ML20082B464

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

ML20082B464
Person / Time
Site:	Callaway
Issue date:	11/15/1983
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY
To:
References
ISSUANCES-OL, NUDOCS 8311210199
Download: ML20082B464 (3)

Text

W DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION N NDY 18 N058 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD UFICE CF SECRETAN

• DCCKETING 4 SEPvic; In the Matter of ) GRANCH

)

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

)

(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 views . . . 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' =

l that the result is satisfactory.1 The Appeal Board should require suffielent information and data to allow it, and if necessary with the aid of an independent engineer, to make its own judgment on 1 Applicant'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, 8311210199 831115 gDRADOCK05000pB 9 @$g3

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

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

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

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 been made for fatigue effects from earthquake vibrations?

6. What are the maximum 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 en independent expert, and order applicant to provide that expert with such information as is necessary to determine the safety of the manually welded embedded plates.

Respectfully submitted, CHACKES AND HOARE A Professional Corporation by -

Kenneth M. Chackes Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missouri 83102 314/241-7961

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, [

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

)

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

)

(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Joint Intervenors' Comments Regarding Responses I 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 I Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Con' mission 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. Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 Docketing and Service Section Office of the Secretary Office of t' ne 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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