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Category:AFFIDAVITS
MONTHYEARML20129H7741985-06-0505 June 1985 Affidavit of DF Schnell Re Issues Raised in Missouri Coalition for Environ & K Drey Petition to Show Cause Requesting Suspension or Revocation of Ol.Root Causes of Questionable QC Certifications Addressed ML20084G1791984-05-0303 May 1984 Affidavit of Cw Mueller Re Financial Integrity of Util ML20084G1731984-05-0202 May 1984 Affidavit of DF Schnell Re Financial Stability of Util ML20078P7251983-11-0303 November 1983 Affidavit of Ew Thomas Re Revised Design Response Spectra ML20076F0891983-08-22022 August 1983 Affidavit of Jd Hurd Re Hydrostatic Pressure Requirements for SA-312 Piping,Per Aslab 830815 Order.Applicant Exhibits Corrected.Certificate of Svc Encl ML20071J0631983-05-18018 May 1983 Affidavit of JW Baer Re Reed Contention 20 on Authorization of Excess Radiological Worker Exposures & Spec of Decontamination Action Levels.Certificate of Svc & Prof Qualifications Encl ML20071J0591983-05-18018 May 1983 Affidavit of Wm Clark Re Reed Contention 20 on Authorization of Excess Exposures to Workers & Spec of Decontamination Action Levels.Planning Need for Authorization Per NUREG-0654,Section III.E.3,met.Prof Qualifications Encl ML20071H5961983-05-18018 May 1983 Affidavit of Ma Stiller Re Reed Contention 5,Parts B & C on Radio Communications.Commitment to Supply Addl Transceivers for Designated Patrol & Rescue Vehicles Provides Sufficient Communication for Patrol & Rescue ML20071H5271983-05-17017 May 1983 Affidavit of T Mitchell Re Reed Contention 3 on Emergency Mgt Director staffing.Full-time Emergency Mgt Director in Montgomery County Unnecessary.Vb Eldringhoff Is Alternate Director ML20071H9961983-05-17017 May 1983 Affidavit of RG Wright Re Reed Contention 19 on Impediments to Use of Evacuation Routes.Resources & Planning Efforts Available to Overcome Impediments ML20071H9561983-05-17017 May 1983 Affidavit of Kv Miller Re Reed Contention 17 on Radiological Monitoring.State Resources in Trained Personnel & Radiation Monitoring Equipment Adequate.Prof Qualifications Encl ML20071H4361983-05-16016 May 1983 Affidavit of Wm Clark Re Reed Contention 1 on Staffing of Sheriff Ofcs.Adequate Personnel Available W/Law Enforcement Training to Provide Emergency Law Enforcement Svcs for Callaway County & City of Fulton ML20071H5091983-05-16016 May 1983 Affidavit of Wm Clark Re Reed Contention 2 on Staffing of Callaway County & City of Fulton Clerk Ofcs.No Addl Clerical Personnel Needed to Provide Assistance During Emergency Shifts.Prof Qualifications Encl ML20071H5311983-05-16016 May 1983 Affidavit of H Lalk Re Reed Contention 3 on Emergency Mgt Director staffing.Full-time Emergency Mgt Director for Gasconade County Unnecessary ML20071H6471983-05-16016 May 1983 Affidavit of Ng Slaten Re Reed Contentions 6 & 16 on Protective Actions Against Radioiodines & Messages W/ Instructions for long-term Sheltering.Explains Effectiveness of Sheltering as Protective Action ML20071H6551983-05-16016 May 1983 Affidavit of Harris Re Reed Contentions 6 & 16 on Protective Actions Against Radioiodines & Messages W/ Instructions for long-term Sheltering.Explains Effectiveness of Ad Hoc Respiratory Protection ML20071J0351983-05-16016 May 1983 Affidavit of H Matthews Re Reed Contention 19 on Impediments to Use of Evacuation Routes.Resources & Planning Efforts Available to Overcome Impediments ML20071H9691983-05-16016 May 1983 Affidavit of Ng Slaten Re Reed Contention 17 on Radiological Monitoring.Util Radiological Emergency Organization Includes Extensive Radiological Monitoring Capability & Resources. Prof Qualifications Encl ML20071H9371983-05-16016 May 1983 Affidavit of Wm Clark Re Reed Contention 15 on Ltrs of Agreement.Sufficient Ltrs of Agreement Exist or Will Exist Prior to Plant Operation to Ensure Necessary Emergency Support & Resources to Implement Util/Fulton Plan ML20071J0141983-05-16016 May 1983 Affidavit of G Epple Re Reed Contention 19 on Impediments to Use of Evacuation Routes.Resources & Planning Efforts Available to Overcome Impediments ML20071J0271983-05-14014 May 1983 Affidavit of VB Eldringhoff Re Reed Contention 19 on Impediments to Use of Evacuation Routes.Resources & Planning Efforts Available to Overcome Impediments ML20071H8831983-05-13013 May 1983 Affidavit of JW Baer Re Reed Contention 13 on Organizations Requiring Sops.Functional Procedures Will Provide Adequate Instructions to Organizations Assigned Emergency Response Role ML20071H8321983-05-13013 May 1983 Affidavit of JW Baer Re Reed Contention 11 on Reentry/ Recovery Radiation Stds.Offsite Emergency Plans Reentry Decision Process Description Complies W/Planning Criteria. Prof Qualifications Encl ML20071H9631983-05-13013 May 1983 Affidavit of Wk Johnson Re Reed Contention 17 on Radiological Monitoring.State Resources in Trained Personnel & Radiation Monitoring Equipment Adequate.Prof Qualifications Encl ML20071H5701983-05-13013 May 1983 Affidavit of JW Baer Re Reed Contention 4 on Emergency Action Level Scheme/Worker Notification.Emergency Classification Sys & Worker Notification Provisions Reflect Sound Operational Concepts.Prof Qualifications Encl ML20071H4901983-05-12012 May 1983 Affidavit of Gw Stanfill Re Reed Contention 1 on Staffing of Sheriffs Ofc.Sufficient Personnel Available Per Shift to Fulfill Law Enforcement Functions Assigned to Montgomery, Gasconade & Osage Counties ML20071H5131983-05-12012 May 1983 Affidavit of Gw Stanfill Re Reed Contention 2 on Staffing of Clerk ofcs.Emergency-related Clerical Functions Described in County Plans Will Be Properly Incorporated in Montgomery, Gasconade & Osage Counties.Prof Qualifications Encl ML20071H6251983-05-11011 May 1983 Affidavit of Kv Miller Re Reed Contention 6 on Protective Actions Against Radioiodines.State of Mo Will Not Administer Potassium Iodine to General Public in Event of Accident,But Drug Will Be Available to State Emergency Workers ML20071H5411983-05-0909 May 1983 Affidavit of J Crowe Re Reed Contention 3 on Emergency Mgt Director staffing.Full-time Emergency Mgt Director for Osage County Unnecessary ML20071H6361983-04-28028 April 1983 Affidavit of Re Linneman Re Reed Contention 6 on Protective Actions Against Radioiodines.Describes Risks & Benefits Associated W/Ingestion of Potassium Iodine & Endorses State of Mo Policy Re Distribution of Potassium Iodine ML20071H7401983-04-28028 April 1983 Affidavit of Re Linnemann Re Reed Contention 8 on Radiation Detection Equipment.State of Mo & Local Govts Have Sufficient Equipment,Lab Facilities & Expertise to Evaluate External & Internal Radiation Exposures ML20071H7611983-04-28028 April 1983 Affidavit of Re Linnemann Re Reed Contention 9 on Radiological Exposure.Means for Controlling Radiological Exposure of Local Emergency Workers During Accident Established Per 10CFR50.47(b)(11) ML20071H7901983-04-28028 April 1983 Affidavit of Re Linnemann Re Reed Contention 10 on Medical Treatment.Upon Completion of Training Program,Callaway Memorial Hosp Will Provide Adequate Local Medical Resources to Handle All Types of Radiation Injuries ML20042A4031982-03-16016 March 1982 Affidavit of Kg Parikh.Data in Table Supports Bechtel Engineering Analysis That Deviations from Required Weld Detail Identified on Manually Weld Embeds Would Not Adversely Affect Load Carrying Capacity ML20009C9431981-07-16016 July 1981 Affidavit Re Joint Intervenor Opposition to Applicant & NRC Motion to Compel.Discusses Consequences of Whistleblowing ML19347D3071981-03-0606 March 1981 Affidavit Re Ed Background & Research on Nuclear Power & Specific Facilities.Certificate of Svc Encl ML20154A1381976-07-13013 July 1976 Affidavit of Westinghouse Requesting That Proprietary Info Be Withheld from Public Disclosure (Ref 10CFR2.790) 1985-06-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212K8711999-09-30030 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirements for Noncombustible Fire Barriers Penetration Seal Matls ULNRC-04117, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.731999-09-22022 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.73 ML20217M2091998-03-19019 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds Amended Requirements. NRC Justification for Avoiding Backfit Analysis,Nonstantial.Backfit Analysis,As Required by Law as Mandatory for Proposed Rule Changes ML20217J9691997-10-16016 October 1997 Order Approving Application Re Corporate Merger Agreement Between Union Electric Co & Cipsco,Inc to Form Holding Company.Commission Ordered to Approve Subj Application ML20148N0511997-06-19019 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,Suppl 1, CR Insertion Problems ML20140G1691997-06-0606 June 1997 Requests Extension of Comment Period Expiration Date from 970619 to 970719,for Comments on Control Rod Insertion Problems ML20077E9041994-12-0202 December 1994 Comment Supporting Proposed Rule 10CFR50 Re TS Improvements. Advises That PSA Portion of Fourth Criterion Should Be Clarified to Include Only Those Equipment Items Important to risk-significant Sequences as Defined in GL 88-20,App 2 ML20071L1951994-07-21021 July 1994 Comment on Proposed Rule 10CFR26 Re Changes to fitness-for-duty Requirements.Urges NRC to Revise Scope of 10CFR26 to Limit Random Drug & Alcohol Testing to Only Workers Who Have Unescorted Access to Vital Areas at NPP ML20065D3851994-03-22022 March 1994 Comment on Draft NUREG-1022, Event Reporting Systems, 10CFR50.72 & 50.73 ML20113H4281992-07-23023 July 1992 Comment Commending Proposed Suppl One to GL 83-28 4.2.3 & 4.2.4 Closing All GL 83-28 Actions for Callaway But Staff Conclusion Should Be Expanded ML20101P4091992-06-26026 June 1992 Comment Supporting low-level Radwaste After Treatment to Reduce Volume & Represents Safest,Most Cost Effective Solution ML20091F9501991-12-0202 December 1991 Submits Comments Opposing Draft NUREG-1022, Event Reporting Sys,10CFR50.72 & 50.73. Licensee Feels That Changes to Intial NUREG-1022 Increases Util Expenses W/O Improving Public Health & Safety ML20058D2741990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20058N9891990-08-0101 August 1990 Comment Re Proposed Rules 10CFR20,30,40 & 70, Notifications of Incidents. Language of Rule Should Be Clarified by Referring to Applicable Reporting Requirements of 10CFR50.72 & 73 for Commercial Nuclear Power Reactors ML20063Q1771990-07-0606 July 1990 Comment on Petition for Rulemaking PRM-50-55 Re Revs to Fsar.Revs Should Be Driven by Circumstances Rather than by Arbitrary Time Schedule ML20235V9301989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Endorses NUMARC Comments.Major Concern Is Lack of Demonstrated Need for Rule Since Most Utils Already Have Effective Maint Programs ML20235T7901989-02-20020 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Establishment of Programs for Operators to Earn Degress Would Be Expensive ML20235T7011989-02-17017 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Which Require Degrees of Senior Operators & Shift Supervisors.Both Alternatives Would Contribute to Lower Morale Among Reactor Operators ML20195J3191988-11-25025 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Policy of Yearly Testing & Testing for Cause,Backed Up by Training for Drug Prevention Supported ML20195E8561988-10-28028 October 1988 Comment Supporting Proposed Rule 10CFR50 Re Renewal of Licenses ML20133B7711985-08-0202 August 1985 Response to 850705 Petitioner Response in Opposition to Util Request That Show Cause Order Not Be Issued.Util Actions Demonstrate Dedication to QA & Safe Plant Operation. Certificate of Svc Encl ML20128K2111985-07-0505 July 1985 Response Opposing Util Request That Show Cause Order Not Be Issued.Requests NRC Independent Investigation & Suspension or Revocation of OL During Period of Investigation ML20129H7511985-06-0606 June 1985 Response to Missouri Coalition for Environ & K Drey 850325 Show Cause Petition Requesting Suspension or Revocation of OL Due to Questionable QC Inspector Certification.Denial of Petition Recommended.Certificate of Svc Encl ML20129H7741985-06-0505 June 1985 Affidavit of DF Schnell Re Issues Raised in Missouri Coalition for Environ & K Drey Petition to Show Cause Requesting Suspension or Revocation of Ol.Root Causes of Questionable QC Certifications Addressed ML20100F4301985-03-25025 March 1985 Show Cause Petition Requesting Suspension or Revocation of License NPF-30,due to Failure to Comply W/Qa Regulations & Guidelines Re Proper Training of QA Personnel ML20092H1141984-06-22022 June 1984 Answer Opposing Petitioners 840613 Instant Motion for Order Setting Aside or Staying Permit for Ol.Certificate of Svc Encl ML20197H4321984-06-13013 June 1984 Motion for Commission Order Setting Aside Low Power Testing Permit Granted on 840611,or in Alternative,Stay to Permit & Prohibit Taking of Any Action.Certificate of Svc Encl ML20091R6401984-06-13013 June 1984 Request That Commission Enter Order Setting Aside Low Power Testing Permit Allegedly Granted on or About 840611,due to Joint Intervenors 840418 Motion for Leave to File Supplemental Contention ML20084G1561984-05-0303 May 1984 Answer Opposing Coalition for Environ,Missourians for Safe Energy & Crawdad Alliance 840418 Motion for Leave to File Supplemental Contention Re Financial Qualifications of Util. Certificate of Svc Encl ML20084G1791984-05-0303 May 1984 Affidavit of Cw Mueller Re Financial Integrity of Util ML20084G1731984-05-0202 May 1984 Affidavit of DF Schnell Re Financial Stability of Util ML20083Q3671984-04-18018 April 1984 Supplemental Contention Re Applicant Financial Qualification to Construct & Operate Facility.Certificate of Svc Encl ML20083Q3521984-04-18018 April 1984 Motion for Leave to File Supplemental Contention Re Financial Qualification of Applicant to Construct & Operate Facility.Certificate of Svc Encl ML20083Q2601984-04-18018 April 1984 Notice of Appearance of LC Green & Withdrawal of KM Chackes as Counsel for Intervenors.Certificate of Svc Encl ML20082A6631983-11-15015 November 1983 Comments on NRC & Applicant Responses to Aslab 831020 Order Requesting Addl Info.Responses Contain Nothing More than Description of Activities & Conclusion of No Safety Significance.Certificate of Svc Encl ML20082B4641983-11-15015 November 1983 Comments on Applicant & NRC Responses to Aslab 831020 Memorandum & Order Re Safety of Manually Welded Embedded Plates.Appointment of Independent Expert Requested. Certificate of Svc Encl ML20078P7131983-11-0404 November 1983 Response to Aslab 831020 Memorandum & Order for Addl Info on Observation 4-1 of Integrated Design Insp Program Rept Re Original Design Floor Response Spectra.Spectra Have No Safety Significance.Certificate of Svc Encl ML20078P7251983-11-0303 November 1983 Affidavit of Ew Thomas Re Revised Design Response Spectra ML20081C3031983-10-27027 October 1983 Reply to Reed 831006 Proposed Findings of Fact & Conclusions of Law Re Contention 6.Findings Mischaracterized Fda Recommendation & Position of Applicant & State of Mo. Certificate of Svc Encl ML20078H1751983-10-12012 October 1983 Response to Joint Intervenors 830823 Petition for Reconsideration of ASLB 830914 Decision ALAB-740. Insufficient Showing Made to Justify Reopening Record. Certificate of Svc Encl ML20080Q4471983-10-0606 October 1983 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20080M6381983-09-29029 September 1983 Motion for Extension to File,W/Commission,Petition for Review of Aslab 830914 Decision ALAB-740.Extension Should Be Granted Until 15 Days After Aslab Rules on Joint Intervenors 830923 Reconsideration Petition.Certificate of Svc Encl ML20078B4981983-09-23023 September 1983 Petition for Reconsideration of 830914 Decision ALAB-740 in Light of New Evidence Re Adequacy of Applicant QA Program. Many Items Remain Open in Integrated Design Insp Program Rept.Certificate of Svc Encl ML20078B8201983-09-23023 September 1983 Proposed Corrections to 830913 Evidentiary Hearing Transcript.Certificate of Svc Encl ML20078B8151983-09-23023 September 1983 Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision ML20024E8211983-08-31031 August 1983 Comments on Applicant Response to Aslab 830815 Order Re Failure to Provide Safe SA-312 Piping & Adequate QA Program.Certificate of Svc Encl ML20080C6991983-08-24024 August 1983 Testimony of Ng Slaten in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence ML20080C7141983-08-24024 August 1983 Testimony of Kv Miller in Response to Reed Contention 6 Re Protective Actions Against Radioiodines.State of Mo Decided Not to Administer Potassium Iodide to General Public Based on Federal Guidance & Weighing of Advantages/Disadvantages ML20080C7121983-08-24024 August 1983 Testimony of Re Linnemann in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence ML20080C7061983-08-24024 August 1983 Testimony of DF Paddleford in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence 1999-09-30
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- UNITED STATES OF AMERICA NUCLEAR REGUIA'IORY COtHISSION BEFORE THE A'ICMIC SAFETY AND LICENSING BOARD In the Matter of )
)
UNION ELECIRIC COMPANY ) Docket No. SIN 50-483 OL
)
(Callaway Plant, Unit 1 )
AFFIDAVIT OF KIRIT G. PARIKH COUNTY OF FONIGOMERY )
) ss:
STATE OF MARYLAND )
KIRIT G. PARIKH, being duly sworn, deposes and says:
- 1. I am employed by Bechtel Power Corporation, Gaithersburg Power Division, Gaithersburg, Maryland. My present position is Engineering Supervisor. I have previously testified on behalf of Applicant in this proceeding on the embedded plate issue, subnitting prefiled written test.imony dated November 6, 1981 (Acolicant anbed Testimony) and appearing for oral testimony at the hearing on this issue on November 18, 19 and 20, 1981. A cwplete statement of my professional qualifications is incorporated in Applicant Embed Testinony, following Tr. 501, at 5 and Attachment 3.
- 2. On February 19, 1982 JI filed their "... Motion for Admission of Additional Evidence", which seeks the introduction into evidence of a Bechtel Power Corporation letter to Union Electric Cmpany, dated April 9, 1980 (" BLUE 675"), with an Attachment entitled " Listing of Plates with Manually Welded Studs Installed in Concrete by 6/9/77."
Ohhofjjjj83 PDR
The 14-page Table included in this document (hereinafter referred to as "the Table"), was prepared under my supervision with sme of the supporting calculations personally prepared by me. I am submitting this Affidavit in order to correct certain mischaracterizations and misinterpretations of the data in the Table, which are contained in Joint Intervenors' Motion and in their "... Proposed Findings of Fact and Conclusions of Law," dated March 1, 1982.
- 3. Contrary to Joint Intervenors' representation, the data in the Table fully supports the Bechtel engineering analysis which determined that the deviations frcm the required weld detail identified on manually welded mbeds would not adversely affect the load carrying capacity or design safety margin of such embeds. The Table is nothing more than a detailed, plate-by-plate breakdown of the load carrying capacity data for the mnually welded plates which was introduced into the record in this proceeding by Applicant. See Applicant Ex. 4 at Appendix B, Calculation Sheet 3.
- 4. The Table, in its columns headed " location of Plate Fbdel" and " Plate No. Civil DWg." together with certain entries in the "R marks" column lists and provides information identifying the location and type of plate for.all manually welded embeds installed in concrete at the Callaway Plant prior to June 9, 1977.
- 5. In the column headed " Capacity of Plate", the Table provides the " design load" or " load capacity" of each manually welded embed. The design load for a particular type of plate, however, is always less than the plate's full structural capacity. Rather the design load incorporates a minimrn safety factor of at least 2.0 against the yield limit state of
the plate and the tensile capacity of the anchor rods. See Applicant Embed Testimony at 34. For example, in the design process, a plate with a full structural capacity of at least 50,000 lbs. would be assigned a design load of no more than 25,000 lbc. Accordingly, even if loaded to its full design load of 25,000 lbs., the plate would have a margin of safety of 2.0. In most cases, however, the actual load on a plate is considerably less than its design load capacity, thereby providing an additional margin of safety.
It is, however, accepted engineering practice to load a plate to its full design load capacity.
- 6. The column headed "Ioad on Plate" provides the actual load imposed on each plate. This load is the maximum load which it has been calculated could be imposed on the plate during the life of the plant and
. includes dead loads, live loads and seismic loads. As can be seen on the Table, in two cases the " load on plate" equals the " capacity of plate",
providing a minimum safety margin of 2.0. For all other plates, the actual load is less than the plate capacity providing increased margins of safety.
- 7. The column entitled " Reduced Plate Capacity" contains the results of calculations I performed to determine the effect of undersized anchor rod welds on the load carrying capacity of the manually welded plates. These calculations were reviewed and approved by other engineers in the Bechtel organization. The calculations provide the reduced plate capacity for each type of manually welded embed, assuming that each anchor rod on each such plate is undersized 1/8 inch for the entire 360 circum-ference of the weld. Additional conservative assumptions were also used in these calculations. See Applicant Embed Testimony at 37. The method used to calculate the reduced plate capacities was the same as that used in calculating the original design loads. Accordingly, the reduced plate
/
capacities also incorporates an inherent margin of safety, allowing the r
arbeds to be loaded up to the full amount of the recalculated capacities.
Because of additional conservatisms assumed in the recalculations, the smallest minimum safety factor was determined to be slightly less than 2.0.
See Applicant Embed Testimony at 38.
- 8. Afterperformingtheserecalculations,thereducedplatS capacities were then canpared to the actual load (column headed "Imd'on Plate") of each manually welded embed installed at Callaway prior to \
June 9, 1977. A review of the data in the Table reveals that in no case i does the actual load on a plate exceed its reduced plate capacity. While ,
it is true that in a few instances the actual load equals or is just.less than the reduced plate capacity, this does not mean, as Joint _Intervenors argue, that "in many cases there is little or no margin for error" or that'
"[ilf Bechtel's calculations are wrong and the reduced load capacity is lower, plate failure can be expected." See Joint Intervenors' Fotion at 3,4. Rather, since each manually welded plate, even with its recalculated ,
load carrying capacity, retains its inherent margin of safety, (See para.
7, supra; Applicant Embed Testimony at 38; Applicant PF 71(1)), it may be safely loaded to its full " reduced" capacity. x
- 9. JointIntervenorsalsoarguethattheabsenceofentbies in the column headed " Type of Icad of Plate" on the Table means that t
...in its engineering analysis, Bechtel apparently did not know, or at least did not consider, the type of load on each plate." See Joint Intervenors' bbtion at 4. This statement is untrue. As is clearly reflected in the record in this proceeding, all manually wel.ded plates
(
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, 4
- support structural steel framing. See Applicant Babed Testimony at 34; Applicant PF 66. This information was used in determining the actual load imposed on each plate, but since the type of load was the same for all plates, I determined that it was r.ot necessary to make entries in this column. Similarly, since there was no additional loads imposed on any of the plates, I determined that no entries were needed in the column captioned " Add'nl Ioads."
(^' Y i 1- cribYX Kirit G. Parikh N TARIZATION i i ,
- Subscribed and sworn b befcre me, the undersigned officer, this IOYh day of March, 1982. ,
a -Notary >'. dai> m-Publig' 1
j My camission expires: Mr /, /Gf.O.
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