ML20082A663

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

ML20082A663
Person / Time
Site:	Callaway
Issue date:	11/15/1983
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - DIABLO CANYON
To:
References
ISSUANCES-OL, NUDOCS 8311180213
Download: ML20082A663 (3)

Text

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DOMETEP UNITED STATES OF AMERICA 'WC NUCLEAR REGULATORY COMMISSION

'83 NOV 17 All:35 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

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SRAfiCh 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) )

JOINT INTERVENORS' COMMENTS REGARDING

' RESPONSES TO APPEAL BOARD'S MEMORANDUM AND ORDER OF OCTOBER 20, 1983 The responses of the applicant and NRC Staff to the Appeal Board's Memorandum and Order of October 20, 1983 contain nothing more than a description of activities and a conclusion of no safety significance. None of the analyses. and assessments are provided from which the Appeal Board or any other qualified engineer can determine whether the conclusion is correct.

The Appeal Board ordered the applicant and staff to provide:

sufficient additional information and vi;:ws . . . to permit us to resolve this issue. Memorandum and- Order of October 20, 1983,

p. 3.

The information submitted, being only a description of what was done, would permit the Appeal Board to resolve the issue only if it is willing to delegate its responsibility.

to Bechtel (as the staff is apparently willing to do) to tell the Board what it did and.

that the result is satisfactory.1 The Appeal Board should require sufficient information and data to eJ1ow it, and if necessary with the aid of an independent engineer, to make its own judgment on IApplicant's submission indicates that the safety of 225 safety-related manually welded embedded plates has been determine, while the staff claims to be satisfied as to the safety of 259 plates. See Thomas Affidavit 111; Allison Affidavit 19.

8311100213 831115 PDR ADOCK 05000483 PDR 0 1

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this issue. Joint Intervenors believe the following information or data would be useful l In that regard: 1

1. What is the combination of loading that results in the maximum load on the plates? i

' 2. In Bechtel's analysis were some or all plates considered defective? l

3. What is the permanent and short-term loading (seismic) capacity of the plates?

4. What is the relationship between the spectra developed and the dominant frequencies of the expected earthquake?

5. Has any allowance be en made for fatigue effects from earthquake vibrations?

6. What are the maxin um forces on the plates?

7. What are the resistence capabilities of the plates?

Therefore, Joint Intervenors request that the Appeal Board grant its Petition, appoint an independent expert, and order applicant to provide that expert with such information as is necessary to determine the safety of the manuaby welded embedded plates.

Respectfully submitted, CHACKES AND HOARE l

A Professional Corporation Wb Kenheth M. Chackes h Af Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missouri 63102 314/241-7961 e

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O CC'aE TLt UNITED STATES OF AMERICA L" #

NUCLEAR REGULATORY COMMISSION 13 NOV 17 All :35 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD c n c Or 5: G E , '

000/iEiihG S SEid-M In the Matter of )

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

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(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Joint Intervenors' Comments Regarding Responses to Appeal Board's Memorandum and Order of October 20, 1983 were served on November 15, 1983 by deposit in the United States mail on the persons indicated below.

Alan S. Rosenthal, Chairman Robert Perlis, Esq.

Atomic Safety and Licensing Appeal Office of the Executive Legal Director Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Gary J. Edles James P. Gleason, Esquire Atomic Safety and Licensing Chairman Appeal Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 513 Gilmoure Drive Washington, D.C. 20555 Silver Spring, Maryland 20901 Dr. Reginald L. Gotchy Mr. Glenn O. Bright Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Thomas A. Baxter, Esq. Dr. Jerry R. Kline Shaw, Pittman, Potts & Trowbridge Atomic Safety and Licensing Board 1800 M Street, N.W. U.S. Nuclcar Regulatory Commission Washington, D.C. 20036 Wash.agton, D.C. 20555 Docketing and Service Section Office of the Secretary Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

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Kenneth M. Chackes CHACKES AND HOARE

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