ML20079F324

Answer Opposing Joint Intervenors 831212 Amended & Supplemental Motion to Reopen Contention 22 & Request for Public Hearing.Certificate of Svc Encl

ML20079F324
Person / Time
Site:	Waterford
Issue date:	01/13/1984
From:	Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20079F327	List: ML20079F324 ML20079F340
References
ISSUANCES-OL, NUDOCS 8401180227
Download: ML20079F324 (45)

Text

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W DOCKETE.D USh?C January 13, 1984

'8;4 JAll 17 P2 :54 UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Apneal Board In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 OL

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(Waterford Steam Electric Station, )

Unit 3) )

APPLICANT'S ANSWER TO JOINT INTERVENORS' AMENDED AND SUPPLEMENTAL MOTION TO REOPEN CONTENTION 22 In ALAB-753, dated December 9, 1983, the Appeal Board denied the July 25, 1983, motion of Joint Intervenors which sought to reopen the record in this proceeding for considera-tion of Contention 22, dealing with safety-related concrete construction at the Waterford 3 facility. On December 12, 1983, Joint Intervenors filed a motion in which that party

" moves again to reopen Contention 22" and "reurges" its request for a public hearing.1/ Applicant herein opposes Joint 1/ ALAB-753 and Joint Intervenors' motion may have crossed in the mail. Because the motion states that it " moves again" to reopen the contention, it is unclear whether it was intended to be a new motion or a supplement to the earlier motion. Appli-(Continued Next Page)

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Intervenors' latest motion. ,

As held in ALAB-753, a proponent to reopen a closed hear-ing record bears a heavy burden in meeting the tests -

established by Appeal Board and Commission case law, and it must provide more than " bare allegations or simple submission of new contentions."2/ Among other things, the motion must be accompanied by "significant new evidence."3/

Joint Intervenors' motion evidences no attempt whatsoever on their part to satisfy any of the Commission's requirements for reopening a hearing record. They have not addressed the three-part test required to be met in such instances;4/ they (Continued) cant's answer herein is applicable in either case, and Appli-cant does not contest the jurisdiction of the Appeal Board, which is uniquely situated to consider the filing because of its familiarity with the matter.

2/ ALAB-753, slip op., at 2-3, and cases cited therein; see also " Applicant's Answer to Joint Intervenors' Motion to Reopen Contention," at 4-7, (September 30, 1983) and "NRC Staff's Answer to Joint Intervenors' Motions to Reopen Contentions 8/9 and 22," at 7-9 (November 28, 1983).

3/ Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2). CLI-81-5, 13 N.R.C. 361, 362-63 (1981).

4/ The three parts of the test are: "(1) Is the motion time-ly? (2) Does it address significant safety (or environmental) issues? [and] (3) Might a different result have been reached had the newly proffered material been considered initially?"

ALAB-753, at 2, . citing Metropolitan Edison Co. (Three Mile Is-land Nuclear Station, Unit No. 1), ALAB-738, 18 N.R.C. 177, 180 (1983), and cases cited therein.

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6' j have certainly not gone beyond " bare allegations or simple ,

i j submission of new contentions;" and they have provided no new j evidence. ,

l The motion consists solely of a one-page cover sheet to

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which articles from a weekly newspaper called Gambit are atta-

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ched.5/ Without question, nuclear power plants invoke contro-1

] versial and hotly debated issues in today's society, and every l

3 nuclear facility in the country has undoubtedly been the i cubject of opposing articles and editorials in the media. In

the absence of affidavits or other means of establishing the validity or credibility of the allegations in the newspaper ar-ticles, an unverified newspaper account, by itself, cannot possibly satisfy the heavy burden demanded by the Commission of a proponent to reopen a cl0ted record. Moreover, by simply transmitting a series of broed-ranging newspaper articles to

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the Appeal Board, Joint Intervenors have not specified any particular issue or issues to be litigated in a reopened hear--

j ing.

l Presumably Joint Intervenors intend that their latest

] motion is to be considered in the context of their previous i

motion relating to cracks in the Waterford 3 foundation mat.

5/ This is the third motion to : reopen filed by the Joint In-

', tervenors before this Appeal Board supported solely by

newspaper artic1'es. The first two -- motions filed on July 25-1 and November 7, 1983, to reopen Contention 22 and Contention i

8/9, respectively -- were denied in ALAB-753.

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, But Joint Intervenors have provided no explanation of how the newspaper articles, or what statements in the newspaper arti-cles, are to be related to their previous allegations wit,h respect to the foundation mat cracking. The only suggestion in that regard is Joint Intervenors' allegation in the motion that

". . . the study made by Harstead Engineering on the Waterford 3 base mat as well as that made by the staff rely on falsified documents for their basic assumptions." Yet Joint Intervenors I

have not identified any such specific documents, have identi-fied no specific statements in any such documents, and have provided no explanation of how the unidentified documents would affect the extensively documented and analytically supported determinations of both Applicant and the NRC Staff -- and in-deed of the Appeal Board -- that the cracking posed no signifi-cant safety concern.

Joint Intervenors' reference to " falsified documents" pre-sumably relates to the statement at page 22 of the Gambit arti-cles alleging ". . . missing [QA] documents that have been replaced by phony documents manufactured af ter the fact; faulty documents that have been altered or ' doctored'; and some in-stances involving possible forged signatures on safety inspec-tions okaying the workmanship on critical safety-related struc-tures." Apart from asserting generally that the " forgery" inI-volved cadwelding records (Gambit articles, at 27) the articles do not identify any specific documents, give no indication of

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d the nature of the documents, provide no explanation of what led the author to conclude that the documents had been wrongfully

tampered with or forged, and provide no explanation whatsoever

of how the documents bear any relationship to the foundation

mat cracking.

I Applicant can only speculate on the source of these i

unexplained charges. The articles describe a meeting of George

Hill, a quality assurance (QA) records reviewer, with Thomas F.

i Gerrets, Applicant's Corporate Quality Assurance Manager, and other QA personnel which took place on July 7, 1983. (Gambit i

articles, at 30). As stated in the attached affidavit of Mr.

i Gerrets (Attachment 1), reference was made by Mr. Hill to a previously existing Nonconformance Report ("NCR"),@/ NCR W3-6245, issued May 20, 1983, which identified 13 daily cadweld inspection reports-(out of thousands of such reports)

containing questionable initials of quality control inspectors

! whose job it was to inspect each cadweld of the reinforcing steel for the foundation mat. Each instance had been investi-gated, and supplementary and backup documentation verified that the involved welds had, in fact, been properly performed and F

inspected. All of this had been documented in the NCR. On i

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@/ An NCR is issued by the Waterford 3 QA organization to

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document nonconformances with requirements or procedures. Each NCR must be clos'ed with documented resolutions of the cited nonconformances.

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this basis, the welds were determined to be acceptable, and the NCR was duly resolved in accordance with the QA program proce-dures.2/ .

It would therefore appear that the charges in the Gambit articles were based on isolated instances concerning documents that had already been identified, duly documented in an NCR, investigated, and properly dispositioned in accordance with the formalized QA program procedures. Of more significance, howev-er, with respect to Joint Intervenors' motion, the NCR documen-tation provides verification that the involved cadwelds had, in fact, been properly made and inspected, and laboratory tests had been properly and successfully performed. Thus, the only allegation actually made in the motion -- that the determina-tions of Harstead Engineering and the Staff concerning the foundation mat were tainted by reliance on " falsified documents" --

is without substance.

2/ Licensee is aware of only one other instance where questions arose concerning the authenticity of record signa-tures or initials. In the course of a quality assurance records review, both original and reconstructed records of lab-oratory test reports on sample or representative cadweld splices were discovered. While the substance of the reports were identical, the signatures differed in some instances. Li-censee's investigation, which included contacting involved lab-oratory and quality assurance personnel, determined that dupli-cates of original records thought to have been lost were reconstructed from original data which existed in the testing laboratory files. The investigation verified that the data on the reconstructed records accurately reflected the actual test data, and no malfeasance was involved. An NCR was issued (NCR l

W3-7481) dures.

and duly resolved in accordance with QA program proce-Gerrets Affidavit, at 2.  ;

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The foregoing graphically illustrates the necessity of ad-hering to the Commission's exacting requirements for reopening a closed record, including the necessity to support a motion to reopen with significant new evidence. In Applicant's view, the use by a newspaper reporter of the NCR involving the cadwelding documentation as a basis for the accusations in the Gambit ar-ticles, without identifying the documents and revealing their lack of safety significance, is both unconscionable and irre-sponsible. Joint Intervenors either did not know the facts behind the Gambit articles, or deliberately chose to ignore them, and did nothing more than simply submit the articles as a basis for reopening the record. With plant preparations at Waterford 3 on schedule for a March 31, 1983 fuel loading, a hearing would delay operation by many months, at a cost to Ap-plicant and its ratepayers estimated to be up to a million dol-lars for each day of delay. To initiate such a hearing based on no more than the newspaper articles, without even a veiled attempt by the petitioner to mect the requirements for reopen-ing, would be inconsistent with the Commission's regulatory structure, and would result in enormous consequences adverse to the public interest.

While not all'eged in the motion, the articles suggest that Harstead Engineering Associates, Inc. and the NRC Staff did not i

know of QA records deficiencies when they arrived at their con-clusions about the acceptability of the foundation mat, and-o

e that such knowledge might have altered their conclusions (Gambit articles at 21, 22). Such was not the case.

Deficiencies or potential deficiencies discovered in the course of QA/QC inspections and audits are documented in NCR's, and all NCR's are subjected to a reportability review against the a

criteria of 10 C.F.R. $ 50.55(e) in accordance with the established QA program procedures and requirements. All NCR's so determined to be reportable are reported to the NRC, and all NCR's, whether or not reportable, are available for inspection by the NRC.

As is obvious throughout the text of Harstead Engineer-ing's initial reports, Harstead Engineering reviewed construc-tion records, including NCRs, in the course of its engineering review of the foundation mat. See, e.g., Section 4.0 of Report No. 8034-1, September 19, 1983, submitted in support of Appli-cant's September 30, 1983 Answer to Joint Intervenors' Motion to Reopen Contention. Morecever, after the Gambit articles ap-peared, Applicant immediately arranged for Harstead Engineering to return to the Waterford 3 site to review the QA and engi-neering records and determine whether any of the allegations in the newspaper articles would have affected the engineering study or its results. On January 9,-1984, Harstead Engineering reported its findings to Licensee and the NRC in Report No.

8304-3 (Attachment 2). On the basis of a broad and detailed i

review of the foundation mat documentation (Report, at 1),

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including the NCRs discussed above (Report, App. III), Harstead Engineering concluded that the construction records show that the design objectives were accomplished, the concrete .

compressive strength is greater than the design strength, the cadweld splices exceed the strength of the reinforcing bars, and the conclusions of its previous two reports are valid.

(Report, at 13-14).g/

As a practical matter, the hearing process must be capable of coming to closure on a reasonable and timely basis. To allow the reopening of a closed record solely on the basis of unverified allegations in newspaper articles would create the potential to protract licensing proceedings indefinitely. As observed by the U.S. Supreme Court, and noted by the Appeal Board, if a party could demand a rehearing as a matter of law "because some new circumstance has arisen, some new trend has been observed, or some new fact discovered, there would be lit-tle hope that the administrative process could ever be consum-mated in a order that would not be subject to reopening." Duke Power Company (Catawba Nuclear Station, Units 1 and 2),

ALAB-359, 4 N.R.C. 619, 620-21, (quoting ICC v. Jersey City, 322 U.S. 503, 514 (1944)).

g/ Other allegations in the Gambit articles, while dramat-ically and repetitively presented, are equally unsubstantiated and vague, with no specific identification of documents or subject matter, and no explanatory connnection to the founda-tion mat cracking. No mention of those allegations is made in Joint Intervenors' motion.

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It hardly needs to be stated that the failure of a peti-tioner to satisfy the Commission's requirements for initiating i

or reopening a hearing does not mean that allegations of real or potential safety concerns are ignored by the NRC. Allega-tions related to safety, with or without bacis, are always given consideration by the NRC Staff through evaluations by the Office of Nuclear Reactor Regulation, inspections by the Office of Inspection and Enforcement, or investigations by the Office of Investigations, or a combination of those activities. As the Appeal Board noted in ALAB-753, several inquiries had been undertaken with respect to the base mat cracking, and, in fact, a rer.ewed inquiry has already been initiated by NRC following the appearance of the Gambit articles accompanying Joint Inter-

venors' motion.

For all of the foregoing reasons, Applicant respectfully submits that Joint Intervenors' December 12, 1983 motion falls

, far short of meeting the Commission's requirements for reopen-ing the record in this proceeding and must therefore be denied.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE f

By BrWee W urchill, P.C.

Counsel for Applicant 1800-M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: January 13, 1984 n

o ATTACHMENT 2 H

f HARSTEAD ENGINEERING ASSOCIATES

• INC.

169 KINDERKAMACK ROAD, PARK RIDGE, N.J. 07656

• Phone:(201)3912115 WATERFORD III SES ANALYSIS OF CRACKS AND WATER SEEPAGE IN FOUNDATION MAT LOUISIANA POWER & LIGHT COMPANY REPORT NO. 8304-3 JANUARY 9, 1984 s l Prepared by: 1 M V \

A.I. Unsal Reviewed and Approved by: - --

G.A. Harstead

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TABLE OF CONTENTS Section Title Pay No.

1.0 Introduction . . . . . . . . . . . . . 1 j 1

2.0 Concrete Pour Packages . . . . . . . . 2 2.1 Available Documentation . . . . . . . 2 2.2 Cedibility of Documentation . . . . . 3 2.3 Strength of Concrete . . . . . . . . . 3 2.4 Remedial Measures for Placement 10B and 19 . . . . . . . . . 3 2.5 Stop Work Order No. 1 . . . . . . . . 4 2.6 Review of Nonconformance Reports . . . 4 3.0 Cadwelding Activities . . . . . . . . 5 3.1 Available Documentation . . . . . . . 5 3.2 Verification of Cadweld Locations . . 5 3.3 Strength of Cadwelds . . . . . . . . 6 3.4 Review of Nonconformance Reports . . . 6 4.0 Clam Shell Filter Blanket . . . . . . 8 4.1 Review of NCR W3-5997 . . . . . . . . 8 5.0 Waterstop Splicing . . . . . . . . . . 11 5.1 Available Documentation . . . . . . . 11 5.2 Nuclear Safety Classification of Waterstops . . . . . . . . . . . . 11 5.3 Observed Seepage at Construction Joints . . . . . . . . . . . . . . . . 11 6.0 Conclusions . . . . . . . . . . . . . 13 References . . . . . . . . . . . . . . 15 Appendix I-Concrete Package Documentation Appendix II-Cadweld Tensile Tests Appendix III-List of Reviewed Nonconformance Reports i

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1.0 INTRODUCTION

This report summarizes a study undertaken by Harstead Engineering Associates (HEA) on behalf of Louisiana Power and Light Company. The report is complementary to the previous HEA reports 8304-1 and 8304-2 (reference 1 and 2) on the structural adequacy of the Waterford 3 Nuclear Power Island Structure (NPIS) basemat.

This study involves the review of documentation which was kept during the construction of the basemat.

Such documentation would show whether the design objectives were obtained during construction and the validity of HEA reports 8304-1 and 8304-2, which had both concluded that the basemat is structurally sound.

The review of documentation was broad and detail-ed.

More emphasis was given to physical test results that were done during the construction; because such test results, more than anything else, represent the strength obtained during construction. The following items where deficiencies in records were detected by the Ebasco Quality Assurance Inspection Review Group (reference 6), were reviewed.

a) Concrete pour packages b) Cadwelding activities including testing c) Clam shell filter blanket under the basemat d) Waterstop splicing and testing 1

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t 2.0 CONCRETE POUR PACKAGES There are 28 concrete pour packages that make up the basemat. These are numbered as: 499S02-1,2,3,4 5A,5B,6,7A,7B,8A,8B,9A,9B,10A,10B; 499S01-llA,12A,13A, 14A, 15; 499S03-llB,12B,13B,14B,16,17,18,19. A 100%

review of these concrete packages were made.

2.1 Available Documentation The following documents were reviewed for each concrete package:

1- Concrete pre-placement checklist record (J.A. Jones) 2- Concrete pre-placement checklist record (Ebasco) 3- Daily concrete inspection (Ebasco) 4- Concrete placement inspection (Ebasco) 5- Concrete curing log (J. A. Jones) 6- Concrete curing record (Ebasco) 7- Concrete test record (Ebasco) i 8- Concrete physical tests (Ebasco) 9- Concrete pour plan (J. A. Jones) 10- Embed map log (J.A. Jones) 11- Cadwelded locations (as-built) 12- Requisition on warehouse 13- Concrete mix delivery tickets Other tnan the above documents, pour package 499S02-5A contained a site audit report. The' availability of the above documents for each concrete package is listed in Appendix I of this report. This list shows that almost all packages contain these records. The list of documentation also shows that-some records are kept both by J.A. Jones Construction Company and Ebasco, independently. This double check ensures two things:

1) If an item is missed by one party, it will be picked up by the other party; 2) If for any reason a

record is missing, it can be obtained from the other

party.

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2.2 Documentation Detailed records were kept during the construction of the basemat. Such detailed information shows that care was given to control the quality of concrete.

Nonconformance reports were issued and resolved.

Separate items are checked and initialed. Overall the records indicate an attentiveness and responsiveness to the construction process.

2.3 Strength of Concrete )

In the design of the basemat a concrete strength (f') of 4000 psi is used (reference 2). During the pouring of concrete, tests were performed. All the tests for the 28 concrete pour packages were reviewed.

These test results show that the average 28 day con-crete strength for all placements is 5305 psi. The minimum average concrete strength is in placement 15 with a value of 4698 psi. As can be seen from these test results that the average 28 day strength of con-crete is 30% over the required design strength of con-crete. At this time, the aging of concrete has caused further increase in the concrete strength.

After the placement of 108, cores were taken from concrete and tested for strength. The average 32 day strength of 20 cores was 6150 psi. For place-ment 10A concrete physical tests show a 90 day average compressive strength of 6406 psi. These show that the concrete strengths obtained in actual construction are much higher than the design requirement of 4000 psi.

2.4 Remedial Measures for Placement 10B and 19 During the pouring of placements 10B and 19, problems were encountered. As described in HEA report 8304-1 section 4.2 (reference 1), extensive evaluation and repair programs were established. These two inci-dents clearly show that problems in pouring concrete were addressed and corrective actions were taken.

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4 2.5 Stop Work Order No. 1 As mentioned in HEA Report No. 8304-1 section 4.1, LP&L issued SWO No. 1 on December 16, 1975 in order to correct deficiencies and nonconforming work in the inspection and control of concrete mixing, trans-l porting and placing of concrete, curing and finishing during placement 499S02-6. This indicates that work not conforming to the specifications was not tolerated by LP&L.

2.6 Review of Nonconformance Reports (NCR)

Major nonconformance reports related to concrete pours including W3-39, W3-93, W3-7149, W3-7150, W3-7151, W3-7252, W3-7154, and W3-7353 were reviewed (see Appendix III for a complete list of reviewed nonconformance reports). Of these, the two most important nonconformance reports are W3-39 and W3-93.

These relate to placements 10B and 19. The disposition of these nonconformance reports needed repairs in these placements.

For sampling purposes, other NCR's relating to the early stages of concrete pouring were also re-viewed. These included NCR's W3-10, W3-24 through W3-27, W3-27, W3-29 and W3-31 through W3-33 (Appendix ,

III). The NCR's show that daily problems existed in the process of placing concrete for the basemat. Such problems are common and occur at each construction site.

The dispositions of these NCR's do indicate that the design strength values for concrete were not adversely l affected. Minor deviations from specifications do not affect the strength of concrete and the structural integrity of the whole basemat.

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t 3.0 CADNELDING ACTIVITIES In the Waterford 3 basemat, cadwelds were used to mechanically splice the reinforcing bars. Cadwelding is very important because, if reinforcing bars are not connected properly, it will result in a loss of strength of the basemat. In reviewing caldweld activities, two important items must be confirmed: 1) Cadwelds are properly placed in the required locations; 2)

Test results of production calwelds indicate that they possess the required design strength.

3.1 Available Documentation The following documents, totally or partially were reviewed for the basemat cadwelds:

1- Daily cadweld inspection reports ( J .A. Jones) 2- Cadweld daily inspection-visual (Ebasco) 3- Reports of tensile tests-cadweld splices (Ebasco) 4* Weekly cadweld or rebar test reports (J.A. Jones)

Emphasis was given to the tensile test reports and daily inspection reportn to confirm the two areas of concern, as mentioned earlier.

3.2 Verification of Cadweld Locations Whenever a cadweld was made, it was recorded in the daily cadwold inspection report by J.A. Jones construction company. This report also included a pre and post weld inspection with regard to the acceptibility of the cadwelds. Such inspections were also partially made by Ebasco, as a double check of the cadwelds. Before the pouring of concrete, loca-tions of cadwelds were mapped. .The pre-placement checklist records for both J.A. Jones and Ebasco show that the cadwelds are checked before the pouring l of concrete. These all show that the possibility of not making a cadweld where it is required is remote.

l The documentation show no indication that such an' error could have occured.

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3.3 Strength of<Cadweldi *

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' Ebasco spe:ificatiotl LCU-1564.479 (reference 3, paragraph 15.91) , q states that the tensile t.csts should meet the following two acceptar.ceistandards:

1- The tensile strength of.9i.ph sample tested shall equal or exceed 125 percent of the minimum yield strengtli specified in ASTM Standard A-615 for the specified grade of reinforcing bars. For the i

specified Grade 60 reinforcing bars, this value is 75,000 psi.

2- The average tensile strength of each group of 15cfnsecutive'samplesshallequalorexceedthe guataateed ultimate tensile strength specified for the reinforcing bar. s For the specified Grade 60 re-inforcing bars, this value is 90,000 psi.

I All'cedwald tensvle tests for the basemat has been include'dfin App't.ndix.Il of this r'eport. All the tests except one are production splice tests, which is a very good indication of'tha in situ quality of con-struction. ,The total of 82 tests resulte,d in an average tensile strength of 95,401 psi'with a minimum '

tensile strength of 80,750 psi. The average tensile strength is 6%, and the r$1nimum tensile strength is 7%overtherequiredstrendthsby..Ebascospecification (reference 3). Thcae test result's indicate that the installed cadwelds meet the required design strengths.

The design strength used for the design of reinforcing bars is 60,000 psi. 'The stresses in the reinforcing bars in'the basemat are, in general, well below this stress value, for the required load combinations (reference 2).

3.4 Review of Nonconformance Reports The major nonconformance reports, relating to the basemat cadwelds, W3-6234, W3-6245 and W3-7481 have been reviewed in detail (see Appendix III for titles).

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4 All of the NCR's have been initiated in 1983, approxi-mately 7 years after the pouring of the basemat, and are related to documentation of the cadweld activities.

The problems stated in theae NCR's are common to nuclear plant construction sites, where a great amount of docu-mentation is generated. However, the overall review of documentation of the basemat does not indicate that the design objectives were not met. As mentioned in paragraph 3.2 and 3.3 of this report, the two important factors relating to the strength of the basement were verified through the available documentation.

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4.0 CLAM SHELL FILTER BLANKET Quality Assurance Nonconformance Report No.

W3-5997 and supporting documentation dated 6/24/1983 i (Appendix III) have been reviewed. Areas of noncompliance were reported in the following categories:

1. Compliance of clam shell filter blanket con-struction with the test fill

2. Traceability / location deficiencies

3. Engineers approval prior to shell placement

4. Certification of personnel

5. Testing

6. Documented deficiencies without documented corrective action Review of the above itemized documentation was con-ducted in order to address the following:

1. Have the apparent deficiencies been satisfactorily addressed?

2. If satisfactory explanations were not provid6d, what would be the impact of inadequate installation of the clam shell blanket on the pouring of the concrete mat and successful implementation of the " floating foundation principle" in the

, construction of the nuclear island?

3. In the light of additional information provided, will it be necessary to modify the conclusions reached in references 1 and 2.

4.1 neview of NCR WJ-5997 It is considered that the explanations provided in Attachment IV of NCR W3-5997 entitled " Engineering Disposition of Non-Conformance Report W3-5997" for the cited deficiencies are reasonable and acceptable.

In view of the extended period of time necessary to excavate and expose the base of the excavation to permit placement and compaction of the filter blanket and pouring of the concrete mat, it is evident that a number of field problems arose during construction 8

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4 which could not have been fully anticipated from the experience gained on the short term duration test fill program. These problems had to be resolved quickly in some instances e.g., drainage of filter layer from rain and runoff, and it is apparent that

the documentation covering the remedial action re-quired was not fully complete.

The major thrust of this review has been to establish that the filter blanket generally functioned as intended during construction. The principal characteristics of the blanket are defined as follows:

1. Free draining capability of the blanket would be required in order to ensure'relatively uniform pore pressure dissipation in low permeability foundation silts and clays on application of load.

2. High permeability of the blanket would permit r.apid piezometric response and provide a means of achieving the dewatering control during construction and backfilling operations.

3. Catisfactory compaction would provide a uniformly dense layer of high strength and relatively incompressible material thereby providing a working surface for the placement of mat reinforcing steel and support of the structures.

From the above it should be noted that.the inclusion of the shell filter blanket underlying the mat was primarily to improve construction expediency and consequently would have negligible influence on the long term operation of the plant. The additional documentation was reviewed to determine if the desired degree of construction control had been achieved during the placemer.t and compaction of the shell material.

The following were noted:

1. The material used in the shell blanket was of similar classification and gradation to that used in the test fill program.

2. The placement of a geotextile fabric (Mirafi) on 9

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the exposed base of the excavation minimized infiltration of underlying clays and silts. ,

3. Material was placed to the approximate design loose thickness and compacted with 10 passe s of and approved 10-ton vibratory roller. From the test program it had been determined that this compactive effort would result in a relatively uniform and acceptable density equivalent to approximately 90% of the maximum Modified Procter Density.

4. In situ density tests conducted after placement and compaction indicated that the required minimum density had been achieved.

5. Mechanical analyses conducted on representative samples of compacted shell indicated that the percentage fines passing the #200 sieve were less than 5% which is indicative of minimum breakdown.

6. Permeability tests conducted in situ after compaction indicated a "k" value greater than lx10-2cm/sec. which is indicative of free draining material.

7. Drainage of filter blanket from rain and runoff was accomplished successfully by excavating locally and pumping from sumps.

8. Short and long term compressibility characteristics of the compacted shell due to planned structural loads (approximately 4 ksf) were negligible.

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5.0 WATERSTOP SPLICING Waterstops are used in the basemat between each placements according to Ebasco drawing G-499501.

Such waterstops are installed to reduce the water leakage to the building through construction joints.

5.1 Available Documentation The following documentation is available for the waterstop splices.

1. Waterstop splice log (,.A.J Jones)

2. Tensile strength test reports (Pitsburgh Testing taboratory)

Each splice is logged into the splice log table.

Samples are tested in accordance with Ebasco specification LOU-1564.476 (reference 5). Samples of documents reviewed show that splices are recorded and tested adequately.

5.2 Nuclear Safety Classification of Waterstops As clearly stated in an Ebasco correspondance (reference 4), neither waterstop material nor installation is Nuclear Safety Related nor Seismic Class I. There is no structural function for the waterstop, as it does not reduce or increase the structural capacity of the basemat.

5.3 Observed Seepage at Construction Joints Note additionally that only two instances of seepage through basemat construction joints were actually observed, in a survey conducted be HEA to map cracks in the basemat outside of the Containment area. The first instance documented was for a construction joint parallel to, and just South of column line R, located between column lines lA and 1M. The second instance is through a construction joint parallel to, and just West of column line 7FH, located immediately South of the Fuel Handling Building ( see Subsection 4.6 and 1

l l 11 r

Appendix A of Reference 1). In both instances the observed seepage is no worse than the usual seepage observed in other cracks throughout the basemat.

l l

12-n

t

6.0 CONCLUSION

S A comprehensive review of the records relating to the construction of the Waterford III Nuclear Power ,

Island Structure basemat was performed. The objective of this review was to determine whether the parameters used in the design are consistent with the actual construction records and therefore the conclusions reached in HEA reports 8304-1 and 8304-2 (references 1 and 2) are still valid.

The concrete pour records show that the average concrete compressive strength is 30% over the required design strength. The actual concrete strengths will be even much greater due to the ageing of concrete.

Records also show that care was taken during the curing process of concrete.

The average of the cadweld reinforcing bar splice test results exceeded the minimum yield strength and the ultimate tensile strength of the reinforcing steel by approximately 59% and 6%, respectively. In addition the records show that cadwelds were properly placed in the required locations.

Upon reviewing the nonconformance report W3-5997 it is considered that the filter blanket was placed and compacted satisfactorily and consequently functioned as intended during construction.- Detailed analysis of the instrumentation readings summarized in the previous report indicated relatively uniform settlement of the structures on application of load and with the general

" leveling off" of the settlement pattern on full application of the buoyancy effect, there is subscantial verification that the required design control was achieved during construction. Among the many purposes ,

of the clam shell layer, the major one affecting the l constructed basemat was to minimize the potential for

~

differential soil settlements, which could cause 13 -

h

- A a -

s2 %+ w _-,, i--Ga b., A a b 4, A -wam --5+ 4 AJ-1+ A 2Jk2 m* a- - ~,o M m

. secondary stresses (references 1 cnd 2) . This objective was obviously achieved.

Overall review of the construction records for the basemat show that the design objectives were accomplished.

Therefore, no modifications are necessary to the con-clusions reached previously in HEA reports 8304-1 and 8304-2 regarding to the structural adequacy of the i basemat.

1 i

i i

1 1

I l

J 14

_ .-_ _ -~ _ __ , _ .- _

.O

. l I

REFERENCES

1. HEA Report No. 8304-1, ' Analysis of Cracks and Water Seepage in Foundation Mat', 9/19/1983

2. HEA Report No. 8304-2, ' Analysis of Cracks and Water Seepage in Foundation Mat', 10/12/1983

3. Ebasco Specification LOU-1564.479,' Mechanical Splicing of Concrete Reinforcing Steel, Seismic Class I, 3/11/1975 (Rev. 2)

4. Ebasco Interoffice Correspondance, B. Grant to A.Cutrona, ' Nuclear Safety Classification of Waterstops', 12/13/1983

5. Ebasco Specification LOU-1564.476, 'Waterstops',

6/15/1972 (Rev. 2)

6. Ebasco Interoffice Correspondance, G. Hill to John Czyrko, ' Review of Seismic Class I Concrete Records', 6/6/1983 i

15 h

l l

~

i APPENDIX I CONCRETE PACKAGE DOCUMENTATION

, i. -n

PROJ. NO. %. \

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- _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ R

w 4

e f

e l

APPENDIX III LIST OF REVIEWED NONCONFORMANCE REPORTS A

NCR No. Title Comment W3-10 Concrete Placement W3-24 Pour 499S02-7A-Air Content W3-25 Pour 499S02-7A-Slump W3-26 Removal of Formwork W3-27 Placement 499S02-8A-Embedded Elephant Trunk 4

W3-29 Foundation Mat-Air Content W3-31 Common Mat-Air Content W3-32 Common Mat-Number of Revolutions W3-33 Common Mat-Air Content W3-39 Common Mat-Strip #3, Section 10B W3-93 Common Mat-Placement Nc. 499S03-19 W3-5563 FHB Bridge Crane-Connection Tests N.A.

W3-5564 FHB Stairs-Welding and Bolting N.A.

Inspection of Seismic Class I Stairs W3-5565 FHB Bridge Crane N.A.

W3-5598 Tubing N.A.

W3-5973 FHB Tornado Door Frame N.A.

W3-5997 Clam Shell Filter Blanket Under the Nuclear Plant Island W3-5998 Production Cadwelding W3-6234 Cadwelding W3-6245 Daily Cadweld Inspection Reports W3-7149 Concrete Placement Packages-Common Foundation W3-7150 Concrete Placement Packages W3-7151 Concrete Placement Packages-Common Foundation W3-7152 Concrete Placement Packages-Common Foundation W3-7154 Concrete Placement Packages W3-7353 Concrete Placement Packages W3-7481 Cadweld Tensile Test Reports N.A. Not applicable or related to basemat 1

1

, -_ ._ - -. ..- N

's e

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Boar'd In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric )

Station, Unit 3) )

CERTIFICATE OF SERVICE This is to certify that copies of " Applicant's Answer to Joint Intervenors' Amended and Supplemental Motion to Reopen Contention 22" are being served to all those on the attached Service List by deposit in the United States Mail, first class, postage prepaid, this 13th day of January, 1984.

]

Bruce WT Chnr~ chill,

[. - _ kiv P.C.

Dated: January 13, 1984

I 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Boa'rd In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric )

Station, Unit 3) )

SERVICE LIST Christine N. Kohl Sheldon J. Wolfe Administrative Judge Administrative Judge Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 W. Reed Johnson Harry Foreman Administrative Judge Administrative Judge Atomic Safety and L'icensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission Director, Center for Population Washington, D.C. 20555 Studies Box 395, Mayo Howard A. Wilber University of Minnesota Administrative Judge Minneapolis, MN 55455 Atomic Safety and Licensing Appeal Board Walter H. Jordan U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Sherwin E. Turk, Esquire 881 West Outer Drive Office of the Executive Oak Ridge, TN 37830 Legal Director U.S. Nuclear Regulatory Commission Docketing & Service Section (3)

Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel ,

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 11

O g LP&L Service List-ASLAB Page Two Mr. Gary Groesch Luke B. Fontana, Esquire 2257 Bayou Road 824 Esplanade Avenue' New Orleans, LA 70119 New Orleans, LA 70116 Brian Cassidy, Esquire Spence W. Perry, Esquire Federal Emergency Management Federal Emergency Management Agency Agency Region I Office of the General Counsel 422 J. W. McCormack 500 C Street, S.W., Room 840 Boston, MA 03109 Washington, D.C. 20472 Carole 11. Burstein, Esquire 445 Walnut Street New Orleans, LA 70118 I

f i

E J

_ __ , , . _