ML20197H392

New Eddleman Contention 65-A Re Questionable Structural Integrity Due to Voids from out-of-spec Slump,Improper Vibration Technique & Inadequate Strength of Harris Containment Concrete

ML20197H392
Person / Time
Site:	Harris
Issue date:	06/14/1984
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8406180405
Download: ML20197H392 (2)

Text

. __

]Vf if 2.

t

[ D0pETp WYt .h fTU g' UWC UNITED STATES OF AMERICA June'81441984 Ay :13 NUCLEAR BEGULATORY COMMISSION

,84 31 % M hFg va.

.. m .

.. a; z w ,,

BRuc"o

. . . _ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

$Ogg Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman '

f In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

ar Harris Nuclear Power Plant,

) ASLBP No. 82-k68-01

) OL New Eddleman Contention s 65-A etc.

(Structuwal Integrity Questionable Due to Voids from Out of Specification Slump and Improper Vibration Technique and Inadequate Strength of Harris Containnent Concrete).

Based on the affidavit of Charles Stokes, concrete expert with 12 years nuclear experience, filed re Eddleman 65 today (received 6/13),

Wells Eddleman makes the followinr new contentions:

65-A. The possibility of extensive voids due to insufficient due to and/or concrete slu=p (dry concrete), inadequate vibration, inadequate strength of concrete in the Harris con _tainment, being known upon j the affidavit of structural engineer Charlean Stokes, P.E., Applicants i have not demonstrated the structural integrity of the Harris w

containment building is sufficient to protect the health and.

l- safety of the public from equipment failure resulting from failure of structures including the base slabs, embeds, pipe supports, 0 piping, pumps, and motors.

I E 65-B. Based upon the 6-12-1984 affidavit of Charles Stokes, PE, 8$

structural and concrete expert, the integrity of the Harris containment o for stoppying-leaks has not been shown to be adequate. Applicants must'show that the damage. to the Harris waterstop due to cadweldin6 etc.

has not comuromised the integrity of the waterstop.

s)so3

af -2

, As required for a new contention, I have an exnert witness, Charles Stokes; his testimony may be deemed to be outlined in his affidavit, e

particularly at pp 10-11: Voids and honeyhombing at Harris are likely due to out-of-specification concrete [too dray, etc), inadequate concrete or improper vibration, and inadequate strength may also contribute to structural problems: These can affect the structural integrity of the Harris I containment building, and vital safety equipment inside it including the base mat, pipe sunports, piping, pumps and motors. The Harris waterstop has been extensively damaged by cadwelding

! and Applicants did not correct the cause of the damage proumptly or effectively, removing the assurance of integrity of the waterstop.

MI?T'G HL@ STcX6S Cffth jbw @$3 crkg W ~7f, mfkS '

5 factors: oood cause for failure to file on time: Unavailability of basis information: Contention written same day Stokes affidavit received, and filed the next with Board and all parties.

Extent to which admission would broaden issues or delay proceeding:

Some (a Eddleman 9, 41 and 116 are going to safety hearing alone with Joint IV -- If Eddleman 65 constinues, these new contentions would add 40% to the number of issues). Extent of delay of proceeding: None, provided a quick decision on admissicn is reached. 65 days for discovery would take us to mid/ late August; the safety hearing is in October, but testimony on these issues could be filed in September and still be available sufficiently in advance of hearing.

Availability of other means to protect interest of W.E.  : None.

Staff is ducking these issues completely, see Bemis affidavit re Eddleman 65 No other party will represent me re these issues.

Extent to which other parties will represent my interests: None.

(see above).

Sound record: I have an exnert working on this. I can do technical cross-examination; without the contention, there is no record.

These are vital safety issues. Were Hcrris OK'd, it should be because

- -