ML20078M255

Response to Applicant Interrogatories on Eddleman Contention 65 (Sixth Set).Certificate of Svc Encl.Related Correspondence

ML20078M255
Person / Time
Site:	Harris
Issue date:	10/21/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8310250086
Download: ML20078M255 (8)

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RELATED C0FES?C:0Z:ICL UNITED STATES OF AMERICA October0 knii

. USNRC NUCLEAR REGULATORY COMMISSION

'83 00124 Pl2:25 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD nCE OF SECRiTAF -

Glenn O. Bright C0CHETlHG & SERV:Cl.

Dr. James H. Carpenter BRANCH James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, Units 1 and 2)

)

Wells Eddleman's Resnonse to Applicants' Interrogatories on' Eddleman 65 (Sixth Set)

This response is filed under an extens, ion of tim negotiated with Applicants' counsel O'Neill. I think it would be more constructive to answer these after I get the information resulting from ny 3

motion to compel on my first set of inteirogatories on this contention (which he says will be filed October 28 or th'ereabouts), but Applicants decline to grant any extensiob for these responses bhond October 21.

RESPONSE TO GENERAL INTER 50 GAT 09IES 01(a) and (b): Answers will annear with specific interrogatories.

-OBJECTION: I have previously objected to identifying nonwitbess exnerts and renew those objections here. (c) See (a) and (b) above and previous objections. This interrogatory is imoroner in that given Applicants' answer to my interrogatory G-5 (that they do have

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information and experts available on the subject matter of Eddleman 65) 0 Applicants cannot make the threshold showing of 10 CPR 2.714 (b)(2~)

that they have substantial need of the information reque sted, and cannot obtain the equivalent of the raquested info without undue ,

hardship. Applicants have yet to make any such showing.

See previous objections which I renew here.

9310250096 831021 N h/

hDRADOCK 05000400 PDR __ _ _, _ _ __

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G2(a) and (b) See specific resnonses. Where documents would identify a nonwitness expert, a version deleting information which would, identify such expert will be orovided. Your resnonses to interrogatoriesy"where cited, you possess.

G3(a) and (b): See specific interrogatory responses.

Specific In;errogatories:

65-14(a) The description is so sketchy (and sometimes conclusory, e.g. " closely controlled", "any defects which may exist aren ...

repaired") that it is impossible to tell. The site work procedures, technical procedures, and administrative procedures referred to therein are not identified or specified; the criteria for purchase and testing of materials are not given, the qualifications required of inspectors are not given, the accentance/ rejection criteria for batches of concrete as mixed are not given, the mix proportions are not given, nor are homogenicity criteria given.

The qualifications of placement insnectors are not given.

and of The method of verification " of placing, consolidation and of finishing are not given. The acceptance criteria for these are not given.

The frequency of molding cylinders are not given for any operation of concrete pouring for the Harris base mat or containment. The applicable applicable NRC and othergstandards are not even cited in the response to 65-1(a). The frequency of monitoring, measurement of temperature and moisture conditions and criteria for nost-placement check (including when and how it is done, and accept / reject criteria) are not given. No means of detecting "any defects which may exist" is given in response to 651-1(a). Which of the information given on page 30 (in response to 65-1(a)) must be in the " pour package"

• dam **fi mentioned on page 31 (of 5-12-83 resconse) is not suecified or characterized. QA and QC nrocedures for verifying that the things described have been done, are not given. No verification of

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l inspection prodcedures, activities, or results is described at all.

In addition, I have been able to see the conditions under which cylinder samples are l concrete in c.ured at Harris, which have no relation to site conditions l or the curing of concrete on-site, according to concrete expert l

Yenta Yoe, who also observed the curing procedure and facilities used.

(I and *YY" saw this years ago; I .have no information that the i curing procedures have been changed). Reserve cylinders are not, so far as I know, cured under condit$ ons matched to those experienced by the actual concrete emplaced, and the retention period given

("several months") for such reserve cylinders appears to mean that after some months, the cylinders are discarded and no further tests can thus be done. In sum, I know the above defects; resnonse to 65-1(a) reads like a lawyer wrote it and conveys virtually no specific info.

(b) See (a); Since question (a) and the resnonse to 65-1(a) do not mention any NRC regulations or industry codes, this nart of (b) appears to be irrelevant or poorly worded. No claim of (or verification of) compliance with any snecific N9C or industry code l re concrete placement at Harris is even alleged in broad terms such as "we rigorously strive to comely with all annlicable codes",

much less identifying any specific codes or regulations which Applicants

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claim to comply with.

(c ) N/A, see (a) and (b) above.

65-15(a) No specific methods of detecting voids or honeycombing are identified. Once I get the discovery information on the actual voids and honeycombing so far detected in the containment, I will be able to comment in more detail. One eroblem wida the respcnse l

l to 65-1(c) is that it describes actions as if they automatically achieve the required results. The answer as to the " nature and

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l-extent of all. inspections" simply states (I quote) "After each l placement is comoleted, a Post Placement Inspection is conducted l

-g-by Construction Inspection personnel who examine the exnosed concrete surfaces for honeycombing and voids". That's the entire direct answer to tha question. It may be a lousy answer, but you made it, and from it I certainly cannot infer any adequacy of insnection.

Together with your restonse to 65-1(d), it seems to say that only the surface of concarete as Harris has been insnected, though of course honeycombing and voids occurring inside the concarete are of concern as to the strength and integrity of the containment and base mat. If you don't look for internal voids and honeycombing (it certainly anpears from discovery so far that you doA't), you can't find them. Please consider the .nreceding an amended answer to your interrogatory 65-3(b) also.

Too few specifics are given about vibration, design of concrete mixes, who watches the placement from where (can they see it all?

If it's one person, I doubt seriously that person never takes her/his eyes off the concrete), and so on are given to evaluate the adequacy of the prevention measures for voiding and/or honeycombing.

No criteria for what is " sound concreto" around/behind an area of voiding and/or honeycombing are given in your answer c

to 65-1(d). No methods of curing or repairing are given.

No criteria for the repair or curing are givenn. No procedures thereform are mentioned or cited. How can I judge the adequacy i

f of the methods, criteria and procedures without knowing them?

i (b) ' See (a) above, though the answer to (a) is basically that insufficient information has been nrovided to assure that l

any methods are adequate, and no efforts to detect voids or honeycombing l

other than at the surface of the concrete annear to exist, a clear

! You identif no N C rules o industry codes or nrocedures in 65-1(c).

inadequacy. (c See b and a above i

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I don't know, some method of detecting voids and 65-16(a) honeycombing which occur other than at the surface of containment and base mat concrete at Harris is clearly necessary. Ultrasonic testing may not be anplicable in many instances because the return of sound pulses along the rebar may give a false " good concrete" sisgnal in terms of the speed of sound found.

65-16(b) CP&L has not met General Design Criterion 1 of 10 CFR 50 Appendix A in that for codes used, it ~ does not accurate give an valuation of their adequacy and sufficiency; GDC 16 on leak-tightness cannot be maintained if there are undetected voids and honeycombing in the base mat or containment which have not been repaired. A void in a basemat area under the reactor could nrovide a pathway for a melted core to more easily escapa containment.

If the containment is not properly constructed to reeti its design basis (GDC 50) it cannot carry out its function under GDC 1: voids do not have strength; honeycombed concrete has less than the required strength and resistance to penetration (from inside and outside)

, under normal- and accident conditions. Voids and honeycombing can serve as loci for fracturing (vaiolating GDC 51); in addition, they can contain moisture which can weaken adjacent narts of the reinforcement and concrete. Voided and honeycombed concrete clearly has less ability to resist residmual, steady-state and transient stresses on the containment (violation of GDC 51).

Finally, .without some method of dtecting voids inside the concrete, there is no assurance the Harris containment and base mat AS BUILT actually meet GDC 1, 16, 50,51, or odher applicable reauirements.

More information Maould be provided 10-28-83 to me on discovery from my first round.

I have not evaluate.d the adecuacy of the codes

mentioned in the FSAR in your response to my interrogatory 65-7.

These appear to be the only codes you have cited so far.

65-16(c) See (a). Not Auplicable.

65-17(a) Per pour statements, dhe renairs would be no more adequate than the original work even if everything you allege is r

done is done perfectly. I have not inspected the work / repairs nor had it inspected at this time; the inadequate explanations and failure to provide procedures discussed under 65-14,65-15 and 65-16 above maMe it difficult to gi've a more detailed answer.

The work procedures mentioned in resnonse to 65-1(j) are not given, means of assuring the adhesion of the patching' to the concrete are not given, and it appears that these methods are only anplied to surface defects (see resnonse to 65-15(a) above).

Your responses contain unsuonorted assertions like " procedures are adequate to insure that the patched area is accentable" -- but how do you know (or figure out) that the" acceptable" patch (according to criteria never ppecified) is really as strong, if you haven't

, calculated it or tested it. Your answer seems to say you didn't calculate it, and it does say you hever have tested the strength of the repairs. How do' I know what "the design engineer desires" as to quality of work. You don't exolain how concrete is tested during repairplacements of what tests are made on it. Answers

_like these seem almost to be designed to annear to contain information l

while containing little or no useful facts or basis for checking.

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Under such circumstances, it is very hard to give a definitive answer to whether what you " describe" (sketchily and conclusorily, without sunport) in your answer is " adequate" -- I'm not sure what

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i it really says about the actual concrete at Harris. It is the actual concrete in place (with rebar) that is of concern here.

65-17(b) I haven't seen the information on their corrective actions that would enable me to verify adequacy. It seems silly to demand that I answer a question before you give me the information on the actual repairs, but you did. I can't specify corrective ,.

actions in any detail (daough it surely would help if you had tried to detect internal voids and honeycombing) without seeing what youd did. -

As discussed under (a) above and other places above, your "answerns" don't give enough information to tell much about what actually was done.

You have claimed no e mpliance with specific NRC regulations or industry codes in your response to 65-1(i) and (j). The answers given are vague and general and often phrased so that they give a conclusion without any information to sunnort it.

65-18(a) Any rebar tends to increase the nossibility that voids or honeycombing can occur. It annears that the Harris base madt was out in mostly in a large monolithic pour. If so, it urobably would not have been poussible to vibrate all of it thoroughly en_ough to minimize internal voids or honeyxcongbing; at any rate, ho attemnts appear to have been made to find them, so we don't know how many are there. A test of the results is required, regardless of the rebar placement, pouring procedures, vibration, concrete characteristics, etc. Obviously, the rebar doesn't act in isolation --

theviscosityandslumpofthecod(ete,therateandmethodofnouring, j and other factors enter into it.

(b) see (a) above.

65-19 (1)-(v) I cannot readily locate detailed info on any of this.

I understand that Daniel is the prime contractor and as such would be i

i in charge of erecting the containment and nouring its wall and base mat.

65-20(o) Asked and answered in previous general interrogatory re witnerses. When I identify witnesses I will let you know.

(b ) N/A

UNITED STATES OF AMERICA NUCLTAR REGULAToNY COMMISSION Dockets 50-400 In the matter of CAROLIKA POWER As LIGHT CO. Et al. )) and 50E01 0.L.

Shearon Harris Nuclear Power Plant. Units 1 and 2 CEftTIFICATEOF SERVICE I hereby certify that copies of wE T,-+. ~.-gg. to DC Staff fad set)

WE Interrogatories to Anolicants (6th set) h,, *S_2e*rh ff["""'

HAVE been served this 21st day of October 198J, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are parked with an asterisk, for whom service was acconplished by

• Interrogatories / responses to Judge Kelley and CA Bat th nnly Per ork1 order, among the parties asterisked.

• JudEen James Kelley, Glenn Bright and Janas Carpenter (1 egy each)

Atomic Safety and Iicensing Board l

US Nuclear Megulatory Commission l Washington DC 20555 l

l George F. Trowbridge (attorney for Applicants) #1Luthanne G. Miller Shaw, Pittman, Potts & Trowbridge ASLB Panel 1800 M St. NW USNRC Washington DC 2055 5 Washington, DC 20036 Office of-the Executive Legal Director Phyllis I,otchin, Ph.D.

Attn Dockets 50-400/401 0.L. 105 Bridle Run USNRC Chanel Hill NC 2751h Washington DC 20555 Dan Read Docketing and Service Section[GK) CEAUGE'/FLP Attn Dockets 50-koo/hol o.L. Box 52h Office of the Secretary Chapel Hill NC 27514 USNBC Washington DC 20555 not ert eruber, axee. Dir.

99 Runkle [ .

307 Granville Rd *Bradley W. Jones Chapel Hill Nc 2751h USNRC Region II

~Travi s Payne 101 Marietta St.

Edelstein & Payne Atlanta GA 30303 Mox 12601 Raleigh NC 27605 Certified by h Richard Wilson, M.D.

729 Hunter St.

Apex NC 27502

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