ML20028G264

Exceptions to Aslab 821213 Partial Initial Decision Re Insp of Embedded Plates.Certificate of Svc Encl

ML20028G264
Person / Time
Site:	Callaway
Issue date:	02/03/1983
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
ISSUANCES-OL, NUDOCS 8302070573
Download: ML20028G264 (8)

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. 1 UNITED STATES OF AMERICA DCr.gE T E9 NUCLEAR REGULATORY COMMISSION LP" BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL 130ARDA N0 50 o; iu s In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

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(Callaway Plant, Unit 1) )

EXCEPTIONS TO PARTIAL INITIAL DECISION Join' Intervenors Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance (hereinafter " Joint Intervenors") take exception to the Licensing Board's partial initial decision of December 13, 1982 and state that the Licensing Board erred in finding or ruling that:

1. Embedded plates similar to those used at Callaway have been utilized in similar construction projects for many years. (Page 4)

2. Bechtel was required only to provide quality surveillance of embed fabrication and only Cives was required to inspect all plates. (Page 5 and Finding 4)1

3. Daniel was required prior to July 8,1977 unly to receipt inspect for quantity and shipping damages. (Page 5 and Finding 4)

4. Prior to the June 9,1977 stop work order, 255 machine-welded and 225 manually-welded plates had been installed in support of safety-related loads. (Page 5, Finding 6)

5. There were no prior indications of significant problems with Cives. (Pages 6-7)

6. An inspection of Cives' manufactured materials in November-December, 1976 provided no indication of defective materials. (Finding 7) 1 The references to the Board's partial initial decision refer to the page number of the Opinion and the num" Saragraphs of the Findings of Fact.

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7. Applicant's failure to meet 10 CFR Part 50, Appendix B, Criterion X was cured. (Page 6)

8. There was no violation of Appendix B, Criteria II and VII. (Page 6)

9. Some of the Joint Intervenors' exhibits were admitted solely for impeachment and cannot be considered as positive evidence. (Page 7)

10. Cives had been inspecting the machine-welded studs correctly. (Page 8, Finding 10)

11. The inspections of the machine-welded plates p; ovide confidence for the safety of those installed prior to June 9,1977. (Pages 8-9, Findings 9-13)

12. The probability analysis performed for machine-welded plates was valid and acceptable. (Pages 9-11, Findings 14-16)

13. The load tests performed on the machine-welded plates provide evidence that those installed did not present a safety problem. (Pages 11-12, Findings 17-20)

14. The location and loads of all machine-welded embeds installed prior to June 9,1977 are known. (Page 12, Finding 21)

15. The location and loads on all manually-welded embeds installed prior to June 9,1977 are known. (Page 13, Finding 23)

16. The pertinent AWS Welding Code Sections were not designed for the kind of manual welds at issue here. (Finding 25)

17. Applicant's reliance on a design safety factor provides adequate evidence of the safety of manually-welded plates. (Pages 18 and 29-30, Finding 31)

18. There is no merit to Joint Intervenors' arguments that sufficient evidence exists to undermine the validity of Bechtel's engineering analysis on the manually-welded plates. (Pages 21-23, Findings 43-44)

19. There is no merit to Joint Intervenors' argument that one/ sixteenth inch undercut may affect the capacity of anchor rods. (Page 23)

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20. The manually-welded plates and welds tested by Lehigh University j consultants provida competent and satisfactory evidence of the safety of the installed plates. (Pages 24-25 and 30, Findings 47-49)

21. The review procedure for machine-welded plates was prepared satisfactorily and followed adequately. (Page 25)

22. There was no violation of Appendix B Criterion III. (Page 27)

23. The apparent lack of knowledge regarding the Daniel inspection data was only a negligent failure in communication. (Pages 27-28)

24. There was no violation in Applicant's failure to file a 10 CFR Part 50, 55(e) Report regarding the manually-welded plates. (Page 28)

25. Exceptions to Code requirements regarding manually-welded plates were proper. (Pages 23 and 28)

26. No other negligence affecting quality assurance requirements exists regarding the embed contention. (Page 28)

27. The analysis of deficiencies, revision in code specifications and imposition of stricter inspection requirements were adequate responses to the embed problem.

(Pages 28-29)

28. The ultimate issues in the embed contention were whether the level of negligence by Applicant and its contractors threatens the safe operation of the plant, and, if tiie basic assumption in Bechtel's engineering analysis was incorrect, whether plate failure could be anticipated. (Page 29)

29. Applicant carried its burden of proof on the safety of the embeds installed prior to June 9,1977 on the grounds enumerated. (Pages 29-30)

30. Evidence showed that welding code revisions will permit smaller weldments in the future. (Page 30)

L; 31. The testimony of Dr. Fisher was reliable. (Page 30)

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32. Applicant carried its burden of proof on the safety of the machine-welded embeds. (Page 30)

33. All honeycombed areas in the basemat were chipped to sound concrete.

(Page 33, Finding 54)

34. Soniscope testing of the basemat provides reliable evidence of the soundness of the internal concrete. (Pages 33-34, 38-40 and 43; Findings 60 and 76-78)

35. No concrete defects of importance to safety exist in the tendon access gallery portion of the basemat. (Page 34)

36. There is adequate assurance of the integrity of the basemat in areas other than the tendon access gallery. (Pages 35-36)

37. Concrete was adequately vibrated during placement in areas other than the tendon access gallery. (Pages 35 and 36, Finding 81)

38. The basemat pour was accomplished with reasonable consistency and tmiformity. (Page 36)

39. Honeycombing comparable to that found in the tendon access gallery would be harmless if it exists in other parts of the basemat. (Pages 36-37, Finding 84)

40. No serious defects in the overall quality assurance procedures exist in connection with the basemat. (Pages 37-38, Finding 74)

41. There was no deficiency in the timing of the non-conformance report regarding the basemat. (Page 42, Finding 92) ,

42. There was no general breakdown of quality assurance procedures evident from the basemat deficiencies. (Pages 42-43, Finding 93)

43. The concrete imperfections in the basemat did not occur due to neglect of quality assurance. (Page 43)

44. There is no reason to doubt the integrity of the basemat or the performance of the trurNplates. (Page 43) l

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45. Measurements of the subject SA-358 pipe demonstrate its lack of ovality.

(Pages 51-52 and 55, Finding 111)

46. The defective SA-358 pipe was properly dispositioned. (Pages 52-53, Findings 113-114)

47. No drop-thru or melt-thru occurred in the defective SA-358 pipe. (Pages 53-54, Findings 115-116)

48. There were no cracks or fissures in the subject SA-358 pipe. (Pages 54-55, Findings 117-118)

49. There was no breakdown in the Quality Assurance Program with respect to the SA-358 pipe contention. (Page 55, Finding 141)

50. The SA-358 pipe defect was a relatively minor one and has been properly removed. (Page 55)

51. A complete schedule of the location of YWEC-supplied SA-312 pipe was provided by Applicant to the NRC. (Finding 123)

52. In the manufacture of SA-312 pipe, are misalignment occurs only where the upper and lower welding arcs are not aligned with the seam and with each other.

(Pages 58-59)

53. Bechtel determined the maximum amount of CLP in the SA-312 piping .

produced by YWEC to be 26 percent and the extent of CLP at Callaway will be no greater. (Pages 59-60, Finding 127)

54. Tensile and hydrostatic tests provide satisfactory evidence of the reliability of SA-312 pipe with CLP. (Pages 60-62 and 65-66, Findings 128 and 131)

55. Engineering analyses performed by Aptech provide satisfactory evidence of the reliability of the SA-312 pipe with CLP. (Pages 61-62 and 65-66, Findings 129-131) 56.. An appropriate screening method for SA-312 pipe is provided by the 85 i

l percent of ASME allowable stresses standard. (Pages 63, Finding 132) l

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57. The use of SA-312 pipe at Callaway will not affect the safe operation of the plant. (Pages 63, 64 and 65-66)

58. There is adequate evidence of the safety of SA-403 fittings. (Pages 63-64, Findings 133-134)

59. Failure of SA-312 pipe would occur only in a " leak-before-break" mode.

(Page 64)

60. No breakdown in the quality assurance / quality control programs at Callaway is evidenced by the use of SA-312 piping with CLP. (Page 65, Finding 141)

61. There is no merit to Joint Intervenors' contention that the evaluation and acceptance of SA-312 pipe were not performed in accordance with the ASME code.

(Page 65)

62. The use of efficiency factors provides a conservative and satisfactory alternative to ultra..anic examination. (Page 65)

63. All SA-312 piping at Callaway complies with ASME Code requirements.

(Page 65).

64. There are no defects in Applicant's quality assurance program with respect to the Gulf and Western preassembled piping formations matter. (Finding 141)

GS. There has been no overall breakdown in Applicant's quality assurance program. (Page 69, Findings 142-146)

66. The deficiencies found were disclosed and remedied within the quality assurance / quality control program itself. (Page 69)

67. The reactor building has been safely built. (Page 69)

68. Applicant has displayed a generally affirmative commitment to quality.

(Page 69)

69. No serious safety matter exists. (Page 109) l

70. Operation of the Callaway facility should be authorized. (Page 110)

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l CHACKES, HOARE & SEDEY 4

j ICenneth M. Chackes #27534 Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missouri 63102 314/241-7961 l

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

)

UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

)

(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Joint Intervenors' Exceptions to Partial Initial Decision have been served on the following by deposit in the United States mail this 31st day of January,1983.

Chairman Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowt. ridge 1800 M. Street, N.W.

Washington, D.C. 20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Roy P. Lehy, Jr., Esq.

Office of the Executive Director U.S. Nuclear Regulatory Commission

• Washington, D.C. 20555 -

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