ML20197H541
| ML20197H541 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/12/1984 |
| From: | Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8406180439 | |
| Download: ML20197H541 (2) | |
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L UNITED STATES OF AMERICA QU NUCLEAR BEGULATORY COMMISSION f1 1
'84 Jtauny gqJ.984 BEFORE THE A'N)MIC SAFETY AND LICENSING RdARDy7 j Glenn O. Bright Baldds '
Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
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Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
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Harris Nuclear Power Plant, ar i
ASLBP No. 82-h68-01
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Joint Intervenors' Response to Motions for Summary Disposition on Joint Contention 7 (Steam Generators )
Af ter consultation with our experts, Joint Intervenors have decided that we lack sufficient resources to document a response to the Applicants Motion (and Staff response which is effectively the same motion),
This does not mean we believe the statements or conclusions of Applicants and Staff are necessarily true.
For example, the omission of actual data from page B-58 (bottom line) of NUREG-101h (Staff Exhibit D to " response") makes it impossible to analyze the conclusions of Applicants and Staff, other than to 4
take their word for it, re flow-induced vibrations.
The lack of such information is a clear handicap to us and our experts (cf. Staff y
affidavit at 3-5, paragraphs 8,10,12, 13) in refuting such claims.
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We stress that it is time and resource constraints that lead to 0
i our response being so limited as this is.
We do not agree with b
the analysis put forward by Applicants, particularly not its strong j8 language suggesting there cannot be problems in th ens id ntified.
$a.O For Joint Intervenors
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We is Eddleman %
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Extension of time for filing approved by Judge Kelley & Applicants. Spop i
JOINT CONTENTION 7 List of facts in dispute where Joint Intervenors have laid out the problem with the " fact" (i.e. missing data) 1.
That Westinghouse et al's vibration analysis for Model D-4 steam generators is accurate in view of test result data.
2.
That the conclusions alleged to be drawn from such tests of tube vibration are accurate.
Joint Intervenors respectfully point out ddat no other facts are listed because we don't have (and our experts lack) time to produce the documentation therefor, or rescurces which would give us or them more time.
We do dispute the motion in many respects, especially in its overdrawn almost absolutist, conclusions.
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