ML20003B253

Responses to New England Coalition on Nuclear Pollution Interrogatories Re Seismic Issues.Affidavits & Certificate of Svc Encl

ML20003B253
Person / Time
Site:	Seabrook
Issue date:	02/09/1981
From:	Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	NEW ENGLAND COALITION ON NUCLEAR POLLUTION
References
NUDOCS 8102100554
Download: ML20003B253 (26)

Text

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.+ :.. - .d ~. .c, -l.-f. BEFORE THE ATOMIC SAFETY AND' LICENSING APPEAL BOARD M, ...;7 ',. e 9,:...,, %..r s. y : @b i. n .M +;{&.. .2.:.

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. i.,.e.!.:.. o ^.5 v 3 1. g..: .s...>.y.g.:..Q;: 4.. Q s:: g ... s.w;.. s' i "2"'/dR SPONSETF THE NRC STAFF T0'NECNP'S INTERR0GATORIES. . ib E 3*:- "$:- ~: y;,.;,s. v.., ;.'. d.;u& .' L y; c.*: ::i':.:s ': :.:'. q:.;. 2'. z .~ The NR. C~ Staff herewith flies si.,ts.. resp.onses to "NECNP Interrogatories tokhe NRC Staff" in.accordance withb,s.(1)):10'.C.F.R. 55 2.720 and 2.740, " (. .r..- N::i',4.f....: . -----..-ind-{ tiMthe4etter-fm 4he 4mders,tgnedjStaff <ounsel.to.Willian s.. Jordan....-.. 4- ..,;. w.. <. ~; w r.s.o. g.vi. ..a. m of ' January',.15.; 19813.Y..1,.j ',. ;.., : _,.:p ,7

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ngP.(L8til.E M.A*5 iTN!_lt.M.EF 1MLRM4A10.eg}, Q.1. please identify everyone whom the NRC Staff espects to call as a witness in the remanded phase of the Seabrook proceedings on seismic issues. j A.I. Based upon the issues prsently delineated, the Staff espects to call Dr. toon helter. Dr. Robert E. Ja kson, and Mr. James p. Knight. If the delineation of issues were to change, or if the flied testimony of Drs. Chtnnery. Trifunac or Holt, were to go into areas beyond the delineated issues, and such testimony were permitted, the Staff, at that time, would have u reevaluate the witnesses it expects to call. l Q.2. With respect to ear.h witness identifled above, please: a. Describe the eatent of the witness' previous involvement in l the Seabrook proceedings. If any. Thit description should i include not only whether the witness has previously testified, but also teether the witness has advised the NRC Staff on seismic issues in the past and the substance 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 testimony, a brief descritplon of the substance of the testimony, and the identity and interests of the party on whose behalf the testimony was provided. c. Identify and provide copies of any analyses that have been pirformed by. the witness concerning Dr. thinnery's methodology for determining earthqua'ke intensity and probability in general and for the Seabrook site in particular. d. Identify ar.1 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. i O e -'---s em -~.

. A.2.a. Dr. Leon Reiter's involvement in the Seabrook proceedings has been limited to the co-preparation of an affidavit " Affidavit of Richard B. ItcMullen and Leon Reiter December 5,1979, and an appearance before the Comission on May 29, 1980, during the public meeting with respect to its review of Seabrook decision. Dr. Robert E. Jackson's and Mr. James P. Knight's involvement in the Seabrook proceedings has been limited to e participation in the May 29, 1980, public meeting before the Comission during its review of the Seabrook decision. i All three individuals identified are members of the NRC Staff and are i routinely involved in discussions on seismic issues for many nuclear facilities. A.2.b. Dr. Leon Reiter_ l. Black Fox - ASLB Construction Permit Proceedings Tulsa, ~ Oklahoma, May 24, 1977. 2. Lacrosse - ASLB Show Cause Proceedings, Lacrosse, Wisconsin, December 16, 1980. In ooth proccebngs, Dr. Reiter testified on seismological aspects of the site review. Dr. Robert E. Jackson 1. Byron 1 & 2 - ASLB Construction Permit Proceedings, February 11, 1975, Bethesda, Maryland. 2. Pilgrim 2 - ASLB Construction Permit Proceedir.gs, March 7, 1978, Boston, Massachusetts. In bMh proceedings, Dr. Jackson testified on the geological aspects of the site review. z u-

.f, . bT 4 Mr. James P. Knight -E !b 1. Diablo Canyon 1 & 2. ASLB Operating License Proceeding. l3.d December 17, 1979 San Luis Obispo California, ASLAB [ Operating License Proceeding, November 10, 1980, San Luis j n .. i Obispo, California - Testified on the seismic design process and the seismic capability of the El Centro j l Steam Plant.' 2. Hartsville 1,. 2, 3, 4 - ASLB Construction. Permit Proceedings, _. [ If February 23, 1977 Nashville Tennessee - Testified on 1 the seismic capability of turbine building and systems. 4. 2 ......._......... _-.. 3. Beaver. Valley.1. & 2.s ASLB. June. 21., 1976.-- Testifted on. asyninetric LOCA loads, fracture toughness cf steam generater 4 iI and steam generator corrosion. n 4. North. Anna 14 2, ASLB,. March 24,1974 .. Testified on ~j asymmetric LOCA loads, fracture toughness of steam

i generator and steam generator c'orrosion.

~ 5. Prairie-Island 1-4 2 - ASLB - Testified.on. pipe whip. 4 ~ protection; ASLAB, January 7, 1976 - 9.itified on steam generator tube corrosion. 6. McGuire -1 & 2 - ASLAB.-June-27,1972 - Testified on. reactor vessel stud bolts. 7. Fort Calhoun 1 - ASLAB, April 9,1969 - Testifled on pipe J i whip protection.

g Dr. Reiter. Dr. Jackson and Mr. Knight all testified on behalf of the NRC Staff.

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x i A.2.c. The only analysis perfomed by the witnesses concerning S. Dr. Chinnery's methodo1Dgy for detennining earthquake intensity and probability in general and for the Seabrook site in particular is contained "(; in the" Affidavit of Richard B. McMullen and Leon Reiter." December 5,1979. which' affidavit was previously provided to NECNP. j A.2.d. The witnesses have not perfonned any analysis concerning Dr. Trifunac's approach to detennining vibratory ground motion or his past ] it: conclusions concerning g'roVnd~ acceleration at the Seabrook site.

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The witnesses were not any of the experts solicited by the } TERA Corporation, under contract to Lawrence Livermore National Laboratories ,.y

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-~and'the~ flR'C in the'd'eyhTop' mint ~6f 'tfid'Siiffinic Hazard Analysis, NUREG/CR-1582. ~' Q.3. Is it the NRC Staff's position that an earthquake of Intensity IX on the Modified Mercalli scale is impossible at the Seabrook site? .},- A.3. No. Q.4. Is it the NRC Staff's position that an earthquake of Intensity IX ~ is impossible in the tectonic province containing the Scabrook site? A.4. No. n Q.5. If the answer to eittier of the previous questions is that an ? Intensity IX earthquake is not impossible, y What does the NRC Staff believe to be the probability a. of occurrence of such an earthquake? b. What is the factual ba'sfs and rationale for that probability judgment? What does the NRC Staff believe to be the earthquake of c. greatest intensity that can occur at the site or in the tectonic province? d. Please provide a detailed justification for the choice of maximum intens,ity earthquake. s .5 1

4 -S-A.S.a. The Staff has no position with regard to the probability of occurrence of an intensity IX at.the Seabrook site specifically or in ,. 7 s New England in general. e A.5.b. The Staff believes that accurate estimates of probabilities l associated with earthquakes particularly those in regions for which there is [ no historical or recent geological record is a very difficult task. This is due to the uncertainties associated with the various parameters used in calculating probabilities. Any such estimate would have to incorporat? extensive sensitivity studies and techniques for accounting for these uncer-tainties. No such extensive studies have been conducted by the Staff. ..... A.5. cad....The Staf.f Aas.no position as..to.the earthquake of. greatest. intensity that can occur at the site or in the province. This, however, is not to say that decision making with regard to engineering design is j . impossible or must-revert..to. the use of. the largest. earthquake that has. occurred anywhere at any time in the past. The regulation which describes the decision making framework for the Staff in t'his area is Appendix A to -10 C.F.R. Part 100. -In-the context oE that regulation it is the Staff's position that the maximum earthquake to be considered for Engineering Design at Seabrook is Intensity VIII. Q.6. - If the answer..to. either or-both.of Questions 3 and 4.is that an Intensity IX earthquake is impossible, please provide a detailed justification for that conclusion. A.6. Not applicable. Q.7. Please identify and provide copies of.all studies or analyses that give rise to or support the conclusions and justification provided in response'to Questions 3-6. m 1 9 +-

. A.7. The justification for the answer to 5.d can be found in the Staff's recent evaluations for sites in New England. These include the SER's for Se.abrook, Pilgrim II, Montague and New England 1 & 2 which documents are publicly available. Q.8. Please describe what the NRC Staff believes to be the tectonic province or seismic area in which the Seabrook site is located, a. Please justify this choice in detail. In so doing, describe, explain the use of, and justify the NRC Staff's conclusions concerning, at a minimum, the following: 1. All tectonic structures. and other. tectonic or. seismic features, including all identified fault lines, that the NRC Staff considered in reaching its conclusions. 2. Any new information concerning tectonic or seismic features or activity in the Northeastern United States -....that.}.as.bac= kmwn to the NRC Staff..since.its. original testimony on seismic issues in this proceeding. 3. All historical earthquakes considered by the HRC Staff, including their intensity on the Modified Mercalli scale. 1 l 4. The " Boston-Ottowa seismic trend." b. Please explain the relevance of this choice of tectonic province to the determination of the design basis earthquake, under the methodology propounded by the NRC Staff-Applicant. c. Please identify and describe the sources from which you have compiled a historical record of earthquakes in the tectonic province or seismic area described in response to this question. In particular, how complete is the record as a function of time, location within the province or area, and intensity. A.8. In accordance with the letter of January 15, 1981, from Roy P. Lessy i to William J. Jordon, a response to this interrogatory is not required in the absence of a prior determination by the-presiding Appeal Board pursuant to j ~ - - 10C.F.R.Il2.720(h)(2)(1)and2.740(b)(1)of: (1) necessity,(ii) inability to obtain the information elsewhere, and (iii) relevance.

4 f 3 7-4 ) 9 5 Q.9. Has the NRC Staff or any of its witnesses examined other possible 0 tsctonic province choices for the area? j; a. If so please describe each one and explain in detail why it 4 was rejected in favor of that described in response to .I Question 8. { A.9. See response to interrogatory 8 above. Q.10. Is it the Staff's position that the location of the Seabrook Ti site within a particular tectonic province or other seismic area determines the maximum intensity earthquake that could affect the Seabrook site? A.10. Within the regulatory context yes, because Appendix A to ld C.F.R. Part 100. IV. a. (6) requires. " Epicenters or locations of highest j 't intensity which cannot be reasonably correlated with tectonic structures 5 f. shall be identified within tectonic provinces any part of which is located 7 within 200 miles of the site;" Section V. a. indicates. "The vibratory ? O ground motion at the site should then be determined by assuming that the } epicenters or locations of highest intensity of the earthquakes are ii situated at the point on the tectonic structures or tectonic provinces }. nearest to the site." Section V. a. (1)(ii) states. "Where epicenters, or locations of highest intensity of historically reported earthquakes cannot s be reasonably related to tectonic structures but are identified pursuant f' to the, requirements of paragraph (a) (6) of section IV with tectonic provinces in which the site is located, the accelerations at the site shall i be determined assuming that these earthquakes occur at the site." See also the total Appendix A to 10 C.F.R.100 and also the response to question 5.c. h --m*==-r -M** -e-----.-

. Q.11. Does the NRC Staff contend that there is not a linear relation-ship between earthquake intensity 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 NRC Staff contends refute Dr. Chinnery's linear hypothesis and other curves that the NRC Staff believes fit the available data. b. If the NRC Staff acceptr Dr. Chinnery's linear hypothesis to some extent, bJt not in its entirety, please explain where the NRC Stoff disagrees with Dr. Chinnery's hypothesis, data, methodology, or conclusions. A.ll. The Staff accepts this hypothesis to some extent. A.ll.a. See A.11.b. A.ll.b. This relationship originally expressed using earthquake magnitude rather than intensity (Gutenberg and Richter,1944) is the most frequently used method of relating earthquake size to frequency of occurrence. This is particularly true with regard to seismic events of moderate intensity, i.e., earthquakes of Modified Herca111 Intensity V VI and VII. Other relationships, howcVer, have been proposed by se,ismologists to explain deviations of data from this proposed simple linear relationship, particularly h at large magnitudes or high intensities. These include truncated linear. bilinear and higher order relatior. ships. Yegian (1979) has discussed these in a recent sununsry of probabilistic approaches to seismic hazard analysis. New forms of frequency magnitude relationship are continually being proposed. An examination of the six issues of the Bulletin of the Seismological Society of America for 1980 alone indicates three different generic approaches to determining the relationship between earthquake magnitude or intensity and frequency. (Bloom and Erdmann),1980; Berrill and Davis,1980; and S

?. i 1 lt Makjanic,1980). The linear assumption is a first order or rough approximation j u which may be adequate for generalized argume.nts but clearly requires ',[ great scrutiny and possibly higher order terms in detailed descriptions h i such as return periods for earthquakes of high intensities. j The NRC Staff believes that the calculation of return periods for .) earthquakes of high intensity, particularly those that have not been reported 4 in the historic record, by linear extrapolation of the data at lower .h n intensities. must. incorporate or..be. accompanied.hy.an assessment of the .) uncertainty involved. Uncertainty also exists with respect to other j 3 aspects' of Dr. Chinnery's " method" (Chinnery,1979). These include the use 3 .5 ....3. -.cf the same b value..(.r41ativa..racurrence rate).for. different regions t of the U.S. and the assumption that upper bounds to earthquake magnitude or intensity cannot be used. McGuiie (1977) examined the uncertainty 3. 1 associated with. somoof.these assumptions.in. calculating. intensities. ....( corresponding to different return periods for sites along the coast of the eastern U.S. In the vicinity of Seabrook, f'or example, the intensity

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associated-with a return period of.10,000. years-varied by.about 1.2 units ..l ~~ depending on which upper intensity cutoff was used and by an additional 0.8 units depending on which b value was used. Utilizing McGuire's estimate that-0.4 units corresponds to a factor of two in risk, this would correspond to variations in estimated return periods of Intensity IX by factors of 8 and 4. Clearly combined uncertainties exceeding an order of magnitude ~~are possible. for reasons such as these we believe that utilization of

. the return periods of earthquakes found in Chinnery 1979 (for example, 1445 years for Intensity IX nr greater in the Bosten, New Hampshire, zone) for quantitative purposes is clearly uncalled for. Chinnery agrees with this. He has stated: We do not pretend that these numbers are very accurate. In fact, because of the subjectivity that has to be used in obtaining the linear relations [ equations (1) to (5)], there is no way to make a realistic assess-ment of errors. We therefore view the numbers in Table 5 as being a qualitative indication of risk, rather. than. quantitative. (.1979) (Chinnary..(1979) at p. 769). References for A.11.b Berrill, J. B., and R. O. Davis (1980). " Maximum Entropy and the Magnitude .. Dis tr.itut. ion,.".2u11.Saism. Soc.. M... 70, 1823-1831........ Bloom. E. D., and R. C. Erdmann (1980). "The Observation of a Universal Shape Regularity in Earthquake Frequency - Magnitude Distributions," Bull. Seism. Soc. M. 70, 349-362. --Chinnery,. Mr A.. (1979). "A Compar.ison cf-.the.. Seismicity of. Three. Regions.... of the Eastern U. S.." Bull. Seism. Soc. M. 69, 757-772. Gutenberg, B. and C. F. Richter (1944), "Frequen.cy of Earthquakes in California," Bull. Seism. Soc. M. 34, 185-188. i McGuirerR.- K...(1977)." Effects.of-Uncertainty.in. Seismicity on. Estimates of Seismic Hazard for the East Coast of the United States," Bull. Seism. Soc. M. 69, 877-892. Makjanic, B. (1980). "On the Frequency Distribution of Earthquake Magnitude and Intensity," Bull. Seism. Soc. M. 70, 2253-2260. Yegian, M. K. (1979) "Probabilistic Seismic Hazard Analysis State-of-the-Art for Assessing Earthquake Hazards in the United Statm," Report 13. U.S. Army Engineer Waterways Experiment Station. Q.12. Has the NRC Staff or any of its witnesses applied the Chinnery hypothesis and methodology to the'$eabrook site using as a local da'ta 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? 'i y .,-.~. --+-- ~

. c. Please provide a detailed justification for the choice of the seismic areas from which the local data base was drawn. i. d. Please provide copies of all work papers involved in this analysis and of any resulting reports or studies. A.12. The Staff, who are its own witnesses, has not done such an analysis. Q.13. Please name one region in the world where it has been clearly and unequivocally denonstrated 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. A.13. As with many other problems in the fields of geology and seismology, no unequivocal statement regarding upper bound to earthquake size can be made. This is not to say, however, that estimate of maximum earthquakes for engineering purposes based upon seismicity, tectonic history, geologic structure, and fault parameters cannot be made which give " reasonable" albeit not absolute assurance. Such estimates are typically made by the Staff in the western U.S. (see, for example, the SER for SONGS 2 & 3) where the plate boundary environment and the concurrence of high,er seismicity, exposed faults, and good tectonic models allow the utilization of techniques not nurmally applicable in most areas of the eastern U.S. such as Seabr sk. Q.14. Maximum possible earthquakes were given by each of the experts in NUREG/CR-1582 (Seismic Hazard Analysis Solicitation of Expert Opinion. TERA Corporation) for regions of New England. a. Where only magnitude is quoted, please state what the NRC Staff believes to be the maximum epicentral intensity of an ~ earthquake of that magnitude. Please describe in detail the method and calculations 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 NRC j Staff agrees to disagrees with the selection and explain why. 0 ? i _.__.,.,,,,9.. ,,,,,,,,y m, %_g

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.C A.14.a. The following table summarizes the responses given by the expert's 'in NUREG/CR-1582'Wfth 'rfgird 'to the-largest earthquake that is gl .-6 expected to occur in the current tectonic framework independent of the g.: )e period of time. It is important to remember that these values represent maxi' mum intensi~t'y cutoffs to b'e used for probabalistic calculations and t ~ not maximum intensities for the purposes of engineering design. The numbers given correspond to that zone in which Seabrook falls to which each expect ); lf assigned the greatest credibility. Y. Expert No. Intensity Estimate $j Lower Bound Best Estimate Upper Bound, 7 .w '.E /, 3 IX X XI 4 VI VIII X 5 XII , J, 7 8.9 9.3 9.9 G 8 8.5 9 7.9 8.9 9.9 'N 10 VIII IX X 4 11 8.5 9.5 10.5 12 8.0 9.0 7 13 IX X XI N Those experts whose intensity estimates appear as Arabic rather than Roman } numerals gave their estir.'ates in terms of magnitude (m ). These were converted b to Epicentral. Intensity.Io using the fo.11oying.re.lationship from Nutt11 and. Herrmann(1978): Io = 2 mb - 3.5 14.b. The Staff. bas not performed independent.arta. lyses to determine the validity of the expert's choices. A further response could only be accomplished after extensive analyses and research which are not required. see.Pennsy1vania. Power.and Liaht Company.and Allegheny Electric. Cooperative (Susquchanna Steam Electric Station, Units 1 and 2), ALAB-613,12 NRC 317 i

'j n. (1980); Houston Lighting & Power Co. (South Texas Project, Units 1 & 2), LBP-80-11,11 NRC 477, 478 (1978). Accordingly, the perfomance of such analyses and research is objected to. Q.15. What, in your opinion, is the maximum epicentral intensity of i 4 the largest earthquake that will ever occur within the province or area described in response to Question 87 ] Please justify your. answer in detail, including reference a. to all relevant tectonic structures, tectonic or seismic features, and historier.1 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 ccnfidence, and explain how it was estimated. A.15. See response to interrogatory eight. i Q.16. Is it the NRC Staff's position that 10 C.F.R., Part 100 Anpendix A, requires that the SSE be the largest earthquake that can be j predicted with 100% confidence ever to occur within the tectonic province j containing the site? If not, what confidence level is acceptable for d this selection, and how did you arrive at this level? jj R A.16. No, it is not the NRC Staff position that 10 C.F.R., Part 100, .) Appendix A requires that the SSE be the largest earthquake that can be pre-dicted with 100% confidence ever to occur within the tectonic province containing the site. No specific numerical confidence level has been defined i i as acceptable by the NRC Staff with respect to earthquake occurrence. [. Appendix A to 10 C.F.R.100 specifies how the largest earthquake should be detemined. See also response to question 10. P 0.17. The NRC Staff'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? 4 g O. .~

14 - A.17. The SSE proposed for Seabrook of epicentral Intensity VIII is defined irrespective of ground conditions. It is based upon the 1755 Cape Ann Earthquake. Street and LaCroix (1979) used a variety of techniques to esti-mate a magnitude of about 6.0 for this earthquake. The method used and the individual estimates arrived at were: total felt area (mblg=6.0), area to which intensity IV was felt (mblg=5.9) and the fall off of intensity with distance (mblg=5.8) Street R. and A. Lacroix (1979). "An Empirical Study 1 of flew England Seismicity," Bulletin of the Seismological Society of America. Vol. 69, pp.154-176. Q.18. What is the total range of ground accelerations that have been obs1!rved fronrvarthquates of the wrgnitude quoted-in-Question-172 - ~ ' - ~

• How many of these were observed on bedrock? Please give references for these bedrock data.

A.18. A response to this question requires an extensive compilation ' " ' "-~- " 8nd trarch or existing -data'n!ts.--We-do not have sufficient-time to-conduct such a project. If:one desires to conduct such a study those references listed by the licensee in its response to this interrogatory may be used. M addit'i5iiW1 cWpfTa'tiMWay b( fdtind ftrtIUREG/CR-1660"(1980): ~ Compilation. Assessment and Expansion of the Strong Earthquake Ground Motion Data Base, Seismic Safety Margins Research Program (SSftRp) C. B. Crouse, J. A. Hileman, - B. E. Turner, and G. R. Martin FQgro Inc. The unanswered portion of this interrogatory is objected to on the J grounds that a further response could only be, accomplished after an extensive ~ 'res'earch project. 'See Pennsylv'a'nia ' Power and Light' Company and Allegheny Electric Cooperative, supra, ALAB-613,12 NRC 317 (1980); Houston Lightino & Power Co., supra, 11 NRC 477, 478 (1978).* e ,,,-_,,_,y .m

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3 4 } ~! 3o,; Can the bedrock acceleration data in Question 18 be represented 4 Q.19. as a Gaussian distribution? -tihat are the mean and standard deviation of j What is the probability that an earthquake of maximum epicentral h these data? intensity VIII will generate a bedrock acceleration in excess of 0.25g7 ,{ Please give details of the probability calculation. We have not conducted such an analysis upon the data sets A.19. mentioned in response to question 18. Such an analysis would also require The remainder of this interrogatory, other than the f extensive research. [ above response, is objected.to on the basis of the authority referenced in the answer to interrogatory #18. 1 Under what factual circmstances would the Staff use the i Q.20. maximum historical earthquake as the Safe Shutdown Earthquake, rather than a stronger earthquake? f The Staff uses the maximum historical earthquake as the Safe 1 A.20. 4 Shutdown Earthquake rather than a stronger earthquake when the factual circum-kI stances delineated in Appendix A to 10 C.F.R. Part 100 are evaluated and I assessed. See also response to question 10. For example, for an eastern

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' l: U.S. site, the maximum historical earthquake in the province that cannot be ) reasonably associated with a structure is assumed to occur at the site. h, Under what factual circumstances would the Staff use an earth-Q.21. quake other than the maximum historical earthquake as the Safe Shutdown Earthquake for a nuclear reactor? The NRC Staff uses an earthquake other than_ the maximum historical A.21. earthquake as the Safe Shutdown Earthquake after an evaluation as per ) Appendix A to 10 C.F.R.100 indicates that the maximum historical earthquake within a given province can reasonably be related to structures and therefore cannot be assumed to occur at the site. The largest historical earthquake remaining in the province that cannot reasonably be related to structures would then be assumed to occur at the site. This procedure would gencrally result in a lesser intensit, earthquake' being assumed to occur at the site. l

!.k .} S}i is 'I. ~ The NRC Staff uses an earthquake greater than the maxima historical

j earthquake if the evaluation as per Appendix A to 10 C.F.R.100 indicates 3

that the magnitude or intensity of earthquakes based on geological and h seismological evidence may be larger than that of the maximum earthquakes f[ historically reported. This would usually occur upon evaluation of a western U.S. site after evaluation of the maximum magnitude earthquake '3 i that could occur on a capable fault which is in c1cse proximity to the site. See also response to question 20. Q.22. Under what factual circumstances would the Staff judge that an earthquake greater than the maxir:m historical earthquake should be designated the Safe Shutdown Earthquake for a particular site? A.22. There is no specific listing of factual ciretrnstances under which the Staff would j,udse_ that an earthquake greater than the maximtsn j historical earthquake should be designated the Safe Shutdown Earthquake f-; other than those delineated in Appendix A to 10 C.F.R.100 a'nd as discussed 3c; in response to question 20 and 21. We have not made a study of the bases ii i for the selection or designation of the maximum intensity earth, quake of 3 \\ Safe Shutdown Earthquake that has been reviewed and accepted by the NRC Staff in the U.S. in the past and to do so would have a severe impact on Staff resources involving a review of all PSARs. FSARs. SERs and USGS letters. Accordingly, the performance of such a study is objected to for the reasons set forth in the answer to interrogatory 18. Some conditions which might warrant selection.of.a larger Safe Shutdown Ear.thquake are: (1)Where the highest intensity of historically reported earthquakes is determined to have been experienced at the site taking into consideration site i foundation condi.ttons...(2) where seismicity. In..the.immediate site vicinity )

i - is significantly higher than that generally existing in the tectonic province as a whole.(3) where there exists in proximity to the site tectonic structure demonstrably like that found where larger earthquakes in the tectonic province have occurred historically. In those regions where there are capable faults, for example, in California the maximum magnitude earthquake is usually determined after evaluation of those faults which are in close proximity to the site. This maximum earthquake usually exceeds the maximum historical carthquake that has occurred on the fault zone. Q.23. What would be the basis for the Staff's choice of a particular Safe Shutdown Earthquake in a case where the Staff had decided to use a value higher than the maximum historical earthquake? Provide all examples of such cases and a discussion of the factors considered by the Staff in choosing each SSE. A.23. See response to interrogatories 20. 21. and 22. Q.24. Please identify and provide copies of all studies, reports, and other. documents prepared by or on behalf of the NRC Staff or available to the NRC Staff concerning seismicity in the Northeastern United States. In particular, please provide co' pies of all documents related to "some recent research by Dr. Chuburis." referred to by Mr. Reiter at page 57 of the transcript of the Comission meeting of May 29, 1980, on Seabrook seismic issues. A copy of the transcript is attached. A.24. A listing of all studies, reports, and other documents prepared c by or on behalf of the NRC Staff was provided as an attachment to the " Affidavit of Richard B. fichu 11en and Leon Reiter." December 5.1979, which was previously served in this proceeding. The following material should be added to that list. A. Contractor: Boston College 1. Northeast Seismic Network Bulletins No. 14 Jan.1.1979 - March 31,1979 - Dec.1979 No. 15 April 1, 1979 - June 30. 1979 - April, 1980 No. 16 July 1.1979 - Sept. 30,1979 - June.1980 s t No. 17 Oct.1.1979.- Dec. 31.1979. Aug. 1980 .e, No. 18 Jan.1.1980 - Mar. 31.1980 - Nov.1980 t aem se u e w e --m y +- + -, -

i et 1 2. Jan.1.1979 - Mar. 31.1979 - Nov. 1979 Apr.1.1979 - June 30.1979 - March.1980 July 1.1979 - Sept. 30,1979 - May,1980 Oct.1.1979 - Dec. 31,1979 - Aug.,1980 Jan.1.1980 - Mar. 31,1980 - Nov.1980 3. Technical Reports: Aug.1.1979 - July 31,1980 - Sept.1980 Technical Progress Report - Annual Report B. Contractor: Massachusetts _[nstitute of Technoloqy 1. Quarterly Progress Reports July,1979 - Sept. 1979.......... Oct.,1979 April,1979 - June,1979.......... July,1979 C. Contractor: New York State Environmental Research and Development Authority 1. Quarterly Reports Jan.1.1979 - April 30,1979 Jan. 1. 1980. March 31. 1980 ..L - April 1.1980 - June 30.1980 s2 Y 2. Annual Report i

s Regional Seismicity Bulletins of the Lamont-Doherty Network; 1979

,}

4 Other Contracts Reports.

.{} 9. Seismotectonics of Northeastern United States and Adjacent Canada. Yang. J. and Aggarwal. Y. P. ..10... Earthquake hazard..in..New. York..and Adjacent Areas. Kafka. A..L.,1980. At the present time, we do not available all the reports listed. We can undertake to make those reports specifically requested available at a later i date. As requested, attached is the docunent referred to by Dr. Reiter during the May 29, 1980 Commission meeting on Seabrook. This report is a draft report to NRC Office of Regulatory Research entitled. " Seismicity. , J. ? .i.

.I Recurrence Rates, and Regionalization of the Northeast United States and Adjacent Areas." undated, and prepared by E. F. Chiburis, Loston College. [ Q.25. Has the Staff prepared or does it have avaf f able to it a map of tectonic provinces in the United States? In New England? If so, please provide a copy and a complete explanation of the principles and data on which the tectonic province boundaries are based. A.25. No. (As to the subject matt _er of this interrogatory, also see Staff response to interrogatory number 8.) Q.26. Please identify and provide copies of any studies or analyses undertaken by the Staff to examine or reevaluate the validity of its approach for determining vibratory ground motion, as presented in the previous phase of the Seabrook adjudicatory bearings? 7. A.26. The Staff has not undertaken any studies specifically directed .h toward examining or reevaluating the validity of its approach for deter-mining vibratory ground motion, as presented in the previous phase of the Seabrook. hearings..We have..however. continued _to examine..our procedures. 1 in light of our licensing experience and new knowledge. This examination has resulted in two recommended revisions to the Staff Standard Review Plan, Section 2.5.2 which.have mot.been fonnally adopted by.the 5taff.due to man-power constraints. These suggested modifications are contained in (1) Proposed Staff revision to NRC Standard Review Plan. Section 2.5.2,1977;(2) NUREG/CR- . -l161, Recomended Revis4cn.to Nuciaar Jtegulatory Comission Seismic Design Criteria. Lawrence Livermore Laboratories May 1980; and Suggested modifi:ations to NRC Standard Review Plan, Section 2.5.2. Lawrence Livennore Laboratories. December, 1979. Copies are enclosed... m y e

~ Q.27. To what extent if any has the Staff modified its approach -to determining vibratory ground motion-since the previous phase of the -r Scab ook adjudicatory hearings? j A.27. Since the time frame of the previous phase of the Seabrook hearings the Staff has placed increased emphasis primarily on two aspects 1 of its approach to determining ground motion. These are:

1) The use of magnitude and site specific spectra rather than intensity l

and standardized spectral shapes to characterize the Safe Shutdown Earthquake.

2) Some use of probabilistic methodologies. These have generally been limited to relative rather than absolute estimates of seismic hazard.

Estimate of this type include the relative differences (ratios) in the chances of exceeding different levels of ground motion at the same site and of levels of ground motion associated with the same relative probab111ttes of exceedence at different sites. Q.28, please identify all nuclear reactors for which the Staff's approach for determining v~lbratory ground motion differs from the approach taken for Seabrook. Please explain and justify any differences in approach in detail. A.28. Appendix A to 10 C.F.R. Part 100 allows for the utilization of different approaches than used at Seabrook especially with respect to western U.S. sites. These different approaches are allowed as long as sufficient supporting justification is provided. Prior to the adoption and promulgation of Appendix A to 10 C.F.R. part 100 in 1973, and development of the Staff standard review plan, different methods were utilized. i To provide a complete response to the question would require a review of all past Preliminary Safety Analysis Reports (pSAR), Final Safety Analysis 4 -n,

21 - Reports (FSAR) Staff Safety Evaluation Reports (SER) and all consultant (USGS) letters for all nuclear plants. Such a request is overly broad and would severely impact available Staff resources, therefore such an analysis has not been undertaken and is not provided. Therefore that portion of the interrogatory that requests such a search and study be conducted is objected to on the basis of the Comission precedent set forth in Staff response to Interrogatory 18. )E A,ttorney Making Objections: 't Roy P. Lessy Dated at Bethesda, Maryland, this 9th day of February,1981. G --e .e .-.---~,--,..,.,e-. ,.-.,.,,-,,,~_..,,,+,--,,,_n,,._,

3 1 '$i .1 UNITED STATES 0F AMERICA NUCLEAR REGULATORY COMMISSION 3v 3' BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 1 In the Hatter of D l ) 2 PUBLIC SERVICE COMPANY OF h Docket Nos. 50-443 f 50-444 NEWHAMPSHIRE,ET,&. J) g ~ (Seabrook Station, Units 1 ) { and2) ) 4t ~7 AFFIDAVIT OF ROBERT E. JACKSON f,t Now comes Robert E. Jackson, Ph.D. and being duly sworn, deposes c ~? and says as follows: i Y 1. I am employed by the U.S. Nuclear Regulatory Connission as ,f Chief, Geosciences Branch. Office of Nuclear Reactor Regulation. 'i ? 2. I am duly authorized to answer Interrogatories 1, 2, 10, 16, 28 J i 20-26 and I hereby certify that the answer given is true to the best of j my knowledge. T. he/uc>O' Robert E. Jackson Subscribed and surn to before me this l/' ' day of ineruary,1981. !/d.b ' ) 2:W.it t. Notary Public / My Commission expires: O4,1,.l9/.V i ) N i 3 .e -w

3') s . a. 4 .7 2;- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMNISSION 4 BEFORE THE ATOMIC 5AFETY AND LICENSING APPEAL BOARD {i In the Matter of .j d PUBLIC SERVICE COMPANY Of Docket Nos. 50-443 NEW HAMPSHIRE, ET AL. 50-444 a f) (Seabrook Station, Units 1 and2) i 3l, l .5 AFFIDAVIT OF LELM REITER Y E Now comes Leon Reiter Ph.D. and being duly sworn, deposes and says + as follows: it 1. I am employed by the U.S. Nuclear Regulatory Commission as a 5 Section Leader Seismology Section, Geosciences Branch, Office of p Nuclear Reactor Regulation. -4 2. I am duly authorized to answer Interrogatories numbered 1,3-4. 5, 7, 27 11-14. 17-19, and I hereby certify that the answer given.is true and correct to the best of any knowledge. v l Leon Reiter ~ Subscribed and sworn to before me this 4.' day of February,1981. -Nh/..e r / /.n & Notary Public c-My Connission expires: re.d /, /k.f M l e ~ ,h / /' d' l

';:3 $.Y 4 '.i!

• f. t UNITED STATES OF AttERICA W

NUCLEAR REGULATORY C0tutIS$10N g!, W: p{ BEFORE THE ATOMIC SAFETY AND LICEhw NG APPEAL BOARD _ is:3 y In the Matter of )l PUBLIC SERVICE COMPANY OF h Docket Nos. 50-443 's NEW HAMPSHIRE, ET AL. I 50-444 l. y yz JT (Seabrook Station, Units 1 ll ]f' and2) ) .e( .o .9 AFFIDAVIT OF JAMES P. XNIGHT Now comes James P. Knight and being duly sworn, deposes and says as follows: .y 1. I am employed by the U.S. Nuclear Regulatory Commission as l$ f. Assistant Director For Components & Structures Engineering Office of ff.k Nuclear Reactor Regulation, 2. I am duly authorized to answer Interrogatories 1 and 2 and I 15 Ai hereby certify that the answer given is true and correct to the best of ,j.;

.~

Ya my knowledge. ./ N '\\~ . -u - (James P. Knight ] I Subscribed and sworn to before me this */" day of. February,1981- .y 'e ~ si b.b r Lll1 i.,& Notary Publi_c p/ j, My Commission expire.: , A, / /f D s 4 / 9 i -Q N

UNITED STATES OF AMERICA NUCLEAR Td'iULATORY CO:VilSSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of ll j. l PUBLIC SERVICE COMPANY OF h Docket Nos. 50-4'3 4 NEW IIAMPSillRE, e_t, al. p 50-444 )> (Seabrook Station, Units 1 and2) ) ~ CERTIFICAT! 0F SERVICE I hereby certify that copies ' f "RESPOT5F. OF THE NRC STAFF TO NECNP'S INTER-o ROGATORIES", " AFFIDAVIT OF ROBERT E. JAL ' SON"," AFFIDAVIT OF LEON REITER", and " AFFIDAVIT OF JAMES P. KNIGHT" in the abwe-captioned proceeding have been served on the following by deposit in thi United States mail, first class, -or-es-indicated by en asterisk, by deposit in-the Nuclear Regulatory Comission-internal mail system, this 9th day of Fet uary,1981: d Alan S. Rosenthal Esq.," Chairman' Dot &ph F. Tobridy, Esq. ~ li Atomic Safety and Licensing 4100 Cathedral Avenue, N.W. a Appeal Board Washington, D.C. 20016 i U. S. Nuclear Regulatory Comissic i Wasnington, D.C. 20555 f Dr. John'H. Buck

• Atomic Safety and Licensing

'21 Appeal Board U. S. Nuclear Regulatory Comissior Uashington, D.C. 20555 Dr. Ernest O. Salo Dr.' W. Reed Johnson.... Professor of Fisheries Research... Institute Atomic Safety and Licensing College of Fisheries Appeal Board University of Washington U. S. Nuclear Regulatory Comission Seattle, Washington 98195 Washington, D.C. 20555 Dr. Kenneth A. McCollom Ivan W. Smith, Esq.* 1107 West Knapp Street ? Atomic Safety and Licensing Stillwater, Oklahoma 74074 -f Board Panel r U. S. Nuclear Regulatory Comission i Washington, D.C. 20555 '{ 1 ':.] j 2 3 .T-l 3 l i l

.t-Eso. Ellyn R. Weist. j H.irann 8 Wins 7 Robert A. W rkus. Fee. f.it t1=: IM5 I Mrst. N.W. ,3 O'NetII. Backus. t.,tt.%% Su'.te :it4 20NS -l 116 Lowell Stnet - 03f fr, Wx.hi.'stin. D.0. Manchester. New ibrpstiN ( Atomic Safety and Licensing ~4 Thomas 6. Dignan. Jr.. uti. Board Panel * -f John A. Ritsher. Esq. U.S. Nuclear Regulatory Comission j 20555 Washington, D.C. 5 Ropes & Gray 225 Franklin Street 02110 f'i: Boston, Massachusetts Atomic Safety and Licensing f Appeal Board *

f.

U.S. Nuclear Regulatory Comission-} Norman Ross. Esq. 30 Francis Street 20555 3 Brookline. Massachusetts 02146 Washington. D.C. 7 Docketing and Service Section* 4 E. Tupper Kinder. Esq. Office of the Secretary i A Assistant Attorney General Office of Attorney General .U.S. Nuclear Regulatory Comiss on V 20555 State House Annex Washington. D.C. ~ ~ ~ ' Concord. New Hampshire' '03301 Ms. Elizabeth H. Weinhold ' ~ Room 208 ~ e 3 Godfrey Avenue ..i Hampton NH 03842 5 Francis S. Wright. Asst. Atty. Gen. Laurie Burt. Esq.. Asst. Atty. Gen. D. Pierre G. Cameron, Jr. Esq. 3 Environmental Protection Div. General Colinsel 'T Comonwealth of Massachusetts One Ashbdrton Pla'ci^ Public Service Company of New ~ 3 liampshire $,i-19th Floor Boston, Massachusetts 02108 1000 Elm Street Ibnchester. NH 03105 s William C. TallmanChairman and Chief Executive Officer ~ ~ ~ ~ ~ Public S6rvice Company bf He9 Hampshire 1000 Elm Street Manchester. NH 03105 O Lfew4-1 itoy P. Lessy (,) I Deputy Assistant Chief Hearing Counsel s. 4 ees ao O - -}}