ML20079H307

Statement of Matl Facts as to Which There Is No Genuine Issue,In Support of Motion for Summary Disposition of Eddleman Contention 65

ML20079H307
Person / Time
Site:	Harris
Issue date:	01/18/1984
From:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20079H297	List: ML20079H295 ML20079H307 ML20079H317
References
ISSUANCES-OL, NUDOCS 8401230395
Download: ML20079H307 (3)

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4 January 18, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (EDDLEMAN CONTENTION 65)

Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman Contention 65, that there is no genuine issue to be heard with respect to the following material facts:

1. Concrete placement for the base mat, exterior walls and dome of the Unit 1 concrete containment structure is complete.

8401230395 840118 POR ADOCK 05000400 0 PDR

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2. The placements followed well accepted industry practices and were carefully controlled through procedures prepared by engineers.

3. A thorough inspection program was followed before, during and after concrete placements.

4. Of 106 relevant placements, only one involved honej-combing -- a nonconformance which was properly identified through inspettion and repaired to original design conditions.

5. Post-placement compressive strength tests show that the containment concrete exceeds design requirements by a siz-able margin.

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6. Absent some technically sound reason to suspect unknown significant honeycombing, soniscope examination of the containment is unwarranted.

I l 7. There is no technically sound reason to suspect the existence of unknown honeycombing capable of influencing the structural strength of the containment.

8. In addition to the concrete containment barrier, there is a steel liner on the inside surface of the containment which t

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acts as a leak-tight membrane and prevents the release of radi-ation.

Respectfully submitted, C A&&

Thomac A. Baxter, P .' C .

SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1090 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicante Dated: January.18, 1984

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