ML20078P713
| ML20078P713 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/04/1983 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20078P720 | List: |
| References | |
| ALAB-740, ISSUANCES-OL, NUDOCS 8311080201 | |
| Download: ML20078P713 (5) | |
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November 4, 1983 DOCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 13 NOV -7 A10:20 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
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E -E _O Sir,
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In the Matter of
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UNION ELECTRIC COMPANY
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Docket No. STN 50-483 OL
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(Callaway Plant, Unit 1)
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APPLICANT'S RESPONSE TO THE. APPEAL BOARD'S MEMORANDUM AND ORDER OF OCTOBER 20, 1983 On September 23, 1983, Joint Intervenors filed a Petition for Reconsideration of ALAB-740, 18 N.R.C.
(Sept. 14, 1983),
which affirmed LBP-82-109, 16 N.R.C.
1829 (1982), the Licensing Board's partial initial decision finding in Applicant's favor as to allegations of construction and quality assurance deficiencies at the Callaway Plant.
Responses in opposition were filed on October 12, 1983 by Applicant and the NRC Staff.
On October 20, 1983, the Appeal Board issued a Memorandum and Order in which it directed Applicant and the NRC Staff to file additional information and views, including any affidavits that may be necessary, with respect to one matter raised in the petition.
The inquiry aims specifically at Observation No. 4-1 in the NRC Staff'.s Integrated Design Inspection Program (IDIP) report.-1/ The Staff indicates, in the IDIP report, that Bechtel's civil-structural engineering group had recalculated the original design floor response spectra based upon as-built conditions, 1/
The IDIP report represents the purported basis for the petition.
8311080201 831104 PDR ADOCK 05000483 G
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, o and that the revised spectra, which in some. cases exceeded the original design spectra, had not been formally transmitted to other engineering disciplines.
In its October 20 Memorandum and Order, the Appeal Board restates Joint Intervenors' assertion that the loads imposed by the floors of the auxiliary building, which in some cases are supported by embedded plates installed before the discovery of defects, may exceed design loads.
The Board observes that, based upon the materials before it, there appears to have been no definitive assessment regarding the safety significance, if any, of the differences between the original and revised spectra.
Consequently, the Board requests addi-tional information ".
. with respect to what has been done since the December, 1982 I&E inspection with respect to deter-mining if the loads imposed by the revised spectra exceed the design loads, and the safety implications, if any."
Memorandum and Order at 3.
More pointedly, the Board asked how the new seismic load would affect the parties' conclusions on the manually welded embeds if the record is based upon the original spectra.
Id. at n.4.
Attached hereto is the Affidavit of Eugene W. Thomas, prepared in response to this Appeal Board inquiry.
In his affidavit, Mr. Thomas provides a technical explanation of floor response spectra and their relationship to embedded plates, reports on the evolution of floor response spectra for the SNUPPS project, and explains the current status and
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I b conclusions of the assessments of floor response spectra as they relate to the safety of the manually-welded embedded plates at issue in this proceeding.
While the entire assessment program is not yet completed, the completed reviews encompass the loads on all 225 safety-related, manually-welded embedded plates installed in the Callaway Plant prior to June 7, 1977.
These reviews constitute a definitive assessment for these plates of the safety significance of the difference between the floor response spectra used in the original design and the revised spectra.
The assessment shows that there are no load increases on any of these plates as a result of the as-built floor response spectrum curves because, among other reasons, the maximum design loads on these plates are controlled by a loading combination which does not include seismic loads.
Consequently, the revised floor response spectra have no safety significance for, and do not alter Applicant's conclusions with respect to, the acceptability of the manually-welded embeds.
Thomas Affidavit at is 11, 12.
The subject observation in the IDIP report therefore could not materially affect the outcome reached by the Board in ALAB-740 and does not carry Joint Intervenors' burden of support for their petition.
Respectfully submitted, i
SHAW, PITTMAN, POTTS & TROWBRIDGE CA Thomas A.
Baxter, F.C.
Counsel for Applicant l
1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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UNION ELECTRIC COMPANY
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Docket No. STN 50-483 OL
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(Callaway Plant, Unit 1)
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CERTIFICATE OF SERVICE
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I hereby certify that copies of " Applicant's Response to the Appeal Board's Memorandum and Order of October 20, 1983" and " Affidavit of Eugene W. Thomas" were served this 4th day of November, 1983, by deposit in.the UjS. mail, first class, postage prepaid, upon the following:
Alan S. Rosenthal, Esquire Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Gary J. Edles, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Reginald L. Gotchy Atomic Safety and Licensing Appeal Board j
U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 James P. Gleason, Esquire
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Chairman Atomic Safety and Licensing Board 513.Gilmoure Drive Silver Spring, Maryland 20901 A
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i 6 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Robert G. Perlis, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Joseph E. Birk, Esquire Assistant to the General Counsel Union Electric Company P.O. Box 149 St. Louis, Missouri 63166 A. Scott Cauger, Esquire Assistant General Counsel Missouri Public Service Commission P.O. Box 360 Jefferson City, Missouri 65102 Kenneth M. Chackes, Esquire Chackes and Hoare 314 N. Broadway St. Louis, Missouri 63102 Mr. John G. Reed r
Route 1 Kingdom City, Missouri 65262 l
l Eric A. Eisen, Esquire Birch, Horton, Bittner & Monroe ll40' Connecticut Avenue, N.W.,
- 1100 Washington, D.C.
20036 2
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A, Thomas A. Baxtbr l
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