ML20140D803

Forwards Supplemental Affidavits of DM Crutchfield, Re Shewmaker,R Pichumani Et Al,In Response to Aslab 841002 Memorandum & Order ALAB-786 Re NRC Evaluation of Basemat Design & Const.Related Correspondence

ML20140D803
Person / Time
Site:	Waterford
Issue date:	12/17/1984
From:	Sherwin Turk NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Johnson W, Kohl C, Wilber H NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20140D809	List: ML20140D803 ML20140D830 ML20140D845 ML20140D881 ML20140D912 ML20140D944 ML20140D962
References
CON-#484-690 ALAB-786, OL, NUDOCS 8412190210
Download: ML20140D803 (2)

Text

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/ '81 f~ 18 P3 :39 L f E E > n c u p, OCCnET' . . ei.s w a EM NCH December 17, 1984 Christine N. Kohl, Chairman Dr. W. Reed Johnson Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Howard A. Wilber p Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of LOUISIANA POWER AND LIGHT COMPANY (Waterford Steam Electric Station, Unit 3)

Docket No. 50-382 - 0 6

Dear Members of the Appeal Board:

Enclosed herewith are the following affidavits in response to the Appeal Board's Memorandum and Order dated October 2,1984 (ALAB-786):

1. Supplemental Affidavit of Dennis M. Crutchfield, dated December 17, 1984;

2. Supplemental Affidavit of Robert E. Shewmaker, dated December 17, 1984;

3. Supplemental Affidavit of Raman Pichumani, dated December 17, 1984;

4. Affidavit of John S. Ma, dated December 12, 1984, with attached report dated December 10, 1984;

5. Supplemental Affidavit of James P. Knight, dated December 17, 1984, with Attachment 1 (Note for J. P. Knight from J. T. Chen, dated December 13, 1984, with attached (undated) repcrt entiticd "Geotechnical Engint.ering Evaluation of Concrete Cracking in the Basemat, Waterford No. 3"), and Attachment 2 (letter from Robert E. Philleo to Dennis M. Crutchfield, dated November 10,1984);and

6. Affidavit of Morris Reich, Charles A. Miller and Carl J. Costan-tino, dated December 17, 1984, with attached Addendum 2 to BNL Report of July 18, 1984.

8412190210 841217 PDR ADOCK 05000382 t.

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The enclosed affidavits respond to the specific questions raised by the Appeal Board in ALAB-786, and also provide substantial new information reflecting the Staff's evaluation of base mat design and construction issues sinc.e the filing of the Staff's previous affidavits on August 7, 1984. Included among these materials are the views of Drs. John Ma and John Chen, which represent opinions differing from those of the Staff as presented by Mr. Knight and the Staff's BNL consultants (Drs. Reich, MillerandCostantino). The views of Drs. Ma and Chen are addressed in both the affidavit of Mr. Knight and Addendum 2 to the BNL report, enclosed herewith.

The Staff has previously transmitted to the Appeal Board and parties the Staff's initial Task Force report on the Waterford allegations, issued on October 1,1584, as Supplement 7 to the Staff's Safety Evaluation Report.

It was this report which was referred to in Mr. Shewmaker's affidavit of August 7,1984, and in ALAB-786 (at 15 n.15). In Board Notification No.84-170, dated October 12, 1984, the Staff identified the specific allega-tions discussed in SSER 7 which relate to the base mat. I wish to advise you that a further supplement to the SER, Supplement No. 9, is scheduled to be issued shortly; SSER 9 will document the final disposition of those allegations identified in SSER 7 as not having been resolved at the time SSER 7 was published.

Finally, I wish to note that for logistical reasons, Drs. Miller and Costantino were unable to execute their joint affidavit as of the time of filing. A fully executed copy of their affidavit will be submitted to the Appeal Board and parties in the near future.

Sincerely, kkiadl E.

Sherwin E. Turk

) Deputy Assistant Chief Hearing Counsel Attachments: as stated cc: Sheldon J. Wolfe, Esq. Docketing and Service Section Dr. Walter H. Jordan Dr. Harry Foreman Ernest Blake, Esq. Bruce Churchill, Esq.

Luke B. Fontana, Esq. Malcolm Stevenson, Esq.

'Mr.' Gary L. Groesch Ien Douglas Lindsey, Esq.

Lynn BerraLei, Esq. William J. Guste, Jr., Esq.

Carole H. Burstein, Esq. Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board Panel Brian P. Cassidy, Esq.

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