering input and those requiring procedural changes or other action to preclude recurrence.
Nonconformance Reports are reviewed and evaluated by Ebasco to ensure that proper corrective action is taken.
Problems that, if left uncorrected, could affect the safety of the plant within the meaning of 10 C.F.R. S 50.55 (e) become the subject of Construction Deficiency Reports and are reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Thereafter, LP&L submits to the NRC a detailed analysis of the deficiency and the means by which it will be corrected.
After repairs or other corrective measures have been completed, the NRC performs an on-site inspection to verify the adequacy of the corrective action.
When the NRC inspection is successfully completed, the Construction Deficiency Report is considered to be closed.
In general, LP&L has taken a conservative approach to reporting defi-ciencies to the NRC.
It has always resolved any substantial doubts in favor of reporting the problem to the NRC in a Construction Deficiency Report.
10.
During the course of construction, the placement of safety-related concrete has resulted in only four Construction Deficiency Reports.
Each deficiency was duly reported to the NRC, corrected by LP&L, and closed out through an NRC inspection.
These four Construction Deficiency Reports are summa,rized below:
1.
Construction Deficiency Report No. 1 Common Foundation Mat-Block 19 Placement 499 S03-19 24-hour notice given to NRC on July 6, 1976 Final Report submitted to NRC on July 19, 1977 Closed out by NRC Inspection No. 77-07 2.
Construction Deficiency Report No. 2 Reactor Auxiliary Building Interior Wall 51B Placement 570S03-51B 24-1.our notice given to NRC on August 18, 1976 Final Report submitted to NRC on April 11, 1977 Closed out by NRC Inspection No. 77-06 l.
3.
Construction Deficiency. Report No. 3 Common Foundation Structure Wall Placement 499S04-11A4 24-hour notice given to NRC on May 19, 1977 Final Report submitted to NRC on November 8, 1977 Closed out by NRC Inspection No. 77-15 4.
Construction Deficiency Report No. 13 Reactor Containment Building Dome Placement 521-1B 24-hour notice given to NRC on August 16, 1979 Final Report submitted to NRC on April 21, 1980 Closed out by NRC Inspection No. 80-03 11.
During the course of construction, the NRC made a number of unannounced visits to the Waterford 3 site to inspect the construction, including the placement of safety-related concrete.
None of the NRC inspections revealed any significant defect in the safety-related concrete placed at Waterford 3 of such seriousness that it should have been reported to the NRC under 10 C.F.R.
S 50.55 (e) because of its effect on safety.
All of the deficiencies concerning safety-related concrete identified by NRC inspections have been relatively minor, mostly involving problems with QA/QC procedures and documentation.
The results of the inspections dealing with safety-related concrete are detailed in NRC Inspection Report Nos. 75-05, 75-10, 76-01, 76-04, 76-06, 76-11, and 77-05.
In each case, the problem discovered has been. corrected by LP&L, and the matter has been closed following a reinspection by the NRC.
12.
Joint Intervenors have indicated that Contention 22 was filed as a result of an article appearing in the April 3,
- 1979, issue of the New Orleans States Item.
The article stated that three constructicm workers had questioned the concrete placement practices at Waterford 3.
The workers were unnamed but were apparently working
on the Intake Structure, which is not a safety-related structure.
LP&L investigated the allegations in the newspaper article, including numerous interviews with construction workers, but was unable to locate the three concrete workers in question, and was unable to discover any factual basis for the questions they reportedly raised.
The NRC investigated the matter independently and it also was unable to find any basis for the allegations.
13.
LP&L is aware of no basis for Joint Intervenors' Contention 22 and believes that no significant defects in safety-related concrete have gone undetected through its QA/QC program, as is demonstrated by the results of the NRC's independent inspec-tions.
LP&L has properly documented, evaluated and corrected as necessary all known defects in safety-related concrete, and it haa fully complied with NRC regulations in reporting deficiencies to the NRC.
l DATED:
August 21, 1981.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 BY:
Ernest L.
Blake, Jr.
James B. Hamlin Counsel for Applicant Louisiana Power & Light Company - -
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