ML20127B645
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{ i MOV 16M , MEMORANDUM FOR: D. G. Eisenhut, Director, Divisten of I.fconsing
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FRON: John T. Co111as, Regional A M afstrator g:, y *
SUBJECT:
INSPECTION OF DEWATERING A88 EXCAVATION ACTIVITIES AND CONSTRUCTION OF THE Coleq0N FOUNDATION M4T FOR THE WATERFDRO 3
- PRIMECT '
i i Louisiana Power & Light Company was issued Construction Permit CPPR-103 to construct the Waterford 3 Pro {ect on November 14,' 1974 o Initial site preparation activities cons'isted of dewatering and excavation to ' approximately 60 feet below grade level with attendant monitoring by piesometers, observation wells, slope indication instruments, and alignment monitors. i Although July 28, 1972, site excavation to 60 feet below grade was authorized by the AEC on digging was stopped at 17 feet to preclude installation of dewatering facilities. An LWA-2 was issued on July 24, 1974, under the j. j
' provisions of 10 CFR 50.10(e)(3), but site excavation ws not commenced until ;
ccrly facilities. 1975 after issuance of the CP and installation of the dewatering Prior fer site to site preparation activities, NRC inspectors reviewed QA/QC procedures preparation. i Inspection of test data and ongoing dewatering activities, waitoring of excavation and dewatering was performed. Dewatering of the site to the required level was completed in January 1975 and excavation commenced about March 1975, and was completed to the top of the , I pleistocene layer about the last quarter of 1975. Strip removal of a top i layer of the pleistocene clay with installation of shell filter blanket and mud met was inspected by the NRC inspectors. l . Follow on inspection activities by the NRC inspectors of initial site i preparation activities included approximately nine inspections. i The common foundation concrete met for the Waterford nuclear plant tsland is a rainforced concrete structure 270 feet wide. 380 feet long, and 12 feet thick. The structure was erected in 28 placements involving approximately 50,000 cubli yards of concrete. l Y RPS-8 V F n l WCrosj/83 man 4 RP81 EJohn n DRRP&EP/Rrl " rdo Vg( 11//, % - 1 11// 83 JGagtp/83 11/p 33//$83 ) ,
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- D. G. Eisenhut *
-2 NOV 16 IS83 ;
i WRC inspecU on activities for concreting. included review of QA/QC procedures for production, placing, and testing of concrete. laspection of concrete ' production facilities included materials, certification, capacity (also backup), batching and transport. Inspection of placing included forms,
- water stops, rate of placement, censolidation, finishing and curing. Inspection of concrete etc.) testing included and compression testing. tests of batched concrete (slump, air entrainment, j
i Reinforcing and steel inspection included receipt hand 11ag, Cadwelding testing, installation. l
! NRC InJpectors began inspection of the licensee 'and contractors
- QA/QC programs
! in late 1974 and continued onsite inspection activities for site preparation I cad placement of the common foundation met until completed. The first placement for the foundation met was completed December 3, 1975, and the whole est was 96X complete on May 7, 1976. NRC inspectors completed approximately 26 inspections during the period November 1974 through September 1177. These inspections also included inspection of corrective correcting of deficiencies. actions krformed by the licensee for testing and 2 i Based on the above inspections, we conclude that site preparation (including dewatering, excavation, and soil compaction) and placement of the common foundation mat (including reinforcing steel) were performed in accordance with approved procedures, specifications and regulations.
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Y* COLtorY %
John T. Collins I ' Regional Administrator l l i I FREEDOV 0F e.' Mwi10N i ACT Rt.Qut3I
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a - s UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION BEFORE THE ATO'MIC SAFETY AND LICENSING APPEAL BOARD i.
i I In the matter of LOUISIANA POWER AND LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station, Unit 3) NRC STAFF'S ANSWER TO JOINT-INTERVENORS' MOTIONS TO REOPEN CONTENTIONS 8/9 AND 22 Shemin E. Turk 6 Counsel for NRC Staff i November 28, 1983 9 b# 0 gPII '/ -
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', TABLE OF CONTENTS Page L
TABLE OF A JTHORITIES . . . . . . . . . . . . . . . . . . . . . . . . 11 t I. INTRb0UCTIONANDBACKGROUND.................. 2
, II. DISCUSSION .......................... 6 A. The Legal Authorities Governing Motions to Reopen .... 7 B. The Motion to Reopen Contention 22 Should Be Denied ... 9
- 1. Timeliness ..................... 9
- 2. Significance of the Issues ............. 10
- 3. Potential Effect on the Outcome of the Proceeding ..................... 15 C. The Motion to Reopen Contention 8/9 Should Be Denied . . . 16
- 1. Jurisdiction to Consider the Motion is Lacking ... 16
- 2. The Motion Fails to Satisfy the Standards for Reopaning . . . . . . . . . . . . . . . . . . . . . . 18 III. CONCLUSION .......................... 21 e
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TABLE OF AUTHORITIES
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i. CASES l I
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U.S Supreme Court
- ICC v. Jersey City, 322 U.S. 503 (1944) .............. 7 Nuclear Regulatory Comission Carolina Power and Light Co. . (Shearon Harris Nuclear Power Plant, Units 1, 2, 3, and 4), CLI-80-12, 11 NRC 514 (1980) . . . . . . 21 Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), CLI-81-5, 13 NRC 361 (1981) . . . . . . . . . . 8
) Atomic Safety and Licensing Appeal Board Commonwealth Edison Co. (La Salle County Nuclear Station, Units 1 and 2), ALAB-153, 6 AEC 021 (1973) .......... 8 j Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-730, 17 NRC 1057 (1983) ................. 8, 9-10, 19 Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-707, 16 NRC 1760 (1982) ................. 19 Duke Power Co. (Catawba Nuclear Station Units 1 and 2), ALAB-359, 4 NRC 619 (1976) .................. 7 Florida Power and Light Co. (St. Lucie Nuclear Power Plant, UnitNo.2),ALAB-579,11NRC223(1980) ........... 17, 18 Kansas Gas and Electric Co. (Wolf Creek Station, Unit 1), ALAB-462, 7 NRC 320 (1978) .................. 8 l Louisiana Power and Light Co. (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076 (June 29, 1983), Comission review declined (September 14, 1983) . . . . . . . . 4-5, 17 j
- Metropolitan Edison Co. (Three Mile Island Nuclear Station.
l - Unit No. 1), ALAB-699, 16 NRC 1324 (1982) . . . . . . . . . . . 8 .
- Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant Units 1 and 2), ALAB-728, 17 NRC 1777 (1983) . . . . . . 8 l
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Page Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-598, 11 NRC 876 (1980) ...... 8 i Public Ser 'v ice Co. of Indiana (Marble Hill Nuclear Generating I Statfon, Units 1and2),ALAB-530,9NRC261(1979)...... 16 Public Service Co. of New Hamnshire (Seabrook Station, Units 1 and 2), ALAB-513, 8 NRC 694 (1978) .......... 16 Vermont Yankee Nuclear Power Corp. (Vermont Yankee Nuclear Power Station), ALAB-138, 6 AEC 520 (1973) .......... 9 Virginia Electric and Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-551, 9 NRC 704 (1979) . . . . . . 17, 18 Washington Public Power Supply System (WPPSS Nuclear Project Nos. 3 and 5), ALAB-501, 8 NRC 381 (1978) . . . . . . . . . . . 16 Atomic Safety and Licensing Board Louisiana Power and Light Co. (Waterford Steam Electric Station, Unit 3), LBP-83-27, 17 NRC 949 (May 26, 1983), exceptions dismissed (August 17,1983) ............ 4 Louisiana Power and Light Co. (Waterford Steam Electric Station, Unit 3), LBP-82-100, 16 NRC 1550, modified, LBP-82-112, 16 NRC 1901 (1982) ................ 4, 20 REGULATIONS 18 10 C.F.R. l 2.206 ......................... 10 C.F.R. 1 2.717(a) . . . . . . . . . . . . . . . . . . . . . . . . 16 T' y<
a -
. UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION BEFORETHEdTOMICSAFETYANDLICENSINGAPPEALBOARD
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L In the Ma,ter of I LOUISIANA POWER AND LIGHT COMPANY Docket No. 50-382
- (Waterford Steam Electric Station, )
Unit 3) ) NRC STAFF'S ANSWER TO JOINT INTERVENORS' MOTIONS TO REOPEN CONTENTIONS 8/9 AND 22 On July 25, 1983, the Joint Intervenors filed their initial " Motion to Reopen Contention", in which they sought to reopen Contention 22 (safety-related concrete) to consider the May 1983 discovery of cracking and water seepage in the concrete basemat at Waterford Unit 3. On November 7, 1983, the Joint Intervenors filed a second " Motion to Reopen Contention", in which they sought to reopen Contention 8/9 (synergism) to i consider a recent report of high levels of leukemia and cancer among children living near the Windscale nuclear plant in England. For the reasons set forth herein and in the three affidavits attached hereto,II l l the NRC Staff (" Staff") opposes both of Joint Intervenors' motions and recommends that they be denied.2/
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Attached hereto are the " Affidavit of John S. Ma" ("Ma Affidavit"), s the " Affidavit of Raman Pichumani" ("Pichumani Affidavit"), and the
" Affidavit of Raymond O. Gonzales" ("Gonzales Affidavit").
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The Staff's response to Jnint Intervenors' motions to reopen is filed pursuant to an extension of time granted by the Appeal Board on November 15, 1983. l
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I. INTRODUCTION AND BACKGROUND Joint Intervenors'- Contentions 8 and 9 were filed on April 11, 19.79. Following ja special prehearing conference held on April 26, 1979, and the I [ e filing of.'the parties' positions on June 1,1979, the Licensing Board admitted a reformulated and combined Contention 8/9 in its " Order" of September 12, 1979. As reformulated by the Licensing Board, Contention 8/9 asserted as follows: Applicant has failed to properly evaluate the cumulative and/or synergistic effects of low-level radiation with , environmental pollutants, known or suspected to be carcinogens. Joint Intervenors' Contention 22 was similarly filed on April 11,1979,1/ and was reformulated and admitted for litigation in the Licensing Board's Order of September 12, 1979. As reformulated by the Licensing Board, Contention 22 asserted as follows: Applicant has failed to discover, acknowledge, report ogf remedy defects in safety related concrete construction.- 1/ As originally filed, Contention 22 asserted as follows: < 22. Applica_nt has failed to discover, acknowledge, r' eport or reme.dy_ defects in materials, conitruc-
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tfonand16rkmanshipsuch_u_ improper.lfpoured and set. concrete anCconcrete-poured without requir_ed. reinforcement durin of the. containment vessel, reactorvessel) (g..the fabrication and/or related integral systems.
.. 4_/ In its Order, the Licensing Board noted the admission by Counsel for the Joint Intervenors that "when drafted, there was no specific basis for this contention" aside from general allegations made by v various unidentified construction workers (Order of September 12, 1979,at7). The Licensing Board observed that it was " loathe to ,
admit any contention founded on purported allegations of unidenti-i fied individuals," but found that "a portion of the contention relating to safety related concrete construction is reasonably specific and perhaps may be fleshed out upon use of the discovery procedure" (!d., at 8). (FOOTNOTECONTINUEiONNEXTPAGE) i q.. . . .
- 3-On August 21, 1981, the Applicant moved for summary disposition of Contention 22. on the grounds that there was no genuine issue of material
. fact.E/ Op September 15, 1981, the Staff filed an answer in support of Applicant motion;SI no response was filed by the Joint Intervenors. On October 20, 1981, the Licensing Board granted Applicant's motion for 4/ (FOOTNOTECONTINUEDFROMPREVIOUSPAGE)
The Licensing Board noted that Counsel for Joint Intervenors had
" represented to the Board that the Joint Petitioners would abandon this contention should discovery fail to disclose facts proving the allegations in the contention (Tr. 102-105)"(M.,at7).
5/ " Applicant's Motion for Summary Disposition of Joint Intervenors'
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Contention 22(Safety-RelatedConcrete)",datedAugust 21, 1981. The Applicant attached to its motion the Affidavit of Thomas F. Gerretts (the individual who served as Quality Assurance Manager for the facility). Mr. Gerretts reviewed the history of concrete placement and QA/QC efforts at Waterford 3, and concluded that (1) no significant defects in safety-related concrete had gone undetected by Applicant's QA/QC program, as demonstrated by the Staff's independent inspections; (2) all known defects in safety-related concrete had been properly documented, evaluated and cor-rected as necessary; and (3) the Applicant had fully complied with 4 NRC regulations in reporting deficiencies to the NRC (Affidavit of Thomas F. Gerretts, dated August 19,1981,114at8). 6/ "NRC Staff's Answer in Support of Applicant's Motion for Sumary Disposition of Joint Intervenors' Contention 22 (Safety-Related Concrete)," dated September 15, 1981. Attached to the Staff's Answer were the affidavits of Ramon E. Hall (an NRC official employed at Region IV) and Joseph Isaac Tapia (an NRC inspector at the Waterford site). Mr. Hall's affidavit stated that the Staff had been unable to obtain substantiation of the allegations relied upon by the Joint Intervenors, and that to the best of his knowl-l edge and belief there was insufficient basis to warrant further investigation of the alle r September 14, 1981, at 2)gations . Mr. Tapia's (Affidavit affidavitof Ramon that concluded E. Hall, dated (1) there were no outstanding defects of any significance in the Applicant's safety-relatad concrete construction; and (2) the
" Applicant's safety-related concrete construction is satisfactory and provides reasonable assurance that the health and safety of the ,
public will be protected following the commencement of operation of the facility (Affidavit of Joseph Isaac Tapia, dated September 11, 1981,at3).
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- summary disposition, finding that the Applicant, as supported by the Staff, had demonstrated the absence of a genuine issue of material fact, and that the Joint Intervenors had failed to meet their obligation of (
countering'thatdemonstrationwithspecificfacts.U Evidentiary.hearingsonJointIntervenors' Contention 8/9(synergism) were held on March 24-26 March 29-April 2, and May 10-11, 1982. Eviden-tiary hearings on Joint Intervenors' Contention 17/26 (emergency plan-ning)wereheldonMay3-7andMay 11-12, 1982. The Licensing Board issued its first Partial Initial Decision on November 3,1982, resolving all contested matters other than the adequacy of Applicant's emergency informationbrochure.U Evidentiary hearings on that one remaining issue were held on February 8-11, 1983, and the Licensing Board's second Partial Initial Decision resolving this matter was issued on May 26, 1983.E The Licensing Board's first Partial Initial Decision was affimed by the Appeal Board in ALAB-732, issued on June 29, 1983, wherein the Appeal Board also completed its sua sponte review of all matters other than the emergency information brochure; the Comission declined review y " Memorandum and Order (Granting Applicant's Motion For Sumary Disposition of Joint Intervenors' Contention 22)", dated October
.- 20, 1981, at 8-9.
y Louisiana Power and Light Co. (Waterford Steam Electric Station, S' Unit 3),L8P-82-100,16NRC1550(1982), modified LBP-82-112, 16 NRC1901(December 14,100). , y LouisianaPowerandLightCo.(WaterfordSteamElectricStation, Unit 3), LBP-83-27, 17 NRC 949 (May 26, 1983), exceptions dismissed (August 17,1983).
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- of that decision on September 7, 1983. E Exceptions to the Licensing Board's second Partial Initial Decision were filed by Joint Intervenors on June 10, 1983; those exceptions were dismissed by the Appeal Board --
and sua spente review of the Licensing Board's second PID was announced f
-- in the Appeal Board's " Order" of August 17, 1983.
' On or about July 12, 1983, the Joint Intervenors filed an undated
" Motion to Reopen Contention", together with a supporting Memorandum; those pleadings were rejected without prejudice by the Appeal Board on July 18, 1983, on the grounds that they failed to conform to the require-ments of the Comission's rules of practice.E On July 25, 1982, the Joint Intervenors filed before the Appeal Board the instant motion to reopen Contention 22, together with a supporting memorandun and notice ofappearanceofcounsel.12/ Several extensions of time in which to 10/ Louisiana Power and Light Co. (Waterford Steam Electric Station.
Unit 3), ALAB-732, 17 NRC 1076 (June 29, 1983), Commission review declined (Memorandum, September 14,1983). The Appeal Board's indication that it had completed its sua sponte review of uncon-tested matters appears in the slip opinion at page 3, footnote 2. 11/ " Order", dated July 18, 1983, at 2. The motion and memorandum were undated, contained no certificate of service, and failed to specify with which adjudicatory tribunal they were intended to be filed (Id., at 1). Prior to filing these pleadings, counsel for Joint interveiiors wrote to the Licensing Board Chairman ex parte, requesting advice as to the appropriate procedures to fo11o Tin seeking to reopen Conten-tion 22; the Licensing Board Chairman responded by letter of June 30, 1983. See Note from Sheldon J. Wolfe, Administrative Judge, to All Parties, dated June 27, 1983; and Letter from Sheldon J. Wolfe, s Chairman, to Carole H. Burstein Esq., dated June 30, 1983. J2/ While Joint Intervenors' pleadings are dated July 22, 1983, the accompanying certificate of service reflects service by mail on July 25, 1983.
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- respond to the motion to reopen were granted by the Appeal Board without objection by the parties, to permit Applicant and Staff to complete and present their assessments as to the significance of the matters raised by the motion. On September 20, 1983, the Applicant submitted to the Appeal f Board and parties an initial engineering report prepared by Harstead EngineeringAssociates,Inc.;E the Applicant's response to Joint Inter-venors' motion was submitted on September 30, 1983; E and a second report prepared by Harstead Engineering Associates Inc. was submitted by the Applicant on October 14,1983.E On November 8, 1983, the Joint Intervenors filed their motion to reopen Contention 8/9. By Order of November 10, 1983, the Appeal Board directed Applicant and Staff to respond to that motion by November 21, 1983; an extension of time until November 28, 1983, in which to file responses was granted by the Appeal Board on November 15, 1983.
II. DISCUSSION In the following discussion, the Staff addresses, first, the legal standards governing motions to reopen, and second,'the legal sufficiency of the Joint Intervenors' motions to reopen. As set forth below, the Staff believes that with respect to both motions, the Joint Intervenors O' j_3/ 3 See Letter from Bruce W. Churchill to the Appeal Board, dated a Teptember 20, 1983. J,4/ " Applicant's Answer to Joint Intervenors' Motion to Reopen Contention", dated September 30,1983(" Applicant'sAnswer"). J,$/
$ See Letter from Bruce W. Churchill to the Appeal Board, dated Etober 14, 1983.
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- have failed to demonstrate the existence of a significant safety or environmental issue that might affect the outcome of this proceeding.
Further, the Staff believes that the Appeal Board lacks jurisdiction to l [t consider the motion to reopen Contention 8/9. For these reasons, as ' more fully set forth below, the Staff believes that both motions should be denied. A. The Legal Standards Governing Motions to Reopen. The legal standards governing the consideration of motions to reopen are well defined. TheAppealBoardhasobservedthat"[a]fteradecision has been rendered, a dissatisfied litigant who seeks to persuade us -- or any tribunal for that matter -- to reopen a record and reconsider
'because some new circumstance has arisen, some new trend has been observed or some new fact discovered,' has a difficult burden to bear."
Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), ALA8-359, 4 NRC 619,620(1976). In so stating, the Appeal Board took note of the Supreme Court's decision in ICC v. Jersey City, 322 U.S. 503, 514 (1944), wherein the Court observed as follows: One of the grounds of resistance to administrative orders throughout federal experience with the administrative process has been the claims of private litigants to be entitled to rehearings to bring the s record up to date and meanwhile to stall the enforce-ment of the administrative order.... If upon the
,. coming down of the order litigants might demand rehearings as a matter of law because some new circum-stance has arisen, some new trend has been observed, v or some new fact discovered, there would be little hope that the administrative process could ever be ,
consummated in an order that would not be subject to reopening. I,d., 4 NRC at 620-21.
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. For a motion to reopen to succeed, the movant must demonstrate that
,such a result is warranted upon a cons'ideration of three factors:
(1) whether, the motion is timely; (2) whether the motion addresses a . L l I significant safety or environmental issue; and (3) whether a different result might have been reached had the newly proferred material been
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considered initially. Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-598, 11 NRC 876, 879 (1980), citing Kansas Gas and Electric Co. (Wolf Creek Station, Unit 1), ALAB-462, 7 NRC 320,338(1978).El Accord, Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-730, 17 NRC 1057, 1065 n.7 (1983); Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-728, 17NRC777,800n.66(1983); Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No. 1), ALAB-699, 16 NRC 1324, 1327 (1982). Further, the motion to reopen cannot succeed based upon bare allegations; rather, the motion must be supported by "significant new evidence." Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant,, Units 1 and 2), CLI-81-5, 13NRC361,362-63(1981).E Finally, it should be noted that in ruling j g/ The Appeal Board's decision in Diablo Canyon, ALAB-598, supra, represents somewhat of a departure from previcus decisions, in its l requirement only that a different result "might" have been reached had the new information' been considered earlier. ' Prior decisions had required that a different result "would" have been reached upon l consideration of the new information. See, M. , Wol f Creek , ALAB-462, supra, 7 NRC at 338. . B While bare allegations are insufficient, the Appeal Board has not I s limited the type of documentary evidence which might be relied upon
- in support of a motion to reopen. Detailed newspaper accounts, in -
appropriate circumstances, might provide sufficient basis to reopen
,the record of a proceeding. See generally, Comanwealth Edison Co.
(LaSalle County Nuclear Station, Units 1 and 2), ALA8-153, 6 AEC 821, t 824(1973). i (
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upon a motion to reopen, the Appeal Board may take into account affidavits and other evidentiary material as if ruling on a motion for summary
- disposition, and the motion should not be granted "if the undisputed facts .
- L establish;that the apparent 1.v significant . . . issue does not exist, has I y
been resolved, or for some other reason will have no effect upon the
- outcome of the licensing proceeding." Vermont Yankee Nuclear Power Corp.
(Vermont Yankee Nuclear Power Station), ALAB-138, 6 AEC 520, 523 (1973). B. The Motion to Reopen Contention 22 Should Be Denied. An application of the foregoing principles to Joint Intervenors' motion to reopen Contention 22 demonstrates that the motion should be denied. In this regard, the Staff addresses each of the three standards seriatim.
- 1. Timeliness.
While the Staff does not contest the timeliness with which the Joint Intervenors have raised the discovery of cracking and water seepage f in May 1983, the Joint Intervenors are extraordinarily late in their attempt to liti, gate the 1977 appearance of cracks and water seepage. As discussed abo've,, Contention 22 was filed in 1979, after the 1977 events had occurred and after those events had been reported by the Staff. See IE Inspection i Report No. 50-382/77-08, at 9 (Attachment 6 to Applicant's Answer). The Joint Intervenors failed to raise this issue at any time during discovery on Contention 22, nor did they raise the issue in response to Applicant's motion for summary disposition. Having remained dormant for so long, it is wholly unacceptable for the Joint Intervenors to challenge the 1977 events at this late stage of the proceeding. See, e.g., Detroit Edison Co. I' .
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', (Enrico Fermi Atomic Fower Plant, Unit 2), ALAB-730, 17 NRC 1057, 1065-66 (1983). Further, the 1977 and 1983-events resulted from altogether
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different .causes I and are unrelated (Ma Affidavit, at 7); accordingly. even if th'e motion to reopen Contention E2 to consider the 1983 events
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should succeed, the scope of the reopened hearing should exclude the
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1977 events.
- 2. Significance of the Issues.
The Staff has conducted an extensive evaluation of the concrete cracking and water seepage, in order to determine whether a significant safety or environmental issue exists. As indicated in the attached Affidavits of John S. Ma, Raman Fichumani and Raymond O. Gonzales, the
~ Staff has concluded that the cracking and water seepage do not present a significant safety or environmental issue.
With resoect to the structural integrity of the base mat, the Staff has determined that, based upon current loads and environmental conditions (such as water chemistry), the ' cracks and water secoage do not represent a challenge to the structural integrity of the base mat (Ma Affidavit,at3). Nonetheless, because this conclusion could be , affected by significantgange5 Jn_Joads .or_ environmental conditions in' the. future, the Staff has determined that an appropriate surveillance program is required, to assure the continuing structural integrity of the base mat ( S ). The Staff's detennination as to the structural integrity of the' . base mat is based upot) (a) the Staff's structural audit, which indicates that the methods'and procedures utilized in the Applicant's analysis and design of the base mat were acceptable; (b) the strength of the base
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11 - mat, which is designed to support dead loads 50% greater than the , estimated dead load on~ top of the mat, and confirmation by the Staff's structuraiauditthatthestrengthofthebasematisadequate;(c)the [ I t insignific' ant width of the cracks, indicating that stresses and . 1 . corrosion of the reinforcing steel are insignificant; (d) the water !I chemistry surrounding the base mat, which has been shown to be non-aggressive with regard to possible corrosion of the reinforcing steel; (e) the adequacy of site preparation and placement of the base mat, as determined by the Administrator of NRC Region IV;EI and (f) the absence of significant additional or uneven settlement of the base mat since 1979, as has been confirmed by Dr. Pichumani (M., at 3-4). Further, the Staff has concluded that the cracking and water l T seepage are unrelated to the concrete cracking discovered in the base matin 1977(H.,at7). The cracking discovered in 1977 appears to l 18/ The Regional Administrator's conclusions are contained in a Memorandum from John T. Collins, Regional Administrator, to D. G. Eisenhut, Director, Division of Licensing, Office of Nuclear Reactor Regulation, dated November 16, 1983 (Attachment 3 to the Ma Affidavit). In his memorandum, Mr. Collins reviews the history o.f site preparation, placement of the base mat, and NRC inspection activities- (including inspection of. corrective actions perfonned by Applicant for testing and correcting of deficiencies). Mr. Collins concludes, based on l these inspections, that site preparation (including dewqtering, excavation, and_ soil compaction) and placement of the common l foundation mat (including reinforcing steel) were performed in Q accordancewithapprovedprocedures,specificatfonsanCregulationsq
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(M.,at27 l These conclusions are consistent with the Affidavit of Joseph Isaac
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' Taph(a) 1981 resented there were noearlier in this outstanding proceeding, defects that as of any significance in oTSeptember the Applicant's safety-reTateCconcreta construEtio'n, and (b) the Applicant's safety-related concrete construction is satisfactory and provides reasonable assurance that the health and safety of the public will be protected following the commencement of plant operation. See n.6, supra. ,
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- have been caused by soil settlement patterns associated with the way in which the concrete was placed; the sequential placement of the 28
- concrete blocks which comprise the comon base mat led to differential .
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. . .j .__ f settlemeny of the blocks, with the mat foming a convex downward shape (M., at 8; Pichumani Affidavit, at 5-6). This phenomenon created the
- maximum tensile stress zone on top of the mat under the reactor _
building, and was responsible for the concrete cracking in 1977; those cracks would tend to close upon placement of the reactor building as a result of compressive stresses caused by the weight of that building (Ma Affidavit, at 8-9). In contrast, the c ckkngdiscoveredinMay1983 appears to have been caused by a combination of tensile stresses ger.erated by flexure, torsion, and punching-induced shear stress, due to the weight andlocationofthestructurasontopofthemat(M.,at7,8). The_ 19R cracks _digd-rom _ soil settlement, unlike the previous cracks, as demonstrated by the absence of any significant additional or uneven soil settlement since April 1979 (M., at 9).E/ With respect to the foundation soils underlying the base mat, the Staff's evaluation has led it to conclude that the foundation provides adequate support for the base mat and the structures and equipment on top of the base mat (Pichumani Affidavit, at 3). To minimize the amount 19/ An additional factor in the appearance of cracking in 1983 is related to the distribution of top and bottom reinforcing steel bars in the base mat. While the amount and distribution of the
- s. reinforcing steel provide adequate strength for the mat, if some of the reinforcing steel had been shifted from the bottom of the mat under the reactor building to the top of the mat under the shield -
building for use in resisting negative bending moment, some of the radial cracking that has appeared around the shield building could have been reduced or eliminated (Ma Affidavit, at 9).
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- of foundation settlement which is ordinarily experienced by structures resting on compressible soil deposits, the Applicant employed the "compensat'ed" or " floating" foundating design concept (M., at 4). This l
[ t design con' cept requires applied effective vertical soil pressures at and
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be1ow foundation level to be approximately equal to the effective , stresses that existed before construction, thus minimizing upward heave during excavation and subsequent recompression under applied loads (H.). While an interruption in watering the foundation soils and extended work stoppages resulted in non-unifonn and greater than anticipated post-excavation heave, a construction procedure employed by the Applicant successfully achieved recompression of the heave and produced net total settlement of the base mat ( M., at 4-5). The Staff is satisfied that adequate consideration was given by the Applicant in its analysis of the base mat to accommodate variations in soil stiffness such as may have been caused by the unanticipated post-excavation heave (H.,at6-7). A review of the settlement record, which demonstrates no significant additional or differential settlement since April 1979, has led the Staff to find reasonable assurance that the foundation soils under the base mat are stable with respect to settlement ( M ., at 7). Notwith-standing this conclusion, the Staff will require continued settlement monitoring by the Applicant throughout the operating life of the plant to
.- provide further assurance that differential settlement will not present a challenge to the base mat in the future ( H., at 7-8).
e The water seepage that was discovered has been evaluated by , the Staff to determine whether it is likely to cause corrosion of the l l T. . .. . __ l
. reinforcing steel in the base mat; in this regard, ground water chemistry is the primary consideration. Based upon analyses of the ground water chemistry ithat have been conducted, the Staff is satisfied that the water .
L l I chemistry.'is non-aggressive with respect to corrosion of the reinforcing steel, and that the chemical content of the ground water is far below
~
levels which would cause concern for corrosion of the reinforcing steel (Ma Mfidavit, at 10).E The Staff's review of potential environmental impacts resulting from the base mat cracking has led the Staff to conclude that the cracks and water seepage will not result in any adverse environmental impact upon commencement of plant operation (Gonzales Affidavit, at 2). This determination is based upon the fact that the normal piezametric level of the ground water surrounding the plant is approximately 55 feet above the bottom of the base mat. This ground water exerts hydrostatic pressure against the nuclear plant island structure of approximately 23.8 psi, whicn is responsible for the ground water seeping up through the base mat. In the event that any radioactive contaminants are released during operation of the facility, this hydrostatic pressure would prevent those contaminants i
~
20/ The Staff does not dispute Applicant's conclusion that the water seepage is incapable of overloading the water treatment system which will treat water collecting through the floor drainage system (Affidavit of Joseph L. Ehasz, at 4). The Staff has noted that the water seepage which has been observed is minimal, and is best , described as damp spots on the surface of the base mat (Ma Affidavit, at 3; IE Inspection Report 50-382/83-18 (Attachment 4 to Applicant's Answer)). The Staff has concluded that the amount of water seepage is not likely to increase with time, assuming the cracks do not increase ' in size, given the impenneable nature of the clay soils and the fact that the ground water level surrounding the plant is expected to remain fairly constant (Gonzales Affidavit, at 4). Moreover, the Staff will require that a surveillance program be established which would monitor the cracks and water seepage over time (Ma Affidavit, at 10-11).
I
. i .
.' from leaking down through the base mat into the ground water (M.). This outcome is ' demonstrated by the results of the Staff's evaluation, presented
. in the Satety Evaluation Report (Staff Exh. 2), of the consequences of a ,
l. postulatec tank failure, wherein the Staff explicitly assumed the existence f of cracks in the base mat (Gonzales Affidavit, at 3). See Staff Exh. 2
- 6 2.4.6, at 2-21. As set forth in the SER, the Staff's analysis confirms that the hydrostatic pressure will prevent leakage of radioactive contaminantsintothegroundwaterthroughcracksinthebasemat(M.).b
- 3. Potential Effect on the Outcome of the Proceeding.
As the above discussion demonstrates, neither a significant safety issue nor a significant environmental issue is presented by the cracking and water seepage in the Waterford Unit 3 base mat. It follows, therefore, that the litigation of those matters could not possibly result in a different outcome to the proceeding. Accordingly, having failed to raise a significant safety er environmental issue supported by information which might result in a different outcome to the proceeding, Joint Intervenors' motion to reopen Contention 22 should be denied.
-21/ Further, even if it is assumed that the hydrostatic pressure does not exist, leakage of the radioactive contaminants through cracks in the base mat would not result in contamination of the Mississippi River or of ground water drinking sources (Gonzales Affidavit, at 3). This conclusion follows from (a) the fact that the clay soils
< underlying the facility are highly impermeable, and (b) the fact that the silty sand layer at E1 -77 ms1 (Zone 3) is characterized by ground water movement away from the Mississippi River at all stages of flow (Id., at 3-4). See Staff Exh. 1 (Final Environmental Impact Statement), 6 4.3.2.2, at 4-18, 9 5.3.1 at 5 5-2, and i 5.9.2.5(5) .
at 5 5-68. e e 99
. s .
C. .The Motion to Reopen Contention 8/9 Should Be Denied. In the following discussion, the Staff addresses, first, the jurisdictibn of the Appeal Board to consider the motion to reopen [ I 'i Contention'8/9 and, second, the substantive reasons why the motion should be denied. As set forth below, the Staff believes that the Appeal Board lacks jurisdiction to consider the motion to reopen Contention 8/9 and that, in any event, the motion fails to satisfy the legal standards which govern reopening. For these reasons, the motion to reopen Contention 8/9 should be denied.
- 1. Jurisdiction to Consider the Motion Is Lacking.
Pursuant to 10 C.F.R. 1 2.717(a), the jurisdiction of the presiding officer (or here, the Appeal Board) to consider motions to reopen expires when the time for Comission review expires ,or when the Commission renders a final decision. See, e.g., Washington Public Power Sucoly System (WPPSS Nuclear Project Nos. 3 and 5), ALAB-501, 8 NRC 381, 382 (1978). Where the Appeal Board has retained jurisdiction to consider certain discrete issues, jurisdiction to consider other, unrelated, matters is lacking. Public Service Co. of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-530, 9 NRC 261, 262 (1979); Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2), ALAB-513, 8 NRC 694, 695-96 (1978). The Appeal Board has summarized the applicable consi-
.. derations in this regard n follows:
[I]rrespective of whether a construction permit or e an operating license is involved, the pivotal factor is "the posture of the case and the degree of final- - ity which has attached to the agency action which is ! in question." Where . . . finality has attached to l some but not all issues, appeal board jurisdiction to I entertain new matters is dependent upon the existence of a " reasonable nexus" between those matters and the issues remaining be4re the board. l l l l ; . . - ( .
e
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. Virginia Electric and power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-551, 9 NRC 704, 707 (1979). Similarly, in Florida Power
- and Light Co. (St. Lucie Nuclear Power Plant, Unit No. 2), ALAB-579,11 .
NRC 223, 2 6 (1980), the Appeal Board restated this standard as follows: "In the absence of a rational and direct link to the limited
~ matters over which we retain jurisdiction, we are without authority to consider new or reopened issues at this stage of the proceeding." This standard is applicable regardless of whether a new matter or a reopening of a previously decided matter is involved:
[I]rrespective of whether a reopening of a determined issue, or instead the raising of an issue not earlier considered, is involved, the concept underlying the finality doctrine -- that litigation must come to an end at some point -- comes into play. In both instances, the decisive factor is whether, except for those limited issues as to which jurisdication has been expressly retained, the case has been decided. North Anna, ALAB-551, supra, 9 NRC at 709. An application of these principles to Joint Intervenors' motion to reopen Contention 8/9 requires a finding that the Appeal Board's jurisdiction to consider the motion has expired. Contention 8/9 was fully litigated and was decided in the Licensing Board's first Partial Initial Decision rendered on November 3, 1982. The Appeal Board considered exceptions to that decision, including numerous exceptions on the synergism issue, and decided those exceptions in its comprehensive decision of June 29,1983 (ALAB-732); the time for Comission review of ALAB-732 expired on September 7,1983 and, indeed, the Comission expressly declined to review that decision. Final agency action with respect to Contention 8/9, accordingly, was taken on September 7, 1983, and the Appeal Board's adjudicatory ju'rfsdiction over the contention
. likewise expired on that date. Inasmuch as the motion to reopen was filed fully two months -thereaf ter, and is unrelated to any issues over whichthe$ppealBoardhasretainedjurisdiction,itisclearthatthe I
;(
motion should be dismissed for lack of jurisdiction. - This is not to say, however, that the Joint Intervenors are without a forum in which to advance the concerns reflected in their motion. The Appeal Board has recognized, in situations such as this, that recourse may be had through informal comunication to the Staff or through a request for the institution of a show cause proceeding under 10 C.F.R. 9 2.206: [T]he absence or loss of appeal board jurisdiction over a particular issue because of finality considerations does not mean that, even if clothed with serious safety or environmental implications for the facility in question, the isrJe must be
+ ignored. To the contrary, it just falls within the staff's bailiwick, not ours. It can there be reviewed on an inf( mal basis; beyond that... the Director of Nuclear Reactor Regulation is empowered
- to institute a show-cause proceeding looking to the modification, suspension, or revocation of a particular permit or license. 10 C.F.R. 2.202, 2.206. In the show-cause proceeding, the new matter would be subject to full ventilation and the grant of such relief as might be warranted by the disclosures of record.
North Anna, ALAB-551, supra, 9 NRC at 709 (footnotes omitted); accord, l St. Lucie. ALAB-579, supra, 11 NRC at 226. Accordingly, the motion to reopen Contention 8/9 should be dismissed, and any request for review of the matters raised by the motion should be directed to the Staff.
.. 2. The Motion Fails to Satisfy the Standards for Reopening.
l Even if the Appeal Board possessed jurisdiction to consider the motion to reopen, it is apparent that the motion should be denied for failing to satisfy the legal standards governing motions to reopen. As l l l i T.' . '.
. s .
. set forth above, whether the motion to reopen is granted turns upon an appraisal of whether the motion is timely, whether it raises a significant safety or pnvironmental issue, and whether the newly presented information :
I h is susceptible of altering the outcome of the proceeding. E.g. , Detroit ' Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-730,17 NRC 1057, 1065 n.7 (1983). The Staff submits that the Joint Intervenors nave failed to satisfy their burden of demonstrating that these factors favor the granting of their motion to reopen. Joint Intervenors' motion to reopen Contention 8/9 is supported only by a brief UPI report which purportedly appeared in a New Orleans newspaper on October 31, 1983. The report discusses a documentary which has been prepared for television broadcast in England, concerning high levels of leukemia and cancer among children who live near the Windscale nuclear plant. It is impossible to ascertain from the newspaper account when the research referred to in the television documentary was conducted or published, nor have the Joint Intervenors provided any information which would assist in ascertaining that fact. In this regard, it is important to note that timeliness must be judged not by when a party learns of a fact but, rather; when it could have done so. See, e.g., Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-707, 16 NRC 1760, 1765 (1982). In view of the Joint Intervenors' failure to demonstrate an
.. inability to have learned of this matter sooner, the timeliness factor should be held to weigh against a reopening of the record.
C' . .
~
Similarly, it is impossible to ascertain from their motion whether the matters referred to by the Joint Intervenors raise a signifi-In this l cant issu( that could affect the outcome of the proceeding. i, I t regard, we' note that the Staff's Final Environmental Statement (Staff
~
Exh. 1) reports that the Windscale plant (an air-cooled graphite reactor) was the site of an accident in 1957, in which a significant quantity of radiciodine -- approximately 20,000 Ci -- was released to the environment. (Staff Exh. 1, at 5-47). The Staff has determined that this kind of accident cannot occur in a water-cooled reactor like Waterford 3 (Id_.); accordingly, the data referred to by Joint Intervenors, even if accurate, may well be irrelevant to this proceeding. Further, Contention 8/9 con-cerned the possibility of synergism involving chemicals and radiation released during routine operations; the contention did not address any synergism which might occur upon an accidental release of radiation. See LBP-82-100, 16 NRC at 1568. Accordingly, the information relied upon by the Joint Intervenors may well be unrelated to Contention 8/9 and could not support a reopening of that contention. In any event, however, whatever may be the relevance of the data referred to by the Joint Intervenors, the limited information supplied by them fails to satisfy their burden of demonstrating the existence of a significant safety or environmental issue, consideration of which could alter the outcome of
.- the proceeding. Accordingly, the motion to reopen Contention 8/9 should be denied.
Finally, while the Jnint Intervenors request a reopening of . the proceeding and seek to reserve their "right" to a hearing, the only imediate relief they request is that the Staff "do a study and make a
. .+......
- report to Intervenor covering 1) whether the nuclear plant caused the disease and 2) whether similar conditions exist at Waterford 3." In this regard, ttel Joint Intervenors appear to be requesting that the Appeal Board L
g I compel the Staff to conduct such a study. That request, however, contravenes established Comission precedent which recognizes that the Appeal Board may not airect the Staff in the performance of its independent duties. See, ed., Carolina power and Light Co. (Shearon Harris Nuclear Power Plant, Units 1, 2 3, and 4), CLI-80-12, 11 NRC 514, 516-17 (1980). Accordingly, Joint Intervenors' request for an order directing the Staff to conduct a study of the data in question should be denied. III. CONCLUSION For the reasons set forth above, the Staff submits that Joint Intervenors' motion to reopen Contention 22 should be denied. Further, Joint Intervenors' motion to reopen Contention 8/9 should be denied or, in the alternative, dismissed for lack of jurisdiction. Respectfully submitted, hE Sherwin E. Turk Counsel for NRC Staff Dated at Bethesda, Maryland
.- this 28th day of November, 1983 e
p
s a 1 UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORETHEdTOMICSAFETYANDLICENSINGAPpEALBOARD l.
In the Matter of ) ?
- )
LOUISIANA POWER AND LIGHT COMPANY ) Docket No. 50-382
)
(Waterford Steam Electric Station, ) Unit 3) ) AFFIDAVIT OF JOHN S. MA Q1. Please state your name, title and by whom you are employed? A1. My name is John S. Ma. I am employed as a structural engineer in the Structural and Geotechnical Engineering Branch of the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission. A statement of my professional qualifications is attached. Q2. What is the purpose of this affidavit? A2. The purpose of this affidavit is to provide the evaluation and con-clusions of the NRC Staff (" Staff") concerning the adequacy of the Waterford Unit 3 foundation base mat in light of the discovery of concrete cracking and water seepage in the base mat. Q3. Please describe the evaluation you performed as part of the Staff's review of this matter? A3. I performed a structural audit of the Applicant's analysis and . design of the foundation base mat. As part of my review, I examined applicable portions of the original design and analysis performed by j ' FREEDOM OF INFOhmaliON y .y h ACT REQUEST p 29-455 s chst da . -
t , g T 1 Ebasco Services, Inc. for the Applicant. I also reviewed the two engineering reports which were prepared by Harstead Engineering Associates, Inc., entitled (1) "Waterford III SES Analysis of Cracks { and Nater Seepage in Foundation Mat / Louisiana Power & Light Company / Report No. 8304-1/ September 19,1983"("HarsteadI"),and (2) "Waterford III SES Analysis of Cracks and Water Seepage in Foundation Mat / Louisiana Power & Light Company / Report No. 8304-2/ October 12,1983"("HarsteadII"). i - In addition, I requested additional information from the Applicant, as set forth in a letter dated October 17,1983(Attachment 1),and I reviewed the Applicant's response to those questions in its letter 4 of October 31, 1983 (Attachment 2). I also participated in two i meetings with the Applicant held on October 26 and November 3, 1983. As part of my evaluation, I relied upon the determination reached by
- 'Mr. John Collins, Regional Administrator of NRC Region IV, that site 3
preparatioliWeluding dewatering, excavation, and soil compaction) m and placement of the mat (including reinforcing steei) were ( t { performed in accoffance with approved procedures,_specificati6 s and regulations (Attachment 3). N /
.- Q4. Please describe the cracking and areas of water seepage that have been discovered.
A4. The cracks and areas of water seepage have been visually examined by , various members of the Staff, including the NRC Senior Resident Inspector at the Waterford site. The cracks are generally invisible eo
, , - .,. - - - , -m, . , , , , - .
"W
r !
. 3-
$ and small in width, are of vary.ing lengths, and may be classified as
" hairline" cracks. The water seepage that has been observed is minimal, and is best characterized as damp spots on the surface of .
the base mat. It is my understanding that the cracks and areas of water seepage appear to be accurately described and delineated in the Harstead I report, referred to above. QS. Have you reached a conclusion as to whether the cracks and water seepage present a challenge to the structural integrity of the foundation base mat? A5. Yes, I have. Based upon current loads and environmental conditions (such as water chemistry), the cracks and water seepage do not represent a challenge to the structural integrity of the foundation base mat. However, this conclusion could be affected in the event
, significant changes inM or enyiNnmental conditions over thef
. ) J -- -
G course of time. Accordingly, the Staff has detemined that a surveillance program should be put in place to assure the continuing structural integrity of the base mat. i Q6. Please explain the basis for this determination. l A6. This determination is based upon the following factors: (a) the structural audit which I performed indicates that the I methods and procedures utilized in the Applicant's analysis and [ .- design of the base mat (performed by Ebasco Services, Inc.) were , acceptable; i
1 1 f (b) the base mat was designed t: support dead loads 50% greater than the estimated dead load on top of the mat, and my structural
~
audit confirms that the strength of the base mat is adequate;
, [t (c) the crack widths are insignificant (indicating that '
stresses and corrosion of the reinforcing steel are insignificant), and the water chemistry surrounding the base mat has been shown to be non-aggressive with regard to possible corrosion of the reinforcing steel; (d) site preparation and placement of the base were adequate, as determined by the Administrator of NRC <- n IV; and (e) there has been no significant additional or uneven settlement of the base mat since April 1979, as confinned in the Staff's evaluation perfonned by Dr. Raman Pichumani. Q7. Please explain your conclusion that the Applicant's analysis and design of the base mat has been adequate. A7. My assessment of the Applicant's analysis and design of the founda-tion base mat focused on the methodology utilized by the Applicant with respect to loading and boundary conditions, and included consi-deration of positive and negative bending moments and shear capacity. l - The Applicant's analysis of the base mat utilized finite element methods and generally recognized formulas presented in a textbook , written by R. J. Roark; these approaches are fundamentally independent of each other. The use of finite element methods in m h.
5-conjunction with electronic computers permits solutions of structures having complex geometry, loading and boundary conditions, such as the Waterford Unit 3 base mat, although correct use of this
, [t
?
method is rather difficult. The use of textbook formulas permits solutions for ideal loading and boundary conditions, but must be utilized in conjunction with engineering judgment to obtain solutions for actual (non-ideal) conditions. In its application of pertinent formulas, the Applicant calculated positive bending moment in the mat under the reactor building by assuming a 20% edge fixity of a circular plate under the shield building, and a uniform soil pressure beneath the mat; the Applicant calculated negative bending moment under the shield building by assuming a 50% edge fixity and uniform soil pressure under the mat. In its finite element analysis, the Applicant calet. lated two bending moments in the mat, by using actual loading conditions and two separate soil conditions: constant soil modulus, and variable soil modulus in which the modulus varies in rough proportion to the deformation shape of the mat.
.- The top and bottom reinforcing steel bars that resist the negative and positive bending moments, respectively, were proportioned in a manner such that a surplus bending moment capacity is always ,
provided, by comparing the three design bending moments calculated for a given location (one derived from use of the formulas and two l l 7 i
derived from the finite element analyses). In each of these three analyses, the estimated daad load on top of the mat was multiplied by a factor of 1.5 before being used in calculating the required . L
?
design bending moments (providing the 50% margin in load capacity referred to above). The shear capacity of the base mat was calculated and provided in n manner similar to the bending moment treatment described above: a surplus shear capacity is always provided, by comparing the design shear forces obtained in each of the three calculations, and the estimated dead load was multiplied by a factor of 1.5 before being used in calculating the required design shear resistance. Based upon my review, I have determined that the procedures and approaches utilized in the Applicant's analysis and design of the base mat are sufficiently conservative and are acceptable. The sum of the top and bottom reinforcing steel bars has provided adequate strength for the mat to resist the load imposed by the reactor and shield buildings. This conclusion is not altered by the cracking i that has been discovered. i Q8. Did your review of the Applicant's base mat design and analysis reveal any significant deficiencies which affect the structural integrity of the base mat? . l A8. No. l f l \ 9 4 a**upp*
8 8
=
. 7-Q9. Does the discovery of the cracking and water seepage require a reevaluatior. of the ability of the structures and equipment placed
~
on or anchored in the foundation base mat to withstand seismic i j( loads? A9. No. Since the crack widths are insignificant and the water chemistry is non-aggressive with respect to corrosion, the cracking and water seepage do not cause any change in the seismic input motion for structures and equipment placed on or anchored in the base mat. In other words, the cracking and water seepage do not present a challenge to the ability of those structures and equipment to withstand seismic loads. Q10. Is the cracking that was discovered earlier this year related to the concrete cracking which was found"during placement of the base mat i in 19777 A10. No. The concrete cracks which were discovered during placement of the mat appear to have been caused by soil settlement patterns associated with the way in which the concrete was placed. In contrast, the cracking which was discovered this year appears to f have been caused by a combination of tensile stresses generated by flexure, torsion, and punching-induced shear stress, as a result of l I
- the weight of the structures (the dead load) and their location on top of the mat.
l Q11. Please explain your response to Question 10 above.
-r--, , ,w---
8
,- All. The Waterford Unit 3 base mat is a reinforced concrete slab 270 feet wide 380 feet long, and 12 feet thick. Because of its size, the concrete placement was divided into 28 blocks, with each .
L block placed sequentially. The first block to be placed was the I block located under the center of the reactor building; subsequent placements extended in strips outwards from that block. The soil under each concrate block was measured to have settled about 3/4 of an inch immediately after the concrete for that block was placed, with settlement under that block occurring at a much slower rate thereafter. As each new block was placed, it was leveled with the top of the adjacent, previously placed block. Since' the new block would settle 3/4 of an inch insnedistely after being placed while the existing blocks would settle at. a much slower rate relative to the new block, the mat formed a convex shape with ) its center higher than its edges. The Applicant reported the maximum measured surface curvature between the center and edges of the mat was 21/2 inches; it is'my understanding that this figure has been verified by Dr. Raman Pichumani of the NRC Staff. In i structural analysis, this effect is equivalent to a flat plate supported at its edges with soil acting as upward-pushing loads. This phenomenon created the maximum tensile stress zore on top of the mat under the reactor building, and was responsible for the concrete cracking discovered in that region in 1977. Upon placement , of the reactor building, these cracks would tend to close, as a _h_
.g. . result of compressive stresses in the region caused by the weight of the reactor building.
L r In co'ntrast, as set forth in response to Question 10 above, the radial cracks which were recently discovered around and outside the shield building (as well as the other cracks that have been discovered) appear to have resulted from a combination of tensile stresses generated by flexure, torsion, and punching-induced shear stress. These cracks did not result from soil settlement -- unlike the previous cracks -- in that the settlement record demonstrates that there has been no significant additional or uneven soil settlement since April 1979. Also, in my opinion, if some of the reinforcing steel had been shifted from the bottom of the mat under the reactor building to the top of the mat under the shield building for use in resisting negative. bending moment, some of the radial cracking that has appeared around the shield building would have been reduced or eliminated. However, the distribution and amount of the reinforcing steel provide adequate overall bending moment resistance ., capacity and, accordingly, as set forth in response to Question 7 above, ! the strength of the base mat is adequate. i i Q12. What is responsible for the water seepage that has occurred in the l ,. base mat? , A12. The water seepage appears to be groundwater that has leaked, under . ! hydrostatic pressure, through joints and cracks into the mat, and appears to be due to the absence of waterproofing membranes under l and around the mat.
~
i _
s
', Q13. What is the significance of this water seepage?
A13. The appearance of' water seepage raises a question as to whether corrosion of the reinforcing steel in the base mat is likely. In [t
. this regard, ground water chemistry is the primary consideration.
The Applicant has analyzed the ground water chemistry, and has a stated that sulfate content is no greater than 60 ppm and that chloride content is no greater than 78 ppm. These levels are considered to be non-aggressive with respect to the corrosion of reinforcing steel, and are well below levels which would cause concern over the likelihood of such corrosion. Similarly, other chemical content of the ground water is far below levels which would cause concern for corrosion of the reinforging steel. Q14. Why has the Staff determined that a surveillance program should be initiated? A14. Notwithstanding the adequate design of the base mat, the lack of recent ' soil settlement, and the non-aggressive nature of the ground water chemistry, the Staff has determined that a surveillance program would provide additional assurance as to the continued structural integrity of the base mat. The advisability of requiring such a program results from the existence of various uncertainties e in current understanding of soil settlement, soil dynamics (such as earthquake-induced vibration), hydrodynamics (such as ground water flow and seepage forces), and the corrosion tendencies of . reinforcing steel. Accordingly, the Staff will require that the
11 Applicant submit an appropriate surveillance program for the Staff's review and approval. Q15. In light of the discovery of cracking and water seepage in the foundation base mat at Waterford Unit 3, is there reasonable assurance that, with respect to the structural integrity of the base mat, operation of the facility will not endanger the public health and safety? A15. Yes. The Staff has determined that (a) the adequate strength of the base mat, (b) the non-aggressive natfre of the ground water with respect to corrosion of reinforcing steel, and (c) the requirement that an acceptable surveillance program be established, afford reasonable assurance that, with respect to the structural integrity of the base mat, operation of the facility will not endanger the health and safety of the public. y= A ap John 5. Ma Subscribe and sworn to before me this day of November, 1983 M Q Notary 20blic b My Comission expires: I 8fo I
- , . _ . -. ? w . ..--
JOHN S. MA STATEMENT OF PROFESSIONAL QUALIFICATIONS Education:; (.
- S.S. degree in Civil Engineering at Taiwan Christian College of Science
& Engineering, Taiwan, China (Sept. 1957-June 1962).
M.S. degree in Civil Engineering (Structures) at The University of Missouri at Rolla, Rolla, Mo. (Feb.1965-May 1966). Ph.D degree in Civil Engineering (Structures) at The University of Texas at Austin, Austin, Texas (Sept.1967-May 1971). Registration: Registered Professional Engineer in the State of California. Experience: Construction Engineer at The Chinese Air Force, Tainan, Taiwan; China (June 1962-June 1963). Airport construction. Teacher of Surveying and Construction at Taiwan Provincial Senior Industrial School, Chiayi, Taiwan, China (June 1963-Sept. 1964). Structural Engineer at Howard, Needles Tammen & Bergendoff, Consulting Engineers, Kansas City, Mo. (May 1966-Aug. 1967). Principal investigator of skew slab bridge design methods. Structural Concrete Research Engineer at The University of Texas at Austin, Austin, Texas (Sept. 1967-May 1971). Testing of reinforced concrete structures. Structural Engineer at Western Precipitation Division, Joy Mfg. Co., Los Angeles, Ca. (June 1971-March 1972). Design of Precipitators, hoppers, flues with high pressure & elevated temperature, and their support structures. Structural Engineer Engineers, Los at Ca. Angeles, Kelly (, Pittelko, April Fritz & 1972). 1972-December Forssen, Consulting Analysis and
.- design of high rise buildings.
Structural Engineer at Bechtel Power Corporation, Los Angeles, Ca. (December 1972-October 1974). Computer program development work and actual design of nuclear power structures. e
-W
_ 2
- Structural Engineer at U.S. Nuclear Regulatory Commission, Office of Standards Development (November 1974-March 1980). Development of Regulatory Guides for structures, coordination of NRC Staff activities on ASME Code, Section III, Division 2.
Structural; Engineer at U.S. Nuclear Regulatory Commission, Office of f-Nuclear Reactor Regulation, Structural and Geotechnical Engineering Branch (March 1980-present). Licensing reviews of nuclear power plant structures and technical contract management. 'l i e 9" e ,
, -. ._.,,..---,.rme_
ATTACHMENT 1
,- OCT 171983 i
Occket No.: 50-382 Mr. R. S. Leddick Senior Vice President - Nuclear Operations Louisiana Power & Light Company Post Office Box 8008 142 Delarende Street New Orleans, Louisiana 70174
Dear Mr. Leddick:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING CONCRETE MAT CRACKING AND WATER SEEPAGE ISSUES AT WATERFORD 3
References:
- 1. Memo to 0. Eisenhut, et al, from E. Christenbury, dated 4
September 22, 1983, subject: "Waterford 3 Report on Water Seepage and Concrete Cracking" with enclosures.
- 2. Memo to Comissioners from D. Eisenhut, dated i September 15, 1983, subject: " Inspection and Enforcement Inquiry Team Report on Waterford QA Allegations (Board Notification No. 83-133)".
f 3. Applicant's Answer to Joint Intervenor's Motion to Reopen Contention, dated September 30, 1983. 4 Letter to R. C. DeYoung from J. M. Cain o'f Louisiana Power and 1.ight, dated September 29, 1983 We have reviewed the above references and found that additional infomation is needed before we can continue our review. Dr. John Ma of Structural Engineering Section A, and Dr. Raman Pichumani of Geotechnical Engineering Section, Structural and Geotechnical Engineering Branch are perfonning the review and have prepared the following questions. The source of the water which is seeping to the top of the mat is believed to be ground water, but the path of seeping water has not been determined.
' N '
yd
# ~
i p+ [:N - t)llt? '
i i Unless it can be shown that the ground water is seeping through vertical construction joints to the top of the mat, it is reasonable to assume that either vertical through cracks have occurred or localized porous zones exist, j( or both. Vertical through cracks are undesirable, especially if the mat was
. designed without shear reinforcement. Whether localized porous zones would affect the structural , integrity of the mat depends on the size, location, and degree of porosity of these porous zones. We would like LP&L to address the adequacy of analysis and design of the mat and the effect of possible porous zones on the structural integrity of the mat.
In addition to addressing the above issues, LP&L should also provide answers to.the following questions:
- 1. ~ Was the mat treated as a one dimensional beam or two dimensional plate in structural analysis?
- 2. How were the shear and bending moment (flexure) diagrams of the mat obtained for proportioning the depth of the mat and the area of reinforcing bars?
- 3. State the causes of the convex shape of the mat prior to the placement of the containment vessel fill concrete.
4 Figure 2.5-117, Composite Fo~ndation u Mat Settlement, indicating the mat settlement in the N-S df rection from 1975 to 1980, does not indicate a convex shape for the mac. Was the convex shape observed only in the E-W direction?
- 5. Figure 2.5-117 indicates a concave shape for the mat, but figure 2.5-118 i
indicates a convex shape for the mat. Clarify the apparent 19 consistency between these two figures.
- 6. Furnish the s'ettlement data for the mat from 1981 to present.
- 7. Describe the. procedures used to determine the subgrade modulus for mat design; how were the effects of the heave (which was larger than estimated) accounted for in determining the subgrade modulus?
- 8. Was a waterproofing membrane placed around all the exterior faces of the mat?
- 9. Are the seepage zones in close proximity to vertical construction joints?
i ( y .- g. 9D
- 10. Were waterstops placed in the vertical construction joints and, if so, where?
; i t.
- We request th'at this information be provided by October 28, 1983. If you have any questions concerning this request, contact the Project Manager, J. Wilson on(301)492-7702.
Sincerely, originalsinnid by: George W.~Knighton George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing cc: See next page i 6 l l l
~
WATERFORD
. Mr. R. S. Leddick Vice President . Nuclear Operations L
Louisiana Powerf& Light Company i
- 142 Delaronde Street New Orleans, Louisiana 170174
. 5,'
cc: W. Malcolm Stevenson, Esq. Regional . Adminstrator-Region IV Monroe & Lemann U. S. Nuclear Regulatory Comission 1423, Whitney Building ' 611 Ryan Plaza Drive ~ New Orleans, Louisiana 70730 Suite 1000 Arlington, Texas 76012 Mr. E. Blake Shaw, Pittman, Potts and Trowbridge 1800 M Street, NW Washington, DC 20036 Mr. Gary L. Groesch b ' 2267 Dayou Road New Orleans, Louisiana 70119 Mr. F. J. Drummond Project Manager - Nuclear Louisiana Power & Light Company , 142 Delaronde Street New Orleans, Louisiana 70174 Mr. D. B. Lester Production Engineer ' Louisiana Power & Light Company 142 Delarande Street ' New Orleans, Louisiana 70174 - Luke Fontana Esq. 824 Esplanade Avenue New Orleans, Louisiana 70116 - Stephen M. Irving, Esq. 535 North Gth St.eet l , Saton Rouge, Lcuisiana 70802 Resident Inspector /Waterfor'd KPS P. O. Box 822 Killona, Louisiana. 70066 - Dr. D. C. Gibbs Middle South Service, Inc. P. O. Box 61000 ' New Orleans, Louisiana 70161 1
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ATTACHMENT 2 LOUISIANA P 4 O W E A & L I G H cmemT ! e=.-e . -- vo,v-.e, ec:a e tsc4: sem October 31, 1983 L t W3PS3-3619 3-A1.01.04 C 3 A14.19.01 1 Director of Nuclear Reactor Regulation Attention: Mr. G. W. Knighton, Chief Licensing Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Ccmmission Washington, D. C. 20555
SUBJECT:
Waterford 3 SES' Docket No. 50-382 Response to NRC 3asemat Quest (ons REyERENCE: 1.) Letter dated October 17, 1983 from G. W. Knighton to R. S. Leddick .
Dear Sir:
j Reference 1 t'.aasmitted to LP&L a set of questions relating to the structural integrity of the Waterford 3 basemat. Please find attached our response to those questions. On October 26, 1983, a draft of this response was given to those members of the staff conducting an independent evaluation of the Waterford 3 basemat; however, the attached response provides some additional information resulting from discussions held at that time. Responses to additional clarifying questions po' sed by your staff at that time are being investigated and will be provided to you shortly. I would also like to take this opportunity to emphasize not'only LP&L's commitment to support a timely resolution of your concerns, but also LP&L's i l complete confidence that the application of engineering practices and regulatory
', guidelines to the design of the Waterford 3 basemat have fully accounced for any and all conditions and functional requirements which the Waterford 3 base =at will realistically see. More detailed discussions of the bases of our confidence can be found in the attached response and in the reports and evaluations previously l
forwarded to you. As you are probably aware, LP&L retained a renevned - engineering specialist, Harstead Engineering Associates, to investigate this matter independently of the evaluations performed by the NRC staff and Ebasco Services Inc. I would like to conclude hy noting to you the closing sentences of the Harstead Engineering Associates final report, which su=marizes the results of their engineering and technical evaluation: 1 pM g G Y W v so s lW -
"While the seepage of water from the cracks precipitated the investigation, all aspects of the [basemat] design were considered, not just those associated with the cracks and se' epa ge . It is our conclusion that the design of the mat j, is. extremely conservative...Therefore, we see no need for I any remedial measures or the necessity of additional analyses", (HEA Report No. 8304-2 dated October 12.1983).
Since timely resolution of this issue is of considerable import to LP&L we are v1111ng to support the staff review in any way possible. Please let me know if you have any additional questions or identify the need for additional information. fK. W. Cook O Nuclear Support and Licensing Manager KWC/RMF/pjl cc: E. L. Blake B. W. Churchill, W. M. Stevenson, J. Wilson, G. L. Constable i l i l l l l l 1 e
Attrehamnt 1
., e . Introductory Question I In a condensed form, this is a request to provide discussions of the following:
- a. Postulated path of ground water though the mat
; addressing: j(
- 1. vertical construction joints
- 2. vertical through cracks
- 3. localized porous zenes
- b. The adequacy of the analysis and design of the mat.
- c. The effect of possible porous zones on the structural integrity of the mat.
i Response We have concluded that the most probable path of the seeping water which is showing as moisture at some hairline cracks in the surfree of the sat originated at flexural cracks at the bottom of the sat and follows embedded itens which intersect these cracks, such as structural steel rebar support structures and conduit, horizontally through the mat to an intarsection with hairline i cracks at the top of the mat. These hairline cracks were mapped during the period of August 30-September 2, 1983 (Reference 1. Appendix A and , Subsections 4.5 and 4.6). The path of the water l seeping through the hairline cracks need not be j determined with a high degree of certainty in order to ascertain that the cracks are not indicative of , a safety concern. When the NRC's independent reviewer postulates mechanisms such as vertical through cracks or localized porous zones, they should be evaluated based on project records and I&E inspections currently in NRC hands to determine whether such mechanisms are credible. This later approach is the one independently adopted by both Harstead Engineering Associates and Ebasco in evaluating this concern and these independent evaluations arrived at the same conclusion that no l safety concerns exist. Recognizing that a portion l of the information available to Ebasco and Harstead Engineering Associates is not currently available
. to your independent reviewers, it is of course l
necessary to identify and supply this information ! so that informed decisions can be made. We will be l glad to support your review by supplying any such l information as you identify a need. There is no direct evidence, nor is it reasonable to assume. l that vertical through-cracks have occurred and/or l localized porous zone exist. We base this l statement on the following points: l i i
.P
- . , . -, ~-,. v e , -,-~,, ,r,-, -. r -
1 , 2
- a. The cracks were found to reflect a pattern of flexure resulting in the development.of
- tension stresses in the concrete, which type of cracking only extends through to the j
; neutral axis. This type of cracking is (
expected in concrete construction. The ~ formation of vertical or near vertical through-cracks would imply an occurrence of
- sheer failure in the mat cen: rete. "udar s.ch an assumption one would expect to find hairline cracks in the high shear stress zones and along the edges of walls and columns.
However, no such crack patterns have been identified.
- b. The formation of vertical through cracks would imply overstress in shear, however, the design of the sat is conservative so that such an overstress would not occur. (Reference 2)
- c. The interconnection of the tension hairline cracks with those near the top and the bottom of mat was possible because of the presence of the embedded structural steel beam and column system utilized to support the top layer reinforcing bars, and other embedded items -
steel plates, electric conduits and equipment anchor bolts, etc. The surfaces of these embedded structural items have provided additional vertical and horizontal seepage paths within the mat concrete interconnecting the fine concrete tensile cracks.
- d. The placement of mat concrete was accomplished under an approved quality assurante program to implement a satisfactory production, placement and curing of the concrete to meet the design requirements and to prevent the occurrence of voids or other deficiencies in the concrete.
The compression tests continuously performed during all construction periods had provided the assurance that the concrete had properly
", obtained the required 28-day compression strength, 4000 psi.
.. e. Any localized porous zones which were formed because of construction difficulties have been ~
identified during and immediately following placement and properly treated and repaired. These areas involved only the placement of Blocks 10B and 19, and the results of the treatment have been documented. p ,
a . 3
, With regard to the adequacy of the analysis and design of the mat, evaluations performed as part of f
our normal Ouality Assurance program, and the ' additional independent evaluation performed by Harstead Engineering Associates, have provided
; adequate assurance of the Waterford 3 basement j(
capability to perform as required. HEA notes that
~
"The basement is very structurally redundant and in verv espeble of ccrryic; Iwait well in excess of o
the applied loading combinations". (Reference 2, Section 6.0; emphasis added). The presence of the
- flexural cracks discovered does not alter'in any way our confidence in the basemat performance capability. " Cracking of the type evidenced at the top of the Waterford 3 basement is expected in concrete construction, and is assumed in establishing the structural capacity requirements in the ACI 318 Code" (Reference 2. Section 6.0; emphasis added).
We believe that the adequacy of the analysis and design of the mat has been well demonstrated. While a reanalysis of the sat to take into account the effect of possible localized porous zones has not been done, we believe that because we have been unable to discover any factual basis for such zones, and furthermore believe that our Quality Assuran:e program effectively ensured that no such zones exist (See response parts d & e above), such reanalysis is neither necessary nor warranted. We further believe the staff will concur with this position when they have had an opportunity to evaluate our documentation and the results of inspections by the I&E staff. 4 4 . G e
4
~
Ouestion 1 Was the mat treated as a one dimensional beam or two dimensional
, plate in structural analysis?
Response: In the structural analysis, the mat was treated as a two . dimensional place. For the design and analysis procedures used for the mat, please refer to FSAR Section 3.8.5.4 (- Question 2 Hnw were the =hetr ard bonding 50 t:0 (fic_ure) diagra-. of J e mat obtained for proportioning the depth of the mat and the area of reinforcing bars? Resnonse: The shear and bending moment of the sat were obtained from the finite element analysis to include all cases of related load combinations as discussed in FSAP. Section 3.8.4.3.2. The reinforcement steel areas were calculated based on the maximum shear and moment in E-U and N-S directions obtained for each of the mat elements from the results of finite element stress analyses. Furthermore, Harstead Engineering Associates (HEA) has concluded on the basis of an independent review and analysis that the bending reinforcement is well over that required (Reference 2 Section 6.3). Question 3 State the causes of the convex shape of the mat prior to placement of the containment vessel fill concrete. Response: The convex shape of the mat resulted from a complex series of events involving the placement of the concrete mat and the l scheduling of concrete placement for the superstructure. The construction of the mat was divided into 28 blocks. The blocks
- located beneath the containment were placed first and then the l blocks away from the containment were placed. Three E-W strips (Strips 1, 2 and 3) of the mat beneath the containment were placed and completed prior to the placement of the mat strips north and south of the containment (Strips 4, 5 and 6). The block placement dates for each of the mac blocks are given in FSAR Figure 2.5-118.
The top elevation of the concrete for each block was essentially level with that of the previous block at the time of placement. l vhich previous block had already undergone some settlement. e i Therefore each block would settle so its surface would reflect the differential settlement only from the time of placement. O 98 6 e
5 In addition, the subsoils beneath the mat in the area which was placed first had started their consolidation process earlier as
. compared to the areas which were placed later. The lag in the starting of the consolidation introduced part of the differential i i settlement creating the convex shape. Furthermore, the area of the containment was left unloaded by superstructure concrete for a considerable period of time while the area outside the shield building was loaded by superstructure concrete during the period of steel
, containment erection. This resulted in f'rtber t differential settlements causing the convex mat shape. As noted in FSAR Figure 2.5-118, the convex shape is only a matter of approximately two inches in height differential over the 380 foot length of the basemat.
Question 4 Figure 2.5-117, Composite Foundation Mac Settlement, indicating the sat settlement in the N-S direction from 1975 to 1960, does not indicate a convex shape for the mat. Was the convex shape observed only in the E-W direction? Res;onse: The convex shape was observed in E-W and N-S directions. FSAR i Figure 2.5-117 plotted the average of the absolute block settlements within each E-W mat strip, and not relative settlements. Relative sectiements are shown in Figure 2.5-118. Question 5 Figure 2.5-117 indicates a concave shape for the mat, but Figure 2.5-118 indicates a convex shape for the mat. Clarify the { apparent inconsistency between these two figures. Responset FSAR Figure 2.5-118 shows the mac differential settlement concours which had used Block No. 6, the first block placed, located at the center of the containment area, as a reference point. The figure indicates that the amount of differential settlement increases in the area of the sat away from the containment area. Question 6 Furnish the sectiement data for the sat from 1981 to present. Response: The settlement of the mat has practically stabilized since the e second quarter of 1979 as reflected in FSAR Figure 2.5-117. Sheet 1 of 2 (Amendment 33). Beginning in 1981, the bench mark points for settlement measurement were transferred from the mat to the exterior walls; the readings are shown in FSAR Figure 2.5-117, Sheet 2 of 2 (Amendment 33). ,
. . .. e m
. 6 Ouestion 7 Describe the procedures used to determine tha subgrade modulus for
~
mat design; how were the effects of the heave (which was larger than estimated) accounted ~for in determining the subgrade modulus?
. Response As noted by HEA in Reference 1 (Section 6.0), the selection of the ,
subgrade modulus applicable to the foundation soils and sat L i geometry is judgemental. The actual value used in the design E
, ,, analysis was a mean value of:
- 1. A typical revehack welae
, 2. A value derived using Waterford 3 soils data and soil recompression characteristics.
The heave phenomenon was taken into consideration in the recompression program of the subsoil system. The recompression process had been completed earlier in the stages of construction, as discussed in FSAR Subsection 2.5.4.1.3.2b) (Page 2.5-96), "the average heave readings at the site were recompressed to their initial readings by July, 1977." Furthermore, for the finite element analysis, additional conservation was established by assuming a variable spring, is, the soil springs under the Reactor Building were reduced to 70pci while the area adjacent to the Reactor Building was set at 110pci. The other parts of the mac remained at 150pci. HEA agreement with this approach is indicated in Reference 2 (Section 6.0). l t Question 8 Was a waterproofing membrane placed around all the exterior faces of the mat? Responser A waterproofing membrane was placed around the exterior face of l the mat from the top of the mat down to 2'-0 below the top of the j mat (FSAR Figure 3.4-1). Question 9 ~Are the seepage zones in close proximity to vertical construction joints? Response: Only a small part of the hairline cracks exhibiting moisture are located in close proximity to vertical construction joints. In a few cases, a construction joint appears to have seepage. The fact e that construction joints have little seepage is to be expected in that construction joints have continuous waterstops. Obviously random forming cracks will not have mechanical water stops. Considering the substantial hydrostatic ground water head, the amount of seepage is insignificant, indicating considerable , resistance to water pressure. l 9
7 Question 10 Were waterstops placed in the vertical construction joints, and if so, where? Response: Two nine inch PVC waterstops were provided at all vertical
; I(
construction joints of the mat. The bottom waterstop is located 2'-6 above the bottom of the mat, and the top is 2'-0 below the top of the mat. O References 1. HEA Report No. 8304-1 dated September 19, 1983
- 2. HEA Report No. 8304-2 dated October 12, 1983 e
6.* De g e o e e. p
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- - ATTACHMENT 3
,.* **'*53, UNIT (o STATES
[, .
- NUCtLAR REGULATORY COMMIS510N
. : V. .J* 1 ac cioN iv
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. su avan es a A nnin suits iaso t.rusu:os. n nr.r. wr.,
NOV 161983 j i t M;-MCRANDUM FOR: D. G. Fisenhut. Director. Division of Licensing TROM: John T. Collins, Regional Administrator s'JBJECT: INSPFCTION OF DEWATFRING AND FXCAVATION ACTIVITIES AND CONSTRUCTION OF THE COMMON FOUNDATION MAT FOR lHE WAIERFORD 3 PROJECT l ouisiana Pow *r & l ight Co:npany was issued Constructiun Permit CPPR-103 to cun,trus,t the Waterfurd 3 Project un Nuvember 14, 1974. Initial site preparation activities consisted of dewatering and excavation to aporoximately GO feet below grade lovel with attendant monitoring by pternenters, obsnevation wells, slope indication Instruments, and alignment ISUrl j LU r', . Although site excavation to GO feet be. low grade was authorized by the A[C on July 28, 1972, digging was stopped at 17 feet to preclude in:,tallation of dewatering facilities. An 1.WA-7 was issued on July 24. 1974, under the prov1<. inns nf 10 crR 50.10(c)(3). but $1te excavation was not corwenced until early 1975 af ter I:,:,uance of the CP and in:,tallation of the dewatering facilities. prior to site preparation activities, NRC ine.pect. ors reviewed QA/QC procedures for site preparation. Inspection of test data and ungulng dewatering activitins, enoniLoring of excavation and dewatering was perf ormed. 0, watering of tbv site to the required level was completed in January 1975 and excavattun com:nenced about March 1975, and was completed to the top of the pleistucune layer about the last quarter of 19/5. Strip removal of a top layer of the pleistocene clay with installation of shell filter blanket and tnd :nat was inspected by the NRC inspectors. Fo11cw on in'.poction as,tivities by the NRC in,pectors of initial site
,. preparation activitivs included approximately nine inspections. *
~
lhe com. mon foundation concrete mat for the Waterford nuclear plant island is a reinforced concrete structure 270 feet wide, 330 feet inenj, and 12 feet thick. The structure was cerrcted in 78 plar.cments involving approximately 50,000 cubic yarde. of concrete.
-fh h p o m C-
-h h hh h
D. G. Fisenhut NOV jgnga NRC inspection a:tivities for concreting included review of OA/0C procedures L for production, placing, and testing of concrete. Inspection of concrete I e , penduction facilities included materials, curtification, capacity (also backup), batching and transport. Inspection of placing included forms, water stops, rate of placement, consolidation, finishing and curing. Inspection of concrete testing included tests of hatched concrete (slump, air entrainment, etc.) and compression testing. Reinforcinq steel inspection included recoipt handling, Cadwelding testing, and Installattun. NRC inspectors began insper tion of the licensee and contractors' QA/QC programs in late 1974 And (untinued onsite inspection ActiVitles for site preparation and placement of the common foundation mat until completed. The f irst p acement for the foundation mat was completed December 3,19/5, and the whole mat was 96% complete on May 7,1976. NRC inspectur> completed approximately 26 inspections during the period Nuvember 1974 through Septother 1977. These inspections also included inspection of corrective actions performed by the licensee for testing and correcting of deficiencies. Ra',ed on the .ibuve inspections, we conclude that site preparation (including dewatering, vacavation, and soil compoetion) and placement of the common foundation mat (including reinforcing steel) were performed in accordance with approved procedures, specifications and regulation'..
,;k.hs*$$ U John T. Collins Regional Administratur 1
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1
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD .
. In the Matter of LOUISIANA POWER AND LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station, )
Unit 3) ) AFFIDAVIT OF RAMAN PICHUMANI Q1. Please state your name, title and by whom you are employed. A1. My name is Raman Pichumani. I am employed as a Geotechnical Engineer in the Structural and Geotechnical Engineering Branch of the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission. A statement of my professional qualifications is attached. Q2. What is the purpose of this affidavit? A2. The purpose of this affidavit is to provide the evaluation and conclusions of the NRC Staff (" Staff") concerning the settlement of the foundation soils underlying the concrete base mat at Waterford Unit 3. l , Q3. Please describe the evaluation which you perfomed. A3. I perfonned a reevaluation of the foundation soils underlying the Waterford Unit 3 base mat, in light of the discovery of concrete h Nk J$ .J -
+>i"*ca p Ju W
- ,' cracking and water seepage through the base mat earlier this year.
As a geotechnical engineer, my review was conducted in order to verify the adequacy of the relevant soil parameters used in the . L Appli' cant's structural analysis of the concrete base mat, and to I provide input concerning foundation settlement to Dr. John Ma for use in his review of the structural integrity of the base mat. As part of my review, I attended two meetings held with the Applicant and its consultants (on October 26, 1983 in Bethesda, Md. and November 3, 1983 in New York, N.Y.) in which the concrete cracking and water seepage issues were discussed, and I examined the following documents: (a) Safety Evaluation Report Related to the Operation of Waterford Unit 3 Steam Electric Station, Unit No. 3 (SER) (NUREG-0787, July 1981), 12.5.4; (b)LetterfromtheApplicanttotheNRCStaffdatedJune24, 1981 (
Subject:
Response to SER Open Item 49, " Reevaluate Foundation Mat for Changes in Value of Subgrade Modulus"); f (c)HarsteadAssociates,Inc.,WaterfordIIISESAnalysisof i Cracks and Water Seepage in Foundation Mat, Report No. 8304-1, September 19, 1983; (d) Harstead Associates, Inc., Waterford III SES Analysis of l ' I ' Cracks and Water Seepage in Foundation Mat, Report No. 8304-2, October 12, 1983; (e) Memorandum from J. Collins to D. Eisenhut, dated November 16,1983(
Subject:
Inspection of Dewatering and Excavation e
Activities and Construction of the Common Foundation Mat for the Waterford3 Project); (f) Applicant's Plan showing mat settlement contours (August i.
?
1979), incorporated in the Final Safety Analysis Report Figure 2.5-118; and o (g) Applicant's field sketches (No. SK 1564-1510G34.1 (2 sheets)), showing the composite foundation mat settlement from January 1981 to August 1983. Q4. Have you reached a conclusion as to whether the foundation soils underlying the Waterford Unit 3 base mat provide adequate support for the base mat and the structures and equipment on top of the base mat? A4. Yes, I have. Based upon my evaluation, I have concluded that the foundation underlying the Waterford base mat does provide adequate support for the base mat and the structures and equipment on top of the base mat. QS. Please explain the basis for this conclusion. AS. This conclusion is based upon my evaluation of (1) the foundation soils underlying the base mat, (2) pertinent construction practices
.c_ employed during placement of the concrete base mat, (3) the soil settlement record, (4) the Applicant's analysis of the effects of changes in soil modulus values as may have resulted from .
non-uniform post-excavation heave, and (5) the previous conclusions as to foundation stability presented in section 2.5.4 of the SER.
0
- The foundation underlying the common base mat consists of soil layers up to 4900 feet in depth. The base mat is founded at E1 -47 ft ms1. The soil profile beneath the mat consists of a j fairlh uniform preconsolidated clay layer with occasional silt and sand down to E1 -77 ms1, dense silty sand from E1 -77 to E1 -92, slightly preconsolidated clay with silt lenses from E1 -92 to E1 -108, organic clay from E1 -108 to E1 -116, and preconsolidated clay with sand lenses from E1 -116 to E1 -317. Dense silty sand exists from E1 -317 to E1 -500.
Since the common base mat is rather large (380 feet long, 270 feet wide, and 12 feet thick), it was built in six strips containing a total of 28 individually poured blocks, with each strip consisting of 4 to 5 large blocks. To :ninimize the amount of foundation settle-ment which is ordinarily experienced by structures resting on compressible soil deposits, the Applicant employed what is termed the " compensated" or " floating" foundation concept in designing the common base mat for the safety-related structures at the site. In this design concept, the applied effective vertical soil pressures at and below foundation level are designed to be approximately equal to the effective stresses that existed before construction, thus
, minimizing the heave during excavation and subsequent recompression under applied structural loads.
The actual post-excavation heave of the foundation soil was non-uniform across the area of the mat and was about two to four l l l e I
. 5-
~
. times greater than the predicted uniform post-excavation heave of two inches, due to an interruption in dewatering of the foundation soils and extended work stoppages. As set forth in section 2.5.4 [t of the Staff's Safety Evaluation Report (NUREG-0787. July 1981), the Applicant recompressed the post-excavation heave by increasing the maximum allowable concrete- and backfill-imposed load at the mat bearing level by 1200 psf to achieve a maximum vertical effective pressure of 4500 psf during construction. Any increases in normal construction load beyond this allowable load were compensated by
- adjusting the operation of the dewatering system.
This construction procedure accomplished the recompression of the post-excavation heave (thereby correcting any significant differen-tial settlement effect which may have been caused by the heave), and also produced net total settlement of the base mat as discussed in section 2.5.4 of the SER. The average total settlements of each of the six strips between December 1975 and April 1979 ranged from about 10.3 inches to 10.8 inches; no significant additional settle-ment has been measured from April 1979 to the present. Although the measured total settlements of the different strips are more or less uniform, the top of the finished base mat has assumed a s. convex downward shape, as indicated in the differential settlement contours prepared by the Applicant. These contours (based on measure- . ments made in August 1979) show that the differential settlement between the approximate center of the mat and the south edge of the
*
- e
', mat was about 2.5 inches, while the differential settlement between
- the approximate -center of the mat and the north edge of the mat was about,1.5 inches. These differential settlements appear to have [r
? '
resulted primarily from the following: (1) each of the 28 concrete blocks appears to have undergone an immediate settlement of about 3/4 of an inch as soon as it was placed; (2) each block has under-gone additional settlement due to recompression of the soil before each adjacent block was placed; and (3) there was a time lag of about 5 months between the laying of the first strip at the middle of the mat and the last s+. rip at the south edge of the mat, resulting in greater settlement at the edge than at the center of the mat. The maximum differential settlement is approximately 2.5 inches over a distance of approximately 200 feet. Q6. Has the Applicant given adequate consideration in its analysis of the base mat to accommodate the variations in soil stiffness such as may have been caused by the post-excavation heave referred to in response to Question 5 above? A6. Yes. The Applicant has performed a detailed soil-structure inter-action analysis to evaluate the effects of changes in the values of the subgrade modulus used in the design of common base mat; the s-results of this analysis are presented in the Applicant's submittal dated June 24, 1981, in response to the Staff's SER Open Item 49 (" Reevaluate foundation Mat for Changes in Value of Subgrade , Modulus"); this analysis was accepted by the Staff in SER Supple-ment 1, 13.8.5 (October 1981).
l i . e
. Three different cases were analyzed by the Applicant: (1) constant subgrade modulus of 150 pci; (2) variable subgrade modulus ranging from 70 to 150 pci, varying from place to place over the mat area, f-
- to account for non-uniform soil stiffness; and (3) a rigid mat.
The design moments and stresses in the base mat were obtained by enveloping the moment and stress curves obtained with the higher subgrade modulus by the curves obtained with the lower modulus. This approach affords appropriate consideration of changes in soil stiffness such as may have been caused by the non-uniform post-excavation heave. Q7. Does the settlement record provide reasonable assurance that the foundation soils are stable with respect to settlement? A7. Yes. As set forth above, there has been no significant additional or uneven settlement since about April 1979; this record indicates that the foundation soils under the base mat are stable. t
- 08. Will the Staff require that the Applicant continue to measure the settlement of the base mat throughout the operating life of the plant?
A8. Yes. The Staff has determined that settlement monitoring should be continued throughout the operating life of the plant, in order to l
< provide assurance that differential settlement will not present a l
- .. challenge to the base mat in the future. This requirement will be imposed notwithstanding the Staff's expectation, based on the -
L- - ,.
. existing soil settlement record, that such differential settlement is unlikely to occur.
I.
~
uw 'cMM Raman Pichumani Subscri and sworn to before me this day of November, 1983 Y Notary Public o\Q $ \ QC My Comission expires: ' s'
~ _ _ . _ _ _ _ . _ . __ _ __ . _ _ __ _ .- .. _ . .
1
.sp j
. RAMAN PICHUMANI PROFESSIONAL QUALIFICATIONS ,
I received a B.E. degree in Civil Engineering in 1952 from the ! j , University of Madras, India, and M.S. and Ph.D. degrees in Civil Engi-neering from Carnegie Institute of Technology (Carnegie-Mellon Univ.), 4 Pittsburgh, PA in 1957 and 1967, respectively. My areas of specializa-
- - tion in graduate school were 1) Soil Mechanics and Foundation Engineering
- and 2) Solid Mechanics and Structural Engineering.
4 I have been employed since September 1980 as a Geotechnical Engineer ' in the Office of Nuclear Reactor Regulation of the U.S. Nuclear Regulatory i Commission. I work in the area of Foundation Engineering as applied to i the evaluation of the suitability of nuclear power plant sites. In my i capacity as a technical reviewer of the geotechnical engineering aspects ; of applicants' safety analysis reports I have performed site reviews, i foundation analyses, and evaluations of engineering data, and have i prepared inputs for safety evaluation reports. ! From 1977 to 1980 I was employed as a Senior Research Engineer at i the Civil Engineering Research Facility (CERF) operated by the University i of New Mexico for the U.S. Air Force Weapons Laboratory (AFWL) where I i was engaged in the analysis of ground motions and dynamic soil-structure ! 4 interaction data obtained from large scale field tests of protective i underground structures loaded by a simulated nuclear environment. I was ,
- also a Principal ' Investigator for an AFWL-funded project for the develop-ment of a 6 degree-of-freedom rigid body model for the Shock Isolation
~ i System for the MX-missile canister, involving modification of an existing computer program. From 1976 to 1977 I was employed by Bechtel Power Corporation as an : 4 Engineering Specialist and was engaged in the seismic (dynamic) analysis ! of nuclear power plant facilities. From 1974 to 1976 I was a Senior Staff Engineer with GAI Consultants, I l i a consulting geotechnical engineering firm, where I was involved with foundation and soil-structure interaction analyses for nuclear power ,
- plants and served as a staff specialist for deep and shallow foundations.
(
- From 1968 to 1974, I worked for the Civil Engineering Research l e Facility (see above), where I was involved in finite element analyses of ;
4 layered pavement systems, and experimental pavement cratering studies.
# From 1967 to 1968, I was an Associate Professor of Civil Engineering l at West Virginia Institute of Technology. From 1966 to 1967 I worked as ,
an Engineer with E. D'Appolonia, Consulting Geotechnical Engineers, and I was engaged in analyses of earth structures and foundations including piles, cellular cofferdams and sheet pile walls, and performed settlement calculations and stability analyses for buildings and earth slopes. ll i !
l *
. From 1964 to 1966 I was a teaching and research assistant at Carnegie Institute of Technology.
From l'J52 to 1964 I worked in India in various capacities, starting as a Junior Engineer and ending as an Executive Engineer (1958-1964) in charge of design and construction of buildings and airfield pavements. j( I am a Member of the American Society of Civil Engineers and a member of the Society of Sigma Xi. I served as a Member of the Deep
, Foundations Committee of the Geotechnical Engineering Division of ASCE (1975-79). I am a Registered Professional Engineer in the State of Ma ryland. I have written several technical reports published by the Air Force Weapons Laboratory, as well as papers published in professional journals and conference proceedings.
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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
. BEFORE THE ATOMIC SAFETY AND LICENSIN'G APPEAL BOARD In the Matter of LOUISIANA POWER AND LIGHT COMPANY ;l Docket No. 50-382 (Waterford Steam Electric Station, Unit 3) h)l AFFIDAVIT OF RAYMOND 0. GONZALES Q1. Please state your name, title and by whom you are employed.
A1. My name is Raymond O. Gonzales. I am employed as a Hydraulic Engineer in the Hydraulic Engineering Section. Environmental and Hydraulic Engineering Branch, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission. A statement of my professional qualifications is attached. Q2. Please describe your responsibilities as part of the NRC Staff's
~
review of the operating license application for the Waterford Steam Electric Station, Unit 3. A2. I performed the NRC Staff's hydrologic review for the plant at the operating license stage. As part of my responsibilities I reviewed applicable portions of the Applicant's Environmental Report and
# Final Safety Analysis Report, and participated in drafting section 2.4 of the Safety Evaluation Report (NUREG-0787, July 1981) and j/nf Yl/ C [r*
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sections 4.3.2, 5.3.1, and 5.9.2.5(5) of the Final Environmental Statement (NUREG-0779 September 1981).
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Q3. Have'you been informed of the discovery of cracking and water seepage in the concrete base mat at Waterford Unit 37 A3. Yes. Q4. Have you determined whether the cracking and water seepage may result in any adverse environmental impact following the commencement of plant operation? A4. Yes, I have. It is my opinion thst the cracks and water seepage will not result in any adverse environmental impact following the commencement of plant operation. Q5. Please explain the basis for this determination. A5. This determination is based upon the fact that the normal piezo-metric level of the groundwater surrounding the Waterford plant is approximately 55 feet above the bottom of the base mat. This groundwater exerts hydrostatic pressure against the nuclear plant island structure of approximately 23.8 psi; this hydrostatic pressure is responsible for the groundwater seeping up through the
.- base mat. In the event that any radioactive contaminants are released during operatinn nf the facility, the hydrostatic pressure that is being exerted against the base mat would prevent those .
contaminants from leaking down through the base mat into the clay underlying the plant or aquifers located beneath the clay. A
- ,' This outcome is demonstrated by the results of the Staff's
~
evaluation of the. consequences of a postulated tank failure. performed during the S'taff's safety review of the Waterford . L operating license application and presented in section 2.4.6 of the f Staff's Safety Evaluation Report. In that analysis, the Staff evaluated the failure of the tank having the greatest potential for release to the environment of liquids containing radioactive materials. In that analysis, we assumed the existence of cracks in, the concrete base mat underlying the facility. As set forth in the SER, our analysis concluded that hydrostatic pressure would cause groundwater to flow upwards and into the nuclear plant island structure through the basa mat cracks, thus precluding the radioactive contaminants from leaking out. Q6. Assuming, hypothetically, that the hydrostatic pressure does not exist, would leakage of radioactive contaminants through cracks in the base mat result in contamination of the Mississippi River or of
- groundwater drinking sources?
A6. No. It should be understood that it is extremely unlikely that i hydrostatic pressure would not exist. Nonetheless, if we assume that there is no hydrostatic pressure and that a radioactive spill l occurs which is not cleaned up, liquids would be able to seep out through the cracks. However, as set forth in sections 4.3.2.2, 5.3.1.2, and 5.9.2.5(5) of the Final Environmental Statement, given (a) the very impermeable nature of the clay soils underlying the l facility, and (b) the fact that the silty sand layer at El -77 msl l w - - - . --- ,_.- - - - __ - _ . - . - - - - . _ _ _ , - . -
t = 4
- (Zone 3) is characterized by groundwater movement away from thit '
Mississippi River at all stages of flow, it is extremely unlikely that contamination of groundwater drinking sources or of the j i i Mississippi River would occur. Q7. Is the amount of groundwater seeping through the concrete base mat likely to increase with time? A7. Given the impermeable nature of the clay soils surrounding the plant, the groundwater level surrounding the plant should remain fairly constant. Accordingly, the amount of groundwater seeping through the base mat is not likely to increase, assuming that the cracks do not increase in size.
- 08. Does the discovery of cracking and water seepage in the base mat at Waterford Unit 3 warrant a reevaluation or modification of any conclusions reached in the Final Environmental Statement?
A8. No. I Rby@nd O. Gonzaleg Subscrib d and sworn to before me this day of November, 1983 O- Mer Notary Public My Comission expires: I eo .4 m 9
i .,- A.
- .. .',. f Raymond O. Gonzales
- Hydrologic Engineering Section 1
Environmental and Hydrologic Engineering Branch ", Division of Engineering Office of Nuclear Reactor Regulation Professional Qualifications l I am a Hydraulic Engineer in the Environmental and Hydrologic Engineering Bronce, i of the Diviston of Engineering, Office of Nuclear Reactor Regulation. ? I rec 6tved say fonnal educational training at New Mexico State University where I received a B.S.C.E in 1965. I also attended an eleven month training program
*- sponsored by the Board of Engineers for Rivers and Harbors of the Corps of i j Engineers in Washington, D.C. My consists of ' seven years as a Hydraulic Engine,experier.ce prior te joining NRCer (hydrology l Planner, and one year as a Construction Engineer, all with the Corps of Engineers
- in Albuquerque, New Mexico; San Francisco, California and Washington, D.C.
t l I joined the NRC in February 1978 as a Hydraulic Engineer. In this capacity, i I review and interpret the hydrologic and hydraulic aspects of applications ! for nuclear facility construction pennits and operating licenses. These j facilities ir.clude nuclear reactors, ursnium mills, fuel fabrication plants
- and low level. waste repositories. More specifically, I review the adequacy j of flood. protection designs of plants; determine the adequacy of safety related l water supplies, and evaluate the dispersion and dilution characteristics of
- 'surfaceand groundwater supplies; and aid in coordinating and developing bases
! for criteria and standards concerning the safety and environmental characteristics i of nuclear facilities related to hydrologic engineering. \ From 1975 to 1978 I was a Water Resources Planner with the Corps of Engineers j j in Albuquerque, New Mexico. I was responsible for managing planning studies i for flood control, irrigation, hydropower, water supply, fish and wildlife and recreation. In addition. I was responsible for coordinating study input from various planning disciplines including economists, hydrologists, designers and l environmentalists, and for preparing cost estimates for planning programs. 4
/
J Frcn1974to1975,IattendedanelevenmonthtraibingprogramwiththeBoard of Rivers and Harbors in Washington, D.C. This trai.ning was for the purpose
! of obtaining specialized knowledge of, planning principles and techniques l necessary for conducting studies of water and related land resource utilization.
!) Classroom work included courses in economics, hydrology, ecology and environmental . awareness. ! From 1973 to 1974. I was a resident construction engineer responsible for several ) .: Corps of Engineers water resources construction projects in New Mexico, Kansas
- t
! and Texas.
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Raymond O. Gonzales
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From 1966 to 1973, I was a Hydraulic Engineer with the Corps of Engineers in Albuquerque, New Mexico and San Francisco, California. During the early part
- of this period, (1966 to 1970) I assisted in hydrologic engineering studies ,
of Corps of Engineers projects in New Mexico, Colorado, Kansas, Texas and Northern/ California. iThis included collecting and analyzing hydrologic and meteorologic data for use in planning and design, estimating long-term water availability, determining hypothetical flood events for use in sizing structures such as dams, channels, and levee systems, and preparing portions of Hydrologic Engineering
" reports. In the last part of the period (1971 to 1973) I was Head of a Hydrology Section. In this capacity, I was ' responsible for planning, scheduling and assigning studies of water resources projects to engineers and technicians in the Section.
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a...* . gg) rW MEMORANDUM FOR: Sherwin E. Turk ,' Counsel for NRC Staff Office of Executive Legal Director FROM: John S. Ma, Structural Engineer Structural Engineering Section A Structural ami Geotechnical Engineering Scanch
SUBJECT:
WATERFORD 3 CONCRETE BASE MAT This is in response to your telephone request on February 14, 1984 to prepare comments and questions in connection with the GAMBIT newspaper. dated December 10, 1983 and F. L. Phearson's memo, dated December 15. 1975 for your meeting with NRC Region IV staf f. ) The GAMBIT newspaper stated that "... the engineers who came to trat conclusion (i.e. , tne cracks had no tnreat to the pt.clicI cic nc r-at; cut tne massive deficiencies in recorcs cetailing octentia'. fia-: in the construction of the foundation" This was a correct state.e : c m. assessment of tiie situation. -Tne Pnearson tre: o nas revivec m;. ;-igir,si hypothesis that localized porous zones due to improper construction exist 3 as stated in a October 17, 1983 memo from G. Lear to G. Knighton. That hypothesis was later abandoned because both the licensee (October 13, 1983 submittal) and NRC Region IV (J. T. Collins to D. G. Eisenhut, dated November 16, 1983) stated that the concrete base rcat was -properly constructed. , , The charges contained in both the GAMBIT article and Phearson's memo Are serious and must be dealt with carefully. "I have listed some comments and questions staff. in the enclosure' for your consideration in meeting with Region IV iq.. ' i Jcnn S. Ma, Structural Engineer l Structural Engineering Section A l Structural and Geotechnical Engineering Branch Division of Engineering ,
Enclosure:
As stated ' T cc: J. Knight G. Knighton G. Lear 3ff FREEuO: O/ :Nr UnmiiON D. Jeng , , , ACT RrQue.Sr
. -i. son p4g Pichumani gp-7; P..
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ENCLOSURE
- 1. J. T. Collins' memo, referenced in J. Ma's affidavit, stated that the concrete base mat was properly constructed. However, memos of inspector Hill and Davis, as reported in GAMBIT, stated ,that they found a broad range of deficiencies in virtually every record package examined and the situation demanded a complete review of all civil / structural records.
The Phearson's memo, if determined to be accurate, would substantiate a part of charges made by inspectors Hill and Davis. NRC needs to produce evidence to substantiate its claim that the concrete mat was constructec properly, or revise its position in the light of new information.
- 2. Presumably the Phearson's meme had nc:. been avaiiatie or ea-; .r t .:: . :: .-
by Region IV when the Collins' memo was preparet. W n e '. i s k ; i :. . . > assessment on the Phearson's memo?
- 3. Was the NRC inspector witnessing the concrete placement No. 499-2? Was placement No. 499-2 same as Block No.108 or 19? Was the NRC inspector qualified in the field of Civil / Structural (concrete) engineering? Did he agree with Phearson's memo? What kind of action did he take?
4. Has Region IV determined whether the charge that unqualified QC/QA inspectors were employed (second paragraph of the last column on page 27 of GAMBIT) is accurate? More specifically, are those inspectors qualified in Civil / Structural engineering? 5. Was the falsification charge on cadweld splices of reinforcing bars accurate (the last column on page 27 of GAMBIT)? FREEDOM OF INFUhmi 0N l ACT REQut.SI i SM 4ii t C h0 L
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- 6. Has the Region IV determined whether the cadweld splices were properly performed and inspected by qualified people?
- 7. What were the problems in the seven NCR's on QA deficiencies in concrete as mentioned in the last column on page 28 of GAMBIT and how were they disposed of?
8 What were the problems of soils, waterstops, cadweld splices, and the olacement of concrete as mentioned in the thir:: column on cage CT cf GAMBIT and how were they resolved? i FRE: DOM OF !NFORMATION ACT REQUEST - 1+- VST C/76e L_
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,E W ASHING TO N, D. C. 20555 ne 1 s m i
MEMORANDUM FOR: Sherwin E. Turk Counsel for NRC Staff . Office of Executive Legal Director FROM: John S. Ma, Structural Engineer Structural Engineering Section A
\ Structural and Geotechnical Engineering Branch
SUBJECT:
WATERFORD 3 CONCRETE BASE MAT This is in response to your telephone request on February 14, 1984 to prepare comments and questions-in sonnection with the GAMBIT newspaper, dated December 10, 1983 and F. L. Phearson's memo, dated December 15, 1975 g for your meeting with NRC Region IV staff. The GAMBIT newspaper stated that "... the engineers who came to that I conclusion (i.e., the cracks had no threat to the public) did not know e about the massive deficiehcies in records detailing potential flaws in the construction of the'toundation". This was 1 correct statement of my assessment of the situation. The Phearson memo has revived my original hypothesis that localized porous zones due to improper construction exist as stated in a October 17, 1983 memo from G. Lear to G. Knighton. That hypothesis was later abandoned because both the licensee (October 13, 1983 submittal) and NRC Region IV (J. T. Collins to D. G. Eisenhut, dated 1 November 16, 1983) stated that the concrete base mat was properly constructed.
% The charges contained in both the GAMBIT article and Phearson's memo are serious and must be dealt with carefully. I have listed some comments and /y questions in the enclosure for your consideration in meeting with Region IV staff.
r i- s (p[ John S. Ma, Structural Engineer Structural Engineering Section A Structural and Geotechnical Engineering Branch
} Division of Engineering f
Enclosure:
As stated 9
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cc: J. Knight " I '. j/[O' /p l ' G. nighton - W OF n'meiiVN D. Jeng ,7 f
/ 'jj ,
ACT REQUESI J. Wilson d& 3 8f 'f S'T R. Pichumani /f / .'I h jh. k ! J. Ma > 7 Ch
/ .
ENCLOSURE .
- 1. J. T. Collins' memo, referenced in J. Ma's affidavit, stated that the concrete base mat was properly constructed. However, memos of inspector Hill and Davis, as reported in GAMBIT, stated ,that they found a broad range of deficiencies in virtually every record package examined and the situation demanded a complete review of all civil / structural records.
The Phearson's memo, if determined to be accurate, would substantiate a part of charges made by inspectors Hill and Davis. NRC needs to produce evidence to substantiate its claim that the concrete mat was constructed properly, or revise its position in the light of new information.
- 2. Presumably the Phearson's memo had not been available or was not noticed by Region IV when the Collins' memo was prepared. What is Region IV's assessment on the Phearson's memo?
- 3. Was the NRC inspector witnessing the concrete placement No. 499-2? Was
' placement No. 499-2 same as Block No.10B or 19? Was the NRC inspector qualified in the field of Civil / Structural (concrete) engineering? Did he a' gree with Phearson's memo? What kind of action did he take?
- 4. Has Region IV determined whether the charge that unqualified QC/QA I
inspectors were employed (second paragraph of the last column on page 27 of GAMBIT) is accurate? More specifically, are those inspectors qualified
, in Civil / Structural engineering?- ,
- 5. Was the falsification charge on cadweld splices of. reinforcing bars -
accurate (the las,t column on page 27 of GAMBIT)? l
- FRte.vv.v, uc 3. . : ._ n.... . . ,o n l ; ACT REQutst 8% -M if C/~161
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- 6. Has the Region IV determined whether the cadweld splices were properly performed and inspected by qualified people?
- 7. What were the problems in the seven NCR's on QA deficiencies in concrete as mentioned in the last column on page 28 of GAMBIT and how were they disposed of?
- 8. What were the problems of soils, waterstops, cadweld splices, and the placement of concrete as mentioned in the third column on page 22 of GAMBIT and how were they resolved?
FREEDOM OF INFORMATION ' ACT REQUEST fy 4ff c.l761
- f
/~.f **%.,), UNITED STATES f ' , s-, q j j NUCLEAR REGULATORY COMMISSION WASHINGTON. O. C. 20555 , gg'/ j %,'d./
APR 6 M4 Docket No.: 50-382 APPLICANT: ' cuisiana Power and Licht Cercany FACILITY: Water #ord 3 con't: '
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SUBJECT:
f1EETING SUt'!%RY FOR LP&L's PRESENTATION OF 3ASEMAT ADECllACY AT NATERFORD 3 A reetine was held at 9:00 an on March 26,108- ?t Louisiana Pcwer 4 f.ich+ Corranv's n##4ces in 9ethesda, Maryland. The cur-'ose o' te ~eetinc bet'.veen LP&L, it's reoresentatives and the IJSNRC was to d scuss the desian, cons *.ruc*ica and dualv sssurance ascer.ts o' 'be %te #crd SES Ifnit 3 #cundatica ba! erat. The list o* a**encees 'or +he teet'ng is shown on Attach ent !. During the morning session, LP&L rea##ir ed their posi'4cn that-11 The basemat desien for Na*.e*#c rf 3 is adecua*.e, 21 The base 9at was develoced usino conserv.1tive desden cafte*49, 3' The cualf tv of -Se basemat constrection is adecua*.e,
- 4) The basemat will perform its intended function durinc olant operations, and
' 5) The Operating 1.icense for Waterford 3 should not be delaved because of cuestions related to basemat intecritv.
Slides used by LP&L during the presentation are included as Attachrent II. As part of the NRC Staff's review of the Water #ord 3 baserat design and *o facilitate LP&L's preparation for the . March 26th meeting, a list of 32 auestinns was orecared and t*ansmitted to LP&L. These cuestions are shewn on At'ac5 ment III. Discussions durino the afternoon session centered about LP&L's responses *o the NRC questions. A draft of LP&L's responses to the 32 cuestions are enclosed as Attachment IV.
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FREEDOM OF INFORMATION
-/ ACT RtQutSI hP y sv-Str g0 chu
e r - 2-The meeting was ad.iourned at 4:00 pm. Technical discussions were resumed the next :nornina at 9:00 am, March 27, 1984 at the Water #ord plant site, where a review of construction records followed a plant tour to observe the basemat cracks. Participants in the technical discussions at the plant site on March 27, 1984 are listed Attachment V. (llkis. 4
.Tt hes H. 'l*' ten, Den lnc*t'?.rmnar Licensire 3 ranch .'!n. 3 Division of Licensing Attachnents:
As stated cc: See next page FREEDOM OF !NFORMA t0N ACT REQUEST
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MEETING SUMMARIES 4 MR6 @ Docket File (50-382) NRC POR , local POR PRC System NSIC LB!3 Reading J. Lee Project Manager J. Wilson Attorney, OELD
. G. W. Knighton -
W. Lovelace (Caseload Forecast Panel Visits) OPA (Caseload Forecast Panel Visits)
;;RC PARTICIPANTS AWang DCrutchfielo
,4_I a vn a JITapia DCJeng Glear '
JSMa JTChen WACrossman - STurk \j LHeller MKarman MWPeranich '
?Kesnisnian JEGagliardo SSarma PCWang MReich FREEDOM OF INFOftMATtON ACT REQUEST
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e e Waterford 3 Mr. R. S. Leddick Vice President - Nuclear Operations Louisiana Power & Light Company 142 Delarende Street New Orleans, Louisiana 70174 W. Malcoln Stevenson, Esq. Regional Adninistrator - Region IV Fenroe & l.eman U. S. Muclear Regulatory Connission 1432 Whitney Ruflding 611 Ryan Plaza Drive New Orleans, Louisiana 70130 Suite 1000 Arlington, Texas 76012 Mr. E. Blake Shaw, DittNan, Dotts and IrCwDridCe 18CO M Straet, '".i Washingtnn, DC 20036
,jr., Gary L.,Gecesch
- , oavou -oao
*%w Orfeens, Louisf=na 70116 dr. F. J. Grunnond Project Manager - Muclear Lcuisiana Dower and Light Ccrpany 142 Delarende Street New Orleans, Louisiana 70174 Mr. O. B. Lester Prnduction Engineer Louisiana Power A Light Company 142 Delarcrde Street New Orleans, Louisiana 70174 Luke Fontana, Esq.
824 Esplanade Avenue l New Orleans, Louisiana 70116 Stephen M. Irving, Esq. 535 North 6th Street Baton Rouge, Louisiana 70802 l Resident Inspector / Water #ord NPS l P. O. Box 822 l Killona, Louisiana 70066 Dr. D. C. Gibbs Middle South Services, Inc.
- e. O. Box 61000 New Orleans, Louisiana 70161
- l l
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ATTACHMENT I LP&L Presentation on Basemat Adecuacy List of Attendees Reoresentatives from Louisiana Power and Licht Company R. S. Leddick K. W. Cook T. F. Gerrets R. F. Burski W. A. Cross
- 8. P. Brown
- 9. C. Gr4cos
- 3. 'd. Churchill (S' raw, itt. man, Fot s and ~rnwbridee'.
J. Gutierrez (EBASCO) ' J. Costello (EBASCO) A. H. liern (EBASCO)
*i. Wittich ,'E3A5CGi P. C. f.u (ESASCO' G. Harstead (Harstead Engineering Asscciates)
A. V. duBouchet (Harts +ead Enoineerina Associates) A. I. Unsal (Hartstead Engineering Associates) Decresentatives from the U.S. Nuclear Ceaulatory Cornission D. Crutchfield J. H. Wilson L. Lazo J. I. Tapia D. C. Jeng G. Lear J. S. Ma J. T. Chen W. A. Crossman S. Turk
. A. Wang L. Heller N. Karman g M. W. Peranich P. Keshishian J. E. Gagliardo l
S. Sharma (Brookhaven National Lab) P. C. Wan (Brookhaven National Lab) - M. Reich Brookhaven National Lab)
8 C ATTACHMENT II SLIDES USED BY LP&L CURING MARCH 26:n PRESENTATION e ' * * * * * * -~~--m . . . - _ , _ , _ _ _ _ _ , _ _ _ , _ , _ _ _ _ l
LP&L POSITION RECARDING WATERFORD 3 BASEMAT OUALITY
- 1. The design of the basemat has been reviewed internally and externally (by NRC) many times over the course of the project. The adequacy of the design has been confirmed throughout these reviews. Most recently the design has undergone additional independent review by Harstead Engineering Associates (HEA), a firm which is well qualified in civil engineering and construction matters. HEA confirmed the design adequacy.
- 2. Design of Nuclear Safety Related structures, systems, and components is based on very conservative criteria. Design loads on the Waterford 3 basemat are developed using such conservative criteria. For purposes of assurance that the base =at is capable of vichstanding the design loads, and to account for reasonable construe.icn variations, additional conservatism is incorporated into the design - extra reinforcing steel is placed and cadwelded (as necessary) and the design concrete mixture is purposely established so as to result in conservative in-situ ecmpressive strength.
- 3. Construction records have been reviewed multiple times. Record deficiencies have been programmatically dispositioned and the satisfactory construction of the basemac is confir=ed.
Deficiencies indicated in certain =emoranda have been addressed through the programmatic requirements of the Waterford 3 QA Program problem reports, including Non-Conformance Reports and Stop Work Orders and were properly dispositioned. Adequacy of construction of the Waterford 3 basemat has also been addressed by Harstead Engineering Associated (HEA), a firm which is well qualified in civil engineering and construction matters. HEA, based on a review of construction documentation and on observation of the basemat itself, concludes that the construction of the basemat is adequate. On these bases LP&L concludes, and is confident, that the Waterford 3 basemat j has been properly designed and constructed and vill satisfactorily perform its function in service, and that the Operating License should not be delayed for I reasons related to basemat integrity. l t l
LP&L PRESENTATION TO NRC MARCH 26, 1984 WATERFORD 3 SES Common MAT INTEGRITY I. INTRODUCTION R. S. LEDDIc:< (LPSL) II. COMMON MAT DESIGN J. EHASZ (ESASCO) III. CONSTRUCTION /QA T. F. GERRETs (LP&L) IV. INDEPENDENT REVIEW G. A. HARsTEAD (HEA) V. LPSL POSITI0tl R. S. LEDD!cx (LPsL) O
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a , GI ic:<!A FCR MAT CESICN CDG o Cctrpensated (floatirg) Foundation design to minimi:e founcation settlerrants durirg operation EMSIC LE/OltC e Earthquake - 0.1g acceleration: greater than any earthquake experienced or excected in the regicn e Soil Prcperties - varied to force peak response of the structure to earthquake loadirg e Lead Factors - conservative load factors utill:ed MAi c <!ALS o Concrete 4000 psi e Reinforcirg Steel 60,000 psi e All Non-exotic, Easily Cbtainable Construction ueterials t ENGINt=nED SECLEG CF CCNSTRUCTICN i e Excavation, concrete placerrent, backfill and dewatering controllec - with instrunentation to trenitor perfonrance i f l l l l
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. Figure LOUISIANA POWER & LIGHT CO* DESIGN CCNCEPT CUTT !NE . 2e-102 Waterford Steam E!.ctrie Station
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9 e 1 . EXIIIBIO B
CRITERIA FCR t.RT CESICN CDM o Ccnpensated (ficatirg) Fot.ndation design to minimize fcuncation settlements during cperation EASIC LC/OlBC e Earthquake - 0.1g acceleration: greater than any eart.Wke ex;:erienced or expected in the regico e Soil Preperties - varied to force peak response of the structure to earthquake loading e Lead Factors - conservative load factors utilized A%TERIALS e Ccncrete 4000 psi e Reinforcirg Steel 60,000 psi e All Non-exotic, Easily Cbtainable Construction Materials ENCINEERE) SELENG CF Cf6mUCTICN e Excavation, concrete placement, backfill and dewatering centrolled - with instrumentation to trenitor perfonmnce 8
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TTL'E C2EERVATIS\t IN MAT EARTFCDWE - e twice the traxim.m expected event (.109 used vs. 05g calculated) SOIL PCPERTIES - e shear troculus 2i tirres calculated value LCAOING - e tEC defined Icad factors REINFUC!tC IN EXCESS Cf: NEED - e actual reinforcirg is 1.28 tirres calculated need TOTAL NELE TRLE F/CTCR CF SAFETY
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Cundixutitun/wA i 0 8ASEMAT QUALITY EFFORT O BASEMAT MAP 0 3ASEMAT CONSTRUCTION SLIDES 0 PLACEMENTS 6, 1 AND 2 0 FACTS
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LOUISIANA POWER a LIGHT COMPANY WATERPORD SES UNIT 3 J. A. JONES CONSTRUCTION COMPANY 0 APPROVED QA MANUAL AND IMPLEMENTING PROCEDURES 0 INSPECTIONS PERF RMED AND DOCUMENTED BY QUALIFIED & CERTIFIED PERSONNEL: CADWELDING PREPLACEMENT C0tlCRETE PLACEMENT POST PLACEMENT EBASCO SERVICES, INCORPORATED ~ 0 APPROVED QA MANUAL AND IMPLEMENTING PROCEDURES EBASCO QUALITY CONTROL 0 IflSPECTIONS PERFORMED BY QUALIFIED & CERTIFIED PERSONNEL 0 PARALLEL OVERVIEW INSPECTION OF J. A. JONES FOR THE FOLLOWING ACTIVITIES: CADWELDING PREPLACEMENT CONCRETE PLACEMENT POST PLACEMENT 0 CONCRETE TESTING BY EsASCO QC SLUMP AIR CONTENT , TEMPERATURE UNIT WEIGHT EBASCO QUALITY ASSURANCE O REVIEW OF CONTRACTOR QA PROCEDURES 0 AUDITS OF CONTRACTOR QA PROGRAM IMPLEMENTATION
-0 REVIEW AND PROCESSING OF NONCONFORMANCE REPORTS LP8L QUALITY ASSURANCE J APPROVED QA MANUAL AND PROCEDURES 0 AUDITS OF ESASCO AND CONTR' ACTOR QA PROGRAM IMPLEMENTATION O SURVEILLANCES OF ESASCO AND CONTRACTOR QA PROGRAM IMPLEMENTATION G . =m.m.,. ,.,
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WATERFORD 3 SES BASEMAT PLACEMENT MAP
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PLACEMENTS 6, 1, AND 2 o PLACEMENT 6 (12/2/75) . o FIRST CLASS I PLACEMENT 0 LARGE " INSPECTION" FORCE o STARTUP PROBLEMS 0 PROBLEMS. CORRECTED IN-PROCESS o ESASCo AND LP&L QA REPORTS (2) DATED 12/2/75 o- MEETING 12/5/75 (LP8L, EsASCO, CONCRETE CCNTRACTOR) TO DISCUSS AND RESOLVE PROBLEMS. O PLACEMENT 1 (12/8/75) o SECOND CLASS I PLACEMENT o LARGE " INSPECTION" FORCE o PLACEMENT CONDUCT IMPROVED o PLACEMENT 2(1$/11/75) 0 THIRD CLASS I PLACEMENT o LARGE " INSPECTION" FORCE o PROBLEMS RETURNED, CORRECTED IN-PPOCESS o LPal QA SURVEILLANCE REPORT DATED 12/11/75 o LP&L STOP WORK ORDER No. 1., DATED 12/16/75 6
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, f TOTALBASEMATCADWELDS - APPROXIMATELY 3673
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( s TOTAL IENSILE IESTS PERFORMED (PRODUCTION TESTS) 81 lt , 95,397 PSI AVERAGEfIENSILE STRENGTH ' HIGHEST IEilSILE STRENGTH 107,051 PSI LOWEST TENSILE STRErl1TH 80,750 PSI MINIMUM AccEPTAsLE TEnsttE STRENGTH 75,000 PSI s Y s I t
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l CONCRETE COMPRESSIVE STRENGTH BY PLACEMENT e PLACEMENT 28-DAY PLACEMENT N0, 28-DAY STRENGTH NO, STRENGTH 1 5771 10B 5632 2 5675 11A 5150 3 5748 12A 4916 4 5466 13A 4871 5A 5554 luA 4861 5B 5568 15 4658 6 6094 11B 5u57 7A 5335 12B 5326 7B 5844 13B 5355 8A 5212 14B e 5386 8B 5193 16 0826 9A 5437 17 5125 9B 5644 18 4924 10A 4722 19 4769 a h e e _.... . . - - . . _ ~ * - - r'- w, -- - - ,r,,. ,.---r- . , - - - - - ,--. -, p-. ,,
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s BASEMAT CONCRETE TOTAL CONCRETE 46,000 YD 3 NUMBER OF MONOLITHIC PLACEMENTS , 28
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Y A I ConcweTE TESTIns : - o CoMpaESS!vE STRENGTHS 464 TESTS (SETS OF 2)
~
*o 5304 PSI
~
AVERAGE (TOTAL MAT) o LOWEST (oF ANY SET) 4065 eSI o HIGHEST (oF ANY SET) '.'/ 6905 PSI ,
~
6106 PSI l o , HIGHEST PLACEMENT AVERAGE o LOWEST PLACEMENT AVERAGE 4698 PSI o MINIMUM. ACCEPTABLE 4000 PSI ,
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o OTHER TESTS (StuMPe AIR, unit wElcaT, TEMRERATuRE) o APPRoXIMATELY 1000 TESTS g
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BASEMAT CRACXING 0 _ CRACKING o HAIRLINE CRACKS IN BASEMAT 0 INITIALLY DISCOVERED AND DISPOSITIONED In 1977 0 ADDITIONAL DISCOVERIES IN 1983 0 EVALUATION e ENGINEERING EVALUATION PERFORMED IN 1977 e ENGINEERING EVALUATION IN 1983 0 SPECIFIC CORRECTIVE ACTION (1977) e CHIPPED TO SHALLOW DEPTH e EP0XY PATCH 0 GENERIC CORRECTIVE ACTION e NONE REQUIRED - SUCH CRACKS ARE AN EXPECTED PHENOMENON O INDEPENDENT ENGINEERING Ev4LuArt0N_ e HARSTEAD ENGINEERING ASSOCIATES ~ ~
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INDE?EN0t:u enutnt:ntne e m um tun 0F BASEMAT CONCERNS 0 PARSTEAD ENGINEERING ASSOCIATES REPORT 8304-1, SEPTEMBER 19, 1983 0 EVALUATED EFFECTS OF CRACKS ON BASEMAT IflTEGRITY 0 MAPPED BASEMAT CRACKS (CRACKS WERE SO SMALL AS TO BE UNDETECTABLE BY STANDARD INSPECTICN TECHilICUES) 0 REVIEdED SIGNIFICANT EVENTS DURING CONSTRUCTION O STOP WORK ORDER NO. 1 0 PLACEMENT DIF:ICULTIES - PLACEMENTS 103 & 19 0 REVIEdED SETTLEME?tT PLAN A?ID DATA 0 EVALUATED CORROSION POTE?iTIAL 0 EVALUATED STEEL CONTAINMENT VESSEL STABILITY 0 PERFORMED A GENERAL REVIEW OF BASEMAT ENGI? LEERING DESIGN AND CONSTRUCTION O HARSTEAD ENGINEERING ASSOCIATES REPORT 8304-2, OCTOBER 10, 1983 0 PERFORMED AN INDEPENDENT STRUCTURAL ANALYSIS OF THE BASEMAT. O HARSTEAD ENGINEERING ASSOCIATES RE? ORT 8304-3, JANUARY 9, 1984 0 REVIEW OF CutlSTRUCTION DOCUMENTATION TO EVALUATE WHETHER DESIGN OBJECTIVES WERE MET y _*wgm.- e.,a m..e-..---
"THE FOUtlDATI0f! CONCEPT IS AN IfiGEllIOUS SOLUTI0fl 0F THE SITE PROBLEM IN MEETING THE SAFETY CRITERIA ESTABLISHED FOR THE NUCLEAR SAFETY RELATED STRUCTURES."
2 HEA REPORT 8304-1 SEPTEMBER 19, 1983
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4 "IN CONCLUSION, THERE IS NO EVIDENCE OF ANY I FROCESS WHICH HAS BEEit GR COULD BE DETRIMEliTAL TO THE STRUCTURAL INTEGRITY OF THE FOUNDATION MAT "
- HEA RE? ORT 8304-1, SEPTEMBER 19, 1983 4
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"IT IS OUR CONCLUSION THAT THE DESIGN OF THE MAT IS EXTREMELY CONSERVATIVE, WHICH, UNDER THE CIRCUMSTANCES IN WHICH THE DESIGN WAS CARRIED CUT, WE CONSIDER PRUDENT AND JUSTIFIAELE.
THEREFORE, WE SEE NO NEED FOR ANY REMEDIAL MEASURES OR THE NECESSITY OF ADDITIONAL ANALYSES." HEA REPORT 8304-2 OCTOBER 10, 1983 t 0 l t
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"0VERALL REVIEW 0F THE CONSTRUCTION RECORDS FOR THE 3ASEMAT SHCW THAT THE DESIGN OEJECTIVES WERE ACCOMPLISHED. THEREFORE, NO MODIFICATIONS ARE NECESSARY TO THE CONCLUSIONS REACHED PREVIOUSLY IN HEA REFORTS 8304-1 AND 8304-2 REGARDING TO THE STRUCTURAL ADEQUACY OF THE BASEMAT."
- HEA RE?cRT 8304-3, JAtlUARY 9, 1984 O
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. _ 7_ _7 _7 USNRC STAFF QUESTIONS l
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OUESTIONS ON WATERFORD 3 BASEMAT 3/26 MEETING IN BETHESDA Allegations recently reported in a GAMRIT newspaper article and in staff investigations concerning the GAP 8IT article have lead to the assicrrent of additional reviewers tn evaluate the base nat adeouacy. This transmi'tal is a composite set of Ouestions from the reviewers, and is intended to faciliate LP&L's preparation for the meeting on March 26, 1984 in Bethesda. Mcw renv ncncon#crnance rarcrts were issuad en '9e baserat? 'ov -ary -
. relate to poor concrete placement practices? What were corrective actions taken? Provide ,iustification to substantiate your cosition that these practives could not have lead to tha davelnorent nf cracks or localized pornec . tares which may be taa ceuse ed water a avsica.
- 2. Ubere was water table when 1977 cracks were discovered?
- 3. Is there'any evidence of convex curvature due to r4ne wall loading?
4 Provide X-Sectirn maps nf nat flexure over time period zero to present.
- 5. Provide complete documentation of groundwater control and #aundation
' heave fren the start of dewatering until the present tir.e. Include the historv of soil excavation and backfill bareath the mat.
- 6. Provide the 'cundation leading history under each block during construction of the mat and walls. This should include the distribution of pressure under each block. Include the location and history of loads due to backfilling adjacent to foundation blocks.
7 Provlqe complete settlement history for each block from initial pouring until the present time.
- 8. Analyse and discuss the relationship of the above variables (Os 5-7 abeve) on the history of all observed mat cracks and leaks.
- 9. What basis is there for accepting the adecuacy of construction of the #irst 3 blocks?
- 10. If engineering judgement was involved in accepting those blocks, what was the basis for that judgement? Where is it documented?
- 11. What corrective actins were necessarv for the first 3 blocks? What corrective actions were taken, and provide spec'ifics for each pour? Where 3re these actions documented?
- 12. Were any cracks discovered in 1977 outside of the ringwall? Provide decurent-tation. If none were discovered cutside ringwall why not infer that these three blocks were poorly constructed?
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- 13. Did Kominsky recopy illegible cadweld records? Under whose direction?
Why? What happened to the original records? 14 Provide summary of actions taken following Hill's presentation of OA
- deficiencies. Provide detailed report on document review urdertaken and all results.
- 15. Provide LP&L's evaluation of adecuacy of Harstead's third report.
Does LP&L assert that it represents their views as well?
- 15. Provide ereci'ic basis for Har-+aad's cerclusden *N,* 'he s~:cre.tatinn rooiens cc rot a##ac* their orior conclusien as 50 base-at's st-aac'".
What documents did Hartstead review? What did he icok at? Ddc he see the Phearson-Brigo memo? Hill's NCR's? Other MCR's?
. Provide cieeerant al set-tenert con curs #re d an- n cer'ocs, s a -'ag i
'rce ear?y 1977 to present.
- 18. According to the settlement contnurs shewn in figure 2.5.118 *he curvature is concave downward in both directions. This imolies cracks on the top surface in both directions which would rot penetrate t.11 the w?y through.
In view o' the above why did the water seeo thru? Why dosen't the crack pattern match the given differential ep*tlement? It is possible that there are localized convex surfaces on the nat which are not shown in the figure (tha grid is cuite roughl?
- 19. Please provide all soil properties (re. results of soil tests, reports confirmed compression test results,' boring records, shear modulus etcl.
- 20. Provide all concrete propertv data, rebar data, placement data lie also cetailed as built drawings of mats).
- 21. Provide any revised calculations that include settlement ef#ects.
- 22. Is the Phearson memo accurate? What kind of actions has LP&L taken to respond to and resol.ve his allegations?
- 23. Memos of inspectors Hill and Davis, as reported in GAMBIT, stated that they found a broad range of deficiencies in virtually every record package examined and the situation demanded a complete review of all civil /
structural records. What is your response to this allegation?
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- 24. GAMBIT reported that there was falsification on cadweld splices of reinforcing bars. What is LP&L's response to this allegation?
- 25. What were the problems in the seven flCR's on QA deficiencies in concrete, as mentioned in the last column on pace 28 of GAMBIT, and hcw were they disposed of?
- 26. What were the problems of soils, waterstops, cadweld splices, and the placement of concrete, as mentioned in the third column on page 22 of Gambit, and how were they resolved?
- 27. On the allecations described ir ?Fearson's memo and tha r-prhi , ar .icie reflect generally what happened during the construction of the mat? If yes, how would these non-conformarce of QA/0C requirements s "ect the structural intecrity of the mat? If not, identify those allpostinn which ara na'aundec and 9e besie mereor.
- 28. In light of the allegations, documented NCRs, and CA/0C deficiercies, what has LP&L done or what does LP&L intenc to do in order 'o resolve the allegations and deficiencies?
- 29. Does maintain that the mat possesses adecuate capability to resis the design loads and confirm to the criteria commited to in the FSAR dasoite all the deficiencies and allerations listed? IV yes, provide the supporting technical basis. If not, propose specific means tc resolve then and thus render the mat acceptable to the staff.
In any case, the "as-built-nat" should be shown by tha applicant, if feasible, to maintain adequate safety margins to perfom its safety function and maintain its structural integrity. A quantitative demonstration of the "as-built" mat caoacity, includinc aooption of test, monitoring and strengthening programs, if needed, should be provided for staff review.
- 30. What is LP&L's technical rationale for explaning what has happened (including, water seepage, potential throuch-thickness cracks, predominently one-way cracks within containment reginn, uneven settlements, etc) to the mat? What monitoring program (s) has been implemented is underway? What are the results of these programs? Did the monitorino data show that both the cracking and water seepage problems have stabilized and there is no sign of continued degration? What improvements, could be applied to the on-going programs?
- 31. .,se there any known voids of some significant size to affect the nat structural integrity? If'yes, what are the sizes (best estimatesi and extent of these voids? What is LP&L's suggested diposition to the issue of voids. If no disposition is needed, what is the technical basis?
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- 32. Conservatively assuming the existence of extensive through-cracks o# the mat, assess the impact of the presence of water on the long-term stuctural integrity of rebars and mat capacity. Also assess the same impacts due to other potential corrosive elements, f
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ATTACHMENT IV LP E DRAFT RESPONSE TO USNRC QUESTIONS 0
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- 1. a) How many nonconformance reports were issued on the basemat? b) Epv c ,
many related to poor concrete placement practices? c) What were corrective actions taken? d) Provide justification to substantiate your position that these practives could not have lead to the development of cracks or localized prous zones which may be the cause of water intrusion. Response: la) NCR's - 106 (See Attachment "A") DN's - 46 (See Attachment "B") DR's - 42 (See Attach =ent "C") Response: lb) NCR's - 7 (Place =ent Practices) DN's - 42 (1 on Placing Practice)(4 on Cracks)(37 on Concrete Trucks etc.) DR's - 22 (Voids) NCR (See Attachment "A") DN's (See Attachment "B") DR's (See Attachment "C") Response: Ic) NCR's - See Attachment "A" DN's - See Attachment "B" DR's - See Attachment "C" Response: Id) I These practices could not have led to the development of cracks or localized porous zones which may be path of water incrusion because the
, deficiencies discovered were all repaired and the practices which led to the deficiencies were corrected.
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i i I. Response: la,bac ATTACHMENT "A" 4 NCR's Written Against Common Foundation Mat Placement Njl NCR0 2 10 Curing temps low 1 day - Accept as is per cylinder breaks and concrete type only requires 3 days of cure 7A 14 Nelson stud brcken off place - place rajected and replaced 4 15 Nelson stud broken off place - plate rejected and replaced 7A 16 #11 bars too long - accept as is 10A 17 Rebar bent - replaced 7A 18 Rebar bent during construction - replaced 4 19 Insufficient concrete cover - area excavated as required 5B 26 Portion of forms removed early - compressive strength and curing acceptable as is 8A 43 Rebar does not have proper projection - replaced SA, 9A 45 #9 dowels misplaced - replaced or bent to design location SA 49 8 #11 bars bent - replaced 7A, 13A 51 2 #11 bars bent - replaced
, 10B, 113 52 Rebar misplaced - replaced 10B 61 (Minor cut) Waterstop - bulb not affected - accept as is 10B 63 1 #6 bar misplaced - replaced l 11B 64 Bolt bent (minor) - accept as is 11B 65 Bolt bent - replaced 14A, 12A 66 Rebar misplaced - accept as is 10B 69 (Minor) Nicks in rebar - accept as is 8B 74 2 bars ' missing', bent - replaced Ring Wall 76 Resteel clearance to form face - change configuration , 11B 78 2 Bars ak #A201 misplaced - moved to correct area 13B 79 1 #8 Rebar 45' out of plumb - replaced 13B 80 1 #9 Rebar 45' out of plumb - replaced 11B 81 1 #9 Dowel missing - replaced 11B 82 1 #8 Rebar misplaced 5" - accept as is 11B 83 1 #9 Rebar misplacc.d 6" - accept as is 7B 84 Rebar bent - cut off and cadweld back 11A 85 Rebar bent - cut off and cadweld back i
11B 87 Rebar - inadvertently cut off - cadwald back
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4 l Response: la,b,e ATTACHMENT "A" (cont'd) l i 12A 89 Rebar - linear indications - effective area insignificant - use as is 19 92 Grout deposited - concrete placed on top and consolidated - use as is - the grout has same 28 day strength 19 93 (SCD #1) (DN-C-62) Poor placement practices - concrete removed - area repaired 1 95 Surface allowed to dry for short period of time - accept as is -
} visual inspection performed.
3 96 Cure temps low 4th and 5th day - minor use as is 1,2,3,4, 97 Cadweld sampling not fc11 owed - engineer eval - cast results etc. SA&B,6,7A&B accept as is 13A 98 11 cadwelds made af ter reject - engineer eval. and QC visual inspection - use as is 19 102 '4rong bolts installed-bolts are same size, only longer-use as is 15 103 1 #10 dowel missing - replaced 10B 104 2 #11 bars cut - (minor) due to insignificant reduction in cross-sectional area - use as is 9B 106 Low air - engineer evaluated - average 4.5% 28 day 5660 psi and placement method - accept as is i 9B 107 1 test interval missed - engr evaluation - 28 day 5660 psi - accept as is 7B 108 Low air - engr evaluated - average 4.6% and 28 day 5601 psi and
, placing method - use as is
- 1 109 Low air - engr evaluated - average 4.7% and 28 day.5748 psi -
accept as is f 1 110 Mixing revs. concrete tests not performed at required intervals - engr eval. 28 day 5748 psi and placing method - use as is 7A 111 DN-C high slump, DN-C-130 - concrete test not performed at required intervals - engr evaluated - accept as is (28 day 5335 psi slump average 3.6) SB 113 High air w/ average of 4.5% - accept as is 5B 114 (DN-C-134) Test sample frequency (DN-C-147) Additional ad ;ing revs - 28 day sevength of 5601 psi and placement method (. . cept as is) (DN-C47,48,49 and 52) SB 115 Truck discharged after 60 min. - FCR-CH acceptable SE 116 (DN-C-46) high slump - evaluation performed by engr-accept as is 4 122 1) Concrete placed w/out required mixing revs.
- 2) Omission of test data - engr evaluated - 28 day 5441 psi, average air 5.3%, and placement method DN-C-65,67,69,70,73675,76,80,121 and 72
4 Response: la,b c i
"A" (cont'd 1)
. ATTACHMENT l
6 123 1) Conflicting test data
- 2) Omission of test data - engr evaluated - method of placement and 28 day 6128 psi DN-C74,77, and 79 DN-C accept as is 6 124 Exceeded mixing count - high slump - accept as is - 28 day 6128 psi and method of placement 6 125 1 hr time limit for concrete discharge - FCR 83 - covers this -
compresive strength average 6128 psi 19 145 Nicks in resteel - minor use as is Void in mat - pour back 19 148 3 core holes repaired w/ cut proper documentation - QA/eng: eva'. l use as is - corrective action retraining and new procedure 12A 151 Resteel missing - replaced s 15 166 Resteel #4 dowels missing - replaced 10E 178 Rasteel nicked - accept as is N/A 181 1 #6 dowel misplaced 8 inches - accept as is 15 187 #4 dowels missing - replaced 19 -242 Resteel cut - replaced 19 491 Repair not done correctly - removed and replaced 3 112 Unit we. test data omitted - strength high and replacement method acceptable - use as is 12B 94 1 #6 dowel does not have min cover - OK use as is 1 127 1) Test data omitted or not taken at right intervals
- 2) Low mixing intervals - engr evaluated - 28 day 5748 psi and i placing method
( 1 128 High and low air concent - ave 4.6% - 28 day 5748 psi and placing methods - use as is 24 High air - engr eval - average air was 5.0% this along with method of placement and consolidation would assure d) durability l requirements i 25 High slump - engr eval - accepted as w/c ration, unit weight and strength would meet the specified requirements. 499-4 29 1 truck high air '- engr eval - next truck was 6.42 all 21 others j taken were acceptable j
'2 30 Concrete discharge 2 min af ter specified time - engr eval '--
. placement time did not exceed the 1 hr overall time limit i I l \
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I Response: la,b,c ATTACHMENT "A" (cont'd 2) 3 32 Mixing rev count not recorded - engr eval - visual observations
- and remarks on test record S02-2 33 2 tickets low air - engr eval - average for placement 4.9% and l method of placements and consolidation would assure acceptance 2 34 Discharge time not recorded - engr eval - 72 min.. batching circle would result in =seting 60 =in. delivery ti=e require
- ents S02-3 35 Low air (2 cickats) engr eval - average 4.7 this with (ete same as below)
S02-2 36 (2 tickets) low air - engr eval - air average 4.9%. This with the
=ethod of place =ent and consolidation assures durability req =ts 2 37 (1 cicket) high slump - engr eval - use as is based on unit weight and strength data 10B 39 Rain in placement concrete placed improperly - engr evaluation -
- repair, core sample and compressive strengths 10A 40 1 cicket high air - use as is - engr eval - air 5.5% average in i placement - method of placement and consolidation.
, 10A 41 Test freq - use as is - engr eval 7 day 4010 and 3530 psi and j slump and air consistant 131 Test freq - see #137 , 132 Batch info see #137 130 High slump see #137 138 Air and slump high - use as is see #137 139 Test freq - see #137 137 Testing frequ - eng and QA use as is - corrective action see me=o ! from W. C. Griggs. 11B 141 High air and no tests or cylinder taken at the right intervals - l use as is - corrective action u/a memo from W. C. Griggs ! N/A 146 Specific gravity - fine aggregate engr eval - minor deviation and cylinder breaks use as is 11B 174 DN-C-113 High slump - engr evaluation - 28 day 4870 psi isolated incident - accept as is ALL 7154 Curing - engr eval - use as is ALL 7150 QV inspectors carts - QA eval - use as is ALL 7151 QV inspectors eye exams - QA eval - use as is
- ALL 7152 QV inspectors eye exams - QA eval - use as is ALL 7153 Curing - engr eval - use as is t
ALL 7149 - QV inspector carts - QA evaluation of exp/ training use as is l 1 sw. o . .em e. . w w y- w === rye--*---yy -----+ y- - -~w------------T-y y- - - - - ----n- ,-- -- ---e *,wm* -*-*w-7y--J- w- e t- en, me-ww---
P Response: la,b c ATTACHMENT "A" (cont'd 3) s ALL 7353 Mix designs - engr evaluated (use as is have FCR's) ALL 7353 Concrete mix design - eng eval - use as is have FCR's) 1 ALL 7154 Mixing cura dates - eng eval - use as is ALL 7153 Missing cura dates - eng eval - use as is based of weather te=p. ALL 7152 No eye exas - eng eval - as is based en previous certs ALL 7151 No eye exam - eng eval - use asis /all have eye exam in cert. package now ALL 7150 No inspection certion file - eng eval - use as is based on exp end ALL 7149 Inspected prior to carts - eng eval - use as is based on prior exp/ training and successfule completion of training 7B 31 Air content of concrete - eng eval - use as is based on overall air content 4.7% j S02-4 12 One truck low mix rev connt - eng eval - use as is - letter en concrete drum revoluation S04-16 414 Concrete void - engr eval - chip out and replace 503-19 341 Concrete coating prior to placement of repair - engr eval - remove and replace CFS 273 Resteel misplaced - engr eval - add resteel BASE 6212 Concrete cracks - engr eval - use as is - based on findings there MAT RAB is no stability or corrosion problems I ALL 6245 Cadwalds (auchenticity of signatures or initials - N/A for
- cracking in CFM ALL 6234 Cadwelding - N/A for cracking in CFM ALL 7481 Cadwelding - N/A for cracking in CFM S02-4 11 High slump - engr eval - use-as-is - new test taken on cruck, found acceptable - people re-instructed i..,.... .- . ... . . . . -.
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Response: la,b.c ATTACHMENT "B" Ebasco Base Mat DN's Where an NCR was not Initiated Date DN# Placement # Description C.A. 11-19-75 C-5 499-502-3 Rebar offset Moved to correct location 12-10-75 C-7 499-S02-6 Cracks & rockpockets Chipped out & infzca repaired 12-18-75 C-12 499-502-1 Cracks in face Chipped out & repair 12-16-75 C-13 499-S02-2 Cracks in face Chipped out & repair 1 01-08-76 C-27 499-S02-6 Cracks & rockpockets Chipped out & i inface repair
! 02-03-76 C-55 499-502-7B Water stop left Repaired 02-10-76 C-61 499-502-10B Misplaced batch tickets Accept-as-is and no records on concrete discharge 02-10-76 C-62 499-S02-10B Excessive time on truck Accept-as-is 02-10-76 C-63 499-S02-10B Excessive ti=e on truck Accept-as-is 02-10-76 C-65 499-502-10B Excessive time on truck Accept-as-is 02-10-76 C-72 499-S02-6 Low air Accept-as-is 02-10-76 C-78 499-S02-6 Excessive mixing Accept-as-is 03-09-76 C-92 499-503-11B 011one rebar Rebar cleaned 499-S03-13B 03-22-76 C-105 499-S03-13B Testing time Use-as-is 03-22-76 C-106 499-503-13B Low air Accept-as-is 03-22-76 C-107 499-S03-13B Testing Frequency Accept-as-is 03-22-76 C-108 499-S03-11B Testing Frequency Accept-as-is 03-22-76 C-109 499-S03-11B Lov air Use-as-is 03-22-76 C-114 499-S02-5A High air Use-as-is 03-22-76 C-115 499-S02-5A Added water twice Use-as-is 03-22-76 C-116 499-S02-5A ' Added water Use-as-is 03-22-76 C-117 499-S02-5A Recording error Use-as-is 03-22-76 C-118 499-502-5A Recording error Use-as-is
I Response: la,b.c ATTACEMENT "B" (cont'd) Date DN# Placement $ Description C.A. 03-22-76 C-119 499-S02-5A Recording error Use-as-is 03-22-76 C-120 499-S02-5A Test-frequency Use-as-is 03-25-76 C-130 499-S02-7A Test-frequency Use-as-is 03-25-76 C-133 499-502-7B Excessive time en truck Use-as-is 03-25-76 C-145 499-S02-8A Excessive time on truck Use-as-is 03-29-76 C-147 499-S02-5B Add water w/no revs on Use-as-is truck 04-20-76 C-152 499-502-2 Test not taken Use-as-is 04-28-76 C-153 499-S03-16 Layers excessive in Inspectors height. Layers sloped. Retrained excessive flow 04-28-76 C-154 499-501-14.*. Spill over on steps & Inspectors excessive height Retrained 05-03-76 C-155 499-501-13A Mix revs exceeded FC2-CH-117 03-26-76 C-158 499-502-8B Excessive time FCR-CH-83 05-01-76 C-166 499-S02-19 lac truck not tested Accept-as-is pumping problems 05-12-76 C-170 499-502-5A Insufficient drum revs Use-as-is 05-31-76 C-176 499-S03-18 Excessive Slump Use-as-is 06-03-76 C-181 499-503-12A Correlacion cast not Use-as-is taken 06-04-76 C-182 499-S03-12A Excessive slump Use-as-is 06-15-76 C-183 499-S03-12A Test frequency exceeded Use-as-is 06-15-76 C-184 499-503-12A No discharge time on Use-as-is i cickat 06-15-76 C-185 499-S03-12B No pump discharge Use-as-is sample 06-17-76 C-187 499-S02-4 Test frequency exceeded Use-as-is 06-17-76 C-188 499-S01-15 Excessive slump Accept-as-is 06-18-76 C-189 499-S03-13B Excessive slump Accept-as-is 06-24-76 C-190 499-S01-14A Cure box too hot Accept-as-is y -~- * -
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i Response: la,b c ATTACHMENT "C" J. A. Jones Base Mac DR's Where an NCR was Not Initiated Date DRd Placemened Description C.A. 04-08-76 5 499-503-123 (Couge) Waterstop Repair EIR-200-7 04-12-76 6 499-S01-12A (Gouge) Waterstop Repair EIR-200-7 04-14-76 7 499-501-13A (Gouge) Waterstep Repair EIR-200-7 04-20-76 3 499-S03-16 (Ceuge) Pipe Tranch Repair Frame 04-22-76 10 499-501-12A Defective concrete FCR-50 04-23-76 11 499-501-14A Defective concrete FCR-50 04-26-76 12 499-503-19 (Gouge) 9" P.V.C. Repair EIR-200-7 vaterstop 04-27-76 13 499-S01-15 " Void" under waterstep Repair FCR-50 04-27-76 14 499-S01-15 " Void" under waterstop Repair FCR-50 04-27-76 15 499-501-15 " Void" under waterstep Repair FCR-50 04-27-76 16 499-501-15 (Gouge) waterstop Repair EIR-200-7 FCR-50 l' 04-29-76 17 499-S01-15 (Gouge) waterstop Repair EIR-200-7 04-30-76 19 499-S01-15 (Gouge) waterstop Repair FCR-50 04-30-76 20 499-S01-15 Void in concrete Repair FCR Dry pack 50 05-03-76 21 499-S01-15 Void in concrete Repair FCR Dry pack 50 05-03-76 22 499-S03-17 Bent studs on frame Bend back Frame 05-04-76 25 499-S03-17 Voids under waterstop Dry pack / FCR-50 05-04-76 26 499-S03-17 Voids under/over Dry pack / waterstop Repair FCR .s 05/06/76 29 499-S03-19 Void concrete Backfill with 499-S03-17 05/06/76 30 499-503-19 Void concrete Backfill with 499-503-17 g-..,s-- ,w,. - g ,y-_m--%- u -__.. __ . - - . _ _ _ _ ..-p_ _-a-.,, , , ,,_ ,v.,m.c --- -
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Response: la,b.c ATTACHMENT "C"-(cont'd) l Data DRG Placement # Description C.A. 05-17-76 33 499-503-17 Void under waterstep Pour with 499-S03-17 05-12-76 36 499-503-19 Concrete Void Pour with 568-8 05-12-76 38 499-S03-18 Void under waterscop Dry pack FCR-CH-50 05-17-76 40 499-S03-18 Void above/below Dry pack FCR-CH-50 waterstop 05-17-76 42 499-S03-18 Void above/below Dry pack FCR-CH-50 waterscop
; 05-17-76 43 499-503-18 Void above/below Dry pack FCR-CH-50
{ waterscop 05-17-76 44 499-503-18 Serial No's Legged on embed she. l 05-18-76 45 499-503-16 Hydraulic oil spill Remove i 18,11B,13B 4 05-19-76 46 499-S03-18 Voids in concrete Dry pack 05-19-76 47 499-S03-18 Voids in concrete Dry pack 05-20-76 48 499-5013FH & W Damaged waterstop Repair EIR-200-7 05-20-76 49 499-S03-16 Concrete Voids Dry pack 05-20-76 50 499-S03-18 Clam shell not covered Cover with visqueen by mud mat prior to placement 05-24-76 50 499-503-18 Gouges in waterscop Repair EIR-200-7 05-27-76 54 499-503-19 Voids in concrete Dry pack FCR-152 05-28-76 56 499-S03-11B & Hydraulic oil spill Remove 499-S02-10B 06-02-76 58 499-S01-12A Gouges in water stop Repair EIR-200-7 06-04-76 59 499-503-18 Voids under elevator Repair FCR-152 pit 06-09-76 63 499-501-7FH & W Damaged waterstop Repair FCR-CH-110
, EIR-300-120 06-09-76 64 499-502-10B , Cadweld at wrong Use-as-is elevation 06-09-76 65 499-S02-9A Cadweld at wrong Use-as-is
- elevation j ,
06-28-77 77 499-S03-18 Gouge in waterstop Repair EIR-200-7
- 2. Where was water table when 1977 cracks were discovered?
;j ~ Response:
At the time of discovery the ground water in the shell fill beneath the mat was at about elevation -20 ft. or about 15 feet above the top of the mat. (FSAR Figure 2.5-113: " Piezometer, Heave Point and Extensometer Responses Sh. 3 of 5). O h 1 1 0 T i
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- 3. Is there any evidence of convex curvature due to ring wall loading?
Response
Attached is a graph (Figure ES-3) reflecting tHe contours obtained from the maps generated on April 22, 1977, November 10, 1977, and October 9, 1979. These curves reflect a before mat (ring wall) loading, af ter ring wall placement and a majority of concrete construction complete. These contcurs do reflect a convex mat with maximum differential of two inches (2"). t 9 i I i a \ I i W
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- 4. Provide X-Section maps of mat flexure over time period zero to present.
Response: s , The following sketches reflect the mat by blocN and point settlement as fh'} monitored. Two full size copies have been provided for staff use. i f ,) ' SK-1564-15.10-G-25.1 SK-1564-15.10-C-26.1 SK-1564-15.10-G-27.1 SK-1564-15.10-G-28.1 : SK-1564-15.10-G-29.1 SK-1564-15.10-G-30.1 l , SK-1564-15.10-G-35.0 SK-1564-13.10-G-35.1 r
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- 5. a) Provide complete documentation of groundwater control and foundation heave from the start of dewatering until the present eine. b) Include the history of soil excavation and backfill beneath the mat.
Response: Sa) Groundwater control and foundation heave from the start of devacering until recent time are exhibited in FSAR Fig. 2.5-L13 (sheets 1/5 to 5/5). Response: Sb) The history of excavation and backfill is provided in FSAR Figures 2.5-102 and 2.5-103. O 1 w I
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- ll m 915 2.o p C YnD- C D CONSTRUCTION STAGES h- t
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-f PilASE I EXCAVATION . EXCAVATION PilAS[S li,111 AND IV E
k CONSTRUCTION
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- DOUYANCE PRESSURE I T / \ IN SilELL FILTER 8
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- 6. Provide the foundation loading history under each block during construction of the mat and walls. This should include the distribution of pressure under each block. Include the location and history of loads due to backfilling adjacent to foundation blocks.
Response
A co=puter program was developed and maintained weekly to monitor the placements made. Accumulative soil stresses were identified and maximum / minimum total stresses were noted. These figures and the differential stresses were reviewed. Differential stress did not exceed the maximum allowable of 1.0 KSF. As can be noted on the Composite Foundation Mat Settlement (Figure 2.5-117 in the FSAR), recharging of the water table began in late 1977 and was gradually charged until completion in late 1979. Recharging commenced based on total stresses achieving the 4.5 KSF criteria. The initiation of recharging the mac was approximately week no. 85 of construction. Distribution of pressure under each block was not maintained since the =at was considered as a single mat. Backfilling and concrete construction was established through drawing no. LOU-1564-G-490, " General Nuclear Plant Island Structure Construction Sequence". This drawing provided the evaluation criterin for top of concrete as related to top of fill. Generally, construction was sequenced to place concrete (walls / floors, etc.) uniformally by constructing the buildings with minimal differentiation in loading. Consequently, backfilling operations followed suit and maintained a uniformity of placement as well. e w 9
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- 7. Provide complete settlement history for each block from initial pouring until the present time. ,
Response
The settlement drawings listed (attached) in response to question four (4) provide the settlement picture by block placement until 1981. At this time.-the number of settlement points was reduced to eight (8). t I O W 4 M'*bH<eneem -m W w ,
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- 8. Analyze and discuss the relationship of the above variables (Qs 5-7) on the history of all observed mat cracks and leaks.
Response
The initial detection of mat cracks was made in mid 1977 when the concrete surface beneath the reactor containment was cleaned up and prepared for concrete fill placement. These cracks were identified by the minor water seepage caused by the temporary high groundwater level beneath the mat. This high groundwater level was shortly thereaf ter lowered by increasing the capacity of the dewatering system. No pther cracks were detected at that ti=a and no organized search was made for such. In 1983, a series of cracks was detected and capped. These cracks, along with those found in 1977, show a pattern generally follewing the pattern of =at differential settlement. The width of the cracks and the spacing of them shevs a very lov state of stress. The crncks vera f:und te ha n:t measurable in width and could be identified in so=e cases only by =oist concrete and in some cases only by a line of old leachate now dry. This shews that the cracks were created at some time previous to 1983 since it takes considerable time for leachate to form a measurable residue when the moisture flow carrying it is very low. The entire process which resulted in mat differential settlements, namely stressing the underlying soils above a level which they originally had been exposed to, was completed in mid 1979 and no further significant net or differential' settlements have occurred since and are not expected in the future. T _ _
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- 9. What basis is there for accepting the adequacy of construction of the first 3 blocks? .
Response
Waterford 3 Ouality Standard Prior to Placement 6, on December 2, 1975, the Waterford 3 Project underwent extensive development and gained significant construction QA experience during the extended qualification programs for the concrete batch plant, the concrete materials (cement, aggregates and admixtures) and the design mixes. During this period prior to i Placement 6, the project also gained experience in the development i and conduct of quality programs for soils, reinforcing steel and c:dvelding. LPSL takes credit for establishing a high quality standard for the whole project during the pre-placement period, which carried over into the placement of the basemat. This high quality standard has been established and maintained throughout the project hist ry. Observation of Placement 6 Since basemat Place =ent 6 was the first Class I placement, there was much interest in LP&L, Ebasco, and the concrete contractor to assure that the placement was carried out in a quality manner. Preplacement inspections were extremely detailed and received input from many project personnel beside those inspectors who actually signed the inspection reports. In addition to the official Quality Control efforts of both Ebasco and the concrete contractor (which, alone, represents considerably more than mini =um Quality control coverage), the placement was observed by several LP&L QA employees, LP&L project employees, Ebasco QA employees, sansgement personnel of Ebasco and the concrete contractor and two NRC inspectors. It is not typical to document such participation, but many of these observers can attest to their presence during the placement. During the conduct of Placement 6 several problems were encountered. The problems were formally documented by Ebasco (JG-75-12-2 dated 12-2-75) and LP&L (W35-75-635, dated 12-2-75). It is noteworthy that, despite the deficiencies which were documented, neither author made any direct statements or recommendations that the quality of the j placement itself should be investigated. On the contrary, both authors (and others) attest to the fact that in-process corrective action was taken, thus preventing the placement itself from being suspect. Consistent with the project quality standards, however, neither the author o. the two reports, nor their superiors, desired the continued necessity for the type of intense in-process corrective action required during placement 6. The purposes of the reports, as attested by their authors, were to cause generic and programmatic corrective action by the concrete contractor, so as to assure that future placements would be conducted with better control. To further assure mutual understanding of the deficiencies and to expedite their resolution, a meeting was held on December 5, 1975
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Response: (Continued) which included representation from LP&L, Ebasco and the concrete contractor. Resolution of the documented deficiencies were adequate to allow the concrete contractor to proceed with the next placement. Basemat Placement 1 Basemat Placement 1 occurred on December 8, 1975. Corrective action on the deficiencies recorded during Placement 6, was obviously effective. No QA deficiency reports were issued. The improvement in concrete contractor performance was, therefore, adequate to allow the concrete contractor to proceed with the place =ent sequence. 4 Ease =at Place =ent 2 3asemat Placement 2 occurred on December 11, 1975. The corrective action effected during Placement 1, although present to some extent during Placement 2, obviously did not meet the quality standard of LP&L. An LP&L QA surveillance report (W3S-75-64S, dated 12-11-75) was issued, listing deficiencies detected during the conduct of Place-ment 2. Since the concrete contractor apparently could not sustain the quality standards expected during the conduct of concrete placements on the basis of QA audit reports, surveillance reports, and meetings, LP&L QA decided to issue Stop Work Order Number 1 (SWO-1) in order to assure both Ebasco and the concrete contractor that LP&L was serious about project quality standards. Again, it is noteworthy that neither the LP&L QA surveillance report nor the Stop Work Order itself, make mention of any need for investi-gation into the quality of Placement 2. Participants attest to the fact that the placement itself was accomplished satisfactorily, albiet with considerable effort. Follow-on concrete placements i Following the issuance of SWO-1, a high level me.ating was called to discuss and resolve the SWD-1 issues. Following implementation of programmatic corrective action to the satisfaction of LP&L, the Stop Work Order was lifted and placement of the basemat proceeded without significant incident, with the exception of placements 10B and 19.
- l. During the conduct of placements 10B and 19, the concrete con:ractor encountered problems which were unique to those placements. It is noteworthy that these two placements were subjected to substantial investigation and repair, including a combined total of 302 core borings. The purpose in pointing out these intensive efforts (including an independent evaluation in the case of Placement 10B) is to emphasize that LP&L has not been bashful in demanding assurance of the quality of Waterford 3 construction. Had the actual quality of Placements 6, 1, and 2 been suspect, LP&L and/or Ebasco would most assuredly have demanded investigative measures.
I
. _ _ ~1
Response: (Continued) Phearson memorandum on December 15, 1975, four days after Basemat Placement 2, a hand-written "Afteraction Report" was written by a Mr. F. L. Phearson, an Ebasco Quality Assurance Engineer who participated in Placement 2, to Mr. W. C. Griggs, then Ebasco Senior Quality Control Supervisor. The Phearson memorandum lists deficiencies in the conduct of Placement 2 which are equivalent to some of the deficiencies listed in the previously discussed LP&L and Ebasco QA reports of December 2 and 11,1975. Mr. Griggs does not recall seeing the memorandum at the time, and LP&L first became aware of it in mid 1983. LP&L vishes to
=ake one speculative and two factual points regarding the Phearson cemorandum.
- 1. Factual - The deficiencias listed in the Phearson mercrandum had already been identified in LPSL and Ebasco QA repo;'s, along with other deficiencias not mentioned in the Phearson memo.
- 2. Speculative - On the hypothetical assumption that Mr. Griggs actually saw the memorandum (he does not recall seeing it), it is reasonable to assume that he would consider it moot, since he already had in his possession the LP&L QA surveillance report, which included the same deficiencies and more.
- 3. Factual - The Phearson me=orandum does not speci-fically state that Placement 2 is suspect, nor does it recommend or imply the need for investigation of the placement. Phearson did not leave'the Waterford 3 project until mid April, 1976.
Ccesidering the reco==endation in his memorandum, it is reasonable to conclude that Phearson's motives in writing the memorandum were similar to those of others who reported deficiencies in the conduct of Placements 2 and 6 - that is, to effect programmatic improvements in the conduct of future concrete placements.
Conclusion:
' Based on this information, the actual performance of the mat to date, the internal review and evaluation, the independent review . and evaluation and the extreme conservatism in the mat design, LP&L has adequate confidence that the base =at will perform satis-factorily in service.
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- 10. If engineering judgement was involved in accepting those blocks, what was the basis for that judgement? Where is it documented?
Response
Placements 6, 1, and 2 were conforming placements. As such, no engineering evaluations nor engineering judgements were required to support their adequacy. See also the responses to Questions 9, 11, 22, 24, 25, 26, 27, 28 and 29. I l l l i
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- 11. What corrective actions were necessary for the first 3 blocks? What corrective actions were taken, and provide specifics for each pour? Where are these actions documented?
Response
Two types of corrective action were effected with respect to basemat Placements 6, 1, and 2, the first three basemat placements. The following discussions characterize both. A. In-process corrective action During the conduct of basemat placements 6 and 2, and to a smaller extent, placement 1, corrective action was taken as deficiencies were detected. These corrective =essures resulted from the fact that there were so many " inspectors", including the official Ebasco and concrete contractor inspectors (who would actually sign the inspection documents), Ibasco 2nd L?SL QA persennel, and others. Althou;h these placements occurred in excess of eight years ago, the significance of these placements (essentially the first substantial permanent safety related work at Waterford 3) and review of site records have refreshed the memories of key personnel. Attachment A represents the recollection
- of in-preccc= corrective actions cal =a during each of the three placements.
B. Programmatic Corrective Action Because of the recurrence of some operational problems requiring 4 ' in-process correction, LP&L issued Stop Work Order #1. The Stop Work Order was not issued because there was concern about the integrity of the work completed or in progress, but to stress the urgency of eliminating the recurrence of problems. Stop Work Order #1 was based on the findings in three QA audit reports:
- 1. Ebasco Audit Report JG-75-12-2 written on Placement 499502-6 en
! December 2, 1975. l 2. LP&L QA Site Surveillance Report W35-75-64S vritten on Placement j 6 on December 2, 1975. ,
- 3. LP&L QA Site Surveillance Report W3S-75-63S written on Placement 2 on December 11, 1975.
l l Attachment B presents each of the audit findings, the contractor responses, and the final LP&L resolution for each item. Attachment B addresses the first and third placements (Placement 6 and 2). The second placement (Placement 1) was quite uneventful and no QA audit report was generated. I
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Response: (11 Continued) ATTACHMENT A l Audit Report No. JG-75-12-2 (Placement 499502-6) ITEM 4: Not enough vibrators were provided for adequate vibration or to make provisions for breakdown of equipment. This finding directs attention to the fact that the auditor was unable to locate (within the immediate area of the placement) extra vibrators for backup in the event of malfunction of vibrators in use. However, no malfunction of vibrators was actually detected. The corrective action response from the contractor to Ebasco Q.A. states that..."During the actus1 peur, a total of twelve (12) vibrators vere in operation with tan (10) more as back-up directly adjacent to the pour area." Therefore, the auditor concluded that the contractor's personnel contacted for verification of this item was not aware of where the back-up vibrators were located and that in reelity no finding may have actually er.isted. Subsequent to this peur, the contractor instituted pre-pour caetings attended by all cognizant supervisory personnel to assure a complete understanding of the contents of applicable work procedures and the applicable pour olan. 4 ITEM 5: Workmen deviated from placing procedure; it was apparent that workmen were not cognizant with placing procedure. This finding identified that workmen deviated from the placing sequence depicted on the pour plan. Concreta placement inspection report dated 12-2-75 indicates that at 9:00 a.m. the contractor was not placing the concrete using the stepping procedure as outlined in their placement diagram. It further states that steps were taken to correct this condition by building up the north side at a faster rate. ITEM 12: It was observed that improper use of vibrators and insufficient
- vibration resulted in honeycomb.
The auditor observed that improper use of vibrators and insufficient ! vibration resulted in honeycomb. This statement relates to an exterior surface area of the placement examined once forms were removed. The condition observed is documented on concrete pour plan form dated December 8, 1985. Extent of honeycomb was relatively minor and was concentrated around the horizontal waterstop located towards the top edge of the placement. Repairs were satisfactorily accomplished as noted on the concrete pour plan form. l l
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Response: (11 Continued) Attachment A ITEM 13: At times height of drop exceeded the 5 foot limit. While in certain isolated instances the height of drop for the concrete exceeded the 5 foot limit, no actual separation / segregation was detected. These occurrences were brought to the attention of the contractor's supervisory personnel who in turn verbally issued corrective action directives. ITEM 16: It was observed that for some loads that as much as 15 minutes elapsed before the discharge time was recorded; censequently, an incorrect tima was i recorded. The auditor monitored the actions of the inspectors checking the inceming e----*
- d---s and en a couple cf instances noticed that ths tima slapsed between the start of discharge of concrete and recordation by Q.C. was approximately 15 minutes. These occurrences were brought to the attention of the Q.C. Supervisor / Lead present. Action taken va to assign an additional inspector to monitor this facet of the operation. Additionally, a check of the batch tickets revealed that all tracks were discharged within the one hour time limit.
- ITEM 21: Improper handling of cylinders resulted in uncircular specimens, also Hi-Lo thermometers were not provided until late evening.
The observation made detected that one set of concrete cylinders were somewhat out-of-round at the top. Also, that thermometers were not readily available to monitor the curing of test cylinders. These occurrences were a one time isolated event and corrective action included re-instruction of personnel and an adequate supply of thermometers procured and made available at point of need prior to initiation of concreting cperations. ITEM 24: Skip pan was observed to stand on top of the mat for several minutes prior to testing of the concrete which was in the skip pan. The concern expressed was that the skip pan which contained the concrete to be used for testing was observed to remain on the mat for an extended period of time prior to testing. This condition was a one time occurrence due to insufficient number of cranes available for use handling the sampling of concrete. Action taken was to provide equipment assigned solely to the
- sampling of concrete.
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Response: (11 Contined) Attachment A Item #25: Workmen were observed to shovel concrete from the ground into the pumps, .thus contaminating the conrete with shell. This finding identifies that A workman was observed shoveling concrete that had spilled on to the ground from the pump hopper back into the hopper. The corner edge of the shovel caught a bit of shell which in turn was dumped into the hopper. The amount of shell was insignificant but practice of picking up concrete from the ground was discouraged. This was a one time occurrence which was corrected on the spot by the contractor's 4 Superintendent. On subsequent placements, the use of plywood was utilized under the pumps to keep any concrete that may spill over o.ff the greund. Item #26: Documentation of tests and checklists were observed to be in error and omissions of data and signatures exists. A review of concrete placement records subsequent to completion of the placement revealed certain irregularities. Corrective action taken was re-instruction of Q.C. personnel and information retrieved which per=itted correction of the irregularities. It should be noted that none of the irregularities impacted.the as-built condition of the placasent. wiy ,4 %.--- , ---a. a_.-7 , w - ,--- -.m.wp., .c -,.------. - -
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Response: (11 Continued) Attachment A Audit Report No. W3S 75-64S (Placement 499 S02-6) OBSERVATIONS:
- 1. Contrary to Section I Paragraph 10.9, concrete was placed even though it exceeded specification requirements.
COMMENT: This observation resulted from a difference in understanding between LPSL and Ebasco. Ebasco Engineering has stated in a November 24, 1973, memorandum that the slump could range between i and 5 inches. Since only one latch exceeded the requirement (5 3/4 inch slu=p), this was a non-problem. This one case of out-of-specification slump was documented and resolved on D.N. #C-77. 4
- 2. Contrary to Section II, Paragraph 5.2, concrete received disturbing shocks and vibrations frem reinforcing steel which was set in motion by concrete pump discharges.
COMMENT: This problem was noted early in the placement. It was quickly corrected by J. A. Jones long before any concrete had set. The purpose of the co= ment was to formally notify J. A. Jones and Ebasco concerning this observation so that it ceuld be prevented on future placements.
- 3. Contrary to Section II, Paragraph 4.13, concrete was inadequately vibrated.
COMMENT: There were some instances during the placement where minor deviations from the correct vibrating procedure was noted. These deviations occurred when the operator slightly exceeded the required spacing between vibrating operators, or did not insert the vibrator in a perfectly vertical manner. These deviations were minor in nature and were corrected by J. A. Jones on the spot.
- 4. Contrary to Section II, Paragraph 5.1, curing water was not continuously i maintained on all exposed surfaces.
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Response: (11 Continued) Attachment A COMMENT: The word "all" is important here. There were a few instances where standing water was not on a few square feet of localized high surface area of the placement. These areas were damp. This was not a major problem as J. A. Jones was conscientious in maintaining adequate curing during all placements. J. A. Jones took immediate action to assure that all areas of the placement were continuously covered.
- 5. Contrary to ACI 318 - Rebar was improperly spaced in some areas of the placement.
CCMIENT: This was a practical problem caused by bulkheads, interferences with embedded items, and cleaner for concrets pumping equipment. The devicti:n from drawings were minor in nature, usually amounting to fractions of an inch. These problems were corrected by J. A. Jones on the spot.
- 6. Personnel involved in placement activities were not aware of or failed to follow J. A. Jones Co., " Concrete Pour Plan".
COMMENT: This comment centered around difficulty in keeping with the inter "scair stepping procedure" for concrete placement. Documentation to this effect can be found in the Ebasco Concrete Placement Inspection record (form no. 6CIP 7-1, 11-30-75) for placement no. 499 S02-6 (12-2-75). See 0900 hours entry in the record.
- 7. Saveral Ebasco concrete test records (form no. QC18-7-2, 11-30-75) were cc completely filled out.
CCdMENT: Problems with the records noted during the placement were minor in nature i and were usually corrected on the spot. Considering that this was the first placement, the inspection documentation was, in fact, very good.
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Response: (11 Continued) Attachment A ITEM 11: Corrective action not taken by some of Ebasco personnel af ter being brought to their attention by LP&L. COMMENT: This corrective action was taken by LP&L. (Corrective action giving directions in problem areas were needed, but also to =ake Ebasco aware of some training was needed by their personnel.) ITEM 12: Completa failure by most to =cet require: ants of procedures and specifications. COMMENT: Complete failure by most to meet requirements of procedures and specifications does not imply that all personnel were not qualified to perform their duties, but there were some which indeed needed training. Such as:
- 1. The limit of acceptable drop of concrete from end of tremie or hosa.
- 2. The proper thickness of placement layers not exceeding the 20 inches.
- 3. Proper use of vibrators.
ITEM 13: No evaluation of crack growth in west wall of pour #6 until brought to the attention of supervisors by LP&L. COMMENT: Was so stated to make Ebasco evaluate the crack and take necessary action on the matter. See Ebasco response to this observation dated December 17, 1975, F-4614 4.0.
Response: (11 Continued) Attachment A ITEM 11: Corrective action not taken by some of Ebasco personnel after being brought te their attention by LP&L. COMMENT:
, This corrective action was taken by LP&L. (Corrective action giving directions in problem areas were needed, but also to make Ebasco aware of some training was needed by their personnel.)
ITEM 12: Complete failure by =est to =eet require =cnts of procsdures and specifications. COMME!!T: Complete failure by most to meet require =ents of procedures and specifications does not i= ply that all personnel were not qualified to perform their duties, but there were so=e which indeed needed training. Such as:
- 1. The limit of acceptable drop of concrete from and of tremie or hose.
- 2. The proper thickness of placement layers not exceeding the 20 inches.
- 3. Proper use of vibrators.
ITEM 13: No evaluation of crack growth in west wall of pour #6 until brought to the attention of supervisors by LP&L. COMMENT: Was so stated to make Ebasco evaluate the crack and take necessary action on the matter. See Ebasco response to this observation dated December 17, 1975, F-4614 4.0.
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Response: (11 Continued) Attachment A Surveillance Report W3S-75-63S (Placement No. 499502-2) OBSERVIATIONS:
- 1. Rejected concrete being used.
- 2. Ebasco inspector's rejection of concrete overriden by Ebasco QC Supervisor.
COMMENT: This scacement was made on Bacch No. 001441, so action would be taken, correcting any doubt about a concrete six in question. See Ebasco response to Surveillance Report No. W3S-75-63S, which states in part: " instructed all Eb:sce Q.C. personnel this date :: h:re 'terifi:nti:n test :da :n questionable items prior to release for use.
- 3. Concrete allowed to be placed that could not be vibrated under rebar.
CCMMENT: A This concrete was removed from the placement immediately. After notification by LP&L Q.A the cause of the problem was from a plugged pump line. From there on a container was used to catch'e'ut of specification ccacrete. 4 Concrete being vibrated in order to flow from truck chute. 1 COMME:;T: This was being done by a J. A. Jones' laborer to assist the flow of concrete to pump hopper. This procedure was stopped when he first started ) by LP&L Q.A. Again stated to employment corrective action. I
- 5. Continuous use of low slump out of specification concrete after being warned by LP&. (Had to have QA Corporation at Placement correct).
COMMENT. This was stated because of a dryer mix which could cause pumping proble=s and delays in placement. This concrete was acceptable, but had a lower slump for concrete to be pumped. 3 l w
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Response: (Il' Continued) Attachment A Item #6: Concrete being controlled before pump hoppers by J. A. Jones. COMMENT: This was stated so J. A. Jones would not have any control on acceptance or rejection of concrete which they placed. Item #7: Dry concrete being removed freu discharge hose and being permitted to drop in place =ent area. (k*as made to remove by LP&L). CCEtE:iT: I Again stated so J. A. Jones would school their employees in the useof a catch plan. See J. A. Jones reply to ~43S-75-63S, which sences in part:
"when a transport line becomes plugges, the area underneath the cleaning operations on the top mat will be covered to prevent the concrete dropping through the top mat into the peur area.
Item 48:. Irproper placement of concrete. COMMENT: So stated even though corrections vera en the spot, so J. A. Jones would be aware of these problems and make necessary corrections to these areas.
- 1. Improper use of vibrators by not inserting the vibrator in the proper vertical position.
- 2. At times height of drop exceeded the 5 foot limit.
- 3. Allowing the concrete triemie to swing while pumping concrete.
Item #9: Inadequate supervision by J. A. Jones. COMMENT: So stated so J. A. Jones would increase their supervision at placement areas. Item #10: Inadequate sue.rvision by Ebasco. COMMENT: So stated so Ebasco would increase their supervision at placement area. e- -
Response: (11 Continued) ATTACHMENT B SWO #1 (Ref. 1, 2) i Rejected Items / Responses / Resolutions CENERAL OBSERVATIONS (Ref. 6) f
- 1. All J. A. Jones responses and corrective action to non-confor=ances are to be accepted by Ebasco.
- 2. Ebasco will be required to have site management conduct audits to see that programs developed for the corrective ce:1cn are being implemented and adhered to.
I. E3ASCO AUDIT REPORT JG-75-12-2 ON PLACEMINT 6 (Ref. 3, 4) , ITEM 4: Not enough vibrators were provided for adequate vibration or to =ake provisiens for breakdown of equipment. J. A. Jones Response (Ref. 5): The approved Concrete Pour Plan dated November 26, 1985 specified that six (6) Electrical and three (3) Air-Powered Vibrators were planned for use on Pour #6. Just prior to pour, twelve (12) Electrical and ten (10) Air-Driven Vibrators were verified for frequency of vibration and certified for use on subject pour. During the actual pour, a total of twelve (12) Vibrators were in operation with ten (10) more as back-up directly adjacent to the pour area. J. A. Jones considers the allegation as stated unfounded. Ebasco Response (15):
.It has been verified by this department that 23 vibrators are available for subsequent placements and that the lack of vibrators would be highly unlikely in the event of equipment failure.
LP&L Resolution (Ref. 6): LP&L considered the response controversial.
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Response: (11 Continued) Attachment B ITEM 5 : - Workmen deviated from placing procedure; it was apparent that workmen were not cognizant with placing procedura. J. A. Jones Resnonse (Ref. 5): Subsequent to this pour, J. A. Jones instituted pre-pour meetings attended by all cognizanc supervisory personnel to assure a com-place understanding of the contents of J. A. Jones Work Procedure W-WP-7 and the appl 1 cable pour plan. J. A. Jones will continue these meetings and will place even greacer emphasis on the contents of the placing procedures. Resolution (Ref. 6) L?&L observad that the respense appeared to be acceptable. ITEM 12: It was cbserved that i= proper use of vibrators and insufficient vibration resulted in honeycomb. Ebasco Response (Ref. 5): A formal training class was presented on December 16, 1975 by J. A. Jones Quality Engineering co.ering proper techniques for vibrator operators. This class, vnich presented the reasons for and the required method of vibrator operation, was attended by all operator personnel assigned to Pour #3 and those Con-struction Supervisors responsible for placement operations. Course contents, graphic illustrations and attendance has been documented and is available on request. It is our intention to conduct this training for any new vibrator operators assigned to subsequent concrete place =ent operations. LP&L Resolution (Ref. 6): LP&L observed that the response appeared to be acceptable. ITEM 13: At times height of drop exceeded the 5 foot limit.
- J. A. Jones Response (Ref. 5):
Cognizant Construction Supervisory personnel have been coun-ciled subsequent to this pour and fully understand to4c the dropping of concrete from a height of more than five (5) feet onto exposed reinforcing steel can cause separation of the aggregate. They have been further instructed that in the future it is mandatory that the approved procedural direction must be followed at all times. , e
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Response: -(11 Continued) Attachment B LP&L Resolution (def. 6): J. A. Jones response must be in the form of written instruc-tione similar to that described in Item 1 on Report W3S-75-63S. Objective evident of implementation is required. J. A. Jones complied via Ref. 14 which directed personnel to read and understand a) Ebasco Specification LOU-1564.472, Section II, b) J. A. Jones Concrete Pour Plan, and c) Concrete Placement and consolidation training session and class notes. ITEM 16: It was observed that for some loads that as much as 15 minutes elapsed before the discharge time was recorded; consequently an incorrect ti=e was recorded. Ebasco Resoonse (Ref. 7): The ti=e that is stamped on the batch ticket at the point of discharge is the discharge completion time. The driver vill not leave until he his the ticket returned to him. A check of the batch ticket did not reveal any discrepancies. All trucks were discharged within the one hour time limit. s LP&L Resolution (Ref. 6): LP&L observed that the response appeared to be acceptable. Ebasco l QA has verbally accepted the response. ITEM 21: Improper handling of cylinders resulted in uncircular specimens, also Hi-Lo ther=ometers were not provided until late evening. Ebasco Response (Ref. 7): All Inspection and Testing Personnel have been instructed as to the proper method of handling concrete test cylinders. The Hi-Lo thermometers have been mounted in the concrete cylinder curing boxes. LP&L Resolution (Ref. 6): LP&L observed that the response appeared to be acceptable. Ebasco QA has verbally accepted the response. P B M,--h--e aPmenph agi+e.- l
Response: (11 Continued) Attachment B ITEM 24: Skip pan was observed to stand on top of the mat for several minutes prior to testing of the concrete which was in the skip pan. Ebasco Response (Ref. 7): The skip pan was moved to the testing area as quickly as it was possible. There were a few times that the crane was being used for another operation and could not be used immediately but was released for the testing as soon as possible. L?SL Resolutien (Ref. 6): LP&L observed that the response appeared to be acceptable. Ebasco QA has verbally accepted the response. I EM 25: Workmen were observed to shovel cencrete from the ground into the pu=ps, thus conta=1= sting the concrete with shell. Ebssco Response (Ref. 7): Ebasco's Q.C. notified J.A. Jones during the placement that this was not permitted. J.A. Jones Superintendent instructed their personnel as to the requirements. Ebasco Resconse (Ref. 15): It should be recognized that we'rkmanship does have an effect on the quality of concrete, therefore, caution must be exer-cised to eliminate any possibilities of contamination. On subsequent place =ent the use of plywood should be utilized en the ground by the pumps. LP&L Resolution (Ref. 6): LP&L observed that the response appeared to be acceptable. Ebasco QA has verbally accepted the response. ITEM 26: Documentation of tests and checklists were observed to be in error and omissions of data and signatures exists. 4 Ebasco Response (Ref. 7): Concrete testing and inspection personnel have been re-instructed in the proper use of forms. Subsequent placement reveals euch improved documentation. eus. .
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- Response: (11 Continued)
Attachment B ITEM 26: LP&L Resolution (Ref. 6): J LP&L observed that the response appeared to be acceptable. Ebasco QA has verbally accepted the response. f I i i e e w
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9 Response: (11 Continued) Attachment B II. LP&L-QA SITE SURVEILLANCE REPORT W3S-75-64S OBSERVATIONS (Ref. 2, 8) ITEM 1: Contrary to Section I Paragraph 10.9, concrete was placed even though it exceeded specification requirements. Ebasco Reseense (Ref. 9): Section I, Article 10.9, of the Concrete Masonry Specification LOU 1564.472 gives a range of slumps for various types of construction. Our Concrete-Hydraulic Engineering Department interpreted this paragraph regarding slumps for the common =at foundation and provided the site with direction in memorandu= from R. Vine /A. Wern to J.O. 3ooth dated November 24, 1994 (Ref. 6). This memorandum stated that slumps could range between 5 inches and 1 inch. This is consistent with the first paragraph.cf Section I Article 10.9, which states that concrete shall be of a consistency and workability suitable fer the conditions of the job. A review of the concrete Test Records, Tor = No. QCIP-7-2, show that only one batch of concrete (5-3/4 inch slump) was used for Block No. 499S02-6 that exceeded the specified require =ents concerning slumps. Ebasco Response (Ref. 12) Please refer to the supplemental response to Item 5 of Site Surveillance Report No. W3S-75-635. LP&L Resolution (Ref. 6) , Me=orandums of interpre. stien of specifications are to be en controlled distribution as discussed under Item 5 of the preceding report (i.e., W3S-75-63S) ITEM 2: Contrary to Section II, Paragraph 5.9, concrete received disturbing shocks and vibrations from reinforcing steel which was set in motion by concrete pump discharges. J. A. Jones Response (Ref. 10): The discrepancy was observed at the start of the pumping operation and was corrected prior to placing second lift of concrete which was vibrated into a homogeneous mix eliminating any detrimental effect on the placement.
. l Response: (11 Continued)
Attachment B ' ITEM 2: In the future, transport lines and conveying equipment will be properly supported and restrained to eliminate transporting shock to forms and embedded items in the placement. We have ordered additional concrete pipe fittings to install a shock absorber on the pump lines to help minimize this shock effect. (J. A. Jones purchase order No. 75-317/po311) ITEM 3: Contrary to Section II, Paragraph 4.13, Concrete was inadequately vibrated. J. A. Jones Reseense (Ref. 10):
' Adequate equipment for proper vibration of the concrete was on hand and the craft has been instructed in the proper use of the equipment with written instructions of required spacing between vibrating operations and depth of vibrations, copy attached (Ref. 17). The craf t had inadequate experience in the usa of the equipment resulting in scme instances in inadequate vibration.
We feel adequate instructions have since been presented to the craftsmen and that they have now gained more experience and a better understanding of why concrete is vibrated. We have experienced better workmanship on the subsequent pours and consequently, efficiency will increase throughout the life of the project. LP&L Resolution (Ref. 6): Response acceptable. ITEM 4: Contrary to Section II, Paragraph 5.1, Curing water was not contin-uously maintained on all exposed surfaces. J. A. Jones Response (Ref. 10): A crew of personnel have been assigned the sole task of con-cinuous placement of water on all exposed concrete sarfaces for the required period of seven (7) days. More areas will be covered with burlap in the future to aid in holding the moisture.
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Response: (11 Continued) Attachment B ITEM 4: We feel that these corrective actions are sufficient to eliminate the problem completely. Additional personnel will be added as required. ITEM 7: Several Ebasco concrete test records (Form No. QCIP-7-2, 11-30-75) were not completely filled out. Ebasco Resoonse (Ref. 9): Concrete Test Records for Block No. 499S02-6 have been reviewed by the Quality Control Civil Supervisor. Ince:plete information
- e9 retrieved, where possible, and recorded. This was the first permanent plant concrete for this proj ect, and prior to the next placement, our Quality Control personnel were instructed and are required to record all data on the for=s as the work is being perfor=ed. A review of our records for subsequent Blocks No. 499S02-1 and 499502-2 indicates that this is being accomplished. As further assurance that concrete is satisfactory, 27 of 30 test cylinders broke in excess of 4,000 psi with the lowest of the remainder being 3,530 psi.
Resolution (Ref. 6): Response acceptable. b
O Response: (11 Continued) Attachment B III. LP&L-QA SITE SURVEILLANCE REPORT W35-75-63S OBSERVATION (Ref. 2, 11) ITEM 1: Rejected concrete being used. i l ITEM 2: Ebasco inspector's rejection of concrete overriden by Ebasco QC Supervisor. t Ebasco Response (Ref. 7): Items 1 & 2 No rejected concrete was used in Block No. 499502-2. Our understanding of these two items is that LP&L is concerned about one truck load of concrete which was initially rejected by our Quality Control Inspector and later allowed to be used. This incident occurred once with Batch No. 001441. Upon arrival at the site, a visual inspection of this load indicated that it probably [ had a slump; consequently, a slump test was perforned. The results were 7-3/4 inches and the Quality Control Inspector rejected the load for placement at that time. The cruck stood turning its drum at agitating speed. After a period of ti=e, which did not exceed the one hour limit, the Quality Control Civil Supervisor visually examined this load of concrete and judged the slump to be less ,than 5 inches and the concrete acceptable for placement. The load was subsequently used in the placement. It is the responsibility of the Quality Control Supervisor to review the evaluations / decisions of inspectors under his super-vision. In this regard, we feel that his decision to override the Inspector was correct. We have instructed all Ebasco Q.C. personnel this date to have verification tests made on question-able ite=s prior to release for use. Ebasco Response (Ref. 12): The Sr. Quality Control Supervisor via written memorandum dated December 18, 1975, has instructed the Quality Control Engineers, Supervisors, and Inspectors to perform verification tests on suspect materials prior to release for use. LP&L Resolution (Ref. 6): The Ebasco position is acceptable provided the instructions to Ebasco QC Personnel are in writing indicating tho date that the instructions are to be implemented and executed by the responsible individual in Ebasco for implementation. 6
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= *m EEA5Co SERVICES INCORpCR Arto S* 0; g pp, g,n,,; I / CU ALITY ASSURANCE ** "* '""#' * /*p2 asponr No."' W3-535-[e/ / .HONCONFORMANCE REPORT Y'"****,'""*"*"'*"""***'"' dispesurien INSTRUCTIONS: (See back of form) k'_* C b4 EN T e4 PROJECT 438 o m agf M G No./S p t C No. 8 31 Waterford SES Unit #3 s u ..b E ., ca .v uctioM ec on co r Ac ro ... ..o.~o.,,, PSAR Section 5.2.2.10 Construction o E c ..vio o, cow.oNENr. . Aa r on sviv E= ... Co on Foundation Mac 1 D ESCRIPTICH O F HCHCCH FO RM ANCE (Irems involved, Speenficaroon. Caae or Standard to noch items Co Not Camaly. Submer sketch if Applicaale) The too of the cat beneath the centainment se ucture centains a number of cracks which were discovered to be weeping watar. The rate of weeping is generally enough to st the crack and to coisten the surrounding cencrete. ' - "r- :S : . ...m . _ _; . :: s s n _ ... ::;ui- 8 -"a - nc1 e ch2;c "-3-' -S: -:::ri:1 M : :w_ E: ;. _ f ; _ . .. . t ic.l. u;i G[f,f)g"'-)7] , / , '".A - , isy ruy pro w *E n soM = E pon t MeNoNCoNPoRMANcE '88 TI T LE oATE 98 7 1Ad%/# R. A. Martncet O. A. Site Sucervisor ! 7-23-77 61 RECOMMENDED Disp 051TlCN ' *
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10CFR21 .. O P' H8V88Hed $ g Mg. N AuE ANo sisNe rumE or *EnsoM mEcomu ENoiNo ois positioM nie riv6s oArE i as _YY RIGG 5* D. ^ & ? ? 3. $4)G '?. ~~ Y!5l ~b Y Y"Y l i t. EVALUATICH OF Dl5PC$1TICH BT f li4ASCO, REASCH FOR DISPC$lTION 088 ' _0L d dOchA M ds.L An Acaka of cwk h wl...,ad e %bMAJ kd m.& a z D a h&,0 2 Dvb /A L rs,M-ELA3& h O.c(d-Al J a< Id_.L!. b)a n Asl YL k A. a ,a -t. m AwA L " i o ac. w- s,uw
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h ENGINEERING CU ALITY ASSURANCE CONSTRUCTICN. CoTHER AUTHCRtZED PER$CNNe; ' .E I5iGN A TU AE) NAME ISIG N A TUR E) MAME (slGN ATUNEl E&$.kaa, . NAME '5IGN A ?uR EI oATEQ'T.f.s.7y Q oATE oATE oATE O acesprao O acascreo O Accurreo O acancreo O accrerso O acascrea 0 4cererso wirw couucurs O Accrerto O acaccres 0 4ceretto wirs cewueurs n accentro wirw ceuucurs _O 4ccentro wirw eeuweNes IV. VERIFICATION C.' Ol5PC$1TICH cuento C No? REQUIREo H Aa n > Ev tdo 6 M e c .ru. 84 A rir 8 4 / M E <u x N77'
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4 . . . - - e m=. e I *h ' s ., . iv ' DISPOSITION FOR NONCONFORMANCE W3-535 In order to establish a method of repair, perform the following operations and resubmit the nonconformance with results. A. Drill and grout in place three 1/8" pipe nipples to a depth of two-three inches. The above to be performed least two cracks. Pipe nipples to be approximately 8" gn -2" at c.c. B. Seal the surface of the crack using a quick setting epoxy. A window may be provided between selected nipples in order to monitor the flow of epoxy which is to be injected as follows. C. Pressure inject Concressive 1380 epoxv as =anufactured by Adhesive Engineering into the middle pipe nip;'.. - Grouting pressure to be ircreased gradually as required to make the epoxy flow. Max 1=um pressure to be used is 180 PSI. New York Engineering (ESSE) to v.tness the grouting operation and provide final dispositten of nonconfor=ance. N O O N C -Q . . . . . . ..- , -. . . - . = .. .- ... -..~. . . - . . - . . . . . .. **e. ' ~ .u '4 h hi - 'q ' fLIA l SUPPLEMENT TO NCR U3-535 . 8 VA ' U 4 7~# # # August 3, 1977 l After an unsuccessfull atte=pt at pressure injecting epoxy grout into the cracks, the following procedure should be used to effectively control the leakage or weeping of water through the cracks. 1 - Chip a 1" deep crench along the length of the crack. 2 - Roughan (by sandblasting or bush ha=ner) and clean the surface thoroughly along the crack as well as a 1 ft. strip on either side of the crack. . ,, 3 - Fill the 1" deep ::ench with SIKA Hi-Mod-L7 epoxy which ay be used as a seal coat in the dry, da=p or vet area --- in acec dance with =anufacture: inst:uctions and < st.!! ace preparation. s, -- .. _ 4 - A' =* ~5e epoxy is tack free, apply a brush coat of .the O v"-Mod-L D the r:ughened and clean surface 2 ft. vide aloog ene crack length.. , 5 - Monitor the repairs for 1 dsy to visually inspect that leakage has ceased to penetrate the c:seks. At this O time, the concrete place =ents may continue. l . N . . i - gg- - ik-Inon w/ wk %ye fik Y . O me e 9 k ge . Y *s ~ s/ ' i u. o s wt k s a d -IL u d .]
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i e lC b l +\ ~ 4 l O o l ~~- l s ..e t O N .s-r-==wwwe e mee .=*w = =r 6* mW O, * .O. SUPPLEMENT (12 TO NCR W3-535 August 5, 1977 All cracks in place ent 302-6 have been inspected and found satisfactorily repaired according to the outlined pr:cedure in supplement til of NCR W3-535. There is no indication of water ,g weeping since the application of the SIKA Hi-Mod epoxy. All subsequent cracks detailed on the attached mat drawing shculd be e repaired in an identical ranner. N Placement 302-6 may proceed af ter Quality Control perfor=s normal pre-placement inspection. A o M l O E. J. Gallagher Civil Site Support Engineer N O C d t 1 . _ _ . .. . . __ . . . . . . . . - . - .. - - - -- * ~ ~ - - -- g6-. aee ne h w- N 4** .- . -- h , - . - - - < ~ . = =- f , e
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INSTRUC.TIONS: (fee sock et formi #'"' * '*'"*"C# CblaMr On pnOJsCT 's' ORawsNG No./spsC NO. Lsf Waterford SES - Unit No 3 sw sisa. CONaravC riom OC Q. CO,er.aCrQ. ... ..O. 80 3, PSAR Sectica 5.2.2.10 Construction O ssC R8 8 vlON OF CQupOMsNr. paar Om sy srau its Cc==cn Foundation Mat Within the RC3 Wall I. O ESCRIPTICH OF NONCONFO R ANCE tireme involved. See<slieerson. Code er $renderd ue which trems ce Nor comoty, Submit $kerek II Analisable) This supple =ent provides additional infor=ation on the crack cattern and docu=ents the crack patterns on the attached Field Sketch No 1564-4.1-G-28. I EEEDRTAgt 3 vco nu. ICCFK50 %'a# 17 % t i / i - 4 m en n mi .!arvines v.s , % .7p O m *f4 G sepC OM PO Rua 8eC s 88 rif bs Da rs 'e Manes R A nartnettaNO sloNa rums OP88'r8Nyj _ Q A Site Supervisor 8 77 i i. aEC:u=ENoEo oiSPo$mcH " > <r.3,., sie,.s ./ 2 . e,- M r c w (% cwan,,u.ege;u J % , % .7,o.c c = = c s msCOusesNo ense Ogs mose rtone in e s verkg et23 3 Na%.*e9 sleM a ru]Rs OP ?eca D%c sa. l2c.maa lgargs't24/77 I l l. EVALUATION OF Di$PC$lTICH BY ES ASCO. REASCN FOR DISPC$1TICN "38 #8 1 A.ut.As.,o _ 3 % A/og b3- $3J La- . 0,x \\- I f C ENGINEERING C QUALITY ASSU R A N CE [ CcNSTRUCTf 0N OTHER AUTNCRIZEDPERSONNEL .e aus 'si 4 ru Naus isioMa rva si Naus sioMarunas kaus isisNa ruas Cars Cars Cars Dars C ACCEPTED C ACCEPTED C REJECTED C REJECTED QACCEPTED C REJECTED C ACCEPTED C REJECTED YACCEPTED WITH CCMMENTS [_l ACCEPTED WITH COMM EN TS ] ACCEPTED WITM COMMENTS C ACCEPTED WITH CCWMENT3 IV. VERIFICATION OF OfsP0$3 TION NoT RECulRED taas a c .e::h:,:: y-.,..>2 ,,,,.T kulmED ,,,E a x w & </ D4,. n r-n e / mOMr .' .. . /-- ~ *',l w "~* NONCCN70Hld.ANCE REPCRT , CLOSURE VERITICATICN NC?. No. W3 .T3 5~ M Sar
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PIINSPECTICN: N Required Not Required %, Repair or rework to be vi::nessed by Ebasco's Q.C. Inspector %es C No Cor ective Action Taken (Use sketch 18 necessar-r) A u ~k /M a *: nu & Y4 Mk 49 Y btr$. Bel, & n 'sdaJ s el n~ m - x a1 ' nSm t n ee c!n Ns NJaa,,m. %J) LL L n s a a G 2 - J,e x!!a .Jn d' L A LtL A f () () I \\ () l O A t 4 t l, L i A d N -d- u A+ = r w* - s&x&L.L. 's/wk s 01 0 0 ,' ! Y m i -_ S 19 sw aU2 L & a !D Ad.kw
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Contractor's Q.C. Inspector- A- Cate ------ C Accept . E5asco's Q.C. Inspector . Date ~" 3ee.udw&, & LL -7n/7 Form No. ASP-III-7-4 (3-16-76) .. . _ . - . - . . . . . . .. .-.1.. .w. .. ~ ~ ' .A. A, EVALUATION OF DISPOSITION TO NCR SUPPL. #3 W3-636 The newly identified cracks which are indicated by the dashed line on the attached sketch, are to be sealed and repaired according to the Supplement 12 attached to UCR 'w'3-535. All such cracks beneath a specific concrete placenent must be sealed and dry prior to concrete piacenent. Ihese cracks, af ter being repaired, will not cause any further effect on the structural capabilities of the foundation mat. If any or the construction joints .e indicate leakage, the entire construction joint is to be sealed until all leakage ceases. Quality Control should carefully inspect the cracks prior to placement to verify that no cracks have been missed due to surface dust or placanent " equip =ent and that the cracids that have been repaired are not continuing to leak. .c .. E. u lagher 3-26-77 N Site Concrete-Hydraulics Engineer C C er ** 6 e e _ - - - *..mm.e.. ..4.. , ., . n o t . e - - e .ame ._ ese ===~ +==*e--=====*======m* - . ~- _ . . . . _ _ _ . . . ~ . . _ . . _ . .-- _ . _ _ . - - - . _ - - . .. s'. e*:.77 ESASCO 53RVICES eMCORPORATED g g,,,%, j,,,, Whire . PCAE , fie, CA Ive.,..se, CU ALITY AssuaANCE ,,,,,,...., y)8-42/G. noncouronnanca nsPour v " - c., >e - . ~ -+ , o.p....i 1 "'" '~" ~ ' "c" issrRectroxs.,s.eb ei<er i mo Teo cces: 2uo.u,e ses. es c l , . . . . . o. ..o ..r ... o.a.i e o.,s.s. o. .s. i tA.w eao sEs u r :n. 3 r.s.A.a. - i ,2..s,....o-sv.u.v.c. c. o. .o r.a.vo. ... . .o . . o. . . . ! J. A. JONES CDNs..wuCN CD. N3-!N-4
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- s. O ESCRIPT10N OF NONCONFORMANCE '" (Irems involved, Specifiserion, Code or $rende,d to which items Co Not Comply, Submit Sketch 11 Applicable) 2ere are concrete cracks in the base mat of the Peacter Auy4'iary W W c. "his is evidence bv the 'eereciation of water in small accents, ue thrcuch these c acks.
i ~hese cracks are lec'*ad " '5 a Gas Eur e Tank Prem, Waste C-as Tank Pcc- , and tiaste 2as C:=crassor "3" Pcc=, all at elevati:n -35.CO. Sse attac'.sf 7.S. A.?. re:ui- s .cs . for suc'31emental information. NCFG: Rese are examples of where cracks were fcund. l' n 45n.0: . .. .45.- , ,
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S. Ecre n JW 'L'--e (.um Q.A. Surv. Encr./Zhasco 5-11-63 I I. RECOMMENDED CISPo$lTl0N '** (Submir Sketch if Applicable) ke e ' c=- 0 F A *E s REPOGTABLC v. e :- ! ~ 10CF950.55fe) ! ~~; p Cle=e:- Shhgo r it l ~, 10CFR21 ,, i [ ["q
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i maus amo stomatuns on season ascouwenoine ossa erio= u n viv 6s /c oupa n y ea rs o. S. e ar e. G b N u_ M-@ M0 C A - 8 45C"O . b 2mE 4 3 , l 111 EVALU ATION OF DISP 051T10N SY EBDO, REASON FOR DISPOSITION HS8 I A , Ash l ' I V. CO RR ECTIVE ACTION "*' C R*mui'ed @ Nsr Required r li. 4L4%3 Y!* h EM*afNEEalNG O 00A'iry AssuaANcE O ceNsraucricN COTHEa man ionarums' maus;ana g ug p ,g mau s isiona ru ssi Naus ision a rvas-car (& ' S L/&& oars cars oars 7 ACCEPTED C REJECTED @ CCEPTED C REJECTED C ACCEPTED C REJECTED C ACCEPTED [ REJECTES O ACCEPTED estM CouesENTs O ACCEPTEo w Tw ComuRMrs O ACCEPTEo stTw OCMMENT.S C ACCEPTED dlTM COMMENv3 Y f. VERIFICATION OF DISPOSITION [ REQuinED [ m 8 "~ .................. ~ ~ATu - T' m =aT-4e6848899#4 e eemsumme .. _._e._._._ ~ Attac. h t #1 r4 7 ~212 Page 1 of 2 WSES-FSAR-UNIT-3 ,.S 3.4 WATER LEVEL (FLCOD) DESIGN 3.4.1 FLCCD PROTICTICN All seismic Category I structures, safety-related systems, and ccoponents 2 necessary for safe shutdown are located within the Nuclear Plant Island Structure (NPIS), which is designed against high water levels and wave run up associated with probable maximum flood (PMF) to elevation +30.0 ft. MSL. The NPIS is a reinforced concrete box structure with solid ex-terior valls with few doors and penetrations. All exterior doors in . 3 scp tu-g - *5"*a apd -- =~ g a related eq 'pcent and pene-y trgti nd - r3 .a l te: Q e Incnorth grade er 7 4@f2 p n L arn tai t side $ @Mt tom*e o + d d e 5 'h 4 5% g es n , & h Ali se
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&;;a:[1 5rd. ate M y$td$: Mh adi are protected agaihst PMF by the following: ccuponents l0 a) The NPIS is the ce==on structure of Reactor Building, Reactor Aux-iliary 3uilding, Fuel Handling 3uilding and Ccaponent Cooling Water System Structure. It is a rectangular box-like reinfor:ed ::ncrete structure 380 ft. long, 267 ft. vide and extending 64.5 ft. below ;2rade. The reneral_ scructural laycut is she".n in Figure 3.5-1_. 2 i Its co=cen foundation mac and 'excerior vall system are designed col ~ ' withstand all loadings of costulated fleeds as well as : crevice 'arrier. o - -J ,, \ a vacertient - m ) The common foundation mat is 12 ft. minimum in chickness and provided with double layers of nine inch PVC vaterstop at all construction joints. The valls subjected to floods are waterproofed up to plant grade. In addition, vertical construction joints of the .ralls be-tween plant grade and elevation +30.00 ft. MSL are provided with minimum six inch PVC vaterscops (Figure 3.4-1). Uplift for'ces created by the PMF to elevation +30.0 ft. MSL are accounted for in the design as described in Subsections 3.8.4.3.1 and 3.8.4.3.2. b) Housing within another structure (NPIS) designed to protect against flooding. The Reactor Building is enclosed within the NPIS and is thus protected against PMF. Table 3.2-1 lists the flood protection criteria applied to plant structures, systems and components. The a or b designation in the table refers to item a or b above. Figure 3.4-1 shows details of penetration, waterproofing and waterstops for the exterior valls of seismic Category I structures. All exterior doors f the NPIS at plant grade or below the FMF elevation, which house and protect safety related equipment, are designed to vichstand the hydrostatic pressures due to PMF and are watertight. The doors, which are located in the Reactor Auxiliary Building, are sving type (single or double) for protection against tornado missiles and PMF. The doors are c:ade watertight by continuous neoprene gasket on the inner face and sealed by the (G s, 4 3.4 1 l OU11p\ ud=ent No. 2, (3/79)g ,
- p )
1 Attach:nant #1 NCF 1-6212 Pags 2 of 2 WSES-FSAR-UNIT-3 use of eight quarter-turn latch and dog devices placed around the peri = ster of the door as shown in Figure 3.4-2. _, N There are a total of eight watertight access doors below elevation +30.0 ft. MSL.
- In the Reactor Auxiliary Building there are three of the flood doors located in the east exterior vall, and two located in the vest ex-terior vall above elevation +21.0 ft. MSL (Figure 1.2-9). In the Component Cooling Water System area there is one flood door located in the vest ex-cerior vall above elevation +21.0 ft. MSL (Figure 1.2-24). In the Fuel Building area there is one removable watertight gate located by the spent fuel cast decontainmination area above elevation +20.0 ft. MSL (Figures d , rg : sb L % ( a
.l qvty a CMR SC SC{ gf c(llaq . 4 4 Mpeng, na;k%34 joa;sdin y d.e Meb vs.rs sn-Coc: et o, jay g*Jacem S. {Y. ystructust:stra W~, M in Secticus A-A, 3-3 and I-I cf Drsvin;;s C-4995C4 to SC6. Those in the exterior valls of Reactor Auxiliary Buildings are shown in Sections A-A, 2 3-5 and F-F of Drawings G-565 to 567. Those in the valls subjected to "lood in Fuel Handling Zuilding are shown in Sections 3-3, C-C, F-? and Y-Y of Drawings G-533S01 to 503. Sece of the penetrations are located in the temporary blockout as indicated in the drawings. All the temporary blockouts are provided with keyvays and continuous PVC vaterstep.to assure watertightness and they are placed and filled with concrate after pipe installation. A typical detail of waterproofing =e=brane at pij.e penetra-tica is shown in FSAR Figure 3.4-1 and Drawing LCU1564 C-499S05. _(Drawings submitted under separate cover _).f'Th't NPTT~is designed to withstand 7 "hydrosti!!Tiosdings due to postulated floods, and water leakage because , - ! of cracks La exterior scructures, W g wate:E 22 and/or wi g Ay.e . ,j I action is not exeected.IIs the NPIS is also provided with floor dra ~ hystem capible of disposing the accumulated water through the vaste =anage-ment system (Refer to Section 11.2). ~ As discussed in Subsection 2.4.14, additional specific provisions for . flood protection include administrative procedures to assure that all watertight 1 doors below elevation +30.0 ft. hSL will be locked closed in the event of a flood warning. 3.4.2 ANALYSIS PRCCEDURES The maximum water level in front of the Nuclear Plant Island Structure following a collapse 'of the Mississippi River leves in the immediate vicinity of the plant concurrent with the PMF and from vindwaves super-imposed on the overland PM11 surge through Barataria Bay has been established in Section 2.4. It is calculated that the effective maximum I vater including dynamic head on the exterior vall is at elevation +27.6 ft. I 17 MSL. The NPIS is designed to. withstand a static water level at elevation +30.0 ft. MSL, thus providing an adequate safety margin. in addition, the subject structure is ^ signed to withstand a static water level at [ elevation +21.5 ft. MSL plus an addi.tional uniform dynamic loading equiv-alent to 300 lb per sq. ft. of exposure below elevation +21.5 ft. MSL. In the design of valls and foundation slab of NPIS, the loads under flood - condition are considered using the following load c.cmbination equa.cion. I \ , 1 NV N ', 3.4 Amendment No. 17, (4/81) A y 6 - , a '- '"E- '_ u m-- %d "- -- ' ^ '- E $g , Y D D *$212 Fage 1 Of, -. ~ _ - - - - , --_y m _ ~_ ,_%. , - g ----% .w ~ -,. m y'- 'un- v-- ___- re- . g 5Cm__.- *w. f-.,.a Aw cn *NS2t"f wee _ , - ~_ _ W.A e ~m 'W - m_ T.1-- - " S p._ . - _ - - - _ _ _ =r .; mA %iR' M- g. -- ,.'= m-: z-s -g m m@".'--- _ _ %_ .. gm awcr --m . _. m l p.2 =x_ m- - -- g- h _-,-n g-3 1 - 7 - -_- - - %.: % -- =-cr' .- . : g- _fI_ _ y- -- ~,ur---=w-ww- ~__g_ { I a g- _ ,,,;,7q y"~ ~ P ,.e W - &g , _ g ; .;.pis z$ ~ "' - t_ . a_- t,_EN . TNT - __ - , 'w ,, 1 l _rQ-Q~E1 o i l m , n . ., -M M._n w m - N I 9m?*'DW~fh$ g- - .r .. . p,.&3: .: = ,W8M,.w.w.6wM.,-35.M .z- - . mm W . W-.& c --h5 n4 wa. .".%&%5B n - u- :.; * :, . ~.-= . w -=- .. W.v--- P.w =a ~,%. .w w w 5G.;...%9 e- ;-- -e.. vp - n~. . -<==~e6~--, ,.. w : -A ^ ~ ~ - - ~ - - - - - *-~~ a; '. ;.^.w^ . & - m.- m; ;. m... m.,-, __.m - = y1,. .r.w"WW a ' * * * * ' am.-- m,- ,. m._,,.?..,. ?.., r. e . n .m.. ~; , 2,,c--:* ; .". .m*W.- ~. ~n., .~:: -:m. ~,~,,". m: . . p - * ^_ _ . h. __=v-.._~,- I _ ,4 _ .. 5 T - -- hk, m ,, 'h$.%~ . M* - " .'. "'%y W""'d"P*%W"r m - A -7 C"--nasn-c.e . <--m=~--- - - .- . M. M M .5 .,c .t ~ . . ' Atsr**'- IcStSv *- ~ . # u w .,- . *E%_ M.:+ Qu . - J '%m._ =.4 , . ..,,,-u.---- ..,n.-.~ --e ' . c._ -e .~....w.<-, M ,f* fig. -- .gggh q he d - _~ - - : & --r s : m-1 W. m + ..M . qqg ggg SM-5 ?5 ;.=--amarwm'- emmtesseere <-w J . . k ~~#O9 G,Ft 5 cth Ge- TAAk f.C":d$$N"zW"4ND*1 *d*O'i ~ me n-mna mm Q E, -1 .._ n-27f ". M W m%e W_st.rma'.saoCe/8:arp wn-mwm oww"<w we a gv.:n;"3$.sL71. A._ ?-2 gar w -- . .- w . mMgD .i u.,s ang ME- -vs-~~ w +, - .S% C P - - - - - --- -- %m v.: C-N :: ._ :::=.r: .M--=- r 25.w_;-r _ - - , 's --T M :b M ~.e--g W .kr a .w k T.Lu =~~ T,~.' W . l 0M - , m > n- mapau q _ . nrN e=: _--_ - - ~_ me%a-a- m_., m %wa.=_ .. .=, -*ca.. ___ _c ,m_ - ;- ., ; , .;y _. _ , , , __- mgN JP W3R -aw== _ v v m--- _._ w Q-Y p _ -.r._- -M,,, _.;.__..___m _W-Kgm-. c- - ~~ W- =- : - r.n<----.- w gy;w. m n _f3nrw,A_--me __-n .m_- =_ - - - - -- - m#Jiu'998"* v ~ --gw p p_ m e - NxufLs:;. h m e s S-Srp .g - - ~ ..- ,. ~. . -, - . .. . r. , - .. - . .._ .1. WQ
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' - -',, 6 w.c. m :_+ .: ~ w <.w =aJ &,ela,e ~ m. o.cw,I - - ~ ~ , _ _ _ . _ . , . - _ _ , _ _ . _ _ ___-,y- - - . , _ - - - - - - - - - m- kN C 3- b 2.12 6de ( ATTAC10fENT HE The effect of postulated widespread hairline cracting of the base =at has been investigated by Civil Engineering for stability of the Containment Vessel against flotation and overturning under buoyant conditions caused by postulated groundwater intrusion and by Corrosion Engineering for groundwater induced corrosion of reinforcing steel and Containment Vessel bottom head. t w w e e.s "* cm P5"**"' " * ^ ' *? "'" n ses vir w = = r*c .ce vo ricarica. @ r -ci. es Based on their findings that there are no stability or corrosion problems it'is concluded that no corrective action is required. i See attached =e=orandu=s:
- 1. Memorandum COR-L'43-77-55M from A.W. Peabody /M.D. Oliveira to ?. Grossman, dated August 5, 1977.
- 2. Me=orandum from P.C. Liu to B. Grant dated May 24, 1983.
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hz ' August 5, 1977 . , COR-LW3 55M. To: P Grossman # / lhw 1 ,% V.) f *W / From: A W Peabody /M D Oliveira
Subject:
LOUISIA R PCUER & LIGIII COMPANY WATERFORD SES U: LIT 3 CORROSION OF REINFORCING STEEL AND STIEL CONIAINMENI VESSEL PIATES IN CC:TIACT WII'd WATER In actordance with your telephone recuest, we have analysed a possible , situation in the ec==cn =at where supposedly secund water weeping fro =
" co'ncrete cracks found on the surface of the nac eculd correde the reinforcing see, and the outside bottes places of the Steel Contaic-ment vessel. '
It is a proven isce that concrete by its alkaline nature passivates carbon steel embedded in it. It is also kncun that water in contact with concrete bece=es alkaline and consequently its corrosivity to steel decreases cenriderably. In addition to these factors, assuming that ground water is lef t inside the crack network to a certain excent, this water will be near stagnant and without replenishment of oxygen. Consequently, the race of corresion
, under the above circu=s cances , if any, will be negli31ble.. This applies to the reinforcing rebars as well as to the outside of the vessel bocc:s plates, in case- the repairs presently being conducted do not fully prevent the water frem reaching the vessel. .
HD0/hn cc: R K S ta=pley , . J 0 Booth /B D Fowler .
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<;h L.;u_ & % . P c. Interoffice correspondence EEASCO cA7t Xay 24,1933 Pit.s arr. Filet 6-s-20 CHICE LOCATION Waterford Site 70 3 Cisn:
cyptCE toCATION 87 WIC mou P C Lih' GusJECT LOUISLANA POWER & LIGHT CCMPMrf WATERIORD 536 UNIT No. 3 5T!EL CONTArtMENT STA3rLm t nent stability ior of the con-This is to confirm our conversation that J:he steel to SL-1.50 ft, The results of the , taimaant would subject to subsurface vatar upreview have , l . inant will not be compromised. Volume II, FEAR Design Input - 6W1 l j . ! ' . / PCLtdg . cc C A Ennalsarts % e' ~ ~ 3 8 Kowalaks / P C Liu }'
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- 13. a) Did Koninsky recopy illegible cadweld records? b) Under whose direction? c) Why? d) What happened to the original records?
Response
a) Kaminski did recepy illegible cadweld records. b) It is not apparent that he received any specific direction to recopy the records. c) He has stated that while he was Supervisor of Inspection for J. A. Jones that " work sheets" were used during the actual inspection of cadwelds. Some of the records became dirty or wet. At the end of each shift or day, the information on the "vork sheet" was transferred to a clean report by himself or another inspector. d) One inspector has stated that the originals were attached to recopied reports. Hewever, L?&L has been unable to locate the originals of the inspection reports.
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- 14. a) Provide summary of actions taken following Hill's presentation of QA
, deficiencies. b) Provida detailed report on document review undertaken
.and all results.
Response: 14 (a) Deficiencies discovered by Hill were being aggressively addressed even before he left the Waterford 3 site.
- 1. On June 8, 1983, Hill's supervisor forwarded his June 6,1983 memorandum to the Ebasco Site QA Program Manager and recommended that the scope of the concrete records review be expanded.
- 2. In a meeting of July 7, 1983 Hill reco== ended that all concrete placement packages and soil packages be reviewed.
- 3. On July 11, 1983, project management decided to review a ~
10% sample of cha concrata placa:ent packages, and L7;L directed Ebasco to begin the review. (NOTE: Hill left the site on July 31, 1983). 4 In August 1983, the review of concrete placement packages was begun. In September, 1983, the review program was expanded to include 100% of the cenerete place = ant packages. The review is now complete and 33 new NCRs were written as a result of this review, none of which identified significant physical deficiencies and all of which have been properly dispositioned.
- 5. Soils and backfill records were previously subjected to a comprehensive review by Ebasco. All records were reviewed for existence of required records, chair completeness, and for proper organization by elevation and fill number.
Approximately 50% of the records were re-reviewed for technical adequacy. No additional soils non-conformances were identified.
- 6. To gain an even greater level of confidence, LP&L personnel, in accordance with standard procedures, are currently performing additional reviews of concrete placement and backfill records. Certain types of civil records are being 100% reviewed by LP&L during this review process.
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Resoonse 14 (b) In August of 1983, four (4) Ebasco Sr. QA specialists were requested to report to Waterford III. The scope of this request was to take a 10% sampling of J.A. Jones Concrete Placement packages and to do an unbiased cursory review (based on the individuals past background of other jobsites civil documentation) to establish an understanding of the general condition of the packages with respect to records accuracy, ce=pleteness, legibility and adequacy of record availability. Following a brief orientation period, the 10% review and summary was conducted. The sampling included 100% of the base mat placement packages and a selection from the Fuel Handling Bldg., Reactor Auxiliary Bldg, Shield, Dome, Ringwall and the Reactor Containment Bldg. The recom=endation proposed to Ebasco/LP&L top management after the review, based on the general concerns noted, was that a 100% review should be performed prior to these packages being turned over to the client. A brief synopsis of the concerns noted in this initial review is as follows:
- 1. Some packages had embed legs which, at the ti=e, were not obtainchie in the package.
- 2. Some packages had cadweld maps which, at the time, were not obtainabic in the package.
- 3. Scme packages had missing concrete test records which at the time were not obtainable in the package.
4 Some packages had curing records which were inadequate.
- 5. Some packages had concrete mix designs which were indicated as being used but which had no apparent engineering approvals.
- 6. Sc=e packages had no traceability as to which concrete =ix design was used.
- 7. Some packages had batch tickets which, at the time, were not obtainable in the package.
- 8. Some packages had problems with respect to the timely certification of inspectors.
Following this 10% sampling review, Ebesco and LP&L management agreed that a 100% review of these records was essential. A new review group was formed in September 1983, (which consisted of two (2) of the original reviewers and our (4) other participants). This group, for a two (2) week period, scanned all applicable procedures, specifications, and standards in order to establish a review procedure which would assure a uniform and
7 acceptable method for the review of packages involved. This procedure (QA-9 Supplement 48-3), which for=ed the basis for the review, also established acceptance criteria for the review. The following are examples of the minimum records which were required.
- 1. Preplacement checklist
- 2. Plar:ement checklist
- 3. Field Test Records
- 4. Lab Reports
- 5. Repair Documents Items within the scope of these records which required review, as a minimum, were items such as:
- 1. Personnel cartifications
- 2. Caring Adequacy
- 3. DNs, DRs, and NCRs were initiated and closed where applicable
- 4. Concrete placed was approved for use
- 5. All tssting and results were acceptabla
- 6. Documentation was legible and co=plete NOTE: Also taken into consideration was. The fact that, during the mat placements, Ebasco performed independent Quality Control functions.
When J. A. Jones records were not available, Ebasco duplicate inspections were substituted per Ebasco Procedure QAI-9 Rev. O Para. 6.1.4 which states, "In case of illegible or missing Jones documentation, the parallel Ebasco QC Inspection can be utili:ed as supporting documentation . . ." During the 10% review, this duplication was not taken into consideration. During the 10% sample review, many items appeared to be discrepant. The 100% review resolved many of these apparent discrepancies. Some examples are as follows:
- 1. Missing records were retrieved from applicable contractors records.
- 2. Missing records were retrieved frem other placement packages (misfiled).
- 3. Missing records were retrieved due to misfiling in the vault.
- 4. Since some placements were conducted at the sare time as others, missing records were retrieved from other packages. (i.e.) If placement No. 10 and 11 were placed together the records generated would reference both placement numbers. The inspector would make (1) one copy of each record and compile (2) two packages. (1) one package would be No. 10 and (1) one No. 11. The placement number pertaining to each unique package would be circled or in some cases highlighted to show which set of records went to which package. While during the review, if the review had, for instance, a preplacement record missing for placement No. 10, he Juld look e another record that was obtainable in package No. 10 to determine if a this placement occurred at the same time. If, for instance, he looked at a postplacement record in No. 10 and saw that No. 11 was also entered on this document, the reviewer would go to package No. 11, pull the missing preplacement record, copy, and place this document into package No 10-thus making a completed package.
M
- 4. Finally at the conclusion of this reorganization and review of these Civil Records, 33 Nonconformance Reports were generated. which adequately documented discrepancies outstanding. The following are the discrepancies which were documented as a result of the review.
Some of these areas were covered under other re<iews in the past, however, since this review was a 100% re-review, new documentation was initiated. Although every placement has been documented in this manner, the following listing only deals with the Basemat. Any discrepancies not noted within the following seven (7) NCRs generated against the basemat were either satisfactorily corrected prior to the conclusion of this review (or) were satisfactorily identified on previous NCRs. (See the response to Question 1). UCR #W3-7152 (Eye Exams) Description (4) Jones Inspectors performed inspection prior to having eye exam on file (10) ce==en fcundatien structures. Disposition Two of the four f aspections were certified on 11-24-75 and 11-26-75 apiarently eye exs=s lost. Other two inspectors listed on NCR#W3-7156 NCR #W3-7153 (Cold Weather Cure) Description Surface temp. of concrete dropped belov 50' on (6) occasions and ambient below 45' on (19) occasions without notifying engineering or an NCR written. Disposition ACI require concrete to be maintained to a min. of 40* for Class I structure 72" thick lowest temp recorded was 42*. Test results on 28 days exceeded 5000 psi therefore on (6) occasions this did not affect the 4000 psi required strength. MCR 173-7154 (Cure'Racords) Description On (19) nineteen placements records of curing are not complete Disposition Method of curing is on Jones Inspection Reports and on Pour Plans. No average temperature occurred to prevent hydration. Cure records shown that moisture was sufficient for proper curing. NCR fW3-7353 (Mix Design) Description Mix designs were used without engineering approval Disposition Mix designs were approved by engineering. Mix design number was apparently misprinted batch tickets give all quantities.
.v.
t NCR #W3-7150 (No Certification on File) Description (2) Jones Inspectors performed inspection without certification on file Disposition Resumes and Dual Inspections by Ebasco rendered work as being acceptable. NCR #W3-7149 (Inspectors Certifications) Description Six inspectors performed inspections prior to certification Disposition Use-as-is based on prior experience / training and currently have records of completing certification NCR OW3-7151 (Eye Exams) Description (9) Jones inspectors perfor=ed inspections prior to eye exa=s Disposition (9) Jones inspectors have exam after the fact. Eye sign usually gets worse rather than better without corrective means Af ter the review of all packages was concluded, but prior to turnover, additional steps were taken to aid in future handling of subject packages. All concrete placement package numbers as well as all DNs. DRs and NCRs were entered into the Waterford III Site computer program. Printouts were developed to aid in package retrievability as well as traceability to discrepancies per package and total placement accounta,bility. Other steps taken were to compile various back-up record traceability through means of various record matrixes (which can be seen in attachment to Item No. 20) to aid in the retrieval of applicable documents which are related although not generally found within the concrete placement package itself. In January, 1984, all records were turned over to the QA Records Vault as being completed for review and closure of all corrective actions taken. 1 e ew ww . m hw
- 15. Provide LP&L's evaluation of adequacy of Harstead's third report.
Does LP&L assert that it represents their views as well?
Response
LP&L contracted with Harstead Engineering Associates (HEA) to perform a review of the records associated with the Basemat. Their review was independently performed and copies of the report (HEA 8304-3) were distributed in parallel to LP&L and the NRC. LP&L has reviewed this report and concludes that the technical review of the records necessary to assure the adequacy of the 3asemat was indeed perfor=ed by HEA. Further, LP&L strongly endorses the conclusions reached in HEA 8304-3, Harstead's third report. i a I I __ ,_
- 16. Provide specific basis for Harstead's conclusion that the documentation problems do not affect their prior conclusion as to basemat's strength.
What documents did Rarstead review? What did he look at? Did he see the Phearson-Brigg memo? Hill's NCR's? Other NCR's?
Response
HEA Report No. 8304-3, dated 01/09/84, su==arizes the results of the review of construction documentation performed on behalf of Louisiana Power and Light Company. The following items were reviewed: a) Concrete pour packages b) Cadwelding activities including tasting c) Clam shell filter blanket under the basemat d) Waterstep splicing and testing Thare are 29 cenerets peur p:chsges that =sha up the bes2= :: 499502-1, 2, 3, 4, 5A, 53, 6, 7A, 73, SA, 83, 9A, 9B, 10A, 10B; 499S01-11A, 12A, 13A, 14A, 15; 499503-11B, 123, 13B, 143, 16, 17, 18, 19. Each concrete pour package contains the following documents.
- 1) Concrete pre-placement checklist record (J.A. Jones)
- 2) Concrete pre-placement checklist record (Ebasco)
- 3) Daily concrete inspection (Ebasco)
- 4) Concrete placement inspection (Ebasco)
- 5) Concrete curing log (J.A. Jones)
- 6) Concrete curing record (Ebasco)
- 7) Concrete test record (Ebasco)
- 8) Concrete physical tests (Ebasco)
- 9) Concrete pour plan (J. A. Jones)
- 10) Embed map log (J. A. Jones)
- 11) Cadweldad locations (as-built)
- 12) Requisition on warehouse
- 13) Concrete mix delivery tickets These documents were reviewed in their entirety.
The following documents were totally or partially reviewed for the basemat cadwelds.
- 1) Daily cadweld inspection reports (J. A. Jones)
- 2) Cadweld daily inspection-visual (Ebasco)
- 3) Reports of tensile tests-cadweld splices (Ebasco)
- 4) Weekly cadweld or rebar test reports (J. A. Jones)
Emphasis was placed on a review of the censile test reports and daily inspection reports. Sections 4 and 5 of the referenced HEA report detail the review
. performed for items (c) and (d), the clam shall filter blanket and waterstop splicing.
, . - , , - - - - . ,- ,- ,- - - - - --r,_ _ _ .
- -- , + - - . -
The Phearson memo, although not a formal document, was provided to HEA by Louisiana Power and Light as part of the documentation comprising Stop Work
- Order No.1 (see HEA Report No. 8304-1 dated 09/19/83, Subsection 4.1).
HEA considers that the issues raised in the Phearson memo (dated 12/15/75) are adequately addressed in Stop Work Order No. 1 (dated 12/16/75). \ J
Following is the list of NCR's that were reviewed by HEA. NCR NO. Title Comment W3-10 Concrete Placement W3-24 Pour 499502-7A-Air Content W3-25 Pour 499502-7A-Slump W3-26 Removal of Formwork W3-27 Placement 499502-8A-Embedded Elephant Trunk W3-29 Foundation Hat-Air Content W3-31 Common Mac-Air Content W3-32 Cc==on Mat-Nu=ber of Revolutions W3-33 Common Mat-Air Content W3-39 Common Mac-Strip #3, Section 10B 43-93 Cc =en Mat-?lacement No. 499503-19 W3-5563 FH3 Bridge Crans-Connection Tests ".A.* W3-5564 FH3 Stairs-Welding and Bolting Inspection N.A.*
~
of Seismic C1 ass I Stairs W3-5565 FH3 Bridge Cran N.A.* W3-5598 Tubing N.A.* W3-5973 FHB Tornado Door Frame N.A.* W2-5997 Clam Shell Filter Blanket Under the Nuclear . Plant Island W3-5998 Production Cadwelding W3-6234 Cadwelding W3-6245 Daily Cadweld Inspection Reports . W3-7149 Concrete Placement Packages-Common Foundation W3-7150 Concrete Placement Packages W3-7151 Concrete Placement Packages-Common Foundation
'W3-7152 Concrete Placement lackages-Common Foundation W3-7154 Concrete Placemen- Packages W3-7353 Concrete Placemenc Packages W3-7481 Cadweld Tensile Test Reports
- Not applicable or related to Basemat ko- -+4*-. _ me
-W
- 17. Provide differential settlement contours for 6 month periods, starting from early 1977 to present.
Response
Attachments are provided which present differential sectiement contours as available. These attachments represent a period between April 1977, and August 1979. I i
- 4 o
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EBASCO SERVICES s v- bEb cave IT. 'Il
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- 18. According to the sectiement contours shown in figure 2.5.118 the curvature in concave downward in both directions . This implies cracks on the top surface in both directions which would not penetrate all the way through.
In view of the above why did the water seep thru? Why doesn't the crack pattern match the given differential settlement? Is it possible that there are localized convex surfaces on the mat which are not shown in the figure (the grid is quite rough)?
Response
The crack pattern does follow generally the pattern of mac differencial sectiecent. The conteurs of diffarancial settle:ent show a prenounced greater convexity in the north-south direction than in the east-west. The general crack pattern lies east-west reflecting the pronounced north-south convexity. The minor water seepage showing at some hairline cracks in the surface of the mat has been identified as originating at flexural cracks at the bottem of the mat and following embedded items which intersect these cracks, such as structural steel rebar support structures and conduit, horizontally and vertically through the sat to an intersection with hairline tacks at the top of the mat. Localized reversal of curvature (convex surface) may occur in the immediate vicinity of heavy loads. These may be undetected by the settlement monitoring program. 0 e = Se p + go .e aw mewe- e e ah
s
- 19. Please provide all soil properties (re. re ults of soil tests, reports confirmed compression test results, boring records, shear modulus, etc.).
Response
Soil properties, boring logs, test reports and results are provided in FSAR Chapter 2.5 and Appendices. e-G 4
-r eos a e-e4 e. , , ege,ee.g--
- - _ _ _ _ _ _ . _ _. . __ = . . . _ _ _ . _ _ . _ ___ _
l , l . l l.
- 20. Provide all concrete property data, rebar data, placement data (ie also
. detailed as built drawings of mats).
Response
i Attachment "A" consists of a listing of documentaion which typically exists in cht. Waterford 3 concrete placement packages. This docu-mentation is available for review at the Waterford 3 site. i I Attachment "B" provides a list of associated quality records generated (not filed in the placement packages) which can be found in other QA record vault locations. l l l l 1 r r e L -- - - - - , - - - - - - - - -
ATTACIDfENT "A" CONCRETE PACKAGE CONTENTS I Required Documents A. Preplacement Checklist Records.
- 1. Concrete A. Sandblast B. Greencut C. Treatment
- 2. Forus A. Dimensions B. Line end Grade C. Clean D. Tight E. Braced F. Coating l
G. Chamfer Strips H. Key Ways I. Block Outs J. Whalers and Strongbacks K. Waterstops L. Release Agent
- 3. Reinforcing A. Bar Quanity B. Spacing C. Elevation D. Cadwald Mapping
- 4. Embeds A. Quanity B. Line and Grade C. Elevation D. Identification
- 5. General A. Cleanliness B. Instrumentation C. Weather. Protection am, e w w - .-me-
i ATTACHMENT "A" (Continued) t B. Daily Concrete Inspection Report
- 1. Q.V. Inspector A. Placement Area / Location B. Area / Location Released by Engineer i
C. Concrete Delivery Acceptable D. Concrete Placement Acceptable
- E. Consolidation Acceptable F. Finishing Acceptable l G. Curing Acceptable C. Concrete Curing Log
- j 1. Q.V. Inspector A. Data
. B. Time C. Current Temperature ( D. High Temp. 2 ' E. Low Temp. T. Continuous Moisture G. Maintain log for seven (7) days for Items A thru T D. Concrete Physical Test Records 1 i Many Concrete Packages contain test records, but not all. A ec=plete file of test records can be found in the vault arranged by placement dates. 1 E. Repair Documents This documentstion eculd be for such ite=s ast repair of bent rabar, addition of stub-ups, or a possible veld repair on an embed place. If there is any damage by whatever means, these items were documented on NCRs. { II Support Documents ]
- A. Concrete Tour Plan l B. Embed Map Log 4
4 C. Cadweld Maps and Map Logs D. Requisitions on Warehouse
- E. Batch Tickets 1 .
4 i i
. . . . . _ _ . . . ~ . _ . . . . _ - , , _ - ~ ~ _
=
e ATIACHMENT "B" Inspector Certifications ( I A. J.A. Jones l
- 1. Cadwelds
- 2. Concrete Placement B. Ebasco l 1. Batch Plant
- 2. Concrete Test Station
- 3. Placement 4 Backfill C. Barrow-Ages / Peabody /GE0 i
- 1. Concrete Lab
- 2. Concrete Field Testing
- 3. Concrete Batch Plant Insp. and Mix Design 4 Soils Lab and Field Testing
- 5. Rebar Tensile Testing
[ II Concrete Materials l A. NTLs Receiving Docs / Carts , 1. Admixtures l
- 2. Cesent Types I & II - Midlothian & Artesia
- 3. Aggregate
- 5. Materials Acceptance Tests '
- 1. Calibration of Test Equipment
- 2. Test Reports on
- a. water quality
- b. sand - daily, weekly, monthly, bi-annually
- c. " - daily, weekly, monthly, bi-ennually
- d. 1" - daily, weekly, monthly, bi-annually
- e. rebar pull tests (tensile)
- 3. Offsite test Reports
- a. cement
- b. water
- c. ice 4 Cadwald tensile tests C. Miscellaneous .
- 1. DNs
- 2. DRs
- 3. NCRs e
n ===.9 mm ee NN ' N *N'*""*'N"'* * ' - ' ' ' W
(
- 21. Provide any revised calculations that include settlement efforts.
Response
1 No revised calculations were made. The original calculations included i provisions for differential settlement effects utilizing variable spring constants to provide sufficient conservatism in the strength of the mat to accomodate differential settlements. 1 i I t i ! i 1 I i l i 4 6 i i I i b i
! l I , f-i I
t i i' l i , I r t t 4 N f I . 'I l , i l l . f
.. . _ . l
- 22. Is the Phearson meno accurate? What kind of actions has LP&L taken to i respond to and resolve his allegations?.
l Responset ' l .
' It is improper to characterize the content of the Phearson memorandum as !
" allegations." The LP&L and Ebasco QA Reports for basemat placements 6 and ;
2 include " findings" which are, in technical content, identical to the items listed in the Phearson memorandum, and other findings not included in the Phearson memorandum. To that extent, the Phearson memoranum may be i characterized as " accurate " although the proper method of reporting these , findings, the formal QA reporting process, was not followed by Phearson. 1 j Since findings essentially identical to the Phearson findings were included [ in the official QA reports and since the QA reports required forms 1 " closure, the Phearson findings were effectively addressed through the i formal QA process. These actions were taken regardless of the fact that l LP&L was not even aware of the Phearson memorandum at the time corrective
; action was being carried out, i .
l It is reasonable to conclude that Phearson himself was satisfied that i adequate corrective action was taken since, to the best of LP&L and Ebasco knowledge, he did not ever formally report dissatisfaction with the {, corrective action, or recommend investigation of the quality of placements
- 6, 1 or 2 during the remainder of his tanure en the Waterfard 3 pauject.
Phearson left the project in mid April, 1976, some 4 months after issuance ; of Stop Work Order 1. i
! i i !
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mes
- 23. Menos of inspectors Hill and Davis, as reported in GAM 3IT, stated that they found a broad range of de'iciencies in virtually every record package examined and the situati..a demanded a complete review of all civil /
structural records. What is your response to this allegation?
Response
Messrs. Hill and Davis were document reviewers. Their assigned duty was to review construction records and to identify records deficien-cies. Their memoranda identified records deficiencies. The deficiencies documented in their memoranda were appropriately entered into the programmatic process required by the Waterford 3 Quality Assurance Program to assure the proper dispositioning of such deficiencies. As a result of the memoranda, the records review program evolved to include a complace review of all civil / structural records. Corrective action on deficiencies, identified during the expanded records reviev program, are nov essentially complete. Little physical corrective action has been required. Also, see Respcase to Question 28. t w m m. m mo + 4 '* *
- 24. CAMBIT reported that there was falsification on cadweld splices of reinforcing bars. What is LP&L's response to this allegation? .
Response
See attached Affadavit of Thomas F. Correts, dated January 12, 1984.
.i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Acceal Board
- In the Matter of )
)
LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 OL.
)
(Waterford Steam Electric Station, ) Unit 3) ) AFFIDAVIT CF THCMAS F. GIRRETS THCMAS F. GERRITS, being duly sworn according to law, de-peses and says:
- 1. - My name is Thecas F. Gerrets. I as e= ployed by Louisiana Pcuer & Light Cc=pany as the Corporate Quality A==ur-ance Manager, with principal" duties related to the design and construction of the Waterford Steam Electric Station, Unit 3,
- 2. The Dece=b'er 10, 1983 issue of Ca= bit alleges en page 22 that at Waterford 3 there are "... missing (QA] docu=ents that !
have been replaced by phony documents manufactured after the facts faulty documents that have been altered or ' doctored's and some instances involving possible forged signatures on safety in-spections okaying the workmanship on critical safety-related structured." I and others in my quality assurance organi:acion have investigated these allegations, and we have found no
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instance of anyl records containing false or manufactured test or inspection data'and no instance of malfeasance in the gener-scion of testing or inspection reports.
- 3. 1 can only speculate on the source of these -
unexplained charges. The articles describe a meeting with . George Hill, a QA records reviewer, myself, and other QA per-sonnel which took place on July 7, 1983. Reference was made by Mr. Hill to a previously existing Nonconformance Report ("NCR"), NCR W3-6245, dated May 20, 1983, which identified 13 daily cadweld inspection reports (out of thousands of such reports) containing questionable initials of quality control inspectors whose job it was to inspect each cadweld of the reinforcing steel for the foundation mat. Each instance was investigated and supplementary and backup documentation, as well as personal on-site inspection of the reports by three of the inspectors involv.ed, verified that the involved welds had, in fact, been properly performed and inspected. On this basis, the welds were determined to be* acceptable, and the NCR was duly resolved in accordance with the QA program procedures.
- 4. I know of one other instance where questions arose concerning the authenticity of record signatures or initials.
This is identified on NCR W3-7481, and involves cadwald tensile test laboratory reports where both an original and a reconstructed duplicats exists. The laboratory which performed the tests was contacted as w' ell as other Ebasco personnel who 2-4 y
__ .-~ were involved with these specific records. The individual who was the =anager of the testing lab during the ti=e when the
- docu=ents were generated has inspected the docu=
- .ncs on site and has certified the original docu=ents. Both the testing laboratory personnel and Ebasco personnel fa=iliar with the ,
procedure which were in effect at the ti=e the docu=ents were generated confir= that, in so=e cases during construction, it was thought that the original test docu=ent was lost and therefere a duplicate was constructed fro = original test data which existed in the testing laboratory log books., In all cases, the tensi'.e test data on the duplicate docu=ent has been verified to be identical to that which exists on one or = ore of the following j docu=ents: the original docu=ent, a photocopy of the original j docu=ent, and the original o'r a photocopy of " Record of Rebar User's Testing" (For= /QC-28). On this basis, the test data were deter =ined to be proper and-acceptable, and the NCR was duly resolved in accordance with QA progra= procedures. W& Tho=as F. Garrets Subscribed and sworn to before ce . . this /@ day of January,1984.
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.srch is,1984 ROTH S. LICC CX Sener voce Presicent Nuc: ear Ccerancns W3K34-0629 Q-3-A35.02.25 Mr. Jchn T. Collins Regional Acninistrator U.S. Nuclear Regulatcry Cc :sissica Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 7c011 SUBJE~T: Waterford 3 SES Oceket Mc. 80-382 ~
Cear Mr. Collins: rra U At a public meeting with NRC in Arlington, Texas og February 1,1984,'LPLL, presented a status report en the results of its eview of public alleg3tiens concerning arcDiems with Waterford 3 qualitf ass #sace cicumentation. We agreed at that meeting to provide MRC with a written sumntry of Our acticns anc ,the resul ts. Enclosed is a su: mary report of LPU, efforts in these areas 'ahich relata to recent allegations regarding Watertord 3 quality. Occumentatien supporting this sumary is located at the Waterford 3 site and is.available for the NRC review. ,, Ar5 7very truly,
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LP&L RISPCNSE TO ALLICATIONS REGARDING 'JATERFORD 3 CUALT"T (.,
?URPOSE The purpose of this docu=en is to provide a su==arr of LP&L effor:s in those areas which relate to recent anegaticas regarding 'Jacerford 3 quality.
Documentation supporting this su==arv is located a: the 'Jacerford 3 si:e and is available for NRC review. 3!! CSS!C'T Allega: ions of Quali:7 . Assurance failures and faul:7 c:nstn ction a: 'ia: arf::d 2 have surfaced via a reporter, writing for a New Orleans, Louisiana weekly newspaper (:he anager) . The identified source of infor=ation for :he alleger has been a person who was a= ployed to reviev Cuali:7 Assurance docenents for Ebasco Se: rices, Inc. , the constne:ics =anager of 'Ja:arfe d 3. .C:h: gh :ha
- ewspaper ac:=un:s s:: ngly insinua:a :ha: :he actual c:=s==c:1:n is unacceptably faulty, :he an egations are essen:1an y li=1:ed to anaged discrepancias in :he instanation docu=entation. For s1=plicity, the anega:1ons are grouped ac:ording :o conten: under r.ine categories, along vi:n L?&L responses based on review and research cenducted to date.
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Page 2 7-.. I. ALLICATIONS THAT THE MANAGEMINT OF THE VATERFORD 3 FROJEC", PARTIC':LARLT IN L?&L AND E3ASCO. CEOSE TO IGNORE OR TO COVER UP DEFICIENCIES.
- Allegacious that the sanagement of the Waterford 3 ? ojec: chose to ignore or to cover up deficiencies are totally erroneous. LP&L is comaicted to che risc hus quality assurance requirements of nuclear power plant const:uction and operation, and has responsibly fulfilled this conniement throughout the projec: history.
L. A multi-layered Quali:7 Assurance ?;ogram, meeting the requirenen:s of 10CyR50, has been in effec: throughout the projec: history. Although cri:eria and interpretatics of c:1:e:12 for nuclear projects have generally become note conservative over the projec: history, the Waterford QA Program has kept pace by increasing :he Quality Assurance effort. i 2. To date. :here has never been a si;;nifican: projec:-specific quali:7 Assurance breakdown oc the project which was discovered other :han through operation of the 7-3 Quality Assurance program 1:self. The m ir such " breakdown" which night Tuly be classified as significant resul:ed in i=posi:1on of a $20,000 fine by NRC in early 1983. This " breakdown" was discovered within the W-3 Quali:7 Assurance ?:ogram, and L?&L established a broad correc:1ve action progra=. Mi:13ation of the fine by NRC from S40,000 to 300,0C0 occurred because of NRC recognition of the broad corrective action taken by L?&L and the LP&L role on ident'fying and reporting the
" breakdown."
- 3. L?&L has, from the outset, let it be known that the coupany's interest is to construct and operate Waterford 3 properly. The first official representation of this interes: in quali:7 vas in :he
? eliminary Safety Analysis Report, issued in the last days of 1970.
The L2&L policy statement in the first L?&L QA Manual for Construe:1ons issued in June 1971, reiterated this interest, as did subsequent revisions of the manual. Since early 1930, :his interes: in quali:7 has been fur: hor emphasized by a letter from LP&L management, posted conspicueusly in various locations on the site, urging all projec: personnel to nake known any deficiencies of which they are aware. Recently, LP&L has initiated a Quality Awareness Hotline Program. This program allows any person on the project to repor: unresolved quality concerns to a telephone number which is =anned during :he normal workday and recorded during off hours. Anonym 1:7 is assured, if desired by the caller. Each call must be followed up by a responsible LP&L Quality Assurance Engineer. The hocline program posters are located throughout the site, and personnel have been individually notified by distributie of hotline information with their paychecks. Sine,e publication of the Hocline program on December 19, 1983, there have beta no calls to report deficiencies. 4 In an effort to further educate craft foremen with regard to the importance of quality assurance, LP&L direc:ed Ebasco to i=plement a Toremen Training Program. The Foreman Training Program was carried out in the summer of 1981. 6 *
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- 5. 10C7R50.55(e) and ICC7121 require reports to the NRC for certain r s, types of deficiencies. A formal program has been in existence at Waterford 3 to assure compliance with these regulations. he -
procedure requires that nasco Nonconformance reports (NCRs) be reviewed for reportability. Primary responsibility for NC2s, including reportability review, has been delegated to nasco. In addition to performing formal audits, L?&L Construction QA is on distribution for n asco NC2 correspondence. Formal in-process L?&L action with NC2s was not required. However L?&L QA has actively participated, by commenting on Dasco's performance of this task and by causing increased attention to particular NC2s as appropriate. L?SL has recently reviewed a sample of approximately 1,100 NC2s (of about 8000 total) using L?&L QA personnel, to make doubly sure that the reportability review has been properly accomplished by nasco. No additional 10C7R50.55(e) or 10C7121 reportable ite=s have been identified in this sa=ple review, although one ice = is curren:iy under further review for reportability. L?tL is. ace ==plishing a 100% review of NC2s in this manner prior to fuel load. .
- 6. Most recently, L?&L has conducted interviews vich over /.00 QA/QC person =e1 at "acerford 3. Anonysity was offered and 7; of interviewees chose to re=ain anony=cus. The results are that:
- a. None of the interviews resulted in the need for significant corractive action.
- b. 82 either identified no cencerns or offered comments 04 -
supporrive of the quality and integrity of Waterford 3 QA activities.
- c. 5: identified minor concerns which were already being addressed.
- d. L3 identified concerns [ r which L?&L incands to respond to the interviewees. These concerns can best be charac:erized as representing communicacious shortfalls (e.g., the inter-viewee was not informed of the corrective action on a deficiency which he/she identified) or 1sek of unders: = ding by interviewees of Quality Assurance Program elements outside of the intervieves's scope of work. L?&L intends to provide written responses to the individuals identifying these concerns.
This series of interviews conf'irmed that intimidation of QA/QC personnel is essentially non-existent. Such intimidation has not been tolerated on the Waterford-3 project and, in at least one instance, a person has been terminated for such intimidation. Good job discipline is one reason why Waterford-3 has achieved a better-than-everage record among U.S. nuclear projects. Disciplinary action for cause does not constitute inr' ddation as used in this context although, in the minds of those personnel who l have been disciplined,*1t night. Dur1=g the course of the project, l allegations of intimidation or harrassment were fo11 cued up prc=pely by D asco and L?&L. L?&L is not aware of any situation whereby (' quality information has been withheld by an individual, including alleger's information source, or whereby inspectors accepted deficient work because of intimidation or harassment. e
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- 7. LP&L offerts have clearly been directed ecvard quality. including
- the identification and correction of deficiencies. On the other hand, the natives of the alleger nust seriously be questioned, since allager publicly boasts that, apparently thr: ugh allager's own deliberate effort, the EC was unsuccessful in " seeking to discover what other facts (allager) night know about problems at Waterford 3...."
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l i Page 3 II. ALLEGATIONS THAT TEE ALLEGER HAS BEEN RES70NSI3tE, TH10CCH !!S p " Dive.sTIGATIONS," FOR SHEDING SIGNIFICANT NEW LIGHT CN THE OUALI~T OF I THE WATERFORD-3 FROJEC". - Allegations that allager's " investigations" have identified, for the first time, any significant new information regarding 'Jacerford 3 quali:7 are totally erroneous. On the contrary, discovery and correction of all significant quality deficiencies has occurred within the bounds of the Waterford 3 Quality Assurance ? ogram itself. A. Basemat Cracks
- 1. Allegers " disclosure" of concrete problems (" cracks" in the Waterford-3 basemat) appeared publicly, for the firs: :1:e.
Long af ter the ft:sc appearance of hairline cracks in the basemat. Cracks were initially discovered in 1977, within the project QA hierarchy and were formally dispositioned i= ac:c: danes vi:h project procedures. Follevi=g the 1:i:121 discovery, there have been several addi:icnal i=scances of crack identification, reporting, and disposition 1=g. " Cracks" were most recently identified on May 9, 1983 by Ebasco quali:7 Assurance, and an Ebasco nonconformance report was issued on May 11, 1983. None of the more rece:: discoveries ess: cono: on the validity of the 1977 dispost:1cn.
- 2. As a consequence of the allegations, an i=dependen: consul:1ng firm was contracted to perform an i= dependent review of :he basemac installation. It should be recognized that " crack" widths were so small as to be undetectable using sta=dard Q- inspection techniques. This expense was authoriand by L?5L despite overwhelming advice f ca 'movledgable civil engineers that the " cracks" posed no threat to safe plant operation. That is, the study was authorized even though L?&L had already achieved more than an adaquate level of confidence in the basemat installation.
The independent consulting fira was allowed to have any information which it desired to complace its evaluatien. A: the outset of the study, the independent consui:ing ft = vas given copies of the Si.=1ficas: C: strue:1:n ::aficiency (SCT' packages relating to the basemac. The consulting firm concluded that "...there is no evidence of any process which has been or could be detrimancal to the structural is:eg:1:7 of the foundation mat." As a further causequence of the more recent allegations, the same independent consulting firm was contracted to review all basemas concrete placement packages and related documen=ation. The consulting firm reported, as expected by kncvledgeable civil engineers. that "...no modifications are necessar* :o the conclusions reached previously in (consulting firm's) reports regarding the structural adequacy of the basemat." e h k .I
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- 3. Construe: ion Records f.- L. Construction records discrepancies have been found and corrected as a matter of routt=e, using project procedures
designed for this purpose. Additional records discrepancies - were discovered during a final review prior to curuing over systems to LP&L Startup forces for testing in early 1982. A typical response to such a discovery is to expand the reviev program to determine the extene of similar discrepancies, and such a program expansion was directed by LP&L in :he fall of 1982. e
- 2. ne alleger's information source, a=eng ochers. was hired for the purpose of reviewing larger sanples of construe:1on documentation and identifying any other discrepancies so :hac the discrepancias could be properly disposi:1oned. Se allegations played no part in :he identification of discrepancias or in the develop =en: or i=ple=en:s:1on of corree:1ve ac:1on regardinz such discrepancies.
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- I Pags 7 III. ALLEGATICNS RELATUIG TO A MEMORANDUM WRI*"ET ST MR. JCSEPH D. DAVIS. CN f-- DECIMBER 9, 1982. AND MR. DA7IS' CHANGE IN ASSIGNMETT.
The allegations relating to the memorandum written by Mr. Joseph D. Davis on December 9, 1982, and Mr. Davis' change in assignment are totally erroneous.
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Mr. Davis was involved in a records review program which had grown ou: of
- he discovery of records discrepancies, in early 1982, during a final records review prior to turning over systess :o L?&L Startup forces for testing. Mr. Davis' job was to identify records discrepancies.
L. Mr. Davis did vri:e a December 9, 1982 =amorandum. The se=orssd= vas written to aid Ibasco in determining an appropriate sa=ple size of civil records to review. The nature of the problems identified by his memorandum reflected poor recor'd-keeping ra:her than actual safety problems.
- 2. Mr. Davis was not " transferred to other, less sensitive duties," as alleged. To the contrary, Mr. Davis was actually placed in a position which allowed his to overview all of the individual QA!2G
- cord revias gr:ups.
- 3. Following the allegations in early December, 1983 Mr. Davis was interviewed by L?&L sacagemen: and was asked to co=en on projec:
document reviews c=cducted since his Dece=ber 9,1982 ===orand=. Mr. Davis issued a samorandum on December 22, 1983, which reads, in 4 part, as follows:
"In summary, ny review of nonconfo =ance reports a=d related correspondence indicates that items addressed in memorandum dated December 9, 1982, have been adequately addressed and/or are being corrected in accordance with Ibasco's program."
4 Alleger's information source was formally invited, by the L?&L Senior 71ce President-Nuclear Operations, to discuss his conce=s in light of more complace information resulting from the expanded records review program begun in early 1982. The LP&L intent, in extending this offer, was to allow alleger's inferna: ion source :o decide for himself, as did Mr. Davis, whether or not corree:1ve action for discovered discrepancies had been satisfac:ortly carried out at Waterford 3. The alleger's i= formation source for= ally declined the LP&L invitation. e e e
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Page 3 I7 ALLEGATIONS THAT WATERFORD 3 MANAGDENT CHOSE TO IGNORE ALLICER'S f- INFORMA!!ON SOURCI. n iegations that Waterf'ord 3 management chose to ignore any infor=acion source are totally erroneous. Such an anaged posture is tocan y contrary to L?&L policy. Furthermore, deficiencies discovered by alleger's information source were being aggressively addressed even before allager's information scurce left the Waterford 3 site,
, 1. In a meeting of July 7,1983, ausger's source recommended that all concrete placement packages and soil packages be reviewed.
- 2. On July 11, 1983, project management decided to review a 10: sa=ple of the concrete placement packages, and L?&L directed Ehasco to begin the review. (NOTE: Alleger's information source left the site on July 31, 1983.)
- 3. In August 1983, the review of concrete place =ent packages was begun.
In September, 1983, the review program was expanded to include 100% of the concrete placement packages. The review is now ce= place and 33 new NCRs were vriccan as a result of this review, acne of which identified sign:.ficant physical deficiencies and all of wht:h hr.a been properly dispositioned. 4 Soils and backfill records were previously subjected to a croprehensive review by Ebasco. All records were reviewed for existence of required records, chair completeness, a=d for proper organizat:.on by elevation and fill number. Approximately !O: of the
% records were re-reviewed for technical adequacy. No additional soils non-conformances were identified.
- 5. To gain an even greater level of confidence. L?&L personnel, in accordance with standard procedures, are currently performing additional reviews of concrete placement and backfill records.
Certain types of civil records are being 100 reviewed by L?&L during this review process. Z no
4 Page 9 4 7 ALLICA!!ONS THAT I.ARGE Nt3GERS OF INS 7Er0RS WERE NOT CERT!7IE. f: Allegations that large numbers of inspectors were not certified - are totally erroneous. , 1. Inspec:or certification audies have been performed at every level of ( the hierarchy of the Waterford-3 Quality Assurance Program throughout the project history. Where deficiencies" existed, for=al corrective action has been inplemenced. The only significant problem of this type occurred in relacion to che Nuclear Scean Supply Sytem (NSSS) installation in 1980. In that case, a Scop Work Order was issued until che contractor's inspector certification i program was upgraded. Corrective ac:1on involved significan :sviev l ' and reinspection of prior verk and revision of the contractor's Quality Assurance ? ogram.
- 2. Recan: reviews of n=n-c:nfor=ance reports and inspec:sr certificacien records related :o concrece placenant supper: :he conclusion that there are no significant problems in the area of inspector qualificacion.
' Gualificacions of inspec: ors involved in concrece placenen:
vere re-reviewed in detail by both Ebasco and L?SL. "r.e documancation indicaces that several inspectors had perforned car:ain inspections prior to fornal on-site certificacion. Further review verified that most of these inspec:crs were veil qualified to perform the inspection functicas, based on cenple 1:n cf onaire crafnfng and examinacion or based on their significant gw ' previous experience. It appears that four inspec crs say have performed up to ten concrete curing (post placement) inspections prior to being certified. However, these inspections require only that the inspector be capable of reading a thermometer and decernining whether or not a concrete surface is vec. In one isolated instance, cadwelds were inspected and accepted by an individual several weeks prior to his formal certificatica. At that eine, the inspector had 6 years of experience and ::aining on ' commercial civil projects, including experience as a civil Quality Centrol Inspetter prio; :s joining the 7aterf::d 3 p cject. An
' engineering evaluation of this situation has shown that the installation meets design criteria.
- 3. Although LP&L already has an adequace level of confidence in the inspector certification condicions at Waterford-3, L7&L QA has embarked on an additional review of inspector certificacien documents to redouble its cenfidence.
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l Page 10 7I. ALLEGATIONS THAT THERE HAS BEEN A "STSTEMATIC PRCCRAM" TO ALTIR. g- "DCC""0R", OR REPLACE DCCOMENTS WI"'E "?HONT"DCCC dDTS. l Allegations that there has been a " systematic program" to alter " doc:or. or replace documents with " phony" documents are totally erroneous. To ; LP&L's and Ebasco's knowledge, there has never been any concerted effor: l to falsify records in any facet of the Waterford 3 project. L. When document discrepancies are discovered, nonconformance reports (NC24), or lover level documents, are written to assure that the discrepancies are corrected. Approved procedures require correction of docu=en discrepancies ' under controlled cendi: ions. Such corrective action,' based on the nature of the discrepancy, may involve resolution in a vide spectrus
. of choices including, if necessary, reinspection, repair, rework, er replace =en: of installed =acerials or equi; en:, nonce:f e----= #
=aterials or equi;=ent installa: ion 21:h design docu=e::s constitutes a discrepancy. When such conditions are discovered, they may be corrected either by reworking, replac1=g, or repair 1:g the nonconforming installation or by changing the design docu=ent to reflect the "as-buil:" conci:1on. Hevever. ::anges is dest;n docu=en:s =ust be reviaved by engineerd 3 perso==e1 to assura cha:
the changed design remains in conformance vi:h the approved design cri: aria.
- 2. In order to further i= prove its confidence that the correettve action process has been properly performed. LP&L has embarked on an g additional review of a samp11=g of nonconformance reports (NCRs).
W NC1's involving "AcceptwAs-Is" and NC1's involving physical work will be selected (sample basis) and will be reviewed to verify that:
- 1. The disposi:1on appropriately addresses the identified conditica.
! 2. Any required work was properly accomplished. l This will involve some field verification.
- 3. The NCR was dispositioned in accordance with the applicable procedures.
- 3. The Waterford 3 Quality Assurance Program includes elements which provide reasonable confidence that document falsification vould be detected. At Waterford 3 three situations have been discovered
{ in which falsification was suspected. These situations were i ( investigated and properly dispositioned.
!s two of the suspec: situations, the persennel involved explaised that the records in question were reproduced becaus a che originals were either lost (they were later found) or in poor condition frem field use. In some instances the inspectors worked in teams whereby one inspected and the other recorded. The accuracy of records has been confirmed by supplementary and backup documet .acion.
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Page 11 The third situation brought into question the quality of a very g-, small quantity of materials used in a safety related installation. Documentation of traceability of the heat number for the materials' was suspected to have been falsified. Since the suspect signature was that of an employee who was no longer on the project, since the amount of materials in question was small, and since this was obviously a very isolated incident, it was decided to simply repl ace the suspect materials with properly certified materials. 4 8 I l O O O (- I
Page 12 7!I. AILECATICNS TEAT DCCUMEIT DISCREPANCIES RE7I.ECT t.ARCE DEFICIETCIES Of 3E r; PHYSICAL PTAIT. Allegations that documanc.discrepancias reflec: large deficiencias in the physical planc are :ccally erroneous.
- 1. Every discovered document discrepency must be disposi:1cced in accordance with approved procedures.
- 2. The number of physical correc:1cus, required as a resul: of docu=ene revieve, including the expanded records review begun in 1982, has been small and physical corrective ac:1on has been, or is being, ac caplished.
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Page 13 7III. ALI.ECATIONS THAT ALLEGED DEFICIUCIES IN THE MASTER UACI U C SYSTri r- CONSTITUTES A SERICUS OUALITT ASSURANCE 3REAC0t.'N, Allegacious that alleged deficiencies is the Master Tracking Sysees conscicutes a serious quality assurance breakdeva are cocally erroneous.
- 1. The Master Tracking System is performing veiy well at Wacerford 3.
The Master Tracking System is, as the name i= plies,. =erely a cool for tracking work items. The allager has been inforned of this face several cises beginning more chan a year ago. D t L i l use i
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, Page 14 II.
ALLEGATIONS 'aTfE RESPEC* TO SPECIAL LP&L ULA*IONSHI?S 'a'ITH ""d! NUCLEAR REGULA*0RY COMMISSICN. (NRC) Allegations that L?&L and NRC have entered into special agreements are
. totally erroneous.
- 1. The allegations insinuate that L?&L has entered into special agreements with NRC regarding questions posed by the allegations.
There are so such agreements.
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e e I 29. Does (LP&L) maintain that the mat possescas adequate capability to resist the design loads and confirm to the criteria commited to in the FSAR despite all the deficiencies and allegations listed? If yes, provide the supporting technical basis. If not, propose specific means to resolve them and thus render the mat acceptable to the staff. In any case, the "as-built-mat" should be shown by the applicant, if feasible, to maintain adequate safety margins to perform its safety function and maintain its structural integrity. A quantitative demonstration of the "as-built" mat capacity, including adoption of test, monitoring and strengthening programs, if need, should be provided for staff review.
Response
It is our conclusion that the mat, as constructed, possesses adequate ! capability to safely resist the design leads. Deficiencies and alle;sti::s brought to our attention either refer to problems in maintaining a clear record of the construction or have been corrected. We therefore conclude that the quality of construction vas substantially in tecordance with the plans and specifications. 1 A monitoring program has been provided for NRC Statf review. This program consists of three areas of monitoring and has been provided in the form of Technical Specifications as requested by the Staff and suggested by the Atomic Safety and Licensing Appeal Board (ASLAB). - ' The first area of the program is to extend the previously agreed to basemat settlement monitoring program for the current three year commitment to a continuing program. Secondly, periodic sampling and testing of the ground water chemistry will be conducted to assure that significant corrosion of the rebar due to ground water intrusion is not expected and that the ground water remains "non-aggressive". ' The third area evolves periodic inspection of the exposed areas of the basemat to docu=ent any new cracking, if it should occur, and to survey the existing cracks to determine if significant changes in crack size have occured during the inspection interval. Specific proposals for each phase of the program have been submitted. 4 3 e e I s
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- 30. What is LP&L's, technical rationale for explaning what has happened (including, water seepage, potencial through-thickness cracks, predominently on-vay cracks within containment region, even settlements, etc.) to the mat? What monitoring program (s) has been implemented is underway? What are the results of these programs? Did the monitoring data show that both the cracking and water seepage problems have stabilized and there is not sign of continued degration? What improvements, could be applied to the on-scing programs?
Response
, It is our conclusion that minor flexural cracking of the mat has occured related to the differential settlement of the mac and that those cracks have intercepted minor moisture paths within the mat. These minor =cisture paths are associated.with the embedded staal construction support =e=bers ]- for the reinforcing steel and embedded conduit. Under the high water pressure head (about 55 feet) these paths allow the passage of trivial amounts of moisture to the surface of the mat. , a The only portion of the monitoring program described in the response i to Question 29 above which has been implementad is the base =at settlement monitoring program. This program has been in effect since the start of the basemat construction. This program has indicated no additional settlement since 1979 and, as such, supports the conclusion that the basemat has stabilized. The proposed monitoring program (Question 29) is considered to adequately address the issue of potential basemat settlement, corrosion of rebar, and basemat stability, i i i i j i i e 4 l
- ~ v .
O o
- 31. Are there any known voids of some significant size to affect the mat structural integrity? If yes, what are the sizes (best estimates) and extent of these voida? What is LP&L's suggested disposition to the issue of voids. If no disposition is needed, what is the technical basis?
, Response: The basemat design and the approved procedures for construction of the basemat include provisions to minimize the formation of significant voids in the basemat placements. There are no known significant voids in the basemat. All significant voids detected during the placements have been repaired. i o 4 6 p rr w y .-m-- r-.- - w- _.y.,y e-p-. y e* y, ---mr--c- - r- ---- - - - - + w. -i , --------
_- . _ .. - . . . _.. .- _- _ - . _ - - _ - _ -. _ =- - -. - - i 32. Conservatively assuming the existence of extensive through-cracks of the sat, assess the impact of the presence of water on the long-term structural integrity of rebars and mat capacity. Also assess the same impacts due to other potential corrosive elements. i Response: (EBASCO) The assessment has been provided in the " Applicant's Answer to Joint Intervenor's Motion to Reopen Contention," dated September 30, 1983. Affidavic of William F. Gundaker, and in a memorandum dated August 5, 1977 by A. W. Peabody /M. D. Oliveira, titled " Corrosion of Reinforcing Steel and Steel Containment Vessel Plates in Contact with Water," which reads in part, " ..we have analysed a possible situation in the common mat where supposedly groundwater seeping from concrete cracks found on the surface of , the mat could corrode the reinforcing steel anc the outside bottom plates of the Steel Containment Vessel. It is a proven fact that concrete by its alkaline nature passivates carbon steel embedded in it.
! It is also known that water in contact with concrete becomes alkaline and consequently its corrosivity to steel decreases considerably.
l In addition to these factors, assuming that groundwater is left inside I the crack network to a certain extent, this water will be near stagnant and without replenishment of oxygen. Consequently, the rate of corrosion under the above circumstances, if any, will be negligible." Response: (HEA) The " existence of extensive through cracks" as hypothesized, considering the hydrostatic pressure acting at the base of the mat, would be manifested i by substantial bleeding of groundwater through such cracks. HEA reiterates ! the summary of a site inspection performed on 08/30-09/02/83. During this time all accessible areas of the basemat were inspected and any cracks found were mapped (See HEA Report No. 8304-1, dated 09/19/83). Subsection 4.6 of the referenced report notes that: l "The amount of moisture noted during this inspection period was l minimal. In some instances dampness / moisture were present. There was, however, no evidence of seepage or migration that might have been ' deduced by the presence of standing water or draining along the local slope of the basemat."
- - - - - - - - - ---~
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4 4
' ATTACHMENT V Atteneas at Wate*#orri site Discussion of 9asera* Adecuacy Reoresentatives fron Louisiana Power & Licht Corneanv K. W. Cook T. F. Gerrets R. F. Burski B. P. Brown J L. Ehasz (EBASCO)
A. H. Wern (EBASCO) P. C. Lu (EBASCO) 1 J. J. Ccstello (ESASCO) J. c fu e -ez (EBASC01 G. Harstead (Harstea(4 Engineering Associates) A. DuPouchet (Harstead Engineering Associates) a, r,ii e.1 1 u. 3 +..,4 gon4n. r4 e a ;ep.+.rs r i Renresentatives # rom Louisiana Power & Licht Comoanv
- . Niisen
- 4. t.en e D. L. Jerg J. T. Chen ,
J. S. Ma i W. A. Crossran J. I. Taoia K. A. '.'hi ttesev
. Reich IPrcM: haver. Natic".a1 Lab)
P. C. Wanc (Brookhaven National Labi S. Shaar.a (Brockhaven National Labi i t i I a 5 1 O
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- 25. What were the problems in the seven NCR's on QA deficiencies in concrete.
as mentioned in the last column on page 28 of GAMBIT, and how were they disposed off Note: GAMBIT (p.28) quotes Hill's memo as follows: "These NCR's are each broad in scope and identify multiple deficiencies." l
Response
Hill's memo to Czyrko dated June 6, 1983 (
Subject:
Review of Seismic Class L i' I Concrete Records) references ! NCR W3-5563: Fuel Handling Building Bridge Crane NCE W3-5564: Fuel Handling Building Stairs , j NCR 93-5565: Fuel Handling Building Bridge Crane '
- NCR-W3-5973
- Fuel Handling Bulding Tornado Door j NCR-W3-6245: Daily Cadweld Inspection Reports l
- NCR-W3-5997
- Clam Shell Filter Blanket j
- NCR-NY-5co8: Sa=ple Splice Failure Rates i i (
and describes these NCRs as examples of deficiencies discovered during a ! } " Review of Seismic Class I Concrete Records". ' i l The problems and disposition of these NCRs are as follows: I ! NCR W3-5563 (Fuel Handling Building Bridge Crane) This NCR was written against Jane Oges (trainee who was inspecting bolts i on the THE Bridge Crane on 11/6//9) and states that a trainee cannot { implement, evaluate, or report inspections and test results. The dis- ' position called for Ebasco QC to reinspect the questioned areas. Ebasco l, Engineering evaluated the recommended disposition and revised it to the i following: J. Portuit was to cosign all applicable inspections by Osea. Portuit was her Level II Supervisor. As a result of this NCR, Portuit submitted signed testimony dated 7/11/83 stating that he was present and supervised all inspections by Oges and this NCR was closed. Note that this NCR has nothing to do with concrete or the common mac. It
- i is not broad in scope and does not involve multiple deficiencies, l NCR W-3-5564 (Fuel Handling Building Stairs) ,
i This NCR states that no welding or bolting inspection reports existed i for the FHB stairs. The disposition instructs reinspection of bolting l and welding. This reinspection was performed by Ebasco QC (Roger West) , and was accepted. (Report i C-0032 dated 11/7/83) Nc that this NCR has nothing to do with concrete or the common mat. It is not broad in scope and does not involve multiple deficiencies, f 4 I l ; l I i ; I ! l
Response: (25 Continued) NCR-W3-5565 (Fuel Handling Building Bridge Crane) This NCR is very similar to NCR W3-5563 in that it was written against Jane Ogas because her supervisor, J. Portuit, neglected to cosign her inspection reports. As a result of this NCR, Portuit submitted signed testimony dated 7/11/83 that he was present and supervised all inspections by Ogea. On that basis, this NCR was closed. The inspections were on the crane reaving on 8/15/79 to 8/22/79. Note that this NCR has nothing to do with concrete or the common =at. It is not broad in scope and does not involve multiple deficiencies. NCR W3-5973 (Fuel Handling Building Ternsde Doer) This NCR states that 1) inspector D. Ness was not a certified weld inspector, and 2) two velds on the door frame were first rejected and subsequently accepted without additional inspectien reports. The NCR was closed on the basis that both welds had previously passed RT and MT examinations and visual inspection was not necessary. It should be noted that D. Noss was technically qualified, by experience and education,at the time the inspections were perfor=ed, and was subsequently formally certified on 8/24/77. Note that this NCR has nothing to do with ccacrete or the common mat. It is not broad in scope and does not involve multiple deficiencies. NCR W3-6245 (Daily Cadweld Inspection Reports) This NCR states that certain Daily Cadweld Inspection Reports have five (5) inspectors' signatures or initials with noticeable differences which renders their authenticity indeterminate. The NCR was initially closed, on the basis that documentation was found which showed that the cadwelds were previously inspected and accepted. This closure accepted the cadwelds "As-Is" with no corrective action. Subsequently, the NCR was reopened and attachments 9, 10, 11 and 12 were added to the NCR package. These attachments included signed state-ments by Sam Horton, H. Don Ernst, Nicholas M. Donlick, and Leonard Kaminski giving explanations for the appearance of irregular signatures and confirming their authenticity. (Original documents were soiled in the field and were re-written.) The NCR was closed 1/12/84. See also the response to Question 13. NCR W3-5997 (Clam Shell Filter Blanket) This NCR is very lengthy (about 200 pages) and addresses 64 individual findings detailed in Attachment 1 to the NRC (copy attached). womo em - *~ me emn e =o = :
i ' e ,
), ,
o . 4 4 Response: (25 Continued) i j The NCR was closed after evaluation and satisfactory conclusions by the j Site Soils Enginaer. The bases for closure are detailed in Attachment IV j of the NCR (copf attached).
! It should be noted that the purpose of the claa shell filter was to ensure {
- a uniform water pressure under the mac during recharge. Settlement data i
shows that settlement of the mat has stabilized with acceptable differencial settling. Thus, it is concluded that the clam shell filter i r
; successfully fulfilled its primary purpose.
NCR-W3-5998 (Sample Splice Failure Parts) ! 4 j This NCR finds that ' k 1) the failure rate in one group of sample splices exceeded the j-specification limit of 1 failure in 15 consecutive samples. q
- 2) splicing was not terminated as required by the specification.
L j
- 3) the cadwalder was not racertified as required by the specification.
j 4) additional samples were not obtained and tested as required by the specification when the failure rate exceeds the specified 11rait. 3 i The recommended disposition stated that the author of the NCR (G. Hill / ! H. Savage) erred (miscounted) and in fact the failure was only 1 in 15 ! not 2 in 15 as stated. Consequently, it was not necessary to terminate ' the splicing, re-certify the cadwelder, or take additional samples. 1 1 The engineering evaluation agreed with the recommended disposition, but t required some additional evaluation (Attachment 5 of NCR-W3-5998) of the I test data based based on AEC clarification of Reg. Guide 1.10 in AEC* memo [ r i dated May 15. 1973. (Attachment 6 of NCR-W3-5998) Although we believe the f I required evaluation was done, it was not properly documented. At the request j of Mr. William Crossaan (USNRC), this NCR was reopened on 3/14/84 and the j evaluation per Attachment 5 of the NCR was performed. We expect the NCR 4 to be expeditiously closed. ! 1
! Note that this NCR is hardly " broad in scope, involving multiple !
deficiencies" and the failed sample splices did not come from the common ) mac. Of four failed sample splices addressed by this NCR. two came from 7 l j the Tuel Handling Building, one came from a pressuriser vall, and one ' 3 came from the primary shield wall. t
- i. .
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, .j j / 1 1 J / 33 2<sponse. . Zf I
i Page 1 of 9 )1- ATT. I to NCR-W3-Mil
! Attachment I - Detailed Description of Nonconformance W3-Item I: Compliance of Clam Shell Filter Blanket construction with the
~
l j Test Fill. 4 A) Description of Nonconformance Contrary to ANSI-N-45.2, para. 6, The Test Fill Report (A c t. III) l. does not provide specific criteria required by Q.C. in order to verify compliance with requirements of Spec. LOU.1564.482, i para. 6.2h or Spec. LOU.1564.482, Attachment entitled Clam Shell Filter 31anket Pi s e s -ent and Ce eactien Precedures. paps 1!.. too paragrapn. i 4
- 1) This c6nditica renders: f
- 4) the acceptability of the scurce of the =acerial actual
- y used during construction indeterminate and
, b) the acceptability of the ccmpactive equipment Ac:ually j used during construction indeterminate.
- 2) The absence of quantitative acceptance criteria renders i
the acceptability of the in-place density test results, for the in-place claa shell, indeterminate. Affects all work. i (* - B) Description of Noctonformance i Contrary to ANSI-N-45.2, para. 6 and Spec. 1564.482 and Attachment i entitled Clan Shell Filter Blanket Placement and Cesetion Procedurg, the construction work performed on the Filter Blanket ' uses techniques not provided for during the Clan Shell Filter 1 - Blanket Test Fill. These violations, by strip, are as follow ,
- 1) I
) a) Report dated 10/24/75 indicates claa shell was not in ; place and Guaite was placed on entire horizontal surface i of Strip 1 The test fill program made no provis' ion for i
claa shell compaction, and effect of compaction on shell, on large gunite surfaces. (See Att. II, page 1) i~ b) Lift thickness for placement dated 10/28/75 is indicated ! as 15 %". Lift thickness for placement dated 10/29/75 l is indicated as 15". A lift thickness of 14 " saximum '
, is required. Site Soils Engineer .aview and approval of this modification is not documented on an Ebasco NCR, TCR, or DCN. (See Act. II, pages 5 and 17) i l .
l
+
1 i I i i
=
, ) 1 / 1 ) ) / 35 Page 2 of 9 ATT. I to NCR-W3 %%
- 2) Strip 2 a) Report dated 2/23/76 does not indicate authority for replacement of gunite with 3 ft. thick concrete wall.
There are no concrete inspection records for the concrete as required by Ebasco Procedures QCIP-6 and QCIP-7 and J.A. Jcnes Procedure W-SIIP-7. Site Soils Engineer review and approval of this modificatics is not docu=ented on an Ebasco NCR, FCR, or DCN. (See Att. II, page 30) b) Report dated 12/13/75 indicates shell place =ent in standing water. Site Soils Engineer revieu and approvs1 fer this codification is net dccu=ented on an Ebasco NCR, FCR, er DCN. (See Att. II, page 42) c) Report dated 12/15/75 indicates pan vibrator used on en-cira surface of strip. Site Sotis Engineer autheri:ed use en " soft spot" caly. Test Till dcas nce previde for use of hand ce=pactors except for restricted areas. (See Act. II, page 53)
- 3) Strip 5 al Report 3, dated 2/10/76 does not indicate authcrity for
,ey replacement of gunite with 3 ft. thick concrete wall.
- 1. There are no concrete inspection records for the concrete as required by Ebasco Procedures QCIP-6 and QCIP-7 and J.A. Jones Procedure W-SITP-7. Site Soils Engineer review and approval cf this modification is not decu=ented on an Ebasco NCR, FCK, or DCN. (See Att. II, page 97) y b) Test fill requires 10 passes of a vibratory roller on the clam shell. The Test Fill Report analyses the effect
- of up to 14 passes on the gradation and per=eability characteristics of the clam shell. The inspection racerds indicate 40 passes of the vibratory roller were applied to this strip. The effect, on the gradation and permeability characteristics, of this overcompaction are indeterminate.
Site Soils Engineer review and approval of this modification is not documented on an Ebasco NCR, FCR, er DCN. (See Act. II, pages 98, 103, 105, 108, and 110a) Item II.*. Traceability / Location Deficiencies A) Description of Nonconformance Contrary to ANSI-N-45.2, para.18 and ANSI-N-45.2.9, para. 3.2.1, records for the Clam Shell Filter Blanket do not provide suf-ficient data to accurately locate the individual placement strips by co-ordinates. Therefore, the square footage of e the strips (individually) cannot be determined. Testing frequencies are based on square footage of the placement. This renders compliance, with the required testing frequency, indeterminate. (This affects all strips)
, ,_w.w..
_ meo & e =de.- m em- +a
. J1 / 1 ) ) / 37 Page 3 of 9 ATI. I to NCR-W3 5eR1 B) Description of Nonconformance Contrary to ANSI-N-45.2, para 18, report dated 2/13/76 adds as area to strip 5, the location of which is indeterminate.
(See Act. II, page 111) Item III: Engineer's approval prior to shall placement A) Description of Nonconformance Contrary to QCIP-1, para. 6.1, the following place =ents of shell proceeded withcut the prior (cr subsequent) approval of the Site Soils Engineer docu=ented on Ebasco Fcrm QC-132.
- 1) Strip 1 a) Placement en 10/24/75, 10/27/75, 10/28/75 er 10/29/75 i
- 2) Strip 4 a) Placement on 2/13/76 or 2/14/76
- L
- 3) Strip 5 l g. ,
a) Placement on 2/5/76, 2/9/76, 2/10/76 or 2/13/76
- 4) Strip 6 a) Placement on 3/10/76 Ites IV: Certification of Personnel A) Description of Nonconformance f
Contrary to ANSI-N-45.2.6, the following individuals perfer=ed inspection without certification to a level and/or to activity.
- 1) Strip 1 a) Inspector Kaminski (Jones)
(See Act. II, pages 1, 2, 7) b) Inspector Phillips (Ebasco) (See Att. II, pages 4, 16) c) Technician T. Hazel (Site Test Lab) (See Att. .II, pages 20, 22, 23, 24, 26)
- 2) Strip 2 a) Inspector Frick (Jones)
(See Att. II, pages 37, 36, 50, 53) -
i
, Jl / i 1 > 7 3 )
Page 4 of 9 ATT. I to NCR-W3 58R1 Item I7: A) 2) (cont.) b) Technician T. Hazel (Site Test Lab) (See Act. II, pages 58, 60)~
- 3) Strip 3 a) Inspector Kaminski (Jones)
(See Act. II, page 70) , b) Technician T. Hazel (Site Test Lab) (See Act. II, pages 81, 33) c) Inspector Eiff (Jones) (See Act. II, page 70)
.) Strip 4 a) Inspector Frick (Jones)
(See Act. II, page 85) b) Technician T. Hazel (Site Test Lab) (See Act. II, page 92) (({,
- 5) Strip 5 a) Inspector Frick (Jenes)
(See Att. II, page 98) b) Inspector Horton (Jones) (See Att. II, page 111) c) Technician T. Hazel (Site Test Lab) (See Act. II, pages 117, 118, 119, 120, 121)
- 6) Strip 6 a) Inspector Frick (Jones)
(See Att. II, page 126) b) Technician T. Hazel (Site Test Lab) (See Act. II, pages 132, 133) Item V: Testing A) Description of Nonconformance Contrary to ASTM-D-2167 '66, in-place density test holes do not meet minimum 0.1 ft3 required test hole size, per Table 2. In addition moisture determination used*in computation of in-place density was not perf ormed in accordance with para. 4.4 Instances are as follow: ,, ..,,,ww--
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' \ 'ATT. I to NCR-W35 m a %
Iten/tt: .A) (c one. . )
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>S
- 1) Strip ,. * * (See Act. II,$agds 10, 25[ 23, 24, 26)
) . L m- a- 3
.,.3 2) Strip 2 (See Act. II, pages'38, 60) -
.)y 3), Strip 3 (See Att. II, page.81) *
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3
' ' ' , 4) Strip 4 dae'Att. II,- page 92)
- h. ^~
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- 5) S c ip 5 *(See Act. II, pages'il7, 118, 119, 120, 121)
,,.- i X
- 6) Strip 6 (Sea Att.Nn( page 132)
- s i
- y, y ~ y -
Qg 3 , ;; 3) Description of Nonconforpan:e .
.. t
, i N s .
s
' C:ntrsr7 t: ?;ec: LC"-1564.469, parn. 5.2 .nd Spe::. LCO '
g 1564.482, page 14, Attach =en , which.giOe testing frecuencies
'i in terms of square footage of pidisenC for the foundation and filter blanket, the in piction records do not prdiide suf-
~
; ficient data'to determine the squard footage of the areas y inspected. De scomplishee of the tasting program vith the 3
h testing frequency is indetermAnate. l((All strips are affected) 3 , s C) Description of Nonconformance .. % n: 4. s x s Contrary to ANSI-FM45 '2, para.18 and ANSI-N-45.2.9, para.
.- 3.2.1, the 1ccaclpi of all in place density tests en the' foundation and tM fC26m Chall, Filter Blacket ris~indeter-minate. The teses were peric3asd in a thrug dimensional '
' medium, but were located in only two dimeraions. '
'(All tests . ".
,i for all stripe are affected) < ,
%' SNDTE: Tests for Strip (1 do not fall anywheeMthin the s txclear Plantp.nimd ss 'per ec-ordinates gi en ec= pared with
,A Yo-ords.nace grid ' attached to te.ot report ,(See Act. II, pages
*J',' 27) '
' (Tesc. M53, #454, M,55), - ' ;} .,
u , ,, , D) Description otfMenconformance i - 2 i s .- ,3 - s
, Contrary to ANSI Na45.2.9, p,a!ra. 3.3.11, the in-place density tests on the foundaCion mate;1al,cenet.b6 traced to the cor-
/# responding Laboraf'6ry Meisture- bca6.y Kals.cion Test Report used in conjunction with per-c$ntstW of s epaction determina-
_' tion. (All. founiation tests ara aftected. . See QC-83 Forms , 9, containing foundacion tests, loc'Etkdain Atc. II) .
,. E) Description of Nonconformance .
..g -. 3
@i:trtry to ANSI-N-45.2.9,ipara. 3.2'.6, the following test
- 4
. reports (by strip) contain improper changes by sunknewc' person-
. nel. Ther.e, alterations change test locations c,e test readings.
,i As determined from the originil, at the Site TesI Lab, the original entry had been noted cn the report conta1'ned
~ .
in Act. II. r, a .
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- 1 j _ - --
. ] ') / l i J / i 0 Page 6 of 9 ATT. I to NCR-W3 5W1 Item V: E) (ccat.)
- 1) Strip 1 a) Form QC-83 for tests 452 thru 461 exists in two distinct versions. The two versions give different hole volumes for Test #452. Percentage ccmpaccion is indeterminate. Other differences have been indicated on the reports. (See Act. II, pages 24, 26) These Xerox copies have ink entries by unknown.
b) Form QC-83 fer tests 486 thru 495 exists in t ie dis-tinct versions. Cne is dated 10/28/75, the cther is dated 10/29/75. Both are Xerox copies containing ink entries by unknown personnel. (See Act. II, pages 20, 22)
- 2) Strip 5 1
a) Forms QC-83 contain improper changes =ade by unknown personnel. The changes censist of erasure of original data and entry of new data. The original records, congleted in pencil, were reviewed et the Site Test Lab, and, where possible, the original data had been noted on the report contained in Att. II. (See Act. II, (,~ .' pages 117, 118, 119, 120)
~ (This is for dispositioning -
purposes only.)
- 3) Strip 6 a) For:ns QC-83 contain improper changes made by unknown personnel. The changes consist of erasure of original data and entry of new data. The original records, ce=pleted in pencil, were reviewed at the Site Test Lab, and where possible, the original data had been noted on the report contained in Att. II. (See Att. II, page 133)
F) Description of Nonconformance Contrary to the Clam Shell Filter Blanket Test Fill Recort, Att. III, the required value of 102 lbs./ft4 was not used to compute the percentage of compaction of in-place clam shell.
- 1) Test 800 used 105.0 lbs./ft.3 (See Act. II, page 119)
- 2) Tests 833 thru 837 used 102.7 lbs./ft.3 (See Att. II. pg.132)
Item VI: Documented Deficiencies without Documented Corrective Action
. A) Description of Nonconformance Contrary to ANSI-N-45.2, para.18, the records do not indicate corrective action for the following documented deficiencies.
. , , . + , . . . , , . - , - ~ . -, - -- r . - - , - -
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. l/ i ) 3 / J l Page 7 of 9 ATT. I to NCR-W3 WM Item VI: A) (cont.)
- 1) Strip 1 a) Report dated 10/27/75 does not indicate status of, in-pact on, or re-compaction of, in-place clam shell when gunite previously applied, was replaced. (See Act. II, page 2)
- 2) Strip 2 a) Report dated 12/10/75 indicates unacceptable crim of gunite and unacceptable re= oval of surplus caterial and overspray. .Ra= arks section indicates the wooden stakes were not removed. No corrective action is indicated. (See Act. II, pages 28, 29) b) Rspert ds sd 12/12/75 dcas net indicata adaquate cerractita action for the 4", compacted lift thickness, clam shell. (See Att. II, pages 36, 42) c) Report dated 12/13/75, first shift, indicates water standing in West half of strip. Centractor allowed to place shell. Site Soils, Engineer review and approval of this modification is not documented on an Ebasco p.
g.j N"R, FCR, or DCN. See note by M. Tenchin at bottom of page 37 of Act. II. (See Act. II, page 42) d) Report dated 12/12/75 indicates 5 temporary su=ps were dug. There is no indication of subsequent place =ent and compaction of clam shall in these sumps. (See Att. II, page 33) e) Report dated 12/15/75 indicates " West." area was cut and part of " East" area was filled. This disturbed the sur-face. Only one pass was applied with a pan vibrator. (See Att. II, pages 51, 52) NOTE: Refer to Item IB2c for use of pan vibrator en large, non-restricted area.
- 3) Strip 3 a) Report dated 12/19/75 indicates "... drainage ditch dug on both sides of Strip 3 ... lined with Mirafi cloth and filled with shell ..." The area identified is indeter-minate. Verification of the foundation material ex-posed is not d .umented. (The Test Fill makes no provision.for compaction of the 2 ft. lift thickness used for this work.) (See Att. II, page 68) b) Report dated 12/19/75 indicates "... temp. drainage ditch dug on North side of Strip 3. App. 2 ft, deep and 3 ft. wide. Covered with Mirafi paper and loose clam shell ... No compaction." The area identified is indeterminate. There is no documented evidence of sub-sequent compactien. (See Att. II, page 69) e 4 a s e-o -mm+*
.?,, _ __ - , , . _ _ j_
J ; / ! 1 -; / 33 Page 8 of 9 ATT. I to NCR-W35W Item VI: A) (cont.)
- 4) Strip 4 a) Report dated 2/11/76 indicates unacceptable trim of gunite. This entry has been changed to acceptable by unknown personnel. The acceptability of corrective action is not documented or verifiable. The current status of this work is indeterminate. (See Act. II, page 84) '
b) There is no record cf slope protectica for the east two-thirds of the Ncrth Wall or on an indeterminate length of the north portion of the East *Jall. Length of exposure ti=e of the foundation material to the elements is indeterminate. Olef. Spec. LCU.1564.482, Attach =ent, page 12, 2nd para.)
- 5) Strip 5 a) Reports 1 and 2 dated 2/5/76 Indicates unacceptable trim of gunite and unacceptabi'e re=cval of surplus material and overspray. No quantitative description et these deficiencies is given. No corrective action en, is indicated. (See Act. II, pages 95, 96) 1-
~
b) Report 2 dated 2/5/76 indicates "some" contamination of the clam shell due to overspray. No corrective action is indicated. (See Act. II, page 96) c) Report dated 2/13/76 indicates alternate methods of compaction used are unacceptable (per the Site Soils Engineer) . No corrective action is indicated. (See Att. II, page 111)
- 6) Strip 6 a) Reports 1 and 2 dated 3/9/76 indicates unacceptable i
trim of gunite and unacceptable removal of surplus material and everspray. No quantitative description of these deficiencies is given. No corrective action is indicated. (See Act. II, pages 124, 125) i b) There is no record of slope protection for the West Wall or for approximately 177 ft. of the South, start-ing from junction with West Wall and moving eastward. Length of expcsure time of the foundation material to l the eleme6ts is indeterminate. (Ref. Spec. LOU.1564. 482, Attachment, page 12, para. 2) l l t . t
. ", 007 i .) / 33 Page 9 of 9 ATT. I to NCR-W3 5W1 Item VI: A) (cont.)
- 7) Strip 2 a) Report dated 12/12/75 indicates the clam shell filter blanket was penetrated by a " mud spurt" cf approximately 120 ft.2 There is no indication of corrective action, particularly placing Mirafi over area and subsequent replacement and compaction of clam shell. (Ref. The Clam Shell Filter Blanket Test Fill Reecrt, para. 4.2, page 5 (Att. III to the NCR) ) (See Att. II, pages 35, 36)
Based on the deficiencies noted above the acceptability of the Clam Shell Filter Blanket is indeter:minate. I. _ * ~ I A t i 4 e..
- h-. - .
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j ,' ,) :) / l ! -) ) / 1 /2s.sponse: 2S' I ATTACHMENT IV ENGINEERING DISPOSITICN OF i NONCONFORMANCE REPORT W3-5997 ITEM I: Compliance of Clam Shell Filter Blanket Construction With Test Fill: 4 I-A-t-a - Use As Is: The test fill for the Clam Shell Filter Blanket was performed on September 10, 1975. The Clam Shell used was supplied by Brothers Construction Inc. (A Giambelluca Construction, Inc.) who was supplying Clam Shell to the site since August, 1974 under camporary purchas3 order W3-848 (Pg. 133). The purchase specification for P.O. W3-84d required that all clam shell material come from Lake Ponchartrain as snown in ene typical supple =ent f/5 to PO W3-848 presented as page 134 Ca September 10, 1975, 3rochers construction ecmpany vas delivering e72 7:-t of clam shell for general surfacing repair of roads, and laydown yards (pg. 135). Several trucks of shell were taken from this delivery order to build the cese fill. All subsequent clam shell used for the construction of the filter blanket was delivered by Brothers Construction, Lac. taken from Lake Ponchartrain as shown in the typical material received report attached as page 136 :nd en cach Ebasco Inspection Report Form QC-93 typically shown on page 4 Therefore, the material used during construction is found to be from the same ([h (. source as the test fill. I-A-t-b - Use As Is: Compcetion of the Clam Shell Filter Blanket Test Section was perfor=ed by a rubber tire, self propelled, smooth drum vibratory roller imparting a minimum of 10 tons of energy in accordance with the cast fill construction procedure CP-203, Section 6.3.4 (Attachment III, Page 3 of 8) and as shown in Clam Shell Filter Test Fill Report, November, 1975 (Accachment III, Photo No. 8). l The compaction of the Clam Shell Filter Blanket itself was performed by an identical rubber tire, self propelled, smooth drum vibratory roller as documented on the Ebasco Inspection Reports (QC-93) typically shown in Attachment II, Pages 5, 33, 72, etc. and in the Waterford Record Photograph #648 dated 3-16-76 showing the roller on the side of strip #6 (pg. 137). Specification requirements in LOU 1564.482, Section 6.2h requiring compatibility of test fill and production compaction equipment type or medel j refer to generic type or model, such as smooth drum vibratory versus static tandom wedgefoot roller and wc12 compiled with. I e t i l l ,__ 1 -- . -
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1 I-A Use As Is: The Clam Shell Filter Blanket was installed in accordance with an accachment to technical specification LOU-1564.482. This attachment was a direct result of the Clam Shell Filter Blanket Test Report (Attachment III) and is a method specification. It requires a roller type and a number of passes on suitable clam shell. Compliance with this method specification is documented en the Ebasco Inspection Report Forms QC-93 typically shown in Attachment II Pages 5, 33. 72, etc. In place density tests were run for information to be provided to the Site Soils Engineer for review and technical evaluation. I-B-1A - Use As Is: The Cunite installed on the west vall of Scrip #1 and on the adjacent 3 fact hori::=tsi ber= se si -40 Actsch: sat II, ps; 1 vss autheri:cd by th Sica 2:112 Engineer, prior to the placement of Clam Shell at this area. This was dene to co= ply with specification requirements stated in the Clam Shell Filter Blanket Accach=ent to the technical specification LCU-1564-482 (Accach=ent III) requiring slope protection of the. exposed vertical faces of the final phase IV excavation within 8 hours of excavation. Delays in Clam Shell place =ent prevented the placement of the shall prior to the guniting; therefore, to
"^ protect exposed faces, guniting was approved out of sequence by the Site Soils Engineer. The horizontal surface mentioned was on the EL -40 berm at the top of 4/ the vertical face and not in Strip #1 as indicated in the NCR. No effects were realized on the Clam Shell Blanket.
I-B-Ib - Use As Is: The chickness requirements of 10-inch minimum and 14h inch maximum for the Clam Shell Blanket as defined in the Attachment to technical specification LOU-1564.482 Page 13. " Placement" (Attachment III) were designed for the following reasons: 1.- The 10-inch minimum thickness was specified to previde the required permeability of the filter blanket. l , 2. The 14 inch maximum thickness was specified so as not to allow an overthick claa shall layer which could conceivably encroach into the base mac above elevation -47 and effect the concrete cover thickness under the boccom rows of rebar. Practical experience gained during the actual Phase IV excavation indicated that excavation usually exceeded the elevation -48.25 goal. Over chick shall [ areas (plus 1-2 inches) were therefore found to be below the elevation of the bottom of the mud mac and not into the area of the structural mat. In cases l where chick shell areas were measured, the shell was either shaved or the mud mat thickness was adjusted. In all cases powever, the bottom of the Class I l foundation mac was kept to E1 -47. I"
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1 i The recorded thickness of 15h" on 10-28-75 (Attachment 2, page 5) and 15" on 10-29-75 (Attachment 2 page 17) are therefore found to be acceptable as is. I-B-2A - Use As Is: i In localized areas where the permanent vertical faces of the Phase IV excavations caved in, and the gunite slope protection was destroyed, lean concrete backfill was used to reconstruct the vertical face and gunite layer. Since these areas were very localized, and since the lean concrete always provided the strength of the pleistocene clay it replaced and offered a vertical l face to form the structural mac against, this backfill procedure was approved and used as necessary throughout the Phase IV excavation operation. The casc , described in 2-23-76 (Attachment II Page 30) is a typical exa=ple where concreta 2 backfill was used for repair without influencing the design of the structural sat. Ibasco procedures QCIP-6 and 7 and J. A. Jones procecure M-STIP-7 cc'rers structural concerece only. Therefore, no FCR or DCN was required for the use of j lean concrete as a substitute for soil. i I I-B-2b - Use As Is: A review of the referenced inspection report (Attachment II, Page 42) (r% indicates the possibility of placement of clam shell into standing water
\./ however, it is not clearly defined. The record further states that a meeting was held between construction (K. Flanigan) and Engineering (B. Watt) and the Site Soils Engineer (M. Temchin) allowing placement of shell. A review of the technical specification LOU-1564.482, Attachment on clam shell, shows that the only moisture content requirement is after compaction. In-place density tests on this Strip (Attachment II Page 58 Tests 2-3 (670) and 2-4 (671)] indicate moisture contents of 5.5 and 5.7% respectively. Therefore, the after cespaction moisture content tests show the shall fill to be acceptable.
4 s I-B-2c - Use As Ist Note: Refer to page 51 for problem statement, in addition to page 53. The inspection report referenced in Attachment II, Page 51 is explained in r greater detail on page 53. From page 51, it is noted that no new shall was placed, only that 15calized areas of chick shell on the west half of Scrip #2 i were bladed to thin sections on the east half of Strip #2. These localized areas were then recompacted by the pan (place) vibrator. Page 53 clearly indicates that the entire Scrip #2 was properly compacted with a large roller. TS exception of the localized repair areas which were properly compacted with the pan vibrator to the Site Soils Engineers satisfaction is in accordance with ! -the specification requirements, t 4 i f l
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This is an identical case as described in Section I-B-2a of this NCR. Please see that disposition, which applies in this case as well. I-B-3b - Use As Is: In a review of the number of passes placed on Strip #5 clam shell the following understandings were developed:
- 1. Shell placed and compacted 9-76 day (Pg. 102-103)
- 2. Thickness checked 9-76 night (Pg. 104-105) Notation of 6 passes given in previous shift is in error. Should have read 10 passes
- 3. Shall race =psetad with 10 passes 10-75 day (P;. 107-109) i 4 Survey error in width of Strip #5 lead to the addition excavation of a narrow scrip of soil on the south end of Scrip #5' (approxi=ately 3' vide). Clam shell'was placed and properly compacted on this narrow scrip on 2-13-76 (Pages 110-113).
- 5. Site Soils Engineering approval of the original (narrow strip) was
[ *) given on 2-11-76 (Pg. 109) prior to the discovery of the survey error.
- 6. Approval was given for the narrow strip on 2-13-76 by the Site Soils Engineer (Pg. 111).
In conclusion, it appears that 20 passes were given to the originally cut Scrip #5 which is contrary to the method specification stated in the attachment to LOU-1564.482, requiring 10 passes. The effects of this overce=paction of the clam shell are'found to have a negligible effect on the quality of the final clam shell blanket for the following reasons:
- 1. An extrapolation of the Settlement vs num'oer of passes curve from the Clam Shell Filter Blanket Test Report (Attachment III) presented as page 138, Attachment IV indicates that less than h" of addition sectiement is realized by the application of the addition 10 passes of compaction equipment.
- 2. An extrapolation of the'% compaction vs. number of passes curve from the Clam Shell Filter Blanket Test Report (Attachment III) presented as page 119 indicates that approximately 1% additional compaction will be realized by the additional 10 passes of compaction equipment.
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- 3. An Extrapolation of the gradation vs. number of passes curve from the -
Clam Shell Filter Blanket Test Report (Attachment III) presented as page 140 indicates that although the surface of the clam shell may undergo some slight additional breakdown from the 3/4" to #16 size screens, no additional - #200 particles will be created which could effect the permeability of the shall blanket. In conclusion, the overcompaction of the Clam Shell Filter Blanket in Strip
#5 created a less compressible, slightly denser blanket without effecting the per=eability of the filter which is therefore found to be acceptable.
ITEM II - Traceability / Location Deficiencies II-A - Use As Is: The docu=ented sizes of each of the Clam Shell Filter Blanket strips is presented in the geologic mapping report dated February,1977 Figure No. I attached as page 141 in Attachment IV. The square footage of each of the strips is thus calculated to be: Number of Tests
. Strip No. Surface Area ft Required Actual 1 267(97.5) = 26,032 6' 6 2 267(58.5) = 15,619 4 4 3 267(70) = 18,690 4 5 4 267(48.5) = 12,976 ft., 3 4 5 267(58.5) = 15,619 4 5 6 -
267(47.0) = 12,549 3 5 267(380) 24 29 Review of the above table indicates that each of the six strips had at least the required number of tests and in fact, five (5) additional tests were performed in total. _p .. +-
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9 j .) / j ') .) ) I d II-B - Use As Is: , As previously described in the response to NCR Item I-B-33, due to a survey error, Strip #5 was cut 8 feet too narrow in the horth-South direction. The addition scrip excavated on 2-13-76 is documented to be on the South side of I Strip #5 (pg. 110) and is documented to be eslied the "Deyo Strip", and is 8 foot wide (pg. 112). Item III - Engineer's Approval Prior To Shell Placement
- 1
- III-A-(1-4) - Use As Is
In all of the scrip placements listed except Strip #1, the J. A. Jones Cla: Shell Filter Blanket Inspection Report Form W-SITP-2 was signed by the Site 3o11a Engineer on the line entitled " Release for Installation and Compaction ] Obtained Yes X No ."
- It is true that the Ebasco Site Soils Engineer Release Form QC-132 From QCLP-1 cannot be found. However, the existing signatures on the J. A. Jones Documentation and the Release on Scrip #1 indicate that the engineers approval was given. Refer to the following Site Soils Engineer Releases:
#"' Strip #1 Page 6 & 7 Qt .*
2 31, 37 & 38 l 3 64 & 70 i 4 85 1 5 98 1 6 . 126 l , Item IV - Certification of Personnel - Use As Is Certification of the personnel referenced in this section of the NCR has ) been reviewed by Ebasco QA, GEO QA, and the Site Soils Engineer. In their
- responses to this issue, attached in Attachment IV, pages 154 - ljj[_, it is stated that all of the personnel listed in this NCR were qualified to perform the inspection they did, at the time they did them, although Employer Certification did not exist. Therefore, the inspection by these personnel, based on their qualification, is acceptable.
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c p dd/ j ) !} ) j -l Item V - Testing V-A-1 Use As Is: 4 An analysis of the gradation of the compacted Clam Shell After 10 passes indicates that over 90% of the shell is smaller.than 3/4 of an inch (page 140) and over 60% of the material is s= aller than of an inch. In accordance with the Site Soils Engineer's interpretati)n of the intant of Table 2 of ASTM D-2167-67 it is our understanding that a minigum test hole volume ranging from .050 ( " material) to 0.075 (1" material) ft would be acceptable (page 142) using this interpretation all of the 29 clam shell denstty tests are found to be valid. The variance in the use of =inor reduced volu:e in the si:e of the density hole has a negligible effect on the cast result in enis case. 1 i V-B - Use As Is: 4 As stated in the response to NCR Section II-A, the Clam Shell Filter 31anket Testing frequencies were compgled with using the requirements for density testing of 1 test per 5000 ft for the foundation materials, 24 casts were required and 27 tests were perfor=ad as shown is foundatica material property table presented in Attachment IV on page 141. f'i , *. 0/ l V-C - Use As Is: Based u'pon the geometry of the phase IV excavation, as shown on design drawing LOU 1564-G-489. Section A-A, the elevations of the f'oundation and clam shell tests are known as follows:
; Bottom of Plant Island Material: -47.00 i
i 2-3" Mud Mac (Avg. 3") -47.252 10-14 Shell Blanket (Avg. 12") -48.252 Using this information, elevations recorded on each Ebasco Inspection Report (QC-93) typically shown on pages 32, 65, etc., and the North-South and East-West coordinates on the density tests forms typically shown on pages 81, 132, etc., the three dimensional location of all foundation tests (El -48.25)
} and clam shell tests (El -47.25) is found.
Relative to the note on the location of clam shell density tests 453-455, these costs were located properly but plotted on the wrong grid (pg. ~7). A i second grid was used for the foundation and clam shell testing program locations as typically shown on pages 61, 82 etc. Replotting the density tests 453-455 on this grid, as shown on Attachment IV, page 143 shows these tests to fall randomly within Scrip #1 as indicated on page 27. l I 6 i
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3 1/ 1 1 ) ) i 1 V-D - Use As Is: In accordance with page 9 of the geologic mapping report dated February.
- 1977, and enclosed in Attachment IV, Page 144, each foundation density test had a proctor test run on the density hole material and surrounding material (50#
sample) to determine the exact percent compaction. The results of the in-place density tests and their corresponding proctor tests are presented on the final geologic map presented in Attachment IV, page 141 along with the minus 200 data and the exact location of the test within the appropriate scrip. Final acceptance of foundation density tests was made in NCR-W3-193 copy attached as pages 145-149. V-E - Use As Is: A general review of all of the changes discussed in this section of the NCR ara the rssult :f a ravisv Of by casting rasults parf:rmad by tha lahcrater; itself. Although the changes were improperly entered on the test records, it is believed that these changes were performed in the interest of correcting errors detected during quality reviews within the testing laboratory itself and are therefore acceptable. V-E-1-a - Use As Is (~% u The following discussion may explain the discrepancy in the volume recorded in test 452. of .0736 On theft 3 initial density record recorded in the field jQC-83 Pg. 24) a volume was recorded yielding a density of 85.0 v/ft . Upon review in the lab, on the'same day, the inspector noted that the volume of this hole was larger than the two following holes he dus which he may have felt was not true dug to his negory of the situation. He therefore adjusted the volume to .0636 ft , a .01 ft adjustment which he believed could have been a reading err:: en the sight tube on the densometer (pg. 26). This is a possible explanation of the change and if it is accepted or not, this cast 452 can be voided without influencing the quality of the shall since it was taken af ter only 6 passes, and not included in the permanent record of required tests taken after 10 passes, i - V-E-l-b - Use As Ist i The Density Test Record on page 20 is a field copy dated 10-28-75. Due to I a significant number of changes and noted recorded in the field, the form was j rewritten for clarity on the following day (gage 22 10-29-75) and a recording j error in density test 495 in volume (8.01 f t ) was corrected. In addition, foundation proctor valves were inserted in the proper boxes and percent compactions were calculated. The form shown on page 22 a corrected record and i superceded the form on page 20 and is acceptable as is. k - i l 1 l .
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l { V-E-2a. 3A - Use As Is: i l A review of these records indicates that in several places, data was erased and changed. In all cases, corrected data appears to be consistent with other } data recorded in this scrip. It can only be concluded that these changes were { " made on the spot by the inspector for the purpose of correcting errors in recording the data. Example; page 118 cast number 751 changed to 752; Test 748 l location E6-84N changed to 74N. 2 Although these changes were documented improperly the corrected data is consistent with the valves of unaltered test data on the same strip and is j therefore considered to be acceptable. I V-F-l & 2 - Use As Is: i l that on page 119 of Attachnent II the n ce at the bett:= ef cne ;s;s indi:ntat i: in the inspectors opinion (due to a local compaction operation by the hand ] j operated place compactor) the clam shell was broken to a greater extent than no r=al . In this case the increase in Lab Standard Density from 102 to 1051/Ft3 I ~! vas more severe on the % compaction calculation and is considered to be conservative and acceptable. In a similar manner, the uge of a clam shell maximum proctor valve of r", 102.79/Ft 3 instead of 102.0#/ft an page 132 could only yield a slightly 1cuer : . \J' compaccion and is therefore considered acceptable. i l' Item VI - Documented Deficiencies Without Corrected Action VI-A-la - Use As Is: As per the NCR response to Section I-B-la and I-B-2a, the replacement of gunite is outside of the neat line of the Class I excavation and above the shell blanket. This type of operation was performed so as not effect the quality of [ j the in-place shell blanket. Even if minor effect were realized on the surface of ' t the shell blanket, this area (10' wide) is so localized that effects on the j permeability of the shell will be negiglible. 1 j VI-A-2a - Use As Ist 4 The wooden stakes referred to in inspection reports for gunica in Scrip #2 page 29 and 29 are in the 3 foot horizontal gunite born at E1 -40 at the top of I
- the Class I vertical face. They are outside of the Class I area and although it was preferable to remove these stakes after guniting, in some cases they were left in place to support the gunite facing without any effect on the quality of j
the slope protection. 4 l I a l i i l 4 .
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.) a/1 i ) ) i 7 VI-A Use As Is:
The defective shell thickness shown on page 36 (12-12-75) of Attach =ent II was corrected as stated on page 42 (by blading shell from the west half of the strip). The final thickness of 9h inches is docu=enced on the inspection report attached as page 41 with the state =ent "OK on 12-12-75". The East half of Strip
#2 was reviewed'by the Site Soils Engineer the following day on 12-13-75 and found acceptable for =ud =at place =ent as docu=ented on page 45 of Attach =ent II.
VI-A-2c - Use As Is: As per the inspector's notes on page 42 of Attach =ent II, in a decisien between the Site Soils Engineer and the Construction Superintendent, cla= shell was placed in standing water (in order to preserve the condition of the foundstion =aterials which vould : ntinue to swell and thsn dr; and :rneh if left uncovered). In place density tests perfor=ed on the West half of Strip 42 nu=bered 670 and 671 (pg. 58) indicate that at the ti=e of final ec=paction :he standing water had drained away and =cisture. contents of 5.5 and 5.7*. were realized co= pared to a =ax1=um allowable =oisture concent of 20%. VI-A-2d - Use As Ist k/ A review of the documentation from Attachnent II pages 32 through 53 indicate that in two locations on the South half of the East half of Strip #2 contained saturated localized spots of. foundation silts. Upon co=paction of the Clam Shell Blanket, water from these sile foundation materials was vibrated to the surface of the shell rendering the shell compaction unacceptable. Five shell drainage sumps were excavated and pumped to remove excess water. Upon further co=paction, foundation siles pumped up through the shell causing a s=all localized " MUD" pocket. The sumps were backfilled with shall and recompacted with a place vibrator (pg. 37) and the mud pocket was allowed to relieve its hydrostatic pressures for a day (pg. 36). Similar liquification proble=s of the foundation siles vers noted and created (pg. 46) on the West half of Scrip v2. Final approval of the entire scrip was given by the Site Soils Engineer on 12-15-75 as stated on page 45 & 53 noting hand compaction of mud pocket areas and that the sumps adequately compacted and approved. VI-A-2e - Use As Ist The understanding of the cut and fill operation documented on pg. 51 of Attachment II is as follows: e e
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j ,1 / 1 1 ) > i I 12-13 day Cut & Fill +2 passes Pg. 42 12-13 Night 4 passes Pg. 43 Total So Far 6 passes As Per Pg. 46 12-14 Day Remainder of 6 passes Pg. 4 7, 48 This documentation indicates that the original Clam Shell Filter Blanket was compacted with twelve passes prior to the cut and fill operation documented
- on page 51. The inspection report on page 51 indicates that only one inch of
=4terial was coved and that the place ce=paction of this one inch of loose caterial was'found acceptable by the Site Soils Engineer as documanced on page 53 approving the entire Scrip #2.
"I-A-3a. 35 "3a .'s3 I3:
Based upon the problems docu=ented in Scrip #2 concerning liquification of I the foundation silts during ec=paction, drainage ditches were cut along the North and South lengths of Scrip #3. This is partially docu=ented on page 69 of I, Attachment II. The drainage ditches were 2 foot deep and 3 foot wide, covered with Miraff; Filter cloth and filled with shell. The normal Clam Shell Filter i Blanket was then placed on top of these ditches (acting as foundation material)
*'5 and due to their narrow size needed no special compaction since compaction to a
[6 t reasonable density would be achieved during Clam Shell Filter Blanket Compaction Operations. This same drainage scheme was used in Scrip #5 and is adequately documented as to location and geometry on page 100 of Attachment II which is typical for Strip #3 as well. VI-A-4a - Use As Ist No special knowledge is known of how this change was made. Documentation , available indicates that gunite placement on the West third of the North Wall of j Scrip #4 originally need to be trimmed. Later during the shift, the gunite was crimmed and the original form entry was changed by J. S. G. or D. S. G. or MR "X" (unknown). Since the gunite was later inspected and accepted by the Site Soils Engineer prior to claa shell placement (page 85. Attachment II) on 2-13-76 and since the gunite is not a Class I material and is documented to be structurally thick enough the gunite, as placed should be considered to be trimmed back in an acceptable mana . t l m-~4 - F +
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VI-A-4b - Use As Is: Although missing documentation is indicated in the place =ent of gunite on Scrip #4, the Scrip #4 was released for clas shell place =ent by the Site Soils Engineer on 2-13-83. Cc=placed gunite slope protection is indicated in Ebasco Record Photographs #607 (West Face And West Half of the North Face), #620 (Entire East Face) and #624 which indicates a portion of the East half of the North face of Scrip #4. Copies of the photo's are attached as page 150 of Attachment IV and originals are available from the site photographer. VI-A-$a - Use As Is:
- Review of the inspection reports on the gunica place =ent of both faces of Strip #5 dated 2-5-76 (pages 95 L 96, Accach=ent II) indicates that the overspray gunite was not cri==ed off. The same day, the Site Soils Engineer and Fiald Ingineer app:oved the strip for cla: shall placa:ent (pg. 93). Thia indicates that either the overtrim was re=oved or it was located in a spot (exa=ple the outer edge of the 3' horizontal bers on E1 -40) that would not affect the Class I clas shall blanket or structural foundation =at. Therefore, the overspray is found to be acceptable without removal.
IV-A-$B - Use As Is: (~x As in the discussion above, without the adequate documentation, it can only be assumed that the gunite contamination of the clam shall along the West wall of Strip f 5 was on the s=sil a=ount of shell exposed on the Southwest Corner Strip #3 under the mud mat. This is believed to be the case since Clam Shell Placement in Scrip #5 itself did not start until 2-9 4 days after the placement of the gunite slope protection'(pages 102-108, Attachment II). In all scrips excavated, clam shall in the common excavation face (in this case, the South edge of Strip #3 is the North edge of Scrip #5) was cut back to key the new shell into the existing shell blanket if the filter cloth was not present. Although not documanced for Scrip #5, this was a required construction operation, documented on the QC-93 form under the heading " KEYING" on page 1 of the form. Review of this item on pages 102, 104 and 107, indicates that the localized nature of this contamination (3' from the West wall in the Northwest corner) by the documented entry "None". Keying was not required for this scrip when the filter blanket itself was placed. Therefore, it is believed that the s=all quantities of contaminated clam.shell were removed and replaced and found acceptable by the Site Soils Engineer on 2-11-76 (pg. 109, Attach =ent II). e e += wgm we =*-em ~
- 4 5
l
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-t3-VI-A-Se - Use As Is:
A review of the Clam Shell Filter Blanket Inspection Report for the "DEYO" ] strip added to the South side of Strip #5 (pg. 111, Attachment II) indicates that the Site Soils Engineer approved the compaction of this Strip (Line 8) and indicated thac alternate methods of compaction were not used (Line #9). The ;
"DEYO" strip was cut af ter most of Scrip #5 was already finished due to a survey i error. The original planned size of Strip #5 ( 55') was originally cut to 30' 4
. wide and then expanded by 8' to a total width of 58'. The 3' oversize (Sa'
' compared to 55') was specified so as to allow for normal compaction of this strip by the 12 con rubber tire, vibratory smooth drum roller which is d' wide.
l The "No" on Line 9 is a stata=ent that alternate =ethods were not used. This strip is therefore found acceptable. J i
- '* -A-6-s
. "se As Is :
l > As stated previously in responses to similar portions of this NCR the gunite is not a safety related =aterial. In this case (pg. 124-125 Attach:ent II) the Class I Clam Shell was not in place when the gunite was placed. The
- crim and overspray indicated are primarily associated with gunite placement at the top of the vertical face on the 21 -40 butm. Therefore, no impacts on the i Clam Shell Blanket or Structural Foundation Kat can be realized oy the lack of
; 't trimming activities on the gunite slope protection. Signatures by the Site
! [!?
' Soils Engineer and the Field Engineer (pg.126. Attachment II) indicate that the minor trimming activities documenced on 2-9-76 were indeed performed and approved prior to the placement of Clam Shell the following day.
J
.VI-A-6b - Use As Is:
. Record photographs #648 (3-16-76), #650 (3-18-76), #662 (4-2c76) and #666 } (4-2-76) located on the strip key plan (Attachment IV Pg.151) enc' shown on
- pages 152 and 153 show the presence of the gunite slope protectier. in question.
!. Although there exists at the present date, no documentation on its placement, it i is known to exist and Clam Shell Filca'r Blanket Placement against it was found
- to be acceptable and approved by the Site Soils Engineer on 3-12-76 (pg. 130,
- Attachment II).
I, 1 VI-A Use As Ist As per the discussion presented in this response to the NCR for section ] VI-A-2d. The corrective action for the " Mud Spurt" was found to be acceptable by the Site Soils Engineer and approved on 12-15 '5. 4 1 I J 4 i ?
- 26. What were the problems of soils, waterstops, cadweld splices, and the placement of concrete, as mentioned in the third column on page 22 of GAMBIT, and how were they resolved?
Response
The GAMEIT article did not identify the specific " records packages" which contained the alleged deficiencies. However, it is kncvn that Hill generated the NCRs addressed in Question 25 which pertain to these subjects. The " soils documents" referred to by GAH3IT 2re probably those addressed by NCR-W3-5997 (about 200 pages pertaining to the clam shell filter blanket). Each of the 64 findings are detailed in Attachment I to UCR-W3-5997 and are su=narized in the response to Question 25. Each of the 64 findings were resolved by the Site Soils Engineer in Attach =ent IV of NCR-W3-5997 . The cadualding pr: bis =s referrad to are probably these docu=antad in NCR-W3-5998 also addressed in Question 25. The waterstop problems were generally gouges or nicks which were repaired. Waterscops are not Class I items; their function is to prevent inleakage of groundwater thereby minimizing the amount of water routed through the Waste Management System. The concrete placement problems were addressed in Question 9. e . - . . , . - - = - . e.m.,-
- 27. Do the allegations described in Phearson's memo and the Gambit article reflect generally what happened during the constructin of the mat? If yes, how would these non-conformance of QA/QC requirements affect the structural integrity of the mat? 4f not. identify those allegation which are unfounded and the basis thereof.
Response
See response to Questions 9, 11, 14, 22, 24, 25, 26 and 28. ,,.wn-
~~ '
4 i
- 28. In light of the allegations, documented NCRs, and QA/QC deficiencies, what has LP&L done or what does LP&L intend to do in order to resolve the allegations and deficiencies?
Response
LP&L letter W3K84-0629, copy attached, provides a summary LP&L response to allegations regarding Waterford 3 quality. The general LP&L con-clusions included in W3K84-0629 are as follows:
- 1. The allegations did not uncover any significant new information regarding Waterford 3 quality.
- 2. Deficiencies in the physical and records quality of Waterford 3 have been and are being addressed under the programmatic require-i
=ents of the Waterford 3 Quality Assurance Progrs=.
- 3. LP&L has exerted extraordinary efforts in the resolution of deficiencies.
4 The general tone of the allegations, and the insinuations that LPit =otires are questi: sble, ars totally arr:necus.
- 5. Continuing Waterford 3 activities in the Quality Assurance areas are designed to redouble LP&L confidence in Waterford 3 quality.
4
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UNITED STATES - i *h 2 i NUCLEAR REGULATORY COMMISSION WASHWCTON. D C. 205$5
\-)$ld
/ i APR 2 71Ba T
M 3 J/ i, r . .:' MEMORANDUM FOR: Dennis Crutchfield Dedicated Senior Manager 1 Division of Licensing, ONRR FROM: George Lear, Chief Structural and Geotechnical Engineering Branch Division of Engineering, ONRR
SUBJECT:
STRUCTURAL ADEQUACY AND SAFETY EVALUATION OF WATERFORD 3
, BASE MAT
References:
- 1. Memo to J. T. Collins, et al, from W. J. Dirks, dated March 12, 1984,
Subject:
" Completion of Outstandir.g Regulatory Actions on Comanche Peak and Waterferd".
- 2. Memo to G. Lainas, et al, from T. Novak, dated April 24, 1984,
Subject:
" Issues Currently Under Review Within NRR to Support Licensing of Waterford 3".
Following the instructions contained in the above references, enclosed is a report of " Safety Evaluation of the Structural Adequacy of the Waterford 3 Base Mat". If you have any questions, please contact at X28085.
//
$1 George LMr. Chief Strectural and Geotechnical Engineering Branch Division of Engineering
Enclosure:
As stated cc: w/ enclosure D. Eisenhut T. Novak G. Knighton R. Vollmer J. P. Knight G. Edison L. Shao J. Wilson L. Heller D. Jeng / J. Chen FREEDOM OF INFCRMATl0N d: J L. '- J. Ma
*f.
ACT RF. QUEST 19-4 5' f g'}2,y' W W.33
1, . . .
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j , i h - l f ' SAFETY EVALUATION OF THE f STRUCTURAL ADEQUACY OF j THE WATERFORD 3 BASEMAT ; i I I i STRUCTURAL AND GEOTECHNICAL ENGINEERING BRANCH ! ( O! VISION OF ENGINEERING l i 1 i l -- L I i i I ! { Prepared by the Staff of the l Structural & Gectachnical Engineering Branch l Division of Engineering i Office of Nuclear Reactor Regulatien i j April 27, 1984 [ l I NEDOW OF INFORMAL 10N
! ACT REQUEST ) f 4-4s f -
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1 l Table of Contents I. Executive Summary 1 !!. Overall Evaluation 3 1. Introduction
- 2. Geotechnical Safety Evaluation of Waterford 3 Foundation (Enclosure 1)
- 3. Structural Safety Evaluation of the Basemat t (Enclosure 2) 4 Independent Evaluation of Basemat Analysis by Brookhaven National Laboratory (BNL) (Enclosure 3)
, 5. Evaluation on Corrosion Effects of Basemat Retar (Enclosure 4) , t'
- 6. Recommendations for Waterford 3 Licensing Action i
f i J
}
e I 1 i e e
EXECUT!vE
SUMMARY
In response to a March 12, 1984 memo from the Executive Director for Operations, subject: " Completion of Outstanding Regulatory Actions on Comanche Peak and Waterford", the Structural and Geotechnical Engineering Branch was assigned the task of reevaluating the structural adequacy of the basemat and the related Category I structures at the Waterford Nuclear Power Plant. Concern was focused on the effect of cracks which had occurred in the concrete during construction, especially in view of some recent allegations pertaining to concrete construction at the site. The SGEB staff and its consultants frem the ! SrookhavenNationalLaboratory(BNL)metwiththeapplicant, Louisiana Power and Light and its architect-engineer consultant finn, ESASCO, a rumber of times. A visit at.the site on March 27, 1984 provided the SGEB staff ano consultants opportunity to see the cracks, question the builders, and examine records. Additional infomation was requested of the applicant. Based upon the observations at the site and the review of information available to the SGEB staff, the SGEB staff and its consultants have completed a safety evaluation on the structural adequacy of the baserat and related Category ! structures. A summary of the cenclusions follows: The geotechnical engineering staff has concluded that: (1) The " compensated" foundation concept is sound and acceptable.
.4.
(2) *he Cracks ir, the foundation t.a* ard Super $*ructure were pr0bably Caused by cifferential Settlements during CCr5truction, ( 2 ,' T .f - ' f f e r e t '. ! Settle erit 5 resulted fr:r ::r 'iC4.t 5:11 C:Ecitions, hign ground a er levels. CCm:4Ctior. Cf snell filter ,
$*rtps and scre COncrett block Con 5truction pro:tCures, and e
imptt'cAben ' : ', ":... 3 :s ce t., f:undnic -n are tne ge:,tn :f t e :en. : wili .
%t once m mat are :: :t .e. - Charac.tertge els . bdh bege of sma.1\ ?
Yecent:. La.\. 'g Enc.tewre i Says future setilement l's negtlofUlt- M e) in sa.me <ena.1. segtemed b '% ii _.. 5 ..,...g
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. . . . . g . 3 ,. . . :......, ... .. .. .,, ,, ..,
...; w .. u tifiec anc C::..e :e: C rstru:t :t : . " :.::: e s.
;C Tre cat is n:: currentis in Cistress tasec :r *e ::se '.nt:r Cf C'"'1-
-uhti ik W. a. yrdotern soon ? uuha.t. dces this mean 7 t,0ba.t% engmeering eva.L. for next 30 yrs?
(3) Verification of shear CaDacity of the_m.it unde * $$i F*a9 te be - g 49 n ,> 00ne, l1 part Cf *.hi$ veri #1Citt:n Cr0 gram, se'e:tive
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- :en u:: ei it ' ; 9 : e.i . n' a e e::- r : e :: :: .i - than Ac..c
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*: men :r Cricts a .:(E::en::ai ,:i:p i n 3 : : e4- go e um e"ee: en :ne nn . @ma.u pe,ed.we =butmant :
don't believe. %e.te are, any b4 4 4.hett are. , catc3 mo ex. i:; :! ;-i' * :a n: :: r r e s i c r. :, ' e' ':r:t e; ta r :,,e :: :~e ; :. :.a:er is te'.*evec 10 :e u.I'hely r a*. t e s'.:t. ' e '. e r :
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5-The structural and geotecnnical engineering staff has jointly concluded that: (1) A general surveillance (monitoring) program is recommended fo ! agret Idantihon Mth crasts 4e the cracks. For evident shear cracks, the length and size of a k wo,4 crack and its propagation against time should be marked and also
% (giq I
recorded. tyge q ces
- continapret en (2) The current monitoring program of foundation settlement should be f*P h
- g h expanded to enable more accurate measurements of differential settlements and crack growths. -
utnM 4 wecq w'if,h cang T*5rmm ? (3) The applicant is requir,ed to either justify that its original analyses are still adequate in light of the NRC geotechnical engineering staff evaluation (enclosure 1), or perform additional analyses to account for the actual foundation soil conditions. (4) The applicant must update its crack mapping records and submit its proposed surveillance programs for settlement, concrete cracks, and corrosion of reinforcing bars prior to issuance of the OL license. - net, Nrdo]I (5) An independent report (enclosure 3) of our BNL consultants in general is supportive of the above conclusions. Our BNL consultants have indicated confidence in the functional performance of the nat, provided confirmatory reasures including monitoring are l accomplished. 1
!!. Overall Evaluation
- 1. Introduction The Structural and Geotechnical Engineering Branch (SGEB), Division of Engineering has been requested to provide structural design adequacy of the Waterford 3 "as-built" base mat. In the course of developing information needed for the assessment, the SGEB staff and its BNL consultants held meetings in Bethesda, MD. on March 21 and 26, 1984, at the Waterford Plant site in Louisiana on March 27, 1984 and at Ebasco headquarters in New York City on April 4, 1984 Additional infomation was also obtained, via phone conversations, from the Region IV staff, the applicant and its consultants.
In brief, it was found that since its construction in late 1975, the concrete base mat of Waterford 3 has experienced cracks and accumulations of minimal amount of water through some of the y cracks. These base mat cracks als everal cracks in the
- g, _
MnRage crMS. reactor shield buildinc and other structural walls su ported by the b%t Eff. p)all will of&cX related ? aqWg-ifnd mat. The cracks are generally believed to have been caused by
+n tract wherg gggg is g differential settlements of the base mat an possibly due to seme
' OA/0C deviations during concrete cours.
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j.32,' 4 pac {ng Technical evaluations of the analysis, design, construction and QA/QC aspects of the base trat were cerformed with their key% on ysde. h rn not a.n Lthe 9Aq "AM findings described in the follcwing sections. i m *H
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Key recommendations to be incorporated as part of theWaterford 3 '- _x y operating license are also } fsted in this evaluation. , 3s , 5 m
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- 2. Geotechnical Safet Evaluation of Waterford 3 Foundation q _,
Thesgeotgehnical engineering staff corclyded that:
~,
( ' * , _ ;c (a) The plant foundation design, i.e., the " compensated" foundation concept, is sound and acceptable.
, i s (b) The cracks in-the foundation mat and other related structural i
elen.enti were probably caused by differential settlement that
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-- occuhred mtjnly during constructicn settlemeSt.
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(c) These dif firential se'ttlements 'are i believed to have resulted 3 et . y frw complicated sol1 condit' ions, l'igh grourdvater level's, N tuw{orm , y. gggn compacticn, of s h51 filter strips and the, concrete olock ,s constry ion procedures. ,' difN.""4u e,tas b - - in gg ? q- ;; ? SeperrjNor poor u>oric 7 (d) Mrbmentsofthe ounds on mat 1rd the.' growth of the cracks s 1 x ' N. i will continue. 9 rwect rwe Ms gab.
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,\ 4 (e) Seasonal groundwater level fluctuatiin will cause somed '
- a. c %I s movement of the foundation mat.
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(f) In order to examine and evaluate the future performance of the foundation, it is recommended that the current monitoring program be expanded to enable more accurate measurements of differential settlements and crack growths. [A55 prominent)- idenh'{q cracks should be mapped and included in the program. N 'ust- Qgh-
. bM Enclosure 1 provides detail technical bases of the above conclusions.
- 3. Structural Safety Evaluation of the Base Mat The structural engineering staff concluded that:
(a) The mat is curren in distress based on the crack observation. Verification of shear capacity under SSE needs to be done. As bU when # (b)
- part of this verification program, selective nondestructive testing and evaluations are reccmended to obtain information i
oncracksand(potentialvoidjandtheireffectontheccncrete
**
- A wha.t is 4he need. to loot. Terr 9 hem ?
M % TAcA. Vohs t>ath onig ere stw{ ace. Wb.bte . (c) The licensee is required to either justify that its original ( analyses are still adequate in light of the NRC geotechnical engineering staff evaluation mentioned above, or perform 1 additional analyses to account for the actual foundation soil 1 concern urd9tlud me.ieria.l orjtAsi. chrnsheQ ? f
**=wn-e
. g.
conditions. M SMutSMn%e? tahg shear cracts ? (d) A general surveillance (monitoring) progra is recommended for the cracks. For evident shear crack , the length and size of a crack and its propagation against time should be marked and recorded. (e) Corrosion of reinforcing bars due to the ground water is believed to be unlikely at the site. Nevertheless, a surveillance program is recomended. Enclosure 2 provides detail bases of the above conclusions.
. 4 Independent Evaluation of Base Mat Analysis by Brookhaven National Laboratory (BNL)
The Structural Analysis Division of the Department of Nuclear Energy at BNL was retained as staff consultant's to provide an t independent evaluation of the structural adequacy of the base mat with emphasis in reviewing the analysis documents provided by the ! applicant and its consultants. l - l The BNL staff has concluded that: t (a) The net expected changes in soil stress due to construction and corresponding settlements of the mat should be relatively i l l a,, m -m~- e- - u . - - --.
sma'11. (b) Having reviewed the information reports and computer outputs 1 supplied to BNL by EBASCO, HEA, and LPL , it was found that
. .. normal engineering practice and procedures used for nuclear power plant structures were employed.
(c) Accepting the information pertaining to loadings, geometries of the structures, material properties and finite element - u:hu g45 adl idealization as correct, it is the judgement of the BNL staff ikd1 ? that: (i) that the bot, tom reinforcement as well as the shear d,og$ qKjg capacity of the base mat are adequate for the loads ' ktda 5SE ? considered. (ii) that computer dead weight output data can be used to explain some of the mat cracks that appear on the top surface. The cracks that appear would have occurred after the construction of the superstructure but before the placement of the backfill. Their growth would be constrained by subsequent backfill soil pressure. 1 LP&L is the utility, Louisiana Power and Light, ESASCO is the engineering consulting firm to the LP&L and HEA is the Harstead Engineering Associates, Inc., for structural cracking evaluation. O mowe.-
(d) Due to the existence of the cracks, it is recommended that a surveillance program be instituted to monitor cracks on a regular basis. Furthermore, an alert limit (in terms of amountofcracks,andorcrackwidth,etc.)shouldbe specified. If this limit is exceeded, specific structural repairs should be mandated. It is also recommended that a program be set up to monitor the water leakage and chemical content. (e) The validity of the BNL conclusions depend mainly on the information supplied by EBASCO, HEA and LPL, either verbally, in reports or in computer outputs. While some checks for accuracy ad engineering approach were made pertaining to the
. supplied information some open questions still remain, safek IS5ues 3 especially those mentioned in the text under topics 4 thru 7 pg under the heading, " Structural Analysis Topics Reviewed" I 'C E f'8( 9 l' (Enclosure 3). It is suggested that the particular issues raised under these items be resolved.
These independent conclusions are supportive of those established by the SGEB staff. These conclusions, where they highlight issues to be resolved, will be resolved through the implementation of the staff's recommendations. i 1 l
- 5. Evaluation on Corrosion Effects of Base Mat Rebar The staff of the Chemical Engineering Branch has reviewed the licensee's proposed Limiting Conditions for Operation on the possible corrosion of basemat rebar due to groundwater penetration through cracks in the concrete basemat (Enclosure 4).
The following factors were considered in the evaluation: (a) Analysis of groundwater at the site indicated a chloride concentration of approximately 35 ppm, which is significantly below the 710 ppm chloride corrosion threshold for reber in the presence of oxygen (D. A. Hausmann, Materials Protection, pp. 23-25, October, 1969). (b) The rate of seepage of groundwater 'through th foot th
~rtba k %r ss e n basemat is small, which restricts the access of dissolved 3-4 m:bes bm rourd -
W r p trl--- chlorides and carbon dioxide to the rebar-concrete weer interface. - LdNik M no 03, needec( Wo sarnpWs for corresfor, (c) The slow movement of water through the basemat causes the t water to become alkaline (pH=12.5) by contact with the calcium oxide and calcium hydroxide content of the concrete. (d) The corrosion rate of steel by alkaline water is low. 8
_ _ _ . _ _ . __ i
~
l l On the basis of its evaluation, the staff concluded that there is reasonable assurance that the basemat rebar will not be significantly corroded by the penetraton of groundwater of the acidity and chlorice content observed at the Waterford site.
- 6. Recommendations for Waterford 3 Licensing Action v
%t ums dM The following requirements should be established prior to issuance g of the OL license:
(a) The applicant should update his crack mapping records, including observable vertical or inclined cracks in Category I structures supported by the mat, 30 days prior to issuance of . license. (b) The applicant shall propose an expanded differential settlements and crack monitoring program and associated plant technical specifications within the next 30 days for staff i review and acceptance. (c) In order to expedite prompt resolution of the Waterford 3 basemat structural adequacy issue, it is recommended that the Division of Licensing forward and direct the Louisiana Power and Light Co. to implement the specific applicant's action items listed in Enclosure 5.
Enclosure 1 Geotechnical Safety Evaluation of Waterford 3 Founnation
- 1. INTRODUCTION
, The safety class structures at Waterford are supported on a
', continuous mat 270 feet wide, 380 feet long and 12 feet thick. The mat has been designed and constructed using the " compensated" or
" floating" foundation concept in which the applied loads on the foundation soil, the Pleistocene clay, have been controlled so that the effective insitu stresses remain essentially the same as the stresses existing before construction. In this way, the overall settlements of the foundation soil are controlled.
%em %e" aums de be ph:sd."
In July 1977, a number of east-wes oriented cracks were discovered at the top of the mat beneath the containment structur . Weeping water was reported to be low and not enough to fem a sheen but encugh to show the cracks and to moisten surrounding concrete. Epoxy grout was used to seal all the observed cracks in the mat 3be{ erg i[ the containment structuref uJas p\ aced. . @ h gg ag N Crac-k a.i iM 4.'tyne. . In May 1983, new cracks and accompanying weeping water were discovered in the base mat outside the containment structure Imh%n h of those cracks were found that extended to vertical wall by an NRC M investigation team in March, 1984. Je* omei$ J t w'na a.a w a~e .F waue - ,,ver.o g3 a * ' *v i ( i . . I
- l
~
This report sum.arizes the results of NRC's geotechnical engineering evaluation of the causes which may be responsible for the observed cracking. This report, also, addresses the present foundation conditions and anticipated future behavior of the mat.
- 2. SUBSURFACE CONDITIONS Subsurface conditions at the site were investigated between 1970 and 1972. 64 soil test borings, 50 to 500 feet deep, were drilled.
A general description of the subsurface conditions is presented in thhtachedTable2 f the Waterford SER.
\ alreadg in earlier SER. oe F5AR, Extensive laboratory tests were perfomed on selected soil samples.
Significant soil charac,teristics are presented in Table 2.6.
- 3. CONSTRUCTION SE00ENCE
, The construction steps involved were:
a) Groundwater control: Groundwater levels in the plant area were controlled during construction from 1972 to 1978 by pumping from 216 shallow wells and 34 deep wells around the perimeter of the plant area. The well tips were located at El. -40 feet for shallow wells and El. -95 feet for deep wells. From November 1972 to November 1974, dewatering was stopped and about 10 feet of standing water l accumulated in the excavation. In January 1977, 12 additional ( wells were installed around the foundation mat area to provide additional groundwater control beneath the mat.
The groundwater level was raised in a controlled pattern in late 1977 by 12 recharge wells, located near the edge of the foundation mat with tips in the shell filter blanket. Additional groundwater recharing was achieved by watering the backfill. By the end of 1979, the groundwater was raised to normal level ranging from El.
+3 to E. +12.
b) EXCAVATION The excavation, about 60 feet below the original grade to El. 47, was done in four phases: Phase I, grade to El. -5, April to July 1972 Phase II, El. -5 to El. -22, January to June 1975 Phase III, El. -22, E. -40, April to August 1975 Phase IV, El. 40 to El. 48, October 1975 to March 1976 Turbine building, grade to El. -40, January to March 1977
, Phase IV excavation, cut into the upper Pleistocene clay from El.
40 to El. -48, was made in six strips, starting with a 120 ft-wide strip across the center of the cor=on mat, and following the alternating strips north and south of the center strip. c) BACKFILL AND CONCRETE PLACEMENT: After each strip was excavated, the filter cloth, the shell filter layer and the concrete mat were constructed as soon as possible so as to reload the foundation soils and minimize heave. Marafi filter cloth was placed over the Pleistocene clay before the shell layer was placed. The shell filter layer, about a foot thick, was ccmpacted by a vibratory roller for 10 pas'ses. ~
The concrete mat was poured in 28 separate blocks from December 1975 to 1976. Each block had a thickness about 12 feet and an area which varied from 2000 to 5000 square feet. The construction of the super-structure was started in May 1977 with all concrete work completed in December 1980. Backfill material of clean sand, was placed below El. +17 around the nuclear plant island structure from August 1976 to October 1978.
- 4. EVALUATION The plant was designed to give a net reduction, by about 200 psf.
of the applied effective soil loading at foundation level. Before . construction began, the initial effective overburden pressure at foundation level was 3300 psf; after construction was completed the final effective static loading of the plant and backfill was 3100 psf. Therefore, the future settlement of the completed plant would
~
be negligible. During construction, tne insitu vertical stresses were controlled by lowering the groundwater level simultaneously with the excavating of soils. The lowering of the groundwater level would give an increase in effective overburden pressure which compensated for the soil removed. Later as structural loads were applied, the groundwater level was raised to reduce the effective overburden pressure and compensate for the structural loading. By this
technique, the differential settlement of the foundation soil would be reduced and its* effects on structures would be minimized. The construction procedures are generally sound. However, the control of insitu vertical effective stresses and groundwater levels was quite difficult because of the subsurface soil g g ,g conditions. Numerous constructi ifficul red during [] 9 construction, may have contributed directly or indirect 1v tn
- clite observed crackina of the foundation mat. Those renstruction problems included:
a) Dewatering: As discussed in 3(a) above, the tips of the dewatering wells were located at El. 40 ft., in the recent alluvium stratum, for shallow wells and at El. -95 ft, in the silty sand layer, for deep wells. The silty sand layer is an identified acuifer at the site. Because of the very low permeability of the upper Pleistocene clay, those wells did not completely lower the groundwater level in the foundations soils to below El. -49, as evidenced by some of the piezametric readings. Locally, those high groundwater conditions appear to have caused soil disturbance, mud spurt, standing water in some area of the excavation and difficulties in compaction of the shell blanket. 0
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S b) Variable foundation soil conditions: The foundation mat was founded on the upper Pleistocene clay. These clays were considered to be fairly uniform and over-consolidated in the design and construction of the mat. However, within the boundary of the foundation mat, the permeability and the compressibility of the clay layer varied significantly from one location to another as evidenced by the results of the piezametric and heave monitoring during construction. The measured heave at various location was 2 to 4 chat -to el in pK times the anticipated maximum heave used in the mat design; this becaaAse c(- indicates that the differential settlements of the mat would be Sw%tiirued-greater than anticipated. c) Variable degrecs of compaction in the six shell filter strips: The compaction procedures were selected based on the results of a test fill program. However, due to the variability of the supporting soil and groundwater conditions, the degree of compaction in these shell filter strips varied widely, from 80 to 98 percent. Filter strip number 1, 97.5 feet long and 270 feet l wide, was compacted to an average of 95 percent. Filter strip number 2, 58.5 feet long and located immediately north of strip number 1, was compacted to an average of 80 percent. Shell filter was placed in standing water in'the west half of strip number 2. A' mud spurt area of abut 120 sq. ft. occurred in strip number 2 i during compaction. Filter strip number 4, 48.5 feet long, was compacted to 98 percent. l 5 i on,
These variable degrees of shell compaction reflect the condition of ' the foundation soils. Settlements of the mat due to uniform structural loads would vary significantly; strip number 2 would settle more than strip number 1 while strip number 4 would settle less. Thus, differential settlements would be experienced by structures founded over different strips. The resulting differential settlement may induce bending stresses in the mat and cause east-west oriented cracking in the foudnation mat. d) Foundation nat construction: As discussed in 3(c), the foundation mat was constructed in 28 blocks with a thickness of 12 feet and an area which varied from 2000 to 5000 square feet. The load due to pouring of the first block of concrete caused an immediate settlement about 3/4 of an inch, and later, some additional consolidation settlement. When the second and third blocks were poured adjacent to the first block, differential settlements between the blocks were observed. This type of settlement pattern occurred for all later constructed blocks. These differential settlements may have induced some residual stresses in the concrete and may have caused concrete cracking, frcSt- likelg opefied Ke.g'i } CraCXS e) Significant hydrostatic pressure change: During the construction of the concrete mat and superstructures, the groundwater levels were changed significantly three times, ranging from 20 to 30 feet. These changes in hydrostatic O b __ __ f**** . _ . . _ . _ _ . _ . - - - - _ .
pressure changed the effective stresses in the foundation soils and caused movements of the foundation soils and the concrete mat. Because of the non-uniform nature of the foundation soils. differential movements within the mat would be expected. These differential movements may have induced strain in the concrete when it was still in the process of curing. The plant foundation design, the " compensated" foundation concept, is a sound one. The cracks in the foundation mat appear to have resulted mostly from the differential settlements experienced and, to a lesser degree, as superstructure loads were applied during construction. These diffe N tial settlements were caused mainly by
. _ . the variable soil conditions, high groundwater levels, and the
.. variable compaction of the shell filter strips and concrete mat construction procedures. The hydrostatic pressure changes, affecting the effective stress state in supporting soils, may have aggravated the growth of the cracks after the mat was completed. The future settlement should be limited and " stable" eche of the
" compensated" design. However,thecrackshcoverehn1983and verticalwallcrackskscovkin1984seemtoindicatethatthe movements of the foundation mat and the growths of the cracks are ouwimar doess y continuing. The current settlement monitoring program provided e some useful information indicating that the mat would move in
% MIS conjunction with fluctuation of groundwater levels. But the scope
***W
and the accuracy of the current program, are not sufficient.to provide accurate information to assess and relate the actual differential settlements to the growths of the cracks in the mat. Sensitive measurements are essential to determine the future behavior of the concrete mat.
. The scope of the current monitoring program should be expanded to collect more accurate information about the differential settlements in the mat and about the precise growth of new and old cracks. The more accurate differential settlement monitoring can --
be achieved by installing additional monitoring points on the mat SROCy eq: ,, with increased monitoring accuracy. The added points can be Pnontkpftng 7 located on the outside walls of the mat. The crack monitoring program would provide information about the development of new cracks and the propagation of the cracks. Specifically, those cracks that extend to the vertical walls should be monitored. Leachate on the cracks should be cleaned out to' expose the cracks. Brass pins or other means should be used to identify the extent ano progression of the cracks.
- 5. CONCLUSION AND RECOMMENDATION Based on the information reviewed to date and such other matters as
,1 in our judgement are pertinent, it is concluded that:
~
a) The plant foundation design, the " compensated" foundation concept is sound and acceptable. O r*cto - _, _ .- ~_ _ _. -
M mechcth6m k%gh slJh.b
- b) The cracks in the foundatio mat and structural walls were k) hat abat probably caused by ifferential ettlement that occurred mainly Tep shrintup! <!qqubb ettt55tST during construction.
NdW c) These differential settlements resulted from complicated soil conditions, high groundwater levels, compaction of shell filter strips and the concrete block construction procedures. _ phCEm.Qat S d) Movements of the foundation mat and the growth of the cracks RtLt.nC-C .3 will continue. e) Seasonal groundwater level fluctuation will cause some movement of the foundation mat. f) In order to examine and evaluate the future performance of the foundation, it is recommended that the current monitoring program be expanded to enable more accurate measurements of differnetial settlements and crack growths. [ promin h racks should be mapped and included in the program. m
' ~- ~~
~
Enclosure 2 SAFETY EVALUATION OF THE STRUCTURAL ADE0VACY OF WATERFORD 3 BASE MAT
- 1. This report provides the structural safety evaluation of the "as-built" Waterford 3 mat. Specific conclusions and recommendations to be incorporated as part of the OL license for the plant are al.so listed herein.
- 2. Insoection of Base Mat Structure Foundation and Review of Mat Construction Records The SGEB staff visited the Waterford 3 site on March 27, 1984 Staff observed cracks on the ring wall and wet cooling tower walls.
These cracks had not been specifically mapped and brought to the NRC/SGEB staff attention until the March 27, 1984 visit. Some of the cracks were inclined to the vertical axis (perpendicular to the mat) and were joined by a crack on the mat. Thus, these cracks were believed to be shear cracks. Other cracks on the walls and on the mat appeared to be shrinkage or flexure cracks. At the site, the Structural Engineering staff also reviewed construction records and interviewed some people who participated in the actual construction of the nuclear island foundation and base mat. _ _ _ _, a-_ __ , . - . _
- _ _ _ _ _ . _ _ _ _ . _ _ _. 1 t
- 3. Analysis and Desian of the Concrete Mat The applicant's analysis of the base mat utilized finite element
- methods and generally recognized formulas presented in a textbook written by R. J. Roark; these approaches are fundamentally independent of each other. The use of finite element methods in conjunction with electronic computers permits solutions of structures having complex geometry, loading and boundary conditions, such as the Waterford Unit 3 base mat, although correct 4
use of this method is rather difficult. The use of textbook formulas permits solutions for ideal loading and boundary conditions, but must be utilized in conjunction with engineering judgement to obtain solutions for actual (non-ideal) conditions.
, In its application of pertinent formulas, the applicant calculated positive bending moment in the mat under the reactor building by assuming a 20% edge fixity of a circular plate under the shield building, and a uniform soil pressure beneath the mat. The applicant calculated negative bending moment under the shield building by assuming a 50% edge fixity and uniform soil pressure under the mat.
f In its finite element analysis, the applicant calculated two bending moments in the mat, by using actual loading conditions and two separate soil conditions: constant soil modulus, and variable soil modulus in which the modulus varies in rough proportion to the deformation shape of the mat. The top and bottom reinforcing
~
~,_ , ,.. ? -. . - ~ - - - - - - - - - - - - - - - - -
steel bars that resist the negative and positive bending moments, respectively, were 'porportioned in a manner such that a surplus bending moment capacity is always provided. This fact was verified by comparing the three design bending moments calculated for a given ~ location: one derived from use of the formulas and two derived from the finite element analyses. In each of these three analyses, the estimated dead load on top of the mat was multiplied by a factor of 1.5 before being used in calculating the required design bending toments, thus providing the 50% margin (surplus) in load capacity.?eferred to above. The shear capacity of the base mat was calculated and provided in a manner similar to the bending moment treatment described above: a
& 8Y
. surplus shear capacity is always provided. Again, this fact was verified by comparing the design shear forces obtained in each of the three calculations. As before, the estimated dead load was multiplied by a factor of 1.5 prior to being used in calculating the required design shear resistance.
The structural engineering staff determined that the procedures and approaches utilized in the applicant's analysis and design of the base mat are sufficiently conservative and are acceptable. The sum of the top and bottom reinforcing steel bars and the vertical shear reinforcing bars have provided adequate strength for the mat to resist the load imposed by the reactor and shield buildings, assuming that the foundation soil behaves as predicted in the O e
analysis and that construction was carried out properly. However, as discussed in our geotechnical engineering evaluation (enclosure 1), the foundation soil did not behave as predicted in the original analysis. Thi h indicate that the concrete mat desig SiaMnetd inadequate because it was designed based on ideal conditions. As a uJhtch MS 5 y confirmatory item, additional analyses using the actual foundation E' soil conditions are required to validate the adequacy of the fcundation mat design. 4 Soecific Calculation of Key Block Mat Caoacities Since shear cracks in the reactor shield building and concrete walls were detected during the staff site visit on fiarch 27, 1984, ._ the applicant was requested to perform calculations to obtain shear stresses under operating and SSE conditions, and also shear capacity (strength) for base mat Blocks SA and 1, where the shear cracks occurred. It was reported by Ebasco via telephone that shear stresses along the crack in Block 5A were 64 k/ft for normal operating loads and 166 k/ft for SSE loads while in Block i they AEI jr sE could. are 52 k/ft for operating loads and 210 k/ft for SSE loads. Shear capacity computed in accordance with applicable ACI Code provisions 31' M N' was 274 k/ft for both blocks with shear reinforcing bars contributing 98 k/ft and concrete 176 k/ft. The shear cracks did not appear to present a challenge to the structural integrity of the mat under operating conditions. This is because the shear reinforcing bars alone have provided more than adequate resistance to the computed shear stress. Yet, there is not encugh evidence to c'erse*_ _
draw the same conclusion for the mat under SSE loads by comparing the calculated shear stress of 210 k/ft with the calculateo shear capacity of 274 k/ft. This is because the shear capacity was calculated based on ideal conditions, i.e., no cracks and voids. Nondestructive testing methods are reconsnended to obtain information on cracks and potential voids in the concrete mat so that a realistic assessment of their effect on shear capacity of . the mat can be performed. The Waterford NPP is located in a low seismicity area and as a consequence there is a very low likelihood of occurrence of an SSE and associated effects. Moreover, the inherent safety margin in the original design of base mat and related Category I structures, as yet unquantified (because of
.. cracking effects and other questions) seems to be sufficiently
. adequate to permit the performance of a confirmatory evaluation in the near future. Therefore, the confirmatory requirements may be accomplished during the final licensing stage and after issuance of the OL, except where otherwise specified.
-1hn enfifrnadorg U4.NCR9hh
- 5. Construction Problems mpA.t h m. S M h &.ryg .
Construction problems described here are limited to the first three blocks of concrete placement where major cracks occurred. Based on d the review of construction records and interviews, we fina that 79
- Louisiana Power and Light (LP&L) quality assurance group did try to make its program a success. Nevertheless, the first three blocks of concrete placement did have quality control problems. These problems included dropping concrete beyond 5' height at times, m.
using a concrete ator impropeM(providing insufficient vibration) as well'as % e hamr reinforcing bars to create openings thus transmitting shock waves to the concrete below through vertical reinforcing bars. Deficiency notes were written for the cracking and honeycombing, and the cracking pattern indicates the concrete might have suffered curing problems. A stop work order was issued by LP&L after the concrete placement of the first three blocks, but lied c or nondestructive testing techniques were used to verify the quality and strength of the 5074 cubic yards of poured and hardened concrete to the staff's kncwledge.
- 6. Conclusions and Recommendations A.
Thematisnohrenthndistressbasedonthecrack observation.
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u nOS. on paqcs 4 f 5 B. Verification of shear capacity unde needs to be done. As part of this verification program, nondestructive testing and Q3 gr evaluation are recommended to obtain information on cracks and potential voids and their effect on the concrete mat. C. The licensee is required to either justify that its original analyses are still adequate in light of the NRC geotechnical engineering staff evaluation mentioned above, or perform additional analyses to account for the actual foundation soil conditions. O e
7-D. A general surveillance (monitoring) program is recommended for ,
- all the cracks.' For shear cracks, the length and size of a crack and its propagation against time should be marked and ~' ,,- recorded.
!' ~ 1 E. Significant corrosion of reinforcing bars due to the ground ~ water is believed to be unlikely at the site. Nevertheless, a surveillance program is recommended. e 4 i i i i 1 3 1 i l
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Enclosure 3 REVIEW OF WATERFORD III BASE MAT ANALYSIS BY Brookhaven National Laboratory April 16,1984 t
- e 0
,. REVIEW 0F WATERFORD III BASEMAT ANALYSIS Structural Analysis Division Department of Nuclear Energy Brookhaven National Laboratory Upton, NY 11973 April 16,1984 D
i I
' ~ ~
'b. _ _ _ . _ . _ .
a TABLE OF CONTENTS Page No. INTRODUCTION ................................................. 1
GENERAL COMMENT
S ............................................. 2 STRUCTURAL ANALYSIS TOPIC REVIEWED ........................... 3
- 1. Dead Loads .......................................... 3
- 2. Buoyancy Forces ..................................... 5
- 3. Variable Springs Used For the Foundation Modulus .... 6 4 Vertical Earthquake Effects ......................... 6
~
- 5. Side Soil Pressure .................................. 7
- 6. Boundary Constraints ................................ 7
- 7. Finite Element Mesh and Its Effect .................. 8 CONCLUSIONS AND RECOMMENDATIONS .............................. 8 e
APPENDIX A LIST OF CONTRIBUTORS ............................. A-1 e G
4 INTRODUCTION At the request of SGEB/NRR, the Structural Analysis Division of the i Department of Nuclear Energy at BNL undertook a review and evaluation of the HEA Waterford III mat analysis documented in Harstead Engineering Associates (HEA) Reports, Nos. 8304-1 and 8304-2. Both reports are entitled, " Analysis of Cracks and Water Seepage in Foundation Mat". Report 8304-1 is dated September ! 19,' 1983, whila Report 8304-2 is dated October 12, 1983. Major topics ' addressed in the first report are: (l') Engineering criteria used in the design, site preparation and con-struction of the Nuclear Power Island Structure basemat. l (2) Discussion of cracking and leakage in the basemat. (3) Laboratory tests on basemat water and leakage samples. (4) Stability calculations for the containment structure. 1 The second report concentrates on the finite element analysis and its results. Specifically, it describes: ) (1) The geometric criteria and finite element idealization. j (2) The magnitude and distribution of the loads. (3) The final computer results in terms of moments and shear versus the resistance capacity of the mat structure. Supplemental information to these reports were obtained at meetings held i in Bethesda, MD, on March 21 and 26,1984, at the Waterford Plant site in Louisiana on March 27, 1984, and at Ebasco headquarters in New York City on April 4,1984. At the close of the ESASCO meeting, a complete listing of the HEA computer run was made available to BNL. 4 e 4 I
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Becaise of the very siort time interval assigt eh for the review and N preparation of this' report. (i .e. , April 4-13, 1980 , it was decided to concen+ trate the BNL efforts on the raview of the results presented il report no : I 8302-2 and on the supplemental ^ infomation contained in the computer <run given - to us by HEA. This run conta ns 9 load cases and their, various combinatiyns. The input / output printout alone consists of roughly J.wo thousand pages cf in ' formation and thus only> selected portions could be reyiewid with some detail . The other sections were howe'er reviewed from an engineering judgement view r t point. Comments regarding the reviewed work are given in the sections that follow. y _s t
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GENERAL CCMMENTS ) s Basically, the HEA report concludes that large primary moments will pro-ducetensiononNhebottomsurfaceofthemat. For, this condition, it is shown that the dqsign fs co'nservative. Furthereire, the shear capacity vs. the shear produced byNoad combinations are concluded to be adequate although
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a few elementspere founC to E,ticlose to th design capacity. Accordingly, the cracking of the tch surface is attributed to " benign" causes such as _ . shrinkage, differeotial soil settlement. and temperature changes. not S Based on the discussiods, held with EBASCO and HEA, and on the review of data given to BNL, it is our judgement that the bottom reinforcement Rs well as the mat shear capacity is adeouate. Thestatementthatthecrackjngofthe g% top surface is attributable to " benign" causes however has not been analyti-kN
- cally demonstrated by HEA. In the BNL review of the reports and data, an at-tempt was made to ascertain the reasons for the existing crack patterns that appear around the outside of the reactor shield building as depicted 3n Figure f .
D'-1 Appendix 0 of the HEA Report 8304-2. Other effects influenci.ng trie structural behavior and safety were also investigated. Specifically, the structural analysis topics reviewed in more detail include: , l / g l .. 1 l
^
l - s i t E l l - .y . , .--
(1) Dead loads and their effects. (2) Buoyancy forces and their effects. (3) Variable springs used for the foundation modulus. (4) Vertical earthquake effects. (5) The side soil pressures. (6) The boundary constraint conditions used for the mat. (7) Finite element mesh size and its effects. STRUCTURAL ANALYSIS TOPICS REVIEWED
- 1. Dead Leads .
As mentioned, EBASCO in their discussion and HEA in their reports have not shown analytically, the cause of the top surface cracks. In reviewing the HEA computer outputs, it was found that element moments and shears for individual loadings are explicitly given. Thus, for the case involving dead loads only, a number of elements in the cracked regions exhibit moments that can produce ! tension and thus create cracking on the top surface. This situation is shown in Table 1 which gives moment data for elements in some of the cracked re-gions. From the HEA report (page C-2-1-9) it seems that the top reinforce-ment, which is ill 0 6" in each direction
- is the minimum requirement for temperature steel according to the American Concrete Institute Building Code l
l
*In a subsequent phone conversation, P.C. Liu of EBASCO stated that some
! additional reinforcement was added on the top surface in one direction. Even if this is the case the statement that follows is true for the unstrengthened direction and perhaps even for the strengthened direction. I
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, TABLE 1 -
Normal Pressure Mx Hy Mxy Side Pressure
+
-( - -
^
ELEMLNT U 8 D 8 0 8 Mx Hx Nxy 4 37 -242 173 -574 19 7 116 - 31 -294 -196 93 , 212 4644 4595 +207 + 91 106 - 25 -663 -392 79 211 -605 205 -412 217 -296 48 -219 -416 - 76 5 207
- 64 99 -136 116 - 81 15 -319 -193 50 "7 441 -105 168 +172 -170 39 - 12 -347 -409 66 Z N 436 -719 269 -1193 357 +531 -130 -274 -258 117
!- A 'T" 4 38 269 142 -159 158 - 60 26 -730 -347 27 447 665 59 210 88 248 - 55 -653 -339 -127 I Of 204 193 87 569 72 -143 28 -361 -420 24 j! 208 350 32 898 - 24 -241 75 -354 -771 - 49 203 -676 260 -995 236 39 - 21 -574 -247 30
; 426 -542 157 -705 310 ,
332 - 65 -171 -486 61 259 62 148 -133 1 8 +154 - 36 , 253 5 71 531 + 75 0 18 j'. 255 30 58 670 5 41 10 5, 252 86 24 611 - 55 87 8 NOTE: D - Dead Load
.A 254 50 26 412 - 41 69 9 E "? 251 37 5 162 - 23 44 12 8 - Bouyancy
"* "E 2S7 320 - 38 57 15 - 81 - 15 248 255 - 26 29 16 - 29 - 6
- 267 -236 11 0 87 118 - 64 28' 269 -173 59 434 10 - 82 32 4 19 -314 137 -635 313 - 30 12 Ei 410 -371 -71 -642 238 270 - 29 4 400 -31S 108 -774 275 - 44 41
% O! 401 -180 42 -201 102 +108 - 23 A' 4 414 -304 1 111 -130 178 + 44 - 19
*E 417 -200 93 440 41 - 17 - 15 404 - 64 17 420 - 32 98 - 18
~~
-S-Speci fication (i .e. , As = .0018 x 12 x 144 = 3.11 in2/ft). The resisting moment capacity based on working stress design is about M = Assf jd = 3.12 x 24 x 131/12 = 817 ft-kips /ft. The steel reinforcement strain for this moment is equal to c
s (" *c )
- s
- 29 000 = 0.00083 in/in while, the corresponding concrete stress is, U = 3 ksi f =c g c s/n = 0.00083 8 In checking the data in Table 1, it can be seen that element 208 has exceeded the working load capacity under the dead load condition and, thus the local area could have exhibited a crack when this load acted alone. Similarly,
. concrete cracking could occur under this load condition in elements 447, 212, Whad .
-f 204, 253, 255, 269, 257, 417, and 404. Thus, the cracks on the upper surface d%
F outside of thd shield wall could have been initiated after ccnstruction of the
. superstructure, before placement of the backfill. It should be noted that since no analysis is available for dead load without the superstructure, the reason for the basemat cracks inside of the shielded wall cannot be explained by this reasoning.
- 2. Buoyancy Forces The moment results from this analysis show that these forces when acting alone would mostly cause tensile stress on the upper surfaces. The moments causing these stresses are tabulated in Table 1 for groups of elements in the cracked regions. As can be seen, these moments are not as severe as those due to dead weight. By superpositon they could in some cases contribute to higher tensile stresses and thus result in further cracking in some of the upper surface areas. .
s . _ _ _ _ . . _ _ _ . .
- 3. Variable Sorinos Used for the Foundation Modulus Moments and shears developed in the basemat were computed using the cnn-cept of the Winkler Founcation; namely the soil is represented as a series of relatively uniform independent springs. The stiffness of the springs is ob-tained from relatively crude analyses which are based on some generalized s' analytic solutions available for rigid mats on the surface of elastic soils.
The actual design of the mat was based on a series of interactive ccgchir
. runs in which the soil stiffness was varied until the computed contact pres-sures under the mat were fairly uniform and equal to the overburden stress at 4
. the elevation of the foundation mat. This approach appears to be reasonable in that the long term consolication effects can be anticipated to cause effective redistribution of loads and cause the mat to behave in a flexible manne r.
4 Vertical Earthcuake Effects Q g g 3g 2 - g,1) 3 i . 1 Vertical earthquake effect was not discussec in the HEA reports. Howe ve r, from the finite element analysis' print out and the conversation with HEA engi-neers, it was . told that this effect was incluced in the loac commination cases !- by specifying an adcitional factor of 0.067, wnich was then applied to the dead and equiprent loac case. From the discu:sions and the review BNL is not l , clear whetner an amplification factor due to vertical mat frequency was used or not. A quick check by the reviewers indicates that this factor could have ! some influence on the results. Horizontal earfM(uske effects were input into the HEA finite element
=
analysis as an equivalent bending moment and in plane (fx2) shear acting on 1 , the_ pertinent noces of the foundation mat. The r.eviewers however, are not
' ~ ' '
certain whether the dynamic interaction efTeIbetwen the superstructiarit and; the mat were accounted for in the analysis, nor are they certain about its , importance in ef fecting the results. ! 5. Side Soil pressure . Accordin,p to the STARDYNE computer results obtained from HEA, the normal side soil pressures produce large moments that are opposite to those caused by tne dead loads. As shown in Table 1 where moments of elements located in one ? of the cracked regions outside of the shield building are compared. The total -
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moments in some cases (i.e. element 447 or 208) become quite small. In other regions there is infact a reversal in the total bending moment which causes .. tension on the bottom surface and compression on the top. This compression would tend to close the cracks on the upper surface. Thus, it appears tnat
},, this pressure is a very important load case for the mat.
m: For the static or normal operating condition the lateral pressures are >
,' based on the at-rest stress condition and are uniform around the periphery of the structure. For. the seismic problems the pressures are computed to ap-proximately account for relative movements between the structure and the soil.
On one side the structure will move away from soil (active side) and reduce the pressures while the opposite will occur on the other side (passive side).
. The actual computations made use of triaxial test data from site soils to arrive at the soil pressures rather than use the standard Rankine analyses.
However, no dynamic effects on either the lateral soil or pore pressures was included. The sensitivity of the calculated responses to these effects are
~-
currently unknown. Since the 1ateral pressures have a major impact on the computation stresses in the mat the dynamic effects can significantly in fluence the stresses computed in load combination studies.
- 6. Boundary Constraints For equilibrium calculations no special consideration need be made for vertical case since the soil springs prevent unbounded structural motion.
However, the same cannot be said for the horizontal case since soil springs are not used to represent the soil reactions. Rather the lateral soil forces are directly input to the modal . To prevent unbounded rigid body motion arti-ficial' lateral constraints must be imposed on the model From the output pre-sented in the EBASCO and HEA reports, it is not possible to evaluate the im-pact of these assumptions. The stresses caused by the artificial boundaries must be calculated and compared with those presented.
- 7. Finite Element Mesh and its Effects In general finite element models for plate structures require at least four elements between supports to obtain reasonable results on stress comp-utations. The models used by both EBASCO and HEA violate this condition in the vicinity of the shield wall. The significance of this effect is demon-strated in Figure 0-3 which presents a plot of moment taken through the center of the slab. The computed moments in adjacent elements 193,194 and 455 are
-3800, -2500 and +400K. The elements used in the EBASCO analysis are constant curvature elements so that the computed moments will be constant within each element. The steep moment gradient in the elements listed indicates that a finer mesh would be required to obtain a better representation of element stresses. A similar effect was also noted when investigating the elements forming the junction between the lateral earth retaining walls and the base mat. In general, it is felt that the finite element grid used for the structural modeling is too coarse.
CONCLUSIONSANDRE0MMENDATION5 (a) The Waterford plant is primarily a box-like concrete structure sup-ported on a 12 foot thick continuous concrete mat which houses all Class I structures. Tha plant island is supported by relatively soft over consolidated soils. To minimi:e long term settlement effects, the foundation mat was designed on the floating foundation principle. The average contact pressure developed by the weight of the structure is made approximately equal to the existing intergranular stresses developed by the weight of the soil overburden at the level of the bottom of the foundation mat. Thus, net changes in soil stresses due to construction and corresponding sellements can be anticipated to be relatively small. I G e O
. - - -- . - - ~ * - - ~,
_g-(b) In reviewing the information reports and computer outputs sup-plied to BNL by EBASCO, HEA, and LPL, it is concluded that nor-mal engineering practice and procedures used for nuclear power plant structures were employed. (c) Accepting the information pertaining to loadings, geometries of the structures, material properties and finite element ideal-ization as correct, it is the judgement of the reviewers: (1) that the bottom reinforcement as well as the shear capacity . of the base mat are adequate for the loads considered. (ii) that computed dead weight output data can be used to explain some of the mat cracks that appear on the top surface. The cracks that appear, would have occured after the construction
-of the superstructure but before the placement of the backfill.
Their growth woul,d be constrained by subsequent backfill soil . pressure. (d) Due to the existance of the cracks, it is recommended that a sur-vetlance program be instituted to monitor cracks on a regular basis. Furthermore, an alert limit (in terms of amount of cracks, and or crack width, etc) should be specified. If this limit is exceeded, specific structural repairs should be mandated. (e) It is also recommended that a program be set up to monitor the water leakage and its chemical content. (f) The validity of the BNL conclusions depend mainly on the infor-mation supplied by EBASCO, HEA and LpL, either verbally, in re-ports or in computer outputs. While some checks for accuracy and engineering approach were made pertaining to the supplied information some open questions still remain, especially those mentioned in the text under topics 4 thru 7 under the heading,
" Structural Analysis Topics Reviewed". It is recommended that the particular issues raised under these items be resolved.
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r . Since the Waterford plant is located in a low seismicity zone, there is a low likelihood of occurrence of an SSE and its as-sociated effects. Thus, although the inherent safety margins in the design of the basemat are as yet unquantified (due to cracking effects and the other items mentioned above), they seem to be sufficiently adequate to permit the performance of a confirmatory evaluation for their resolution in the near future. o b 4 k 4 O G 'f
- Q ._ - . _ -. ., . . _ - , _ . . . - - - - - . - _ . - -
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guico fo, UNLTED STATES Enclosure d ((Y .-
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*,' Ei NUCLEAR REGULATORY COMMISSION WA$McNGTON. D. C. 20555
**"* APR 121984 NOTE To: CEeTrie'%earxhteTSESTEBQ FROM: Victor Benaroya, Chief. CMEB
SUBJECT:
CORROSION EFFECTS ON BASEMAT REBAR AT WATERFORD III - We have reviewed the licensee's proposed Limiting Conditions for Operation on the possible corrosion of basemat rebar due to groundwater penetration through cracks in the concrete basemat. He considered the following factors in our evaluation:
- 1. Analysis of groundwater at the site indicated a chloride concentra-tion of approximately 35 ppm, which is significantly belew the 710 -
ppm chloride corrosion threshold for rebar in the presence of oxygen (O. A. Nausmann, Materials Protection, pp. 23-25, October, 1959).
- 2. The rate of seepage of groundwater through the 12-foot thick basemat is small, which restricts the access of disolved oxygen, chiurides and carbon dioxide to the rebar-concretc interface.
- 3. The slow movement of water through the basemat causes the water to become alkaline (pH=12.5) by contact with the calcium oxide and calcium hydroxide content of the concrete.
4 The corrosion rate of steel by alkaline water is low. On the basis of our evaluaticn, we find that there is reasonable assurance
~
that the basemat rebar will not be significantly corroded by the senetration of groundwater of the acidity and chloride content observed at the Waterford site. The board required mont'toring the quality of groundwater at the Waterford site. The licensee has prepared a Limiting Condition for Operation requiring the analysis' of a sample of groundwater at least once per S2 days to verify that the chloride content does not exceed 250 ppm. On the basis of the above evaluation, where the time element is not critical, we conclude that the proposed Limiting Condition for Operation is acceptable. I
\(
Victor B nareya, Chi f Chemical Engineering Branch
+
9 1 Enclosure 5 Specific Applicant's Action Items , It is recommended that the Division of Licensing forward and direct the Louisiana Power & Light Co. to implement the following " Specific Appli-cant's Action Items":
- 1. The applicant should update his crack mapping records, including observable vertical or(((clined cracfh in Category I structures supported by the mat days prior to issuance of licen
- 2. The applicant shall propose an expanded differential settlements and crack monitoring program and associated plant technical speci-fications within next 30 days for staff review and acceptance.
- 3. The applicant shall propose a surveillance program to monitor potential rebar corrosion due to the ground water and associated plant technical specifications within next 30 days for staff review and acceptance.
4 The applicant shall propose a program, within next 30 days for staff acceptance, to selectively perform nondestructive testing of matcracksand($tentialvoid31 The program should also include the procedures and schedule for evaluation of the effect of cracks and potential voids upon the concrete mat integrity.
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. 2-
- 5. The applicant is required, within next 30 days, to either justify that its original a'nalyses are still adequate in light of the NRC geotechnical engineering staff evaluation or perform additional analysestoaccountforthe(Clualfoundationsoilcondition's?')))
6'. The applicant shall provide additional justification and/or propose a confirmatory analysis program, within next 30 days, to resolve the concerns pertaining to mat analysis raised by the BNL consul-tants in the enclosure 3 to the safety evaluation report. 4 e a e G
- - -- n
A-1 APPENDIX A-1 LIST OF CONTRIBUTURS Listed below in alphabetical order are the names of the contributors to this report: Costantino, C.J. Miller, C. A. Philippacopoulos, A.J. Reich, M. Sharma, S. Wa ng, P.C. N e e 4 4 9*W
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