ML13303A480
| ML13303A480 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/20/1981 |
| From: | Chandler L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | FRIENDS OF THE EARTH |
| References | |
| ISSUANCES-OL, NUDOCS 8105270344 | |
| Download: ML13303A480 (10) | |
Text
5/
20/8 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY, )
Docket Nos.
)50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
NRC STAFF'S FURTHER RESPONSE TO INTERROGATORIES BY FRIENDS OF THE EARTH SERVED ON FEBRUARY 19 AND 20, 1981 In accordance with the provisions of 10 C.F.R. 2.720(h)(2)(ii) and 2.740b, and as directed by the Atomic Safety and Licensing Board in its Order (Rulings on Motions to Compel Answers to Interrogatories) dated May 13,
- 1981, the following is the Staff's further response to interrogatories propounded by Intervenors Friends of the Earth, et al.
(FOE) served on February 19 and 20, 1981, in particular, interrogatories nos. 45, 47, 3-5, 7, 12-17, 19, 21, 22 and 24 of the interrogatories dated February 19, 1981, and nos.
18, 19, 50 and 54 of the interrogatories dated February 20, 1981.1/
1/
Copies of the "Bolsa Island Report" referenced in interrogatories 28-32 of the February 19th interrogatories were sent to the Licensing Board, as directed, by cover letter dated May 13, 1981.
Dso SaQ5 2~
7
0 0
-2 FEBRUARY 19, 1981 INTERROGATORIES Interrogatory No. 45:
Explain and document exactly when, where, how, and who among the USGS scientists was asked to conduct research independently of the Edison Company's consultants prior to 1980, during the OL review for the SER.
Interrogatory No. 47:
Provide the names and qualifications of any USGS scientists who have been requested by the AEC or NRC Staff to review the Edison Company's Consultants' Reports regarding earthquake hazards at the SONGS 2 and 3 site since the AEC issued the SONGS 2 and 3 Construction Permit in 1973.
NRC Staff Response:
As stated in the "NRC STAFF RESPONSES TO INTERROGATORIES BY FRIENDS OF THE EARTH SERVED ON FEBRUARY 19, 1981 AND MOTION FOR A PROTECTIVE ORDER," served on April 1, 1981, specifically in response to interrogatory no. 47, "The NRC Staff has not and does not request review assistance of specific U.S. Geological Survey (USGS) scientists. The NRC Staff under a Memorandum of Understanding, a copy of which is enclosed, and under NRC-USGS Interagency agreement NRC-03-80-113, requests review assistance of the USGS through a USGS-NRC coordinator (a USGS employee) who selects the specific USGS reviewers."
Furthermore, the Staff has not "asked [USGS scientists] to conduct research independently.
. during the OL review for the SER."
The Staff was informed by the USGS, however, that it officially designated F. McKeown to review the A, B, C, D features, in 1974, and with respect to those aspects of the OL review on which the USGS was asked to provide its review, James F. Devine, Robert H. Morris, H. Gary Greene, Joseph S. Andrews and Robert Yerkes, were officially designated.
In the course of their efforts, discussion with numerous other USGS employees took place.
-3 Statements of Qualifications for the above-named individuals have been requested and will be promptly transmitted upon their receipt.
With respect to interrogatories nos. 3-5, 7, 12-17, 19, 21, 22 and 24, the Staff was directed to provide an identification of the witnesses the Staff expects to call and the anticipated substance of that particular witness' testimony. Accordingly only the substantive question posed by the interrogatory is restated followed by the identification of the witness(es) and the substance of anticipated testimony.
Interrogatory No. 3:
Do you contend that the Cristianitos Fault does not extend southward for a distance greater than 6000 feet offshore from its coastal expression?
NRC Staff Response:
Witnesses James Devine and H. Gary Greene, both of the USGS, and Michael Kennedy of the California Division of Mines and Geology.
Testimony The substance of their testimony may be found in the Staff's Safety Evaluation Report (SER, NUREG-0712)
Sections 2.5.1.12 and Appendices F and G thereof (pp. G-3 and G-4 and Addendum To:
Review of Offshore Seismic Reflection Profiles in the vicinity of the Chrisianitos Fault, San Onofre, California).
Interrogatory No. 4:
What do you contend is the minimum age of last displacement on the Cristianitos Fault?
-4 NRC Staff Response:
Witnesses A.T. Cardone (NRC Staff) and James Devine (USGS)
Testimony The substance of their testimony may be found in SER Sections 2.5.1.12(5) and 2.5.1.12(6) and Appendix G (p. G-4) thereof.
Interrogatory No. 5:
Do you contend that the Cristianitos Fault is not a "capable fault."
NRC Staff Response:
Witness A. T. Cardone Testimony The substance of Mr. Cardone's testimony may be found in SER section 2.5.1.12(6).
Interrogatory No. 7:
What do you contend is the maximum magnitude earthquake that could occur on the OZD?
NRC Staff Response:
Witnesses Leon Reiter (NRC Staff) and D. B. Slemmons (consultant)
Testimony The substance of their testimony may be found in those portions of the SER identified in the NRC Staff's Response to this interrogatory dated April 1, 1981.
Interrogatory No. 12:
Is it your contention that the postulated zone of deformation which extends from the coastal exposure of the Cristianitos Fault toward the OZD dies out before reaching the OZD?
-5 Interrogatory No. 13:
Do you contend that there is not a structural relationship between the Cristianitos Fault and the OZD?
NRC Staff Response:
Witnesses H. Gary Greene (USGS) and Michael Kennedy (CDMG)
Testimony The substance of their testimony may be found in Appendices F and G of the SER (pp. G-3 and G-4 and Addendum To:
Review of Offshore Seismic Reflection Profiles int he vicinity of the Christianitos Fault, San Onofre, California).
Interrogatory No. 14:
Do you contend that the OZD does not extend south of the Rose Canyon Fault Zone?
Interrogatory No. 15:
Do you contend that there is no structural relationship between the Rose Canyon Fault Zone and the San Miguel Fault in Baja, California?
Interrogatory No. 16:
Do you contend that there is not a structural relationship between the Rose Canyon Fault Zone and the San Miguel Fault in Baja, California?
Interrogatory No. 17:
Do you contend that there is not a relationship between the OZD and and San Andreas.
NRC Staff Response:
Witnesses A. T. Cardone and D. B. Slemmons Testimony The substance of their testimony may be found in section 2.5.1.11 of the SER and Appendix E (p. E-6) thereof. See also NRC Staff Response to interrogatory no. 17 dated April 1, 1981.
-6 Interrogatory No. 18:
Do you contend that.67 g is the proper design acceleration value for SONGS 2 and 3?
[Provided for context.]
Interrogatory No. 19:
If your answer to Interrogatory No. 18 is yes:
NRC Staff Response:
Witnesses Leon Reiter and James Devine Testimony The substance of their testimony may be found in section 2.5.2 of the SER and Appendix G thereof (pp.
(G-4 and G-5).
Interrogatory No. 21:
Have you contracted with or contacted any consultants to analyze any aspect of the Imperial Valley earthquake of October 15, 1979?
NRC Staff Response:
Witness Leon Reiter Testimony The substance of Dr. Reiter's testimony may be found in section 2.5.2.4.3 of the SER.
Interrogatory No. 22:
Do you contend that the Cristianitos Fault is only about 32 kilometers (20 miles) in length?
NRC Staff Response:
Witness A. T. Cardone Testimony See NRC Staff Response to interrogatory no. 22 dated April 1, 1981.
Interrogatory No. 24:
Do you contend that the Cristianitos Zone of Deformation's structural relationship with the OZD is not the controlling geologic structure for the seismic design of SONGS 2 and 3?
-7 NRC Staff Response:
Witnesses Leon Reiter and A. T. Cardone Testimony The substance of their testimony may be found in section 2.5.1.12 of the SER.
FEBRUARY 20, 1981 INTERROGATORIES Interrogatory No. 18:
Have you ever asked the Applicants to do research on the Cristianitos Fault Zone which compares with the techniques used by the oil companies when they search for gas and oil onshore? If not, why not?
NRC Staff Response:
The Applicants voluntarily employed or were requested to employ the following techniques on the Cristianitos Fault Zone.
- 1.
Trench along the fault and provide logs of the trenches.
- 2. Analyze existing seismic reflection profiles in the vicinity of the fault and to perform additional profiling offshore.
- 3. Develop geologic and structural maps from existing oil well drill holes and seismic reflection profiles.
- 4. Analyze Landsat and other imagery and investigate the observed linears for new faults.
- 5. Employ age-dating techniques to date the strata overlying the fault.
- 6. Perform geomorphic analyses and nap terraces to determine the deformational history of the area around the fault.
- 7. Analyze aeromagnetic and gravity data to interpret subsurface structure.
-8 Although the Staff does not know precisely all of the research techniques employed by oil companies, we would expect that these techniques would be employed by them.
Interrogatory No. 19:
Compare the amount of trenching done on the Cristianitos Fault Zone done by SONGS Applicants to the amount of trenching that has been done along the Verona Fault by the Applicants at the Vallecitos Nuclear Center in Northern California since a new fault was discovered near the-reactor there by the USGS in September 1977?
NRC Staff Response:
Approximately 13,000 feet of trenching was done at the G.E. Test Reactor site compared to approximately 1800 feet as part of the Cristianitos fault zone investigation. A total of 2900 feet of trenching was done at the SONGS site. The principal reason for the difference in the amount of trenching is that the faulting at the GETR site is not exposed in outcrop and has not been mapped prior to the geologic investigations, consequently much exploratory trenching was performed, whereas the Cristianitos fault is exposed in outcrop and has been mapped along much of its length. Trenches at the GETR site were made by the licensee to verify the existence of postulated faults that were nowhere exposed. Discovery of 3 thrust faults in trenches at the base of the Vallecitos Hills resulted in a whole series of additional trenches to determine the length and location of the faults.
Further trenching was done in the Hills to investigate a postulated landslide, and also to investigate air photo lineaments on the site.
-9 At SONGS 2 & 3 trenching was done along the sea cliff to investigate in detail the Cristianitos Fault seen in outcrop.
Also the mapped fault was trenched inland at Plano Trabuco to determine the age of the last movement on the fault, at the Mission Viejo location of the lime-filled crack reported by Donald L. Fife, at the Southern California Edison Company Viejo Substation, and at Arroyo Trabuco.
The plant site excavations were trenched to determine the origin, age and extent of the A, B, C, D features which were exposed in the excavations.
The "E" fault, the Trail 6 landslide, and Target Canyon faults were also investigated by means of trenching.
Interrogatory No.
50:
Are the SONGS 2 and 3 design criteria of.67g horizontal ground acceleration and.44g vertical accelerations based on the assumption that verticals would never exceed the horizontal accelerations?
Explain your answer.
NRC Staff Response:
No.
The general Staff position with respect to the relationship between vertical and horizontal design response spectra has been based upon statistical studies as discussed in the attached letter.
Interrogatory No. 54:
Are the Staff or Applicant using the concept of "effective" accelerations in analyzing the seismic design of SONGS 2 and 3?
Are there any plans to use "effective" accelerations at SONGS as was done at Diablo Canyon?
Explain how this concept is being used and to what extent in relationship to peak ground accelerations
'(instrumental free field).
NRC Staff Response:
The Staff in its OL review has not and does not presently intend to use the concept of effective acceleration in its review of the seismic adequacy of SONGS 2 & 3, as it was used by Dr. Newmark in the review of the Diablo Canyon facility.
01 10 The term "effective acceleration" has been used in different contexts by different engineers and scientists.
Broadly, "effective" can be interpreted as meaning of "engineering significance."
In the context of Diablo Canyon (SER for Diablo Canyon Supplement #5, September 10, 1976)
Dr. Nathan Newmark (NRC consultant) defined effective acceleration as being:
"that value which corresponds to the acceleration level which is used as a basis for drawing the spectrum."
In the Staff's evaluation of the SONGS 2 & 3 seismic design during the OL review, the concept of using an acceleration value as the basis for drawing a response spectrum did not play any significant role.
Primary emphasis was placed upon deriving the response spectrum values directly utilizing empirical techniques, theoretical modelling and recent recordings of strong motion data (SER, 2.5.2.4 and 2.5.2.4.1-6).
Peak acceleration can be shown to be equivalent to the high-frequency assymptote (zero period) of the response spectrum.
Ratios of peak accelerations and a frequency dependent weighing factor were used by the applicant to scale the empirically derived response spectrum from Ms = 6.5 to Ms = 7.0.
Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel Dated at Bethesda, Maryland this 20th day of May, 1981