ML19353A227
| ML19353A227 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/02/1981 |
| From: | Jordan W, Weiss E NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SHELDON, HARMON & WEISS |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| NUDOCS 8101070513 | |
| Download: ML19353A227 (11) | |
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UNITED STATES OF A!1ERIC3.
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l BEFORE THf: ATOMIC SAFETY AND LICCNS I:;C APPEAL HO A (It f
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In the Mat.ter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443 NEW HAMPSHIRE, et al.
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50-444
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(Scabrook Station, Units 1 and 2)
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NECNP INTERROGATORIUS TO APPLICANT PUBLIC SPRVICE CO. OP : ':W HAMPSIIIRL Pursuant to 10 CFR 2.740b, NECNP poses the following interrogatories to be answered under oath by Applicant Public Service Co. of New Hampshire, its employees or representatives.
For each interrogatory, please identify the persoa or persons who prepared the response.
Reference to the Applicant in these interrogatories includes reference to any experts or others with whom the Applicant has con-sulted or on whom it relies for information on t.he subject matter of the particular interrogatory.
1.
Pleace identify everyone whct the Applicant expects to call as a witness in the remanded
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phase of the Seabrook proceed.tngs on setsmic issues.
2.
With respect to each witness identified above, please:
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a
. a.
Describe the extent of the witness' pre-vious involvement in the Seabrook prouced-ings, if any.
This description should include not only whether the witnesu has previously testified, but also whether the witness has advised the Applicant on seismic issues in the past and the sub-stance of that advice.
b.
Identify all NRC hearings, trials, and other adjudications in which the witness has provided testimony, including the date and location of the testinony, a brief description of the substance of the testimony, and the identity and inter-est of the party on whose behalf the testimony was provided, c.
Identify and provide copics of any analyses
'that have been performed by the witness concerning Dr. Chinnery's methodology for determining earthquake intensity and pro-bability in general and for the Seabrook site in particular.
d.
Identify and provide copies of any analyses that have been performed by the witness concerning Dr. Trifunac's approach to determining vibratory ground motion or his conclusions concerning ground acceleration at the Seabrook site.
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e.
If the witness was one of the experts solicited by the NRC for its Seismic Ilazard Analysis, NUREG/CR-582, identify the witness' responses in that document.
3.
Is it the Applicant's position that an earthquake of Intensity IX on the Modified Mercalli scale is impossible at the Seabrook site?
4.
Is it the Applicant's position that an earthquake of Intensity IX is impossible in the tectonic province containing the Seabrook site?
5.
If the answer to either of the previous questions is that an Intensity IX carthquake is not impossible, a.
What does the Applicant believe to be the probability of occurrence of such an earthquake?
c.
What is the factual basis and rationale for that probability judgment?
c.
What does the Applicant believe to be the earthquake of greatest intensity that can occur at the site or in the tectonic pro-l vince?
l d.
Please provide a detailed justification for the choice of maximum intensity earth-quake.
6.
If the answer to either or both of Questions 3 and 4 is that an Intensity IX carthquake is impossible, L
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pm please provide a detailed justification for that
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7.
Please identify and provide copies of all studies or analyses that give rise to or support the conclusions H:
and justification provided in response to Questions
{U 3-6.
"if 8.
Please describe what the Applicant believes to be
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the tectonic province or seismic area in which b eT the Seabrook site is located.
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Please justify thir choice in detail.
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so doing, describe, explain the use of, and justify the Applicant's conclusions concerning, at a minimum, the following:
9" 1.
All tectonic structures and other file tectonic or seismic features, inclu-pig gr f.
ding all identified fault lines, that D
the Applicant considered in reaching k
its conclusions.
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Any new information concerning tec-3 tonic or seismic features or activity in the Northeastern United States
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that has become known to the Appli-(g rtf:r cant since its original testimony on N
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3.
All historical earthquakes considered g
by the Applicant, including their intensity on the Modified Mercalli f
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The " Boston-Ottowa seismic trend."
b.
Please explain the relevance of thic choice of tecconic province to the deterraination of the design basis earthquake, under the methodology propounded by the Applicant.
c.
Please identify and describe the sources from which you have compiled a historical record of earthquakes in the tectonic pro-vince or seismic area described in response to this question.
In particular, how complete is 'he record as a function of time, location within the province or area, and intensity.
9.
Has the Applicant or any of its witnesses examined other possible tectonic province choices for tne area?
a.
If so, please describe each one and explain in detail why it was rejected in favor of that described in response to Question 8.
10.
Is it the Applicant's position that the location of the Seabrook site within a particular tectonic province or other seismic area determines the maximum intensity carthquake that could affect the Seabrook site?
11.
Does the Applicant contend that there is not a linear relationship between earthquake intensity l
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and probability of occurrence, as posited by Dr. Chinnery?
a.
If so, please provide the basis for that conclusion, including any empirical data that the Applicant contends refute Dr.
Chinnery's linear hypothesis and other curves that the Applicant believes: fit the available data.
b.
If the Applicant accepts Dr. Chinnery's linear hypothesis to some extent, but not in its entirety, please explain where the Applicant disagrees with Dr.
Chinnery's hypothesis, data, methodology, or conclusions.
12.
Has the Applicant or any of its witnesses applied the Chinnery hypothesis and methodology to the Seabrook site using as a local data base tectonic provinces or seismic areas that differ from the
" Boston-New Hampshire area" used by Dr. Chinnery in his Statement on behalf of NECNP during the original Licensing Board hearings?
a.
If so, what conclusions were reached?
b.
In particular, to what extent, if any, did altering the size of the seismic area data base alter the slope of the probability-intensity curve?
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c.
Please provide a detailed justification for the choice of the seismic areas from which the local data base was drawn.
d.
Please provide copics of all work papers involved in this analysis and of any recult-ing reports or studies.
13.
Please name one region in the world where it has been clearly and unequivocally demonstrated that an upper bound to earthquake size exists.
What is the upper bound?
How does the geological structure of this region compare with the New England area?
Please give references.
14.
Maximum possible carthquakes were given by each of the experts in NUREG/CR-1582 (Seismic Hazard Analysis Solicitation of Exp'rt Opinion, TERA e
Corporation) for regions of New England, a.
Where only magnitude is quoted, please
-state what the Applicant believes to be the maximum epicentral intensity of an earthquake of that magnitude.
Please describe in detail the method and calcu-lations used to convert from magnitude to intensity.
b.
For each maximum possible earthquake stated by each expert for regions of New England, please state whether the Applicant agrees or disagrees with the selection and expl'in why.
_a_
15.
What, in your opinion, i.s the maxinium epicentral intensity of the largest earthquake that will ever occur within the province or area described in response to Question 8?
a.
Please justify your answer in detail, includ-ing reference to all relevant tectonic structures, tectonic or seismic features, and historical earthquakes.
b.
Explain why you are exactly 100% confident that your ' answer is correct.
If you are not exactly 100% confident, state your degree of confidence, and explain how it was estimated.
16.
Is it the Applicant's position that 10 CFR, Part 100, Appendix A, requires that the SSE be the largest earthquake that can be predicted with 100% confidence ever to occur within the tectonic province containing the site?
If not, what con-fidence level is acceptable for this selection, and how did you arrive at this level?
17.
The Applicant's proposed SSE for the Seabrook site has a maximum epicentral intensity of VIII.
On what ground conditions is this defined?
What is the magnitude of such an earthquake?
18.
What is the total range of ground accelerations that have been observed from carthquakes of the magnitude quoted in Question 17.
How many of
_9 these were observed on bedrock?
Please give references for these bedrock data.
19.
Can the bedrock acceleration data in Question 18 he represented as a Gaussian distribution?
What are the mean and standard deviation of these data?
What is the probability that an earthquake of maximum epicentral intensity VIII will generate a bedrock acceleration in excess of 0.25g?
Please give details of the probability calculation.
For The New England Coalition on Nuclear Pollution
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Y Ellynd. Weiss
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William S., Jordan, III Ilarmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 January 2, 1981
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UNITED STATES OF 73: ERICA NUCLEAR REG'R ATORY COM*:ISSIO:2 BEFORE THE ATOMIC SAFETY AND LICE::SI:;C APPEiL BOARD In the Matter of
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PUBLIC SERVICE COMPANY OF h
Docket Mos. 50-443 NEW HAMPSHIRE, et al.
)
50-444
)
(Seabrook Station, Units 1
)
and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the "NECNP Interroga-tories to Applicant Public Service Co. of New Hampshire, Notice of Taking Depositions and NECNP Interrorgatories to the NRC Staff," have been served postage pre-paid this 2nd day of January, 1981, to the following parties:
Alan S.
Rosenthal, Chairman Dr. John H.
Buck Atomic Safety & Licensing Atomic Safety a Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Frank Wright, Esquire Assistant Attorney General Assistant Attorney General Environmental Protection Division Environmental Protection Office of the Attorney General Division State House Annex, Room 208 Office of the Attorney General Concord, New Hampshire 03301 One Ashburton Place Boston, Massachusetts 02108 Thomas G.
- Dignan, Jr., Esqbire Ropes & Gray Robert A.
Backus, Esquire 225 Franklin Street O'Neill, Backus, Spielman, E, Little Boston, Massachusetts 02210 116 Lowell Street Manchester, New Hampshire 03101 Docketing and Service Section U.S.
Nuclear Regulatory Commission Roy L.ssy, Esquire Wachington, D.C.
2055_r Olfice of Executive Legal Direccor U.S.
- uclear Regulatory Cominion Washington, D.C.
20555
Lld L
-- 2 Dr.
W.
P.eed Johnson D.
Pierre G.
- Cameron, Jr.,
1:sg.
Atoalc Safety & Licensinq General Counsel App.'al Board Pulali c Set t'i ce Company of U.S.
Nuclear Regulatory Commi.ssion New Hangshi.re Washington, D.C.
20555 10 0 0 1:1:.~. Strect l'.anche c t a r, ';H 03105 i
William Sgti[hn, ~111O
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