ML20197H499
| ML20197H499 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/14/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20197H504 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8406180433 | |
| Download: ML20197H499 (7) | |
Text
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UNITED STATES OF AMERICA June 14, 19B4%
1 NUCLEAR REGULATORY COMMISSION
'84 gf7; 7g fJf I3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Ystter of m
CAROLINA POWER AND LIGHT CO. et al.
)
(Shearon Harris Nuclear Power Plant,
)
Unit 1)
)
ASLBP No. 82rbhA01
)
OL Wells Eddleman's Response to Sum.ary Disposition Motion on Eddleman 65 (Concrete)
Thi$ motion should be denied under 10 CFR 2.749 where there are (1) serious problems documented (see affidavit of Charles Stokes, attached) with concrete placement and practices which show there is no assurance that unacceptable, undocumented voids and honeycombing do not exist throughout the Harris containment and base mat.
These questions must be resolved on the record at a hearing in order to assure the safety of the plant.
(2) Applicants are not entitled to summary dianosition as a matter of law; nor are the Staff.
Applicants bear the burden of showing that NO set of facts available to me can prove my case on Eddleman 65.
And they must do so through affidavits of versons whose comn6tence 1
(10 CFR 2 749)
]
to testify at a hearing is shown in their affidavits. - However, neither Staff affiant Bemis nor Applicants' affiant Parsons shows direct knowledge of Harris. concrete.
Did they actually see the 1Filing date for hand service approved in June 12 conference call, by the Board, Applicants and Staff.
8406180433 840614
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batching of concrete, the pours, the vibrating, the samoling, the testing, the inspections, the repairs?
Parsons doesn't say he did, so his statements are hearsay.
Bemis says some NRC inspectors other than he witnessed many pours.
(As will be shown later, given the extensive QA failures already d ocumented by professional engineer Charles Stokes for the 5% sample of Harris plant pours provided by Applicants, Staff's statements, e.g. items 4,5 and6 on pp 3-4, and the conclusions in items 3 and 7 of Bemis' affidavit, cast doubt on the nonitoring capability, if not the integrity,of the Staff. )
But Bemis adnits (item 6, p.3 of his affidavit for the Staff) thtt the Staff did not witness the pouring of the Harris base mat.
Since many of the problems of Harris contrete are in the base mat nours and moisture seal under the base mat and around it, as Stokes documents (itens 12 and 13, pp 8-11 of his affidavit, attached),
the Staff witnesses are not competent to testify about these problems, nor do staff reports of inspections document it.
In summary, the affiants on this contention have neither direct experience and knowledge, nor documentary proof, to show that Eddleman C ntention 65 has no substanco.
Thus, as a matter of law, the o
Applicants ' motion, and Staff's suptort of it, must fail.
However, the Board (9/22/82 Order, p.58) required Contentien 65 to be supported by evidence.
Even though the '. olicants and Staff provide little or no competent evidence against the contention, this requirement seems perfectly reasonable.
I therefore engaged Charles Stokes, a structural engineer with 12 years nuclear plant experience, whose degree is in civil engineering specializing in structural and foundation design, to review the information which my discovery had brought to light re the Harris plant containment / base mat concrete.
Due to time constraints and other work, Stokes'has only conpleted a review of the 5% sample of Harris containment / base-mat pour packages
originally supplied by Applicants, and of the pour package for the one pour Applicants admit is defective.
He establishes credentials adequate for an expert witness on page 1 of his attached affidatits and lists the documents he reviewed on pages 1, 2 and 3 Items 10 thru 22 are the pour packages he reviewed.
(About 3000 pages of additional pour packages are in my possession; he can review these at a later date but was unable to even begin reviewing them by June 12.)
Stokes finds problens, based on his analysis of CP&L's own documents, in the following pours:
(1) ICBEW 219001,12.2.78 (p.3 of affidavit), 3 problems :
inadequate vibration of concrete, slump out of specification, r
and exposed aggmegate.
He also calculates that the test strength values do not comply with Ebasco's Concrete Specification Section 13.5.
(2) ICBXW 2h2001, 9.2h.80, p.k affidavit, 2 problems: inadequate vibration of concrete, and concrete being slow to set up.
Contrary to code requirements, the defect is not adequately documented (problem not clearly described) and its resolution is not adequately documented in the pour package.
(It should be noted that by vibration, voids and honeycombning in the concrete are reduced.
Therefore, inadequate or inparpper vibration can leave voids -- see p.9, parrgraph 2 of affidavit).
(3) ICBXW 256004, 8.11.81: " Incorrect vibration is a problem" Workers were warned about vibration technique.
This is the first notice of such corrective action in a packago Stokes reviewed 6p.4).
This is the pour pre-identified by the inspector as a "most difficult placement".
The slump variance is out of specification (p.5) which nakes voids likely below reinforcing steel as well as between forns and reinforcing steel.
(4) ICBXW 276002 5.2.80 (p.5) shows a vibration problem; slump was out of the given specification of 4" max, no tolerance; i
l l
' l and the weathen conditions were not roted on the CTR (Concrete Test Report) form, and this omission wasn't caught in reviews.
(5) ICBXW 290001, 7.23.82 (pp5-6) ind shows that htwritax vibration problens have not been resolved, and the concrete strength does not neet soecification.
The report even contradicts itself (see 1st paragraph, p.6) concerning the lack of strength of concrete in one sample and the strength requirements quoted.
As shown on page 7, 4 of 5 samples failed the specification requirement for concrete.
This pour is unacceptable by CP&L's o'n information, w
and tuis was not noted until Stokes ' review.
(6) ICBXW 308001 8.25.83: Two probleas, inadequate vibration and inadequate strength.
Voids are possible due to inadequate vibration.
(Affidavit of Charles Stokes, p.7)
(7) ICBXW 336003, 9.21.83 indicates vibration problems still not corrected (this af ter 5 years of pouring concrete at the Harris containmenti).
Mix problems may continue also.
Affidavit, p.7 (8) ICBXW 386001, 3 12.82, mix code docunentation problems. (Ibid p.7)
(9) ICBXW 396002, 4 5 or 6.82, indicates vibration problems (up A7-8).
(10) ICBXW 425001, 10.5.82, vibration problems with mix M81.
(11) ICBXW 444001, 12.21.82, says bothi that it did, and did not have vibration problems.
Air conten', of the mix was out of svecification, but since it was low, Stomkes does not consider this out-of-specification candition a serious problem.
(However, a field change or docunehtation that it was acceptable should be supolied).
Stokes affidavit, p.8.
(12) basemat pour ICBSL216001-shows several problems, including inadequate vibration, damaged waterstop, and out-of-specification slump which a shows the mix was too dry,. making voids likely.
l In addition, this and subsequent pours show out-of-soecification clearances to sabestos board, with no corrective action taken in
-5 inc?udingIU$3L216004 and ICBSL 216005.
several later nours, Especially significant is that 29 or 64 samples are out of specification for slump.
This was not corrected during the ulacement.
(Stokes affidavit, pp 8-9.
This is in the part mhis computer lost, and was retyped.
Basenat cour ICBSL 216002, where a large void and honeycombing were found (on the surface, since that's the only inspection CP&L/ Daniel does), has similar defects -- extensive waterston damage, 49 of 97 samples out of specification, below the minimum allowed, for slump.
Again these indicate a mix d too dry, and this can leave voids.
(Stokes, p.9).
Stokes concludes, p.10, that all pours where the slump was out of specification should have non-destructive test (s) made to find more voids; all voids found should be repaired.
This is exactly what Eddlenan 65 calls for.
He also concludes that damage to the waterstop, which has safety significance in providing a leak proof barrier, was extensive, and that management let personnel continue to damage it, without corrective action, for a long period.
Stokes' final conclusion is that possible voids due to out-of-specification slump is a serious structural concern as well as a. Safety concern due to the need to prevent leaks (the same reason the waterstop is of safetr concern).-
(p.10).
I will endeavor to locate the pages Stokes references from these pours and make them available to the Board directly on June 14/15 or at another appropriate time.
I am not sure I can get them all to the cony center in time to deliver this with them attached.
Apulicants clearly bear the burden of proof of showing that Harris meets 10 CFR 50 Appendix A General Design Criteria 16 and 50 (cf. their Motion, fn4, p.5) and 10 CFR 50.57(a)(3)(1) and (ii) wnich require that the plant be able to operate safely.
The defective concrete, only visually insoected (see, e.g.
Applicants ' answers to interrogatories 65-14(d),3-23-84 at 18, and to 65-1(a),(b) and (c) (1983), is not a leak-tight barrier, as Stokes points out.
It is likely to have voidas.
Also, the waterstop is damaged (stokes itens 12,13), and is not assured to be leak tight.
Thus GDC 16 is not assured to be complied with by Harris.
The defective concrete is also not in c) mpliance with GDC 50 because its strength is not proper in all cases, it is likely to have voids, and the waterstop is defective, this providing inadequate assurance against leakage, particularly around reinforcing, embedded pipe, and nenetrations where"many small voids are likely" (stokes affidavit at p.10)
Parason's affidavit (e.g. paragranh 23, ref p.13 of Applicants' Motion) is simnly and directly contradicted by Stokes ' analysis of the concrete pour nackages in Applicants ' own random sample.
Cohtrasting Stokes ' affidavit with Applicants ' statement of " facts" not "indisputc", we find that
- 1 is contradicted because concrete placement is not complete if all voids have not been found and filled.
- 2 is centradicted by numerous violations of slump specification,'
numerous instances of improper vibration, some below-strength concrete, sone insafficiently well-documented repairs.
l
- 3 is contradicted in that the "thonrough insnection program" did not stop repeated errors, e.g. in waterstop damage, asbestos board too close to rebar, improper vibration, and too-dry concrete l
mix which has a below-sp'cification slump.
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- 4 is contradicted because internal honeycombing is likely whenever the concrete is too dry or not properly h vibrated, q conditions Stokes finds repeatedly in the 5% sanple of Harris I
base mat and containment concrete pour packages.
- 5 is contradicted by at least one pour, ICBXW 290001, where 4 of 5 concrete samples were below required strength, and correction was not made.
Other such cases may come to light igikk beyond the 5% sample.
- 6 is contradicted strongly since Stokes docunents extensive problems with kim vibration and concrete alunp, which can lead to honeyconbing and in his view (affidavit p.10) require non-destructive examination to check for honeyennbing and voids.
4 #7 is directly contradicted by Stokes on p.10 of his affidavit where he says the concrete problems he has reviewed I
bring the structural strength of the con *ainment into question.
Stokes is a structural engineer.
Parsons shous no concrete or structural design experience in his qualifications attached to his affidavit.
Nor does NRC 's BEMIS, to my reco11e ction.
- 8 is contradicted because steel liners rust, and it's humid inside the containment.
Due to space ccnstraints I ask the Board to accept the -
l above as a separate list of facts in dispute, and to DENY the motion of Applicants to dismiss Eddleman contention 65, and to take such other action as may be ne' 'ssary or appropriate l
in light of the serious problems raised by ' Charles Stokes' analysis.
-I am filing June 14 two new contentions. based on this analysis, 65-A and *B.
I note that 10 CPR 2 7549 provides for further l
discover or depositions as part of the summary dis;osition process, and respectfully ask the Board to consider ordering these measures here.
Wells Eddleman.
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