ML20072B635
| ML20072B635 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/02/1983 |
| From: | Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-OL, NUDOCS 8303070118 | |
| Download: ML20072B635 (28) | |
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UNITED STATES OF AMERICA J* I ETO
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NUCLEAR-REGULATORY COMMISSION
'q q BEFORE TII.! ATOMIC SAFETY AND_ LICENSING APPEAIl(BOARD "2:46
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In the Matter of
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Docket No. STN 50-483-OL UNION ELECTRIC COMPANY
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(Callaway Plant, Ur.it 1)
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4 BRIEF IN SUPPORF OF EXCEPTIONS
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TO THE PARTIAL INITIAL DECISION OF ATOMIC SAFSTY AND LICENSING BOARD
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CHACKES AND HOARE Kenneth M. Chackes Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missouri 63102 314/241-7961 March 2,1983 B303070110PDR ADOCK 0 0 0 83 PDR Q
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TABLE OF CONTENTS
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TABLE OF CONTENTS i
l TABLE OF AUTIIORITIES CITED 111 l
INTitODUCTION 1
ARGUMENT 2
TIIE BOARD ERRED IN CONCLUDING THERE WAS NO OVERALL BREAKDOWN IN THE OPERATION OF APPLICANT'S QUALITY ASSU'RANCE PROGRAM AND THAT APPLICANT MET ITS BURDEN OF PROVING THAT Tile PLANT CAN DE OPERATED WITHOUT ENDANGERING THE IIEALTH AND SAFETY OF THE PUBLIC 2
L EMBEDDED PLATES 9
A.
THE BOARD ERRED IN CONCLUDING THAT APPLICANT MET ITS BURDEN OF PROOF ON Tile SAFETY OF EMBEDS INSTALLED PRIOR TO THE DISCOVERY OF DEFECTS 9
B.
THE RECORD ON THE EMBEDDED PLATE ISSUE DEMONSTRATES THE GENERAL FAILURE OF APPLICANT'S QUALITY ASSURANCE PROGRAM 12 IL HONEYCOMBING IN THE REACTOR BUILDING BASE MAT 12 THE BOARD ERRED IN CONCLUDING THAT APPLICANT DEMONSTRATED THE SAFETY OF Tile BASE MAT WHEN NO RELIABLE DOCUMENTATION OF THE CONCRETE POUR EXISTS AND NO RELIABLE TESTING WAS PERFORMED AFTER THE DISCOVERY OF DEFECTS 12 IIL SA-358 PIPING 14 THE BOARD ERRED IN IGNORING EVIDENCE OF SERIOUS QUALITY ASSURANCE VIOLATIONS IN THE MANUFACTURE AND INSPECTION OF SA-358 PIPING AND IN CONCLUDING THAT THE SA-358 PIPING IS SAFE 14
IV. SA-312 PIPING 15 A.
THE BOARD ERRED IN FINDING THAT SA-312 PIPING WOULD PERFORM SAFELY WIIEN IT IS KNOWN TO BE DEFECTIVE AND THE EXTENT OF ITS DEFEC'IU ARE UNKNOWN AND UNDETECTABLE, AND WHEN NO DETAILED ANALYSIS WAS MADE OF SA-403 PIPE FITTINGS MADE FROM DEFECTIVE SA-312 PIPING 15 B.
THE BOARD ERRED IN IGNORING EVIDENCE OF CODE VIOLATIONS AND VIOLATIONS OF NRC QUALITY ASSURANCE REGULATIONS WITH RESPECT TO SA-312 PIPING 17 V.
PREASSEMBLED PIPING FORMATIONS 17 THE BOARD ERRED IN IGNORING EVIDENCE OF QUALITY ASSURANCE BREAKDOWNS AND VIOLATIONS OF NRC QUALITY ASSURANCE REGULATIONS WHEN APPLICANT FAILED TO DISCOVER AND INSTALLED VISIBLY DEFECTIVE PIPING FORMATIONS 17 CONCLUSION 18 ATTACHMENT 1 CERTIFICATE OF SERVICE 11
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TABLE OF AUTHORITIES CITED l
Cases Page Consumers Power Co. (Midland Plant, Units 1 and 2)
ALAB-382, 5 NRC 603, 607-08 (1977) 18 I
In the Matter of Houston Lighting and Power Co.
(South Texas Projects, Units 1 and 2), CL1-80-32, 12 N.R.C. 281 (1980) 3 In the Matter of Virginia Electric and Power Co.
(N. Anna Power Station), ALAB-256,1 N.R.C.10,17, n.18 (1975) 2 Local 138 v. NLRB 321 F.2d 138,138 (2d Cir.1963) 5 Lloyd Sabaudo Societa v. Elting 287 U.S. 329, 53 S.Ct.167 (1932) 5 Melody Music, Inc. v. FCC 345 F.2d 730 (D.C. Cir.1965) 4 i
Northeast Airlines v. CAB 331 F.2d 579 (1st Cir.1964) 4 SEC v. Chenery Corp.
318 U.S. 80, 94, 63 S.Ct. 454, 462 (1943) 4 Wingo v. Washington 395 F.2d 633 (D.C. Cir.1968) 5 Statutes, Regulations & Other Authorities 10 C.F.R. Part 50, Appendix B 2, 3, 6, 12, 13, 17 ill
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INTRODUCTION This matter is before the Atomic Safety and Licensing Appeal Board after a partial initial decision of the Licensing Board on Contention One of Joint Intervenors Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance.
The Partial Initial Decision was docketed on December 3,1982.
Joint Intervenors' exceptions were filed on January 31, 1983 in accordance with an I
order granting their request for an extension of time.
Joint Intervenors contend that there has been failure of Applicant's quality assurance program, and that Applicant has not met its burden of proving that the Callaway Plant has br.en constructed in such a manner that it can be operated without endangering the health and safety of the public. Joint Intervenors' Contention One alleges:
i Surveillance and inspection functions of Applicant Union Electric Company, and others, including Bechtel Power Corp.
(lead architect / engineer),
Daniel International Corp.
(construction contractor) and Code Authorized Nuclear Inspectors, failed to ensure the quality of safety-related material, structures, systems and components through all phases of their fabrication, construction, testing and inspection, contrary to the qual!ty assurance criteria of 10 CFR Part 50, Appendix B.
Many vendor-supplied components were on the construction site and were approved for Installation before code-defined deficiencies and nonconformances were identified.
During construction deficiencies and nonconformances were accepted against code requirements. Without effective surveillance and inspection by the Applicant, and others, of material suppliers, component vendors, and construction contractors, all safety-related material, structures, systems, and components must be considered of questionable integrity.
Because effective surveillance and inspection were not performed, the safe operation of the Callaway Plant is in jeopardy and [it] should not be licensed.
j Contention One then cites several"[d]eficiencies and nonconformances which evidence the failure of the quality assurance program," including the five items that are addressed below: embedded plates, SA-358 piping, SA-312 piping and SA-403 fittings, preassembled I
piping formations, and honeycombing in the basemat.
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ARGUMENT THE BOARD ERRED IN CONCLUDING THERE WAS NO OVERALL BREAKDOWN IN THE OPERATION OF APPLICANT'S QUALITY ASSURANCE PROGRAM AND THAT APPLICANT MET FIB BURDEN OF PROVING THAT THE PLANT CAN BE OPERATED WITHOUT ENDANGERING THE HEALTH AND SAFETY OF THE PUBLIC Exceptions 65 through 70 address the findings and conclusions of the Licensing Board with respect to Joint Intervenors' allegations that there has been a general breakdown in the operation of Applicant's quality assurance program and that there is no assurance that the plant, as constructed, can be operated safely.
Four basic propositions require reversal of the initial decision's recommendation that the operating license be granted:
First, evidence adduced at the hearing demonstrates a pervasive failure of Applicant's quality assurance program to perform its intended functions in conformity with the regulations of the NRC,10 C.F.R. Part 50, Appendix B.
Secondly, and of equal importance, is that Applicant failed to prove that certain safety-related structures, systems and components in the plant are adequate to assure that it can be operated without endangering the health and safety of the public.i Thirdly, the evidence suggests that because of the firing of ironworker foreman Bill Smart in March 1978, following widespread publicity about his allegations of construction deficiencies at the plant, other construction workers have been unwilling to come forward with evidence of nonconformances.
Finally, Applicant and its architect / engineer, the Bechtel Corporation, have made material misrepresentations of fact both to the NRC Staff during the course of its investigations, and to the Licensing Board in connection with this proceeding.
1The magnitude of the burden on an Applicant for an operating license is not:
l established by statute or regulation. Whether the burden is to be "beyond a reasonable doubt," or "by clear and convincing evidence," or "by a preponderance of the evidence,"
is to be determined with due regard to the gravity of the issue in controversy. In the Matter of Virginia Electric and Power Co. (N. Anna Power Station), ALAB-256,1 N.R.C.
10,17, n.18 (1975).
2 l
I The Licensing Board found several violations of the quality assurance critetla of 10 C.F.R. Part 50, Appendix B, but either failed to address or summarily dismissed Joint Intervenors' arguments regarding a number of additional violations. The Board completely ignored the evidence concerning the effect on other construction workers of the firing of whistle-blower Bill Smart. And notwithstanding its own expression of serious doubts about the truthfulness of significant testimony offered by Applicant and Bechtel (Opinion po. 20 and 26),2 the Board ignored those doubts in its ultimate findings and conclusions.
The Commissioners of the NRC have indicated that strict scrutiny must be given in an operating license proceeding where, as here, there are numerous instances of the failure of the Applicant's quality assurance program to perform in accordance with 10 C.F.R. Part 50, Appendix B Criteria; where, as here, there is evidence of an atmosphere where workers would be reluctant to come forward with information regarding construction defects; and where, as here, there is evidence of apparent misrepresentations and misleading statements to the liRC. In the Matter of Houston Lighting and Power Co. (South Texas Projects, Units 1 and 2), CL1-80-32,12 N.R.C.
281 (1980). The Commissioners indicated that Atomic Safety and Licensing Boards, in dealing with quality assurance issues, must look at "the broader ramifications" in order to determine whether the operating license application should be denied. IA at 291-92.
The Commissioners also indicated that " material false statements" made to the NRC may themselves be grounds for the denial of an operating license, "certainly if the falsehoods were intentional,... and perhaps even if they were made only with disregard for the truth." & at 291, n. 4.
In addition to the similarities to the South Texas case, this case presents an additional ground for denial of the operating license:
the failure of Applicant to meet its burden of proving that structures and components 2 References to the Partial Initial Decision are to the pages of the Opinion (pp.
3-69), or the paragraphs of the Findings of Fact (pp.70-108, referred to as " Findings"),
l or both.
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I with known defects, such as the embeds, SA-312 piping, and the reactor containment building, are adequate to perform their intended functions. To the contrary, there are substantial questions whether the embedded plates can support the loads imposed on them, whether SA-312 piping and SA-403 fittings will fail because of their centerline lack-of-penetration welding defect, and whether the base mat and dome of the reactor building are adequate to contain the radioactivity released during the routine operation of the plant, and in the event of an accident.
The Board's failure to address many of the arguments advanced by Joint Intervenors, both on the specific safety questions and on the failure of the quality assurance program may make effective review of its decision impossible. It is a basic premise of administrative law that "the orderly functioning of the process of review requires that the grounds upon which the administrative agency acted be clearly disclosed and adequately sustained." SEC v. Chenery Corp., 318 U.S. 80, 94, 63 S.Ct. 454, 462 (1943). An agency is required to articulate clearly reasons for ruling and the reasons have to be rational. Northeast Airlines v. CAB, 331 F.2d 579 (1st Cir.1964). It is not enough for an agency to make simply a great number of findings or to render a bulky decision, the agency must make findings and give reasons for its resolution of the perintent, vital questions in contention among the parties. See, e.g., Melody Music, Inc. v. FCC, 345 F.2d 730 (D.C. Cir.1965).
In this proceeding, Joint Intervenors placed a substantial number of issues into contention.
The proceedings were lengthy and complex and generated a massive transcript. Joint Intervenors submitted very detailed and lengthy proposed findings of fact and conclusions of law. Yet in several instances it is barely discernible from the decision that the Intervenors appeared at all. Not only is our input rejected, in many cases it is rejected without being confronted in a perceptible way. In instance after instance, the decision of the Board gives no guidance to the Appeal Board, the reviewing court or the parties in judging whether the evidence and arguments advanced by Intervenors have been properly disregarded in favor of the Applicant's and Staff's case.
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J The remarks of the Court in Local 138 v. NLRB, 321 F.2d 138,138 (2d Cir.
l 1963) are applicable:
I am disturbed by what seems a rather frequent practice of some of the Board's examiners, instanced here, of endeavoring to support findings by applying a ' credible' rubber-stamp to one witness and a 'not credible' one to another, with no explanation that will assist the Board or a reviewing court in ascertaining l
what -led to the use of the particular stamp.
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It was held in Wingo v. Washington, 395 F.2d 633 (D.C. Cir.1968) that the agency was required to do more than make conclusions, that it must " confront the facts on which appellant relles and the legal inferences those facts suggest." Such a forthright confrontation is manifestly lacking in the Board's decision, notwithstanding its bulk. See Lloyd Sabaudo 80eleta v. Elting, 287 U.S. 329, 53 S.Ct.167 (1932).
While the safety of all of the plant's structures, systems, and components is in question because of the failure of the quality assurance program, the issues raised by Joint Intervenors - the embedded plates, the piping, and the honeycombing in the reactor containment building - of themselves, cause grave concern. For example, at least some of the over two hundred safety-related manually welded embedded plates installed prior to the stop work orders in June 1977 and supporting main structural flooring beams in the auxiliary and control buildings and control may be loaded to or beyond their full structural capacitics.
In a second example, the case of SA-312 piping and SA-403 fittings, a welding defect - centerline lack-of-penetration - is known to exist, but impossible
+4 detect.
The piping was manufactured without adequate controls and under an inappropriate procedure.
That situation is rendered intolerable by the fact that there are no nondestructive examination methods that can detect the existence of the defect or,
determine its extent.
A third example, honeycombing in the reactor containment building, involves :
the ability of the reactor building to contain radioactivity during the normal operation,
of the plant and in the event of the accident.
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Under NRC regulations Applicant is responsible for the implementation of a quality assurance program relating to all activities affecting the safety-related functions of all structures, systems, and components of the plant.
The activities for which Appilcant is responsible include " designing, purchasing, fabricating,... erecting, s
installing, inspecting, testing, operating, maintaining, [and] repairing." While Applicant may delegate some of the work involved in establishing and executing the quality assurance program, Applicant remains responsible for every aspect of it.
10 C.F.R. Part 50, Appendix B, Introduction, and Criterion 1.
The evidence in this case establishes several instances where Applicant's quality assurance program has failed to assure that structures, systems and components have been (1) properly designed and/or selected; (2) manufactured or constructed in conformity with applicable codes; (3) properly inspected for deficiencies; (4) appropriately evaluated, corrected or otherwise dispositioned after nonconformances have been identified; and (5) properly controlled to prevent inadvertent use or installation of nonconforming items.
Among the failures of concern is the performance of inspection and reporting activities with respect to deficiencies in purchased materials manufactured by other companies at their own facilities. In July 1977, after discovery by the NRC staff of welding deficiencies in embeds, the NRC staff cited Applicant for Bechtel's failure to follow documented quality assurance procedures requiring inspection of welds at vendors' facilities, and cited Applicant's construction contractor, the Daniel Company, for failure to follow documented procedures requiring weld inspection upon receipt of items. (J.I.
Proposed Findings of Fact 11 5-7). Immediately thereafter, Applicant directed Daniel to receipt-inspect all safety-related items for conformance to procurement document specifications. (& 18). Nevertheless, as late as 1979 a piece of SA-358 piping and several piping assemblies from Gulf and Western with visible welding defects were l
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accepted on site, released for installation, and in some cases installed. (J.I. Proposed Findings of Fact 1 1 68-74, 138-141). Bechtel's " highest level" of vendor surveillance l
at Gulf and Western's facililty failed to identify numerous welding defects by visual i
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Inspection and on radiographs. (AI 1 142)
In light of the obvious failure to improve inspection and surveillance activies after the early discovery of the embed deficiencies, there is no basis for the Board's conclusions regarding the overall effectiveness of Applicant's quality assurance program. Appilcant's inspection and surveillance activities are responsible for safety-related materials provided by approximately 200 suppliers and contractors (Schnell, T, 216 (9)).
The Licensing Board concluded that the deficiencies and nonconformances identified by Joint Intervenors are merely a few isolated occurrences that in no way suggest the existence of a larger problem.
(Findings,144 and 146).
One of the difficulties with that conclusion is Joint Intervenors' inability to pursue actively certain issues because of limited resources (see, eg Joint Intervenors' Answer to Applicant's and Staff's Motions for Summary Disposition - concrete cracks and concrete cover),
and because of lack of firsthand information (honeycombing in reactor building dome).
More important, however, is the question of the willingness of construction workers at the Callaway Plant to report deficiencies and nonconformances to their superiors and the NRC staff, especially after the firing of Bill Smart. The history of Bill Smart's reporting of construction defects to the NRC, and his firing and reinstatement, are a part of this record an.d relevant to Joint Intervenors' Contention One. Clearly, if the environment at the Callaway construction site has been such that workers have been unwilling to report defects for fear of reprisals, a valuable source of information regarding the quality of construction has been lost. Bill Smart's initial allegations to the NRC were made in October,1977.3 Investigations by the NRC were performed as a result of those allegations in October and November 1977. In December 1977 Mr.
Smart visited the plant site with NRC inspectors to point out certain deficiencies to l
311is allegations regarding embedded plates led to the NRC's on site investigation in November 1977 when the NRC obtained a copy of the Daniel inspection data (J.I.
Ex.12) which resulted in questions being raised regarding the validity of Bechtel's engineering analysis of the adequacy of the manually welded plates (J.I. Ex. 34, NRC Report No. 77-10).
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them. If Mr. Smart's identity as a whistle-blower was unknown prior to that visit, it was clearly established at that time. Further investigations into Mr. Smart's allegations occurred in December 1977 and January 1978.
In February 1978 the findings from those investigations were released by the NRC at a news ccaference. In the following month, March 1978, Bill Smart was fired by Daniel allegedly for disobeying an order of a superior. As a result of his union's arbitration of his discharge Mr. Smart was ordered reinstated with back pay, as the alleged grounds for the discharge could not be substantiated.
The arbitrator's opinion, according to the NRC, noted that Daniel requested that reinstatement be denied even if the discharge were not for good cause.
The NRC staff failed to make a determination one way or the other on the question whether Mr. Smart's discharge was in retaliation for his whistle-blowing activities, and failed to make a definitive finding regarding the possible chilling effects of Mr. Smart's case on other workers. (J.I. Ex. 74, NRC Report No. 50-483/78-12; 50-486/78-02). An example of Applicant's attitude toward Mr. Smart's activities is contained in an excerpt from the transcript of a meeting regarding his allegations attended by Mr. Smart, NRC inspectors, and Union Electric and Daniel personnel. At that meeting Mr. Smart reported some negative information regarding an individual, who had made a conflicting statement to Mr. Foster of the NRC Staff. Mr. Smart asked Mr. Foster: "Well, would you expect him to tell you that he told us to move those tags?" In rcsponse, Morgan Doyne, the second highest on-site management official of Union Electric responsible for plant construction, stated to Mr. Smart, "We would expect him to be more honest and forthright than we would expect from you, Bill."
(J.l. Exs. 55 and 56, transcript pp.
22A-23; T.1755-57). Such a comment indicates an attitude on the part of Applicant's management to discourage, rather than encourage, reporting of concerns regarding plant construction. Moreover, in light of the publicity surrounding Mr. Smart's discharge and the fact that the alleged grounds for his discharge were not substantiated in the arbitration proceeding, it had to have been clear to workers that whistle-blowing at the Callaway Plant meant risking one's job.
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Each of the subcontentions raised by Joint Intervenors is addressed in more detail below.
L EMBEDDED PLATES Joint Intervenors' exceptions 1 through 32 address the embedded plates issue.
Embedded plates, or embeds, are structural steel devices used at the Callaway Plant to support steel floor beams, critical piping systems necessary for a safe shut-down of the plant in case of an emergency, and other critical parts. (Findings 1 and 2). Whea the Callaway Plant was less than ten percent complete, in June of 1977, it was discovered that embedded plates that had not yet been installed in the plant, were defective (Opinion p. 5, Finding 5). Prior to that discovery, at least several hundred similar plates, manufactured in the same manner and by the same manufacturer as the defective plates, had been embedded in concrete in the plant, and, therefore, were not available for inspection (Opinion p. 5, Finding 6). The condition of the plates installed prior to June 1977 is not known and has only been hypothesized based on information generated from the inspection of plates that had not yet been installed after the discovery of the defects.
A. TIIE BOARD ERRED IN CONCLUDING THAT APPLICANT MET ITS BURDEN OF PROOF ON THE SAFETY OF EMBEDS INSTALLED PRIOR TO THE DISCOVERY OF DEFECTS.
1.
Manually Welded Embeds The Licensing Board expressed a deep concern over the handling of the
[ manually welded] embed plate problem by the Applicant, the Bechtel Company and the NRC Staff" and stated its " apprehensions over the quality of work performance" by Daniel (Applicant's construction contractor) and the Cives Company (the manufacturer of the defective embeds) (Opinion p. 25). The Board also expressed its doubts about the truthfulness of testimony and written reports presented by Applicant as part of its proof on the embed issue (Opinion pp. 17,19-20, and 26). The Board found, despite Applicant's representations to the contrary, that no documentation exists of the assumed I
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" worst case" welding defect upon which critical engineering analyses and performance tests were based (Opinion pp.1G-17, and 26). The Board concluded that there had been "a serious disregard by the Applicant and its major contractors for quality assurance considerations in the handling of certain aspects of the manual welded embed plate problem." (Opinion p. 29). Yet despite all those negative findings the Licensing Board i
ultimately concluded that Applicant met its burden of pror' with respect to the safety 1
of the manually welded embeds.
Joint Intervenors contend that that conclusion is erroneous as a matter of law based solely upon the underlying facts as found by the Licensing Board. In addition, however, the Board made several erroneous factual findings which further undermine its ultimate conclusion.
Joint Intervenors' arguments and citations to the record regarding the failure of Applicant to prove the safety of the manually welded embeds installed prior to the discovery of defects are adequately set forth in Joint Intervenors' Proposed Findings of Fact and Conclusions of Law (pp.16-37) and will not be repeated. Joint Intervenors adopt those arguments herein.
Of critical importance, however, and worthy of repetition, is the basic fact that all that is known about the extent of weld defects on the manually welded embeds installed prior to the discovery of defects is based on the inspection of similar embeds that had not yet been installed.
No g situ testing of manually welded plates was performed. Before accepting any of Applicant's conclusions based upon the inspection effort, documentation of the inspection results must be shown.
As found by the Licensing Board, no such documentation exists: "the Bechtel Corporation had no written support for its assumption that the maximum undersize was always less than 1/8 inch but relied solely on oral communication.s." (Opinion pp.16-17).
l Despite the fact that it found no reliable documentation of the extent of welding deficiencies, the Board concluded that Applicant met its burden of proof on the safety of the manually welded embeds (Opinion pp. 29-30).
In reaching its conclusion, the 10
'l Board was willing to hypothesize that the undocumented maximum weld deficiency assumed by Bechtel was incorrect:
The central issue of this contention then is: If the acsumption used by Bechtel in its engineering evaluation, that no weld deficiency was more than 1/8 inch undersize was an incorrect asaumption, could plate failure among those embedded prior to June 9,1977 be anticipated. (Opinion p. 29).
Although it had no reliable evidence before it that indicated how defective the embeds really were, the Board answered its question - whether plate failure could be anticipated
- in the negative. "We think not."
( AI )
The grounds relied on by the Board for its ultimate conclusion are unreliable without documented evidence of how bad the embeds really are (Opinion pp. 29-30).
A safety factor of 2.0 provides no assurance of safety if the actual defects reduce the capacity of the embeds by a similar factor. The tension tests referred to by the Board were performed on welds that were not even as defective as Bechtel's assumed
" worst case." Moreover, no attention was paid to the fact that many plates contain multiple welding defects. (See, J.I. Proposed Findings of Fact,144, pp. 34-35). That future welding code revisions might permit 25 percent smaller weldments4 is of no comfort when we don't know how far undersized the weldments really are. The Board's final ground for its ultimate conclusion is an off-the-cuff comment by Dr. Fisher which was based upon no knowledge of the actual loads imposed on the embeds, based upon no formal evaluation or testing, and contrary to the findings of Bechtel's engineereing analysis (See, J.I. Proposed Findings of Fact,145, pp. 35-37).
4This was the undocumented prediction of one of Applicant's expert witnesses.
There is no evidence that such a relaxation was ever adopted. Although not a part of the record, the Appeals Board can take notice of the fact that the code has not been am ended. Rule 201, Federal Rules of Evidence. See Attachment 1.
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2.
Machine Welded Embeds i
Joint Intervenors' arguments and citations to the record regarding the safety of the machine welded embeds are adequately set forth in Joint Intervenors' Proposed Findings of Fact (pp. 38-40) and are adopted herein.
B. THE RECORD ON THE EMBEDDED PLATE ESUE DEMONSTRATES THE GENERAL FAILURE OF APPLICANT'S QUALrrY ASSURANCE PROGRAM.
As stated above, the Licensing Board found several violations of the quality assurance criteria of 10 C.F.R. Part 50, Appendix B, in connection with the embedded plate issue (Opinion pp. 5-6, 26, 27-28). Numerous additional violations of Appendix D criteria exist, however, but were either overlooked or excused by the Board. Joint Intervenors again rely on their Proposed Findings of Fact rather than restating herein their detailed arguments and citations to the record (See, J.I. Proposed Findings of Fact, pp. 3-11 and 40-46).
H.
HONEYCOMBING IN THE REACTOR BUILDING BASE MAT THE BOARD ERRED IN CONCLUDING THAT APPLICANT DEMONSTRATED THE SAFETY OF THE BASE MAT WHEN NO RELIABLE DOCUMENTATION OF THE CONCRETE POUR EXISTS AND NO RELIABLE TESTING WAS PERFORMED AFTER THE DISCOVERY OF DEFECTS In the concrete slab of the reactor buildi.g base mat, areas of honeycombing, or voids, were discovered at the bottom of the slab in the only area available for inspection. (Opinion p. 32). Much of the visible honeycombing was located such that it undermined the base of tendon trumplates, steel devices that anchor the vertical steel tendons that extend from below the basemat, through the walls and over the dome of the reactor building. The concrete directly behind those trumplates bears more stress than any other concrete in the Callaway Plant and must do so for the operating life of the plant.
See, J.I. Proposed Findings of Fact 1153, p. 92. The extent of honeycombing in other areas, not accessible for visual inspection, is not known. (Opinion
- p. 35). The honeycombing was caused by overcongestion of reinforcing bars and other internal structures, a phenomenon also existing near the reactor cavity; and by improper 12 l
4 quality control procedures including lack of documented instructions and inadequate training of personnel. The evidence does not establish the absence of honeycombing in other areas and, therefore, does not establish the safety of the base mat. In addition, the total lack of documentation during the 62 hour7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> concrete pour renders it impossible to be confident that the pour was performed properly or to extrapolate about the quality of the mat in areas not accessible to visual inspection.
The Board erroneously placed the burden of proof on Intervenors when it stated, with regard to the base mat: "We criticize the documentation procedure but do not find evidence that the inspectors failed to perform their duties at the time the concrete was actually placed." (Opinion p. 41). Where is the evidence that the inspectors did perform their duties? How can the Board express confidence in the integrity of the base mat when it makes no positive finding that inspection work was performed during the pour? Without proof of inspection during the pour, there is no basis for the Board's finding that the base mat is safe. See, J.I. Proposed Findings of Fact,1159, p. 95.
The Board dismisses Joint Intervenors' arguments regarding the effect of steel on the soniscope results with the conclusion that the presence of steel cannot cause an increase in sound velocity. (Opinion pp. 38-39, Finiing 77). The Board finds that sound waves cannot go through an interface between concrete and steel. (id.) That finding is clearly erroneous. The Wiss, Janney report en the soniscope testing indicates that a majority of the soniscope measurements that were taken directly through the steel trumplates ("SV shots") were successful. Applicant's Ex. 2, p.15.
Thus, sound waves can and do travel through concrete and steel, and their velocity obviously would be increased due to the presence of large amounts of steel throughout the base mat.
As no account was taken for that fact, the soniscope testing results are unreliable.
Exceptions 33 through 44 address the errors made by the Licensing Board with l
respect to the base mat subcontention. Joint Intervenors adopt and respectfully refer I
the Appeal Board to the other arguments and citations with respect to the safety of I
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the base mat and the violations of Appendix B quality assurance criteria contained in their Proposed Findings of Fact, pp. 89-98.
IH. SA-358 PIPING THE BOARD ERRED IN IGNORING EVIDENCE OF SERIOUS QUALITY ASSURANCE VIOLATIONS IN THE MANUFACTURE AND INSPECTION OF SA-358 PIPING AND IN CONCLUDING THAT THE SA-358 PIPING IS SAFE A piece of SA-358 piping, at the point of installation in the emergency core cooling system at the Callaway Plant, was discovered by a pipefitter to be defective.
(Opinion p. 51). The pipe in question was manufactured without adequate conLol and documentation of welding activities.
Despite the visibly defective condition of the pipe, Applicant's quality assurance program failed to prevent its bcing approved for shipment from both the manufacturer of the pipe and from the vendor that had assembled it into a pipe spool, and failed to cause it to be rejected upon receipt at the plant site.
If the pipefitter would not have reported the deficiency when he was fitting the pipe, the defective pipe spool would be in place today. After discovery of the defective condition the nonconformance was not dispositioned in accordance with documented procedures by Applicant and its contractors.
The NRC staff had to rely on communications from a confidential source, and media and citizen involvement,in order to be apprised of and to be able fully to evaluate the defective part, the inoperative quality control system and the significance of both. Only because of that outside input did the NRC Staff's investigtion result in the issuance of a notice of violation based upon Applicant's violation of an NRC quality assurance criterion. The evidence fails to establish the safety to the SA-358 pipe in question and demonstrates the failure of Applicant's quality assurance program to identify and properly disposition nonconformances.
Exceptions 45 through 50 address the Licensing Board's errors in connection with the SA-358 pipe issue.
14
i The Board's findings and opinion with respect to the SA-358 pipe issue ignore virtually all of the arguments asserted by Joint Intervenors concerning the safety of the pipe in question and the deficiencies in the operation of Applicant's quality assurance prrgram. See J.I. Proposed Findings of Fact, pp. 52-65.
In particular, the Board, failed to respond to Intervenors' arguments that the s
defective weld condition may have resulted from drop-thru or melt-thru, a condition that would adversely affect the mechanical properties of the weld, and hence the safety of the pipe. See, Opinion pp. 53-54; J.I. Proposed Findings of Fact, 11 63-75, pp. 53-55.
In addition, the Board completely ignores Intervenors' arguments and the evidence demonstrating that several serious quality assurance problems occurred in the failure to discover the defects in a timely manner and the failure to disposition properly the nonconforming conditions. Among the evidence ignored by the Board is that a critical portion of the welding process, the back grinding of the longitudinal pipe weld, was accomplished for this and other SA-358 pipe without any documented procedures. See, Oph.lon p. 55; J.I. Proposed Findings of Fact, 11 68-79, pp. 56-63.
IV. SA-312 PIPING A. TIIE BOARD ERRED IN FINDING TIIAT SA-312 PIPING WOULD PERFORM SAFELY WIIEN IT IS KNOWN TO BE DEFECTIVE AND THE EXTENT OF ITS DEFEC'IB ARE UNKNOWN AND UNDETECTABLE, AND WHEN NO DETAILED ANALYSIS WAS MADE OF SA-403 PIPE FITTINGS MADE FROM DEFECTIVE SA-312 PIPING SA-312 piping, installed in the emergency core cooling system and other safety-related systems at the Callaway Plant, was manufactured without adequate control of welding parameters. This lack of control resulted in a defective condition of incomplete fusion in the longitudinal weld of the pipe, known as centerline lack-of-penetration (CLP). Because nondestructive examination methods are unable to detect it, the extent of the CLP defect in any particular piece of pipe is unknown. The evaluation and acceptance of this substandard piping were inadequate and were not consistent with the ASM2 Code.
The evidence fails to establish the safety of the SA-312 piping 15
/
e installed in the plant, and indicates the inadequacy of Applicant's quality assurance I
program.
Joint Intervenors' exceptions to the Board's decision on the SA-312 piping issue are set out in paragraphs 51 through 63.
Again, with respect to the SA-312 piping and SA-403 fittings, the Licensing Board has failed to address the central arguments of Joint Intervenors with respect to the ability of the piping to perform without failure, and the failure of Applicant's quality assurance program. See, J.f. Proposed Findings of Fact pp. 69-83.
Of particular concern on the safety issue is the Board's finding that the SA-312 piping at the Callaway Plant has no greater than 26 percent CLP (Opinion pp. 59-60, Finding 127). That this finding is unsupported by the record is demonstrated by the facts that (1) there is no way to datect CLP without destroying the pipe; (2) none of the SA-312 pipe at Callaway has been inspected for CLP; and (3) misalignment of welding arcs, a manufacturing condition that is known to occur but is virutally uncontrolleo, aan cause extreme amounts of undetectable CLP, See, J.I. Proposed Findings of Fact 11 108-114, pp. 71-75. The Board recognized that nondestructive examination methods cannot reliably detect CLP and that none of the Callaway SA-312 pipe was inspected for CLP (Opinion p. 59, Finding 126). Although the Board found that misalignment of the welding arcs can cause CLP,it failed to consider the seriousness of that problem (Opinion pp. 58-59). Joint Intervenors' discussion of the evidence and arguments in support of the proposition that misalignment may have caused extreme amounts of CLP are contained in their Proposed Findings of Fact, 1 T 105-107 and 113, pp. 70-71 an 74-75.
The evidence cited in those proposed findings, and the conclusions drawn therefrom, are totally ignored by the Board in its conclusion that the maximum extent of CLP at Callaway is 26 percent.
One of the critical findings of the Board in support of its conclusion regarding the safety of the SA-312 piping at Callaway is that pipe failure due to CLP would result only in a small leak and that catastrophic failure would not occur (Opinion pp.
16
(
61-62). The impossibility of a catastrophic break is based on the absurd conclusion that the amount of CLP in the weld would have to exceed the wall thickness of the pipe (Id). Apparently, therefore, according to the Licensing Board, completely unwelded SA-312 pipe would be acceptable.
B.
THE BOARD ERRED IN IGNORING EVIDENCE OF CODE VIOLATIONS AND VIOLATIONS OF NRC QUALITY ASSURANCE REGULATIONS WITH RESPECT TO SA-312 PIPING The Board's finding that Applicant and its contractors have satisfied appilcable code requirements for the use of SA-312 piping is unsupported in the record (Opinion
- p. 65). Again the Board has failed to respond to the detailed arguments advanced by Joint Intervenors. See, J.I. Proposed Findings of Fact 11 115-121, pp. 76-80.
Finally, the Board dismissed without discussion the evidence and arguments of Joint Intervenors with respect to the multiple failures of Applicant's quality assurance program and violations of Appendix B criteria in connection with the SA-312 piping issue. See, Opinion p. 65; J.I. Proposed Findings of Fact 11 124-129, pp. 81-83.
V.
PREASSEMBLED PIPING FORMATIONS THE BOARD ERRED IN IGNORING EVIDENCE OF QUALITY ASSURANCE BREAKDOWNS AND VIOLATIONS OF NRC ' QUALITY ASSURANCE REGULATIONS WHEN APPLICANT FAILED TO DISCOVER AND INSTALLED VISIBLY DEFECTIVE PIPING FORMATIONS In 1979 welding deficiencies were discovered in preassembled piping formations manufactured by Gulf and Western and intended for and in some cases already installed in several safety-related systems at the Callaway Plant.
Despite the fact that the deficiencies were apparent on radiographs of the welds, and in some cases were visible, they were not discovered by Bechtel's surveillance activities at the manufacturer's facility. Bechtel's surveillance inspection at that facility was the highest level Bechtel performs. The deficiencies also were not discovered by Daniel personnel either upon j
receipt at the plant, or at the point of installation. The initial discovery of defects i
17 1
was reported as the result of a nonmandatory inspection by a craft worker at the Wolf Creek Plant - the other SNUPPS construction site - and then communicated to Applicant. These circumstances indicate the continued failure of Applicant's quality assurance program to identify nonconforming and defective materials.
Exception 64 addresses the Board's findings with respect to the Gulf and Western piping issue.
This subcontention provides perhaps the most blatant example of the Board's failure to deal with the issues before it.
The Board's findings and opinion merely recite the virtually uncontested evidence concerning the piping assemblies, the discovery of defects, and their repair (Opinion pp. 66-69, Findings 135-140). There is no mention whatsoever of the failure of Applicant's quality assurance program to discover the visibly defective condition of the piping formations at the manufacturer's facility (despite the performance by Bechtel of its highest level of vendor surveillance), upon receipt at Callawa;, and during the installation process. See, J.I. Proposed Findings of Fact, 11 138-145, pp. 85-88.
CONCLUSION For the reasons stated above the Appeal Board should reverse the Partial Initial Decision of the Licensing Board and enter an Order recommending that the application for an operating license for the Callaway Plant be denied. In the alternative, the case should be remanded for further proceedings, including a requirement that the Licensing Board appoint independent experts to analyze and assess the evidence presented by Applicant and the NRC Staff and to perform such additional analyses and tests as may be necessary to demonstrate the safety or lack of safety of the plant, and the adequacy or inadequacy of the Applicant's quality assurance program during the plant's construction.
Cf. Consumers Power Co. (Midland Plant, Units 1 and 2) ALAB-382, 5 NRC 603, 607-08 (1977).
1
Respectfully submitted, CHACKES AND HOARE
.A~
Kenneth M. Chackes ~
Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missouri 63102 314/241-7 9 61 i
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19 b
January 10, 1983 American Welding Society 2501 N.W. 7th St.
Miami, FL 33125 Gent 1 w Would you please tell es if the American Welding Society hee changed the Structurel Weldino Code D1.1 requiremente for welchnents on enchor rode on sabedded pistes since 1975 so that today a weld would be i
permitted with an undersias greater then 1/S of an inch? I would eleo appreciate it if you would tell me if en undercut greater then 2/16 of an inch for up to ten percent of the weld length would be permitted today according to the Bode.
Your response will be appreciated.
Sincerely, l
~
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- - - - - ~ _... - _ _ -. _ _ - - - - - - - - - - _ - - - - -
American Welding Society 550 N.W. LeJeune Road, Miami, Florida 33126 P.O. Box 351040, Miami, Florida 33135. (305) 642-7090 Telex: AMWELD SOC. No. 51-9245 January 18, 1983 Mrs. Leo A.
Drey 515 West Point Ave University City, MO 63130
Dear Mrs. Drey:
Enclosed are excerpts from the Structural Welding Code - Steel, AWS Dl.1-82, and the Structural Welding Code - Reinforcing Bars, AWS Dl.4-79.
Both Codes prohibit welds undersize to any notice-able extent, and both prohibit undarcut deeper than 1/1f inch.
These specifications are available for anyone to consult in a library of all AWS publications maintained by our St. Louis Sec-tion at 1413 N.
Pennsylvania Avenue, St. Louis, MO 63133.
John Weaver at Lincoln Electric Company, phone 314/647-5886, should know how you could see the Codes.
Very truly yours,
/
w llock C. Campbe 1 Consultant Welding Education HCC/sh Encl.
Files Dl-30 l
pm -
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- b.,h l2:2 - 19f 3 12/ REINFORCING STEEL CDDE 4.2.4 For indirect butt splices, the maximum gap between 4.4.4 There shall be thorough fusion between weld metal the bar and the splice member shall be no more than one-and base metal and between successive passes in the quarter of the bar diameter, but not more than 3/16 in.
weld.
(4.8 mm).
4.4.5 All craters shall be filled to the full cross section 4.2.5 For direct 1:p welded splices,if the bars deviate by of the weld.
more than one-half of the bar diamsMr or by more than 4.4.6 Welds shall be free from overlap.
I/4 in. (6.4 mm) from each other while the bars remain 4.4.7 Undercuttina deeper than 1/32 in. (0_.8 mm) shall, in approximately the same plane, the joint sha!! be made not be aTowed. regardless of the direction of stress, ex-through a splice bar or plate and the requirements for an cept that at points where welds intersect the raised pat-Indirect lap welded splice shall apply. (See 4.2.6 and tem of deformations, undercuttina less than 1/16_in.
3.73.)
(1.6 mm) deep shall be acceptable.
4.2.6 For indirect lap welded splices, the maximum gap 4.4.8 The sum of diameters on piping porosity in flare-between the bar and the splice plate shall be no more bevel-groove, flare V-groove, and fillet welds shall not-than one quarter of the bar diameter, but not more than exceed I/8 in. (3.2 mm) in any linear inch (25.4 mm) /
3/16 in. (4.8 mm).
of weld and shall not exceed 9/16 In. (143 mm)in any 4.2.7 Welding shall not be done on or within two bar 6 in. (IS2 mm) length of weld.
diameters of any bent portion of a bar that has been 4.4.9 In direct butt splices inspected by radiographic bent cold.
testing, the maximum dimension of any single porosity 4.2.8 Welding of crossing bars shall not be permitted for or fusion type discontinuity or the sum of the maximum assembly of reinforcement unless authorized by the En-dimensions of all porosity or fusion type discontinuities gineer.
shall not exceed the limits given in Table 4.4.9. For radiographic testing, see 7.7.3.
4.3 Control of Distortion, Radi ic criteria Shrinkage, and Heat T
Sum of Single 43.1 In assembling and joining parts of a structure or se ntinuity dscontinuity' precast member, the procedure and sequence followed shall minimize distortion and shrinkage.
in.
mm in.
mm 43.2 When welding is performed on bars or other stmc-8 3/16 4.8 1/8 3.2 tural components that are already embedded in concrete, 9
3/16 4.8 1/8 3.2 allowance shall be rnade for thermal expansion of the 10 1/4 6.4 1/8 3.2 steel to prevent spalling or cracking of the concrete or 11 1/4 6.4 3/16 4.8 significant destmetion of the bond between the concrete and the steel.
g 4.4.10 Ultrasonic inspection of direct butt splices in de-4.4 Quality Of Welds formed reinforcing bars is not considered feasible except by highly sphd techniques and is not recom-
. mended.
4.4.1 The faces of fillet welds shall be slightly convex, 4.4.11 Welds which do not meet the quality requirements flat, or slightly cory: ave as shown in Fig. 4.4 A, B, and C, or 4.4.1 through 4.4.9, inclusive, shall be corrected by and with no imperfections exhibited in Fig. 4.4 D.
removal of unacceptable portions cr by rewelding, which-4.4.2 Groove welds shall be made preferably with slight ever is applicable.
or minimum reinforcement escept as may be otherwise 4.4.12 Corrections to welds made with the shielded metal provided. In the case of direct butt splices and flare-a5:, gas metal arc, or flux cored arc processes shall be groc.e welds, the reinforcement shall not exceed I/8 in.
made in accordance with an approved procedure specifi-(3.2 mm) in height measured from the main body of the cation applicable to these pro: esses.
bar and shal. nave gradual transition to the plane of the 4.4.13 Corrections to welds made with el*.her the thermit base metal surface (Fig. 4.4E). 'Ihey shall be free of the or the pressure gas welding proceu may be made with the imperfections shown in Fig.4.4F.
SMAW, CMAW, or FCAW processes using the filler met-4.43 Welds shall have no cracks in either the weld metal al and preheat temperature specified in Section 5 for the or hent affected zone.
base metal being welded.
Yh JJ N J Mbhd<0 $.n. 14 0.b;@. '
hd l st.
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m/3 3 /,( - FLW
%%W2&ubdmuhipt133A "'
t layen orweia metarana betwerweld metal and base I!
metal.
I 21/2 8.15.1.3 All craters are filled to the full cross section N
of the weld.
wide of wide of 8.15.1.4 Weld profiles arc *n accordance with3.6.
wider plate A
narrower plate 8.15.1.5 Irrespective oileng.h. utdercuuhall not ca-
/ \\
I ceed the value shown in Fig. 8.17.1.5 'of the primary stress direction category gelicable to the area containing
}
2 1/2 /
surt Joint 1l the undercut. Further. the undercut may be twice the value permitted by Fig. 8.15.15 (for the applicaale stress cate-gory) for an accumulate 0 length of 2 in. in any 12 in (51 Fig. 8.10B '&ansition of thicknesses or widths mm in 305 mm) leng b of weld. tCn no ease may undercut on one side te greater than1/16 ut. (1.6 mm). For 2 weld lengths less than 12 in. (305 mm), the permitted /
length should be proportional to the actual length.
8.15.1.6 The sum of diameters of pipirg porosity in '
stiffeners or flanges. or both, whose least panel dimen*
fillet welds does not exceed 3/8 in. (9.5 mm) in any I
sica is d shall not exceed the following:
linear inch of weld and shall not exceed 3/4 in. (19.0 mm) in any 11in. (305 mm) length of weld.
Leading 8.15.1.7 A fillet weld in any single continuous weld Dynamic Statie Intermediate stiffeners on both sides of web shall be permitted to underrun the nominal fillet size wherrD/t< 150. maximum variation = d/115 d/100 required by 1/16 in. (i.6 mm) without conection, pro-whereD/r> 150. maximum variation = dl92 d/80 vided that the undersize portio.n of the weldJoes_ not Intennediate stiffeners on one side only of web exceed 10% of the length of the_sveld. On web-to-flange where D/r< 100. maximum variation = d/100 welds on girders, nUndErrEn is pe mitted at the ends for where D/r> 100, maximum variation = d/67 a length equal to twice the width of the Dange.
?
No intermediate stiffeners 8.15.1.8 Complete joint perwtntion gt@m welds in maximum variation = D/150 buttjoints transverse to the direccion of c,n.pu:ed tensile (See Appendix G fortabulation.)
stress shall haw no piping porosity. Foi allother groove welds, piping porosity shall not exceed 3/8 in. (9.5 mm) 8.13.3 Web distortions of twice the allowable tolerances in any linear meh of weld and shall not exceed 3/4 in.
of 8.13.1.2 shall be satisfactory when occurring at the end 8.15.l.9 Visual. 005 rnmHeng6 0f weld.
('** " *"I '
'n.
of a girder which has been drilled. or subpunched and mspection of welds,m all steels may reamed; either during assembly or to a template for a field beg.,in immediately after the compl:ted welds have cooled bolted splice; provided. when the splice plates are bolted.
am ent temperstme. Aueptarce entena for Q t
the web assumes the proper dimensional tolerances.
A514 and A517 steels shall be based on visualinspection i
g l
8.13.4 If architectural considerations require tolerances performed not less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the more restrictive than described in 8.13.1. specific refer-weld.
g ence must be included in the bid documents.
8.15.2 Radiographic and Magnetic Mrticle laspection.
Welds that are subject to radiographic or magnetic particle l
testing in addition to visual inspection shallhave no cracks 8.14 TemporaryWelds.
and shall be unacceptable if the radiograph or magnetic particle inspection shows any of the types of discon-Temporary welds shall be subject to the same welding tinuities given in 8.15.2.1 or 8.15.2.2.
8.15.2.1 Individual discontinuities hrn,n; a greaten procedure requirements as final welds. They shall be re-i moved when required by the Engineer. When they are dimension of 3/32 in. (2.4 mm)or greatet.,if (1) The greatest dimension of a discentmuity is removed, the surface shall be made flush with the original larger than 2/3 of the effective throat. 2/3 the weld size, j
- surface, gr1},ja. (19.0 mm).
N (2) The discontinuity is closer than three times its l
greatest dimension to the end of a grcove weld subject I
8.15 Quality of Welds to primary tens;ie stress,s.
- 0) A group of such discontinuities is in line such that 8.15.1 Visual Inspection. All welds shall be visually,
(a) The sum of the greatest dimensions of all such inspected. A weld shall be acceptable by visual inspec-discontinuities is larger than the effectise throat or weld i
tion if it shows that size in any length of six times the effective throat or weld 8.15.1.1 The weld has no cracks.
size. When the length of the weld being examined is less 51.14.1.2 Thorowh fusion esists between adiacent than sit times the ' effective thmat or weld sire, the per-
i s
if f
3 cp 5
UNITED STATES OF AMERICA NUCLEAR RGULATORY COMMISSION ht BEFORE THE ATOMIC SAFETY AND LICENSING BO ARD In the Matter ofl
,' )
3 s
UNION ELECTRIC COMPAN1
)
Docket. No. STN 50-483-OL
)
f(Callaway Plant, Unit 1)
)
s
\\
l5 s
g' CERTIFICATE OF SERVICE
, I hereby certify that copels of Joint.Intervenor:s' Brief in ' Support of Joint
~
- Intervenors' Enceptions to the Partial Initial DecLslon of the Atomic Saf sty and Licensing Board have tieen served this 2nd day.of March,1983 by deposit..in the United States mall en 3he persons indicated below.
' Alan S. Rosenthal, Chairman Roy P. Lessy, Jr., Esq.
Atomic Safety an'd Licensing Appeal Office of the Executive Legal Director Board U.S. Nuclear ' Regulatory, Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i Washington, D.C.
20555 Gary J. Edles A. Scott Cauger, Esq.
Atomic Safety and Licensing Assistant General Counsel Appeal Board Panel Missouri Public Service Commission U.S. Nuclear Regulatory Commission P.O. Box 360 Washington, D.C.
20555 Jefferson City, MO 65102 Dr. Reginald L. Gotchy Atomic Safety and Licensing Appeal Board Panel N
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Strect, N.W.
Washington, D.C.
20036 Docketing and Service Section Office of the Secretery U.S. Nuclear Regulamy Commissior.
i Washington, D.C.
20555
(
e Ke'nneth M. Chackes N
CIIACKES AND IIOARE i, j
,