ML20085D721
| ML20085D721 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/22/1983 |
| From: | Burstein C BURSTEIN, C.H., JOINT INTERVENORS - WATERFORD |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20085D698 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8307290067 | |
| Download: ML20085D721 (9) | |
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UNITED STATES OF AMERICA Offiteof thesee, NUCLEAR REGULATORY COMMISSION 9,'
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ATOMIC SAFETY AND LICENSING APPEAL BOARD Administrative Judges:
Christine N. Kohl, Chairman Dr. W. Reed Johnson Howard A. Wilber In the Matter of LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 OL (Waterford Steam Electric Station, Unit 3)
MEMORANDUM IN SUPPORT OF MOTION TO REOPEN CONTENTION July 22,1983 The Waterford 3 Joint Intervenors respectfully subnit that the proposed nuclear plant at Taft, Louisiana can never safely be licensed, since it is defective both in the concept and the execution, from the sikb up, to such an extent that it can never be brought up to the high standards promulgated by the U. S. Nuclear Regulatory Commission in 10 CFR 50, Appendix B, which deals comprehensively with quality assurance.
The original Contention 22 dealt with the cracks in the slab underlying the reactor that first appeared in 1977.
At that time, the Nuclear Regulatory Comunission apparently decided that the cracks could be filled with epoxy and more concrete added, eliminating any potential problems.
But on May 11, 1983, what Louisiana Power
& Light Company described as " hairline cracks" reappeared.
Much infonnation is now available, including cormnents made by LP&L k
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2 officials the day before the newest cracks were discovered, which suggest the cracks in the plant's foundation raise fundamental questions about the integrity of the plant's design and the effect it will have on future safe operation for any length of time sufficient to justify going on line.
Even though the water seeping through the cracks in the foundation now, as far as is known, is a small amount, the plant's design anticipates that the foundation will be watertight throughout its projected operating life of thirty to forty years.
Despite LP&L's current attempts to minimize the importance of the new cracks, that company's own internal documents written in 1977 af ter the cracks in the foundation directly below Waterford's nuclear reactor were discovered called them a "significant deviation from performance specifications" which could affect the " safe operation of the plant."
Water seepage through the foundation was not l
anticipated by Waterford's designers, raising questions about the adequacy of the original design and the engineering assumptions it is based upon.
If the assumption of impermeability' is wrong, what other assumptions dependent upon that basic assumption must also fall?
It is reasonable to infer that the new cracks are caused by the same mistakes that caused the original fissures.
There is no way to predict what other mishaps can flow from a design system proven already to be conceptually infirm from the outset.
Unfortunately, Waterford 3's " floating design" is sui generis among U. S.
reactors, and it is doubtful if there is an identical
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i situation anywhere in the world from which we may analogize safe i
design vel non.
Louisiana's unique geological structure, especially the mushy " jelly. ground" nature of the soils nearest the Mississippi River, made the plant's designers plan a foundation without pilings.
Three of Waterford 3's main buildings, all of those dealing with the handling of nuclear materials, were built on a " common foundation mat", a huge steel-reinforced concrete slab 270 feet wide, 380 feet long, and 12 feet thick.
Thus, the facility was to be, as it were, a steel and concrete vessel floating on the water-impregnated sands beneath and around it.
But to keep the excavation dug for the common l
foundation mat dry while the vast slab was assembled and the three l
buildings it supports erected, the builders had to install an elaborate water control and pumping system.
Under the "re-charging theory", the flow of ground water would be controlled in such a way that the water around this nuclear island would be in equilibrium with the weight of that island, creating a buoyant effect that would l
" float" the island on the hydrostatic sand around it.
But in the spring of 1977, shortly before the initial cracks under the reactor were discovered, the Waterford 3 engineers could not control the rate of recharging as their construction plan required.
According to Brian Grant, a civil engineer for Waterford's prime contractor, EBASCO Services, Inc. was slow to achieve the necessary equilibrium between the weight of the plant and that of the water in the surrounding soils.
That lag let the common foundation
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mat flex in an unanticipated way, causing a condition EBASCO's engineers later analyzed as " stress reversal", a reflection of motion in the foundation, creating cracks running all the way through the foundation and letting water into the supposedly floating vessel.
In a report written July 29, 1977, an unidentified EBASCO official wrote, "The 12 foot thick common foundation mat is considered to be thick enough to not require waterproofing to prevent leakage, therefore, this defect is considered to have possibly adversely affected the safe operation of the plant and is considered a significant deviation from performance specifications j
which will require extensive repairs to establish the adequacy of the structure."
A few days later EBASCO and LP&L reported the f
problem to the NRC as a significant construction deficiency, one i
of this Commission's most serious categories of construction failures, as we understand it, in a nuclear plant.
Despite the above report to the Commission from which further hearing is sought, the builders of Waterford 3 never addressed the underlying cause of the cracks.
Instead, they patched the cracks from the top of the foundation mat to stop the immediate water seepage through those cracks and went ahead with their construction schedule, which called for pouring great quantities of concrete over the places where the cracks first appeared.
Brian Grant, the
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l aforementioned EBASCO engineer, and Tom Gerrets, LP&L's Quality Assurance Manager for Waterford, defended this solution in a May 10, 1983 interview with Gambit Magazine, as reported in the edition of May 28,1983.
They insisted at this time that the cracks revealed no structural problems with the foundation, and :said that in
~1977 the only problem :was the possibility that the leaking water might affect the structural integrity of the concrete scheduled to be poured over the cracks.
But that problem, they felt, had been overcome by patching the cracked surfaces long enough for the new i
concrete to be poured and to set.
Now there would be no prGblem as
.t-long as there wae no further movement in the foundation, these iU" engineers said, while admitting that the movement causing thg 1977 cracks had never been anticipated.
Grant then opined that the plant had finished settling, but admitted that further settlement would be a serious matter.
And then, the very next day, new cracks appeared, raising the probability, it is submitted, of further settlement and I
thus of an admittedly serious matter.
On May 11, 1983, the day after telling Gambit that all was well, EBASCO engineers wrote a new non-conformance report revealing the discovery of the new cracks.
Report # 6212 made the admission that water was percolating through new cracks in the floor of the reactor auxiliary buildings, this floor also being the top of the common foundation mat.
Now LP&L officials have announced publicly that they are considering seeking NRC approval to change their Final Safety l
Analysis Report so that, despite the contrary theory on which Waterford 3 was conceived, this nuclear plant need not be watertight.
Mover 4
6 understands that the FSAR is LP&L's basic blueprint for the construction of Waterford 3, an agreement with the NRC spelling out how Waterford 3 is constructed and guaranteeing ita safety.
It is quite upsetting to an inhabitant of New Orleans, a city immediatel'/
downstream from Taft, to find all the basic theories on which this Waterford 3 was built in danger of being radically changed,now that the structure is built,in order to be in 'accordance with the way Waterford actually turned.out. Presumably, it will be necessary to formulate, retroactively, new thcories of safety to go with the fact that the slab is not watertight as planned.
But now, will not high-level radioactive material be leaking through the cracks as long as Waterford 3 is in operation, and finding its way into the Mississippi River, from which New Orleans derives its drinking water?
The reason for particular concern in the matter of Waterford 3 is that it is, as has already been observed, sui aeneris -- there is i
no nuclear plant like it in existence to which we can look, to see if a plant built without pilings on a cracked slab can operate i
safely for a reasonable amount of time.
Might still more settlement be expected, and if so what are the implications?
No doubt scientists can be found to support Messrs. Grant and Gerrets in their sanguine predictions of safe operation.
It is equally certain that other experts will disagree, and we pledge to produce them at a hearing.
Yet, even if Waterford 3 could under these conditions safely produce power for thirty years, we would have at best a nuclear plant that no one could ever have thought in good faith was needed in the slow-growing New Orleans area when Grand Gulf I and II are so near.
7 Waterford 3 is only 18 air miles from New Orleans, a city virtually surrounded by water and thus impossible to evacuate.
But the damage radius in the event of a meltdown is 50 miles.
According to the Sandia Report, commissioned by the NRC, 97,000 people in the New Orleans area could die in what is said to be the unlikely event of a meltdown.
The Sandia study found that a meltdown would make Waterford 3 the third most dangerous nuclear plant in the country.
Mover finds it impossible to believe, even if Waterford 3 can safely produce energy for a few years, that in its unalterably defective condition it can safely give thirty to forty years of dependable service.
When the plant must be shut down for safety reasons, one hopes not as the result of an accident, then the plant must be decommissioned.
Dr. Duane Chapman of Cornell has found after extensive studies that the cost of decommissioning equals the cost of building in the plants he has studied, which do not sit en major rivers or have cracked slabs.
How does one decommission Waterford 3, at any cost?
The people of New Orleans cannot afford, either 1
physically, psychologically, or economically, to be made guinea pigs.
Thus, the Joint Intervenors pray for a new hearing in the light of newly discovered evidence, and to reopen Contention 22.
Respectfully sulanitted, I
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Carole H. Burstein Co-Counsel for Joint Intervenors 445 Walnut Street New Orleans, Louisiana 70118 Telephone:
(504) 866-6363
CERTIFICATE I hereby certify that service by First Class Mail has been made by me this day on the parties named on the appended list, which is attached hereto and made'a part hereof.
New Orleans, Louisiana, M-.
, 1983.
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WY$hw Carole H. Burstein Co-Counsel for Waterford 3 Joint Intervenoz 445 Walnut Street New Orleans, Louisiana 70118 Telephone (504) 866-6363 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ~
Before the Atomic Safety and Licensing Appeal Board In the Matter of LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 OL (Waterford Steam Electric Station, Unit 3)
SERVICE LIST Administrative Judge Administrative Judge Christine N. Kohl, Chairman Sheldon.J. Wolfe, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Commi Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Docketing & Service Section (3)
W. Reed Johnson Office of the Secretary Atomic Safety & Licensing U.S. Nuclear Regulatory Comm.
Appeal Board Washington, D.C.
20555 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Administrative Judge Bruce Churchill, Esquire Howard A. Wilber Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing 1800 M Street, N.W.
Appeal Board Washington, D.C.
20036 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Sherwin E.. Turk, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555
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