ML20004E785
| ML20004E785 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 06/10/1981 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-SC, NUDOCS 8106150254 | |
| Download: ML20004E785 (86) | |
Text
-. - _ - _ _ _ _
JWBr,ach 6-10-81 2222 NRC-SF GETR 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY CO!1 MISSION 3
x In the Matter of:
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j 5,
GENERAL ELECTRIC COMPANY Docket No. 50-70 Operating License 6
[Vallecitos Nuclear Center -
No. TR-1 General Electric Test Reactor]
(Show Cause) 3 7'
,a
x S,
E Redwood Room, 9
Holiday Inn - Golden Gateway,
an Ness at Pine,
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10 '
San Francisco, California, f
11 Wednesday, 10 June 1981.
E 12 :
The hearing in the above-entitled matter was 5
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13 reconvened, pursuant to recess, at 8:30 a.m.
E E
14 BEFORE:
f I
15 HERBERT GROSSMAN, Esq., Chairman
'2 Atomic Safety ~& Licensing Board Panel 16 U.S. Nuclear Regulatory Commission E
Washington, D. C.
20555 5
.7 i.
GEORGE A. FERGUSON, Ph.D., Member I
t '3 HARRY FOREMAN, M.D,,
Ph.D., Member l
ti 19 l
s APPEARANCES:
U 20 1
On behalf of the Nuclear Regulatory i
21 commission Staff:
3 9.2 I DANIEL SWANSON, Esq.
RICHARD G. BACH!iANN, Esq.
23 Office of the Executive Legal Director
,.9 U.S. Nuclear Regulatory Commission l
f% 24 Washington, D.C.
l 25
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APPEARANCES (continued) :
2 On behalf of the Licensee:
3 EDWARD A. FIRESTONE, Esq.
General Electric Company 4'
Nuclear Energy Company 175 Curtner Avenue j
5 San Jose, California 95125
'?
5 6
-and-j 7I GEORGE L.
EDGAR, ESQ.
JAMES B. VASILE, Esq.
g 8;
1800 M Street, Northwest 9
Washington, D. C.
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10 '
On behalf of the Intervenors Friends g
of the Earth, et al.:
g 11 '
E GLENN CADY, Esq.
j 12 i Carniato & Dodge 5
3708 Mt. Diablo Boulevard
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13 Suite 300 E
Lafayette, California 94549 E
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vom WITNESSES:
DIRECT DIRE CROSS BCARD 3EDIIGIT RIIROSS Joseph A. Martore
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4 Christian C. Nelson )
2226 2255 2257 John F. Burdoin
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2259 6
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Garrison Kost
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Richard Harding
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2264 2294 2296 8
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2 Richard Meehan
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15 EEElBilS neg 16 EXHIBIT NO.
FOR IDENTIFICATION IN EVIDENCE E
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Licensee No. 42 2301 19 l
Licensee No. 43 2301 ti 19
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_P _R O_ C_ _E _E.D _I N G_ _S 1
2 (8:30 a.m.)
3 JUDGE GROSEMAN: The eleventh day of the 4
hearing in the Show Cause proceeding is now in session.
}
5' It is my understanding, Mr. Edgar, that 6:
Mr. Meehan has not yet arrived, but ought to be arriving j
7 at about 9:30.
Is that correct?
5 S
MR. EDGAR:
That's correct.
E 9
JUDGE GROSSMAN: Okay.
And since he is coming a
4 10 '
in on one of those all-night coaches,. it is my intention f
11 '
of putting him on as soon as you say he is ready so he E
E 12 1 doesn't have to sit here and wait for other testimony.
S 13 MR. EDGAR:
And we are going to put Dr. Kost
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14 up with him in case we get into the structural interface.
I 15 It may well be more efficient to do it that way.
E IF JUDGE GROSSMAN:
That's fine.
E i
17 MR. EDGAR:
And we think that Mr. Harding f
13 will be here, if there are any geological elements of i
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19 questioning and he could join that panel for that purpose. l
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E 20 JUDGE GROSSMAN:
Thank you.
E 21 l
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Whereupon, 2
JOSEPH A. MARTORE, 3
CHRISTIAN C. NELSON, 4
and j
5 JOHN F. BURDOIN j
6 resumed the stand and, having been previously duly sworn, i
7 were examined and te'stified further as follows.
8 JUDGE GROSSMAN:
Would the panelists now, 3
3 9<
the structural panel for NRC, pleasr state your names a
d 10 again so the reporters have you correctly?
f 11 WITNESS MARTORE:
Joseph A. Martore.
E E,
12 :
WITNESS NELSON:
Christian C. Nelson.
5 13 WITNESS BURDOIN:
John F. Burdoin,
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14 B-u-r-d-o-i-n.
E 15 JUDGE GROSSMAN:
Thank you.
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u 16 BOARD EXAMINATION (resumed) 5 i
17 BY JUDGE GROSSMAN:
f3 4
I had almost concluded my questioning d
19 yesterday afternoon.
I do have one or two more questions. l W
M 20 MR. BACHMANN:
Judge Grossman?
E 21 BY JUDGE GROSSMAN:
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Mr. Nelson, we discussed yesterday the 23 possibility of simultaneous design-basis accident and k 24 a seismic event which you responded to; but I hadn't
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25 asked you whether the NRC had considered the possibility i
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of a design basis accident occurring first, and then a 2
seismic event occurring.
Could you respond to that?
3 Do you understand the question?
4 A
(Witness Nelson)
Yes, sir.
2 5:
MR. BACHMANN:
Judge Grossman, may I clarify 5
6,
something that we were able to discuss last evening?
j 7
JUDGE GROSSMAN:
Oh, fine.
Yes, I would 8
appreciate it.
g 9
MR. BACHMANN:
Your original question a
4 10 concerned the integrity of the containment structure, in 5g 11 that it was not considered necessary to survive -- for E
j ll i the GETR to survive the seismic event.
And then you 5
L3 queried:
Well, what would happen if you had a design
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14 basis accident, assuming that the containment structure I
15 had lost its integrity?
And how did we justify not 4
taking this into account when analyzing tne seismic G
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17 avent?
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'3 We checked it through, and Mr. Nelson has g
19 a cogent explanation to give you.
However, first I would C
20 like to preface that with a reference to Appendix A of
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21 Part 50 of 10 CFR.
i 3
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l 12 There is a criterion two in Appendix A to i
23 Part 50 of 10 CFR which talks about design bases for i
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24 protection against natural phenomenon.
And then it says:
25
" Structures, systems, and components important to safety i
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shall be designed to withstand the effects of natural I.
phenomena such as earthquakes."
And then it goes on for 3
a few more.
And then it says:
"The design bases for 4
these structures, systems, and components shall reflect" i
5 and part two says, " appropriate combinations of the l
5 6
effects of normal and accident conditions with the l
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effects of the natural phenomena."
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Thic would appear to require doing what you 9
suggested should be done.
However, the introduction a
4 10 to Appendix A says that:
"These general design criteria i
.l 11 establish minimum requirements for the principal design.
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12 :
criteria for water-cooled nuclear power plants."
s 13 It is the Staff's position -- and then there 3
2 14 is a further discussion and definitions.
It is the
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y 16 requirement for a facility such as the GETR.
Similar to 2
y 17 Part 100, we have used this as a guideline.
But from a l
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13 legal standpoint, it is the Staff's position that we are d
19 not required to do the simultaneous situations that would l
5 L
M 20 apply in the case of an actual, say, 1000 megawatt power l
5 21 ;
plant.
3 12 Now Mr. Nelson has a further substantive
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24 simultaneous accident conr',itions.
25 JUDGE GROSSMAN:
Fine.
I appreciate your s
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telling me the legal standpoint, and I understand that 2
this issue involves both legal and technical considera-3 tions, and it is very hard to separate them out.
But 4
that is fine.
I understand that you do have this legal 1
5 position now, and I will ask Mr. Nelson t.* also discuss 6
how the evaluation resulted in this type of procedure.
j 7
WITNESS NELSON:
Yes, sir.
The Staff 8
reviewed the justification for not seismically qualifying A
9 certain equipment that was designated previously as a
4 10 safety related -- for example, the containm-ant.
We h
11 <
considered several factors.
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12 i One, the differences between the GETR and s
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13 nuclear power plants, including the power level or 1
E 14 fission product inventory; the seismic scram system at E
15 the General Electric Test Reactor; the lack of need for i
g 16 complex systems to mitigate accidents; and the fact that 2g 17 at operating temperature the GETR is subcooled at h
13 atmospheric pressure.
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19 The Staff's evaluation also found that the j
i 1
E 20 loss of nonseismically qualified equipment, safety-I 21 related equipment, within containment did not result in
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?.2 releases which exceeded the Part 100 limits.
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24 scenarios associated with design-basis events -- and I 25 refer to the Staff's Safety Evaluation Supporting Power I
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Increase '--- we determined that a seismic event would not 2
be a cause for such accidents.
3 Finally, it is the Staff's opinion that there 4
is no need to postulate or require that it be postulated j
5 that two very low likelihood events be considered S
6' simultaneously for design purposes.
j 7
BY JUDGE GROSSMAN:
5 g
Well, now that we've had the situation 3
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involving Three Mile Island in which the effects of a a
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10 '
design, or what may o.: may not have been a design-basis f
11 accident, have been prolonged and the reactor was not u
5 12 in operating condition for quite some time, do'esn't it 5
t3 seem that the Staff might consider that -- should have i
E 14 considered that possibility, too, in conjunction, or to i
15 be followed by a seismic event?
E j.16 Do you understand my question?
We're back to 9
3 17 the first question I raised.
Let me rephrase it,
)id j
13 the Staff take into account the possibility that there d
19 might be first a design-basis accident in which there was l
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20 then need to rely upon the containment; and then E
21 subsequently a seismic event which might breach the 3
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containment?
12 23 A
(Witness Nelson)
No, we did not.
h 24 G
Now is there -- What is the reason why you 25 didn't consider it?
You didn't think of it?
Or you didn't
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think it was important?
Or there was a legal basis for 2
not doing it?
Or any other possibility?
Could you 3
explain to us?
4 A
Well, I think there are two factors.
- One, 3
5 the legal basis, which Mr. Bachmann'briefly discussed.
6 The second, what I just tried to present, is the logic j
7 behind not requiring the two low likelihood events, the 8:
design basis event and the seismic event.
9 G
Simultaneously.
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10 A
well, simultaneously or one right after the f
11 '
other.
I treat those both the same.
M E
12 i JUDGE GROSSMAN:
Okay, Mr. Bachmann, what 5
L3 takes the place of Part 50 when it comes to a test reactor i
E 14 of this size and used for this purpose?
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I 15 MR. BACHMANN:
I did not mean to imply that i
g 16 Part 50 itself did not apply.
What I was explaining was 2y 17 the application of the criteria given in Appendix A to f
'S Part 50, in which criterion two seemed to fit the d
19 scenario that you were postulating in your question s
E 20 yesterday.
Excuse me just for a second.
f E
l 21 JUDGE GROSSMAN:
Sure.
t 3
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12 (Counsel conferring.)
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23 MR. BACHMANN:
Basically, when you are l
l dealing with a test reactor of which there are only two 24 25 licensed in the United States -- one at the National 1
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1-10 jwb 2232 1
Bureau of Standards and the GETR -- the NRC does not 2
really have specific regulations to apply to these.
3 We have a lot to do with large power reactors, but the 4
testing facilities are such, I guess, an odd situation 3
5 that for the most part it is in the technical Staff's 6
judgment as to how they must be constructed and what j
7 they must withstand.
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S; As Mr. Nelson mentioned before, there are significant differences, whole orders of magnitude as 9
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10 far as power levels and fission inventories, and f
11 pressures and temperatures between these.
So to answer 4
g 12 your question briefly, it is essentially a matter of s
El Staff judgment using Part 50 primarily as guidelines,
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14 and not as specifically legally binding r.equirements.
I 15 JUDGE GROSSMAN:
Well, then, doesn't that i
g 16 lead to the position now that it is the Board's judgment 2g 17 as to whether to apply Part 50 or to use it as an analogy?
f.
13 (Counsel conferring.)
d 19 MR. BACFliANN:
Let me just set the record l
1 I
E 20 straight.
Part 50 as a whole does apply.
E 21 JUDGE GROSSMAN:
I'm sorry.
I meant Appendix 3
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A to Part 50 and the particular part that you mentioned.
12 23 I just didn't care to make it that specific.
But the
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At this point in the proceeding, is it not s
25 then the Board's responsibility to make that same f-JE.9dCN #E.*CRT"MG c:l:MP ANY. INC.
2233 1-11 jwb determination for itself that the Staff has made for 1
itself, whether to apply those particular sections to 2
3 this situation?
4 11R. BACHMANN:
In the sense of -- when you 2
5 say " apply," I would say in the sense of using it as
.S 6
guidelines and requiring the Staff or the Licensee to 3
7' conform to these prior to a licensing, or in this case a
an action of putting the reactor back in operation,yes, 9
I would have to say that it would be in the Board's a
4 10 judgment.
The Staff gives its opinion, but the Board f
11 must judge based on the evidence presented here.
M j
12 JUDGE GROSSMAN:
By the way, just to clarify 5
E3 the record, I didn't suggest that this should have been
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14 done yesterday.
If I did, I didn't intend to suggest
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I was asking what the Staff's position was with 2[
16 regard to it, and I wasn't suggesting that it do it one 9
i 17 way or the other.
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IS will suggest one thing or another, but we certainly 2
M 20 have not reached any position on that.
5 21 BY JUDGE GROSSMAN:
3 12 G
Now, Mr. Nelson, did you quantify at all
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23 the probability of these events occurring simultaneously, 24 or close together?
25 A
(Witness Nelson)
The only quantification
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that was done was with respect to the seismic event, 2
which has already been discussed during this proceeding 3
as far as probability of occurrence.
We did not quantify 4
the probability of the other design basis events or 5
the simultaneous -- the probability of simultaneous 6'
occurrence of both of them.
7 JUDGE GROSSMAN:
Okay.
I am finished'with 8
g my -
9; MR. EDGAR:
Judge Grossman, may I -- I have a
d 10 remained silent --
ig 11 '
JUDGE GROSSMAN:
Oh, certainly.
S 5
U' MR. EDGAR:
-- through practically all of E
13 these discussions, and I would maintain that posture 5
14 for the near term.
But I h' ave some strong views on r
a 15 the subject that I will present in my brief.
I think h '16 there are many factors that are in this record that can E
W 17 be brought to bear on the ultimate judgment, and they 9
need to be integrated, and that can be done in the briefs.
f 19 So I just want to make it clear that that is why I have l
D 20 hesitated.
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JUDGE GROSSMAN:
I only ask that you bring to 2
the Board's attention whatever position you think would be 3
a foundation for asking quest ins of the technical peopl 4 4
But as f ar as argumentation goes, that is cert.ainly unne mssary 3
5 at this point.
g 6
M R. EDGAR:
Understood.
3 7
JUDGE GROSSMAN:
Anything further from the Staff?
r, 8;
MR. BACHMANN:
No, sir, not at this time.
- e 9
JUDGE GROSSMAN:
Okay.
I have concluded my a
d 10 questioning in this area, and Judge Ferguson has questions i
11 now to the people.
3 j
12 i JUDGE FERGUSON:
Mr. Bachmann, let's start with 5
~
13 a question to you.
W E
14 Did I understand you to say. just a moment ago 3
15 that this reactor and the one located at the Bureau of j
16 Standards are unicue?
Staff considers them unique and 9
E 17 there are no other reactors similar to these two?
'S MR. BACHMANN:
Yes, sir, as far as being
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19 licensed by the NRC.
I understand the Department of Energy '
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20 has some like tnis, but they are not licensed by us.
These E
21 are the only two of that configuration and that power level.
U JUDGE FERGUSON:
Could you tell us what the power
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23 level of the NBS reactor is?
24 MR. BACHMANN:
Well, of course the GETR is 50 25 megawatts thermal, and the ene at N& ional Bureau of i
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Standards is 10 megawatts thermal, and they have applied 2
for a power increase to 20 raegawatts thermal.
3 JUDGE FERGUSON:
And it's the Staf f's positj on 4
there are no similar reactors in that power range that are 2
5 lii:ense d, is that correct?
?
j 6,
MR. BACHMANN :
Licensed by the NRC, yes, sir.
j 7
We have small research reactors of much less power range, 8
for instance, under 1 megawatt thermal.
There are several a
9 of those, but in this particular power range, those are the a
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10 only two.
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11,
BY JUDGE FERGUSON:
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12 Q
Let me turn to you, Mr. Martore, for just a s
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13 moment, and recall that last Friday, I believe, we had E
E 14 begun to discuss the effects, seismic ef fe cts on the 5
15 structure of the GE Test Paactor, and we sort of postponed
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16 a discussion of soil-to-structureoccupl dag.
You had E
M 17 indicated that yea would be able to tell us very briefly f
13 something about that.
My question to you is this, and I would like for l 19 E
20 you to be as brief as possible:
5 21 Would you review very briefly for us what i
the Staff investigated in its analysis of the Licensee's
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.@ 23 submissien as regards the soil-to-structure coupling?
24 A
(Witness Martore)
When you say " investigated,"
25 do you mean the type of review that the Staff did of GE's l
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work?
you do any independent investigation of that 2
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3 matte r? ' Dic the Staff do any independent investigation?
4 A
The Staff did certain independent analyses to j
5 check the output at various steps of'GE's work; than is to f6 say, for example, we did our own analysis of the soil 3
7' springs that were used in the soil structure'iitteraction
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8 analysis and interim steps such as that throughout the g
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design and analysis procedure.
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10 Q
Are you saying that you essentially reviewed ig 11 the analysis that the Licensee did?
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12 '
A Essentially that's the role of the NRC Staff.
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13 It's to review, to set the criteria, review the methodology,
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14 the analysis, proce,dures, and then the results at various E
15 ste ps and, of course, the final results and their 2
3 16 ap pl.ic abil ity.
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17 Q
What I'm trying to get at, Mr. Martore, is
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d 19 Staff, other than the review of what the Licensee proposed l
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20 on th is particular point.
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21 A
The only independ at studies we re ag ain calcula-
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tions at interim steps, but certailly no analysis as in depth
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f 24 Q
We have had some description of how that f airly 25 detailed study was done that I believe was discussed by Dr.
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Kost and others, and I assume based on your statement and 2
your testimony that that was satisf actory; is that correct?
3 A
Yes, sir, tr.at's correct.
If I could add one 4
thing.
This is similar to the type of review that the NRC
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Staff does for -- or is common to the review NRC does for 5
6' other licenses f or power reactors and for other similar j
7' licenses.
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8 The Staff performs basically an audit review 9<
function.
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O Very good.
E 11 '
If that is the case, then let me incuire very E
,E 12 i briefly into arather matter that perhaps you have reviewed s
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13 in the same way.
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E 14 We have had some testimony about water levels, l
E3 15 the replenishing of water in the event of 5 seism!.c event,'
16 and there has been testimony as regards the rate at which 2
W 17 water will be boiled off or evaporated.
Did 30u review
'S that?
f 19 A
No, I did not.
That was reviewed by our Systems
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21,
Q Did your Systems people also review the effects of heat on the reactor shield, or was that part of your 23 review?
24 A
The reactor shield?
I'm not sure what you mean.
25 The vessel or the concrete core structure?
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Q Well, let's call it the concrete core structure.
2 A
That would have been part of my review.
3 0
Very good.
4 There was some discussion yesterday about that.
3 5
Do you recall that discussion?
5 6
A Yes, I do.
3 7,
O Then I can refer very briefly to some things g
8; that were said.
There. was a discussion about the effects,
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the radiation effects, on the concrete of the core shield, a
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10 '
and I think the testimony indicated that over the life of ig 11 '
the reactor, the shield hasaactually gotten stronger. Is
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12 l that also your belief?
s
. 13 A
Yes, sir.
1 E
14 0
And could you tell us why it is your belief
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I 15 that the shield gets stronger as it is irradiated?
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16 A
It is not my belief, or I did not mean to say 2
M 17 that it gets stronger as it is irradiated.
It is a property
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'S of concrete to increase -- its strength increases with time.
f 19 0
Yes, I think we understand that, but this is a b
20 pecul dar situation.
Not only is time hardening the i
21 concrete and causing it to strengthen, but there are other
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23 Is it your testimony that in spite of those k 24 other effects -- and I'm talking ehout the radiation 25 effects -- the net effect is that the concrete has gotten e
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stronger or is stronger new than it was when it was first 2
laid?
3 A
Yes, sir.
It is my belief that the net area 4
or the significant part of the area of the concrete that That is j
5 does resist the various loads does get stronger.
~f6 to say that if there were any effects' from irradiation, 3
7i that that would be restricted to a smaller portion of the 8;
concrete.
E 9'
O Presumably very close to the core;' isthhat a
4 10 correct?
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5 11 A
Yes, sir.
j 12 '
O All right.
Perhaps we 'll get back to you, Mr.
E 13 Martore, but I' d like to ask you a cuestion, Mr. Nelson,
li 5
14 regarding your testimony.
I was a little perplexed.
On
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5 page 3 of your testimony, you state in your answer N'o.
15
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E 16 that :
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17 "If the equipment identifi5ed in Section l
'3 A satisfies the seismic design criteria for I
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19 the GETR site and remains operable to the I
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20 extent described in Section A, tne re actor i
5 core and irradiated material.in the storage 21
, '2 canal will remain submerged in coolant, and
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$* 23 ade cuately cooled during and following tre
- /
24 design basis seismic events."
Now did you have Pny question about the f act l
25 i
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that the equipment would in f act satisfy the criteria in 2
section A?
3 A
(Witness Nelson)
When Section A was written, it 4
was to verify the identification that had been made of 5
what equipment was safety-related and direct the engineering 5
6 review to the equipment that required seismic qualification.
3 7
Q What I'm asking you is, do you have any quest in
~
~
g 8;
in your mind that the equipment will in f act satisfy the 9'
criteria in section A7 a
4 10 A
At this time, no, sir, the re's no quest ion.
j ig 11 '
Q What do you mean by "at this time"?
3y 12 i A
This equipment that needed seismic -- or needed 13 to be seismically qualif id was identified during the 4
2 14 initial phase or shortly af ter the General Electric Test
=
E 15 Reactor was shut down.
At that time the proper seismic iy 16 desi,gn citeria had not even been determined, and that's why 9
5 17 it's written in this fashion.
l
'3 0
All right.
I'm a little more confused now than 19 I was in the beginning.
Is this answer something that you E
20 answered a long time ago and it's not your answer new to i.
l 21 the question No. 5 that has been asked?
3 l
T A
No, I believe, first of all, it was a review
~
23 done a while ago, couple of years ago, and updated as t
l 24 necessary.
l 25 But, secondly, the only purpose of Section A of l
i
/.1.::ERecN NE.SCRT*NG COMP ANY. ;NC.
2242 ar2-8 1
the SER was to identify the equipment that should be seismica ll-2 qualified. and not make a conclusion regarding its seism i:
3 qualification, and I believe that's all that statement 4
indicates.
5 The SER was written in, or this pa' ticular port br r
5 6
of the SER was written in four sections, this being the 3
7' first.
g 8:
Q In 1980, October 27, 1980; is that correct?
9 A
Yes, sir.
But it was -- Section A identified a
4 10 the equipment that must be seismically qualified.
Section ig 11 i B discussed in detail the electrical aspects of the review.
H j
L2 Q
I think that's cle ar, yes.
But I'm only trying 13 to get your feeling or your answer to the s qpestion c;
14 that was asked in question No. 5 of you by the Staff,
r E
15 presumably.
Wha't is your feeling today?
E 16 A
It says written in the answer, if that equipment 2
W 17 Sentified in Section A satisfies the seismic design f
'S criteria, then the fuel will remain, you know, cove red d
19 and adequately cooled.
l b
20 Q
What, Mr. Nelson, is the Staff doing, based on 1
5 21 your understanding, to be sure that that equipment does in 12 f act satisfy the criteria in Section A?
What will it do?
~
23 A
As far as the functional criteria, and that is g
E'C; 24 that valves be operable or flow rates be established and l
25 maintained, there are a number of items that are done or l
I l
- ,cLqscn qtsoft-*Ne COMPANY. INC.
2243 ar2-9 l
1 have been done and will be done to assure that the equipment 2
functions. as indicated.
3 One is reviewed f rom the seismic design basis 4
to assure that it's capable of performing its intended 2
5 function.
6-Secondly, we impose limits through technical 3
7 specifications to ensure that the functioning of the system
~
~
g 8;
-- for example, flow rates, operability of ele ctrical
- e 9
valves -- are periodically checked to verify that these a
4 10 equipments continue to operate as designed.
i E
11 Q
And this is dono during your normal inspection H
j 12 procedure?
s
~.
13 A
Yes, sir.
The technical speu:ifications will be 2
5 14 imposed before the GE Test Reactor resumes operation,
E 15 assuming that-it does, and the compliance with technical 2
y 16 specifications and periodic test and maintenance procedures Ey 17 is verified by our office of Inspection & Enforcement.
i h
'S Q
Yes, I understand.
f 19 okay, following that same line, if I may, Mr.
l 20 Burdoin, there is a description of the se ismic triggers.
E 21 A
(Witness Burdoin)
Yes.
T-
'2 '
Q And they are in the SER.
As I understand
~
23 '
those seismic triggers, they are small coils that'ine asure 2 N 24 acceleration.
I think it says they are three octagonal 25 coils, is that right, that move?
Or are accelerated by an A*
E.*i4cN 9E. cfC"NG COMP ANY. INC.
i 2244 ar2-10 1
event, a seismic event, and those are sort of electromechanic al 2
type devices?
3 A
There are three transducers that are electro-4 magnetic.
}
5, o
Excuse me just a moment.
Let me finish asking
'?
5.,
6 the> question.
3 7
There is a discussion regarding the. point at Q
which the seismic triggers will scram a reactor and that, I 9<
think, is.0lg; is that correct?
a d
10 A
- Yes, f
11 Q
What I want to get at is that that trip point M
j 12 <
is determined presumably by setting on an amplifier; is i
s
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i 13 that also correct?
E E
14 A
Yes.
r 3
15 0
And it can be changed by changing the setting of E
I 16 the amplifier; is that correct?
E i
17 A
Yes, that's the way I understand it.
].
'S Q
Very good.
And I thought we had had testimony d
19 earlier that these triggers had been qualified by the li M
E 20 manufacturer; is that correct?
3 l
21 A
Seismically qualified, yes.
I l
't2 Q
Ok ay.
My question to you is -- and it concerns 23
-- relates to my concern about qualifications.
Whose h
24 statements do we take as regards equipment being qualified?
25 Do you know of the procedure by which these triggers will be
/.t.J",E3t4CN agycg='NC COMP ANY. INC.
2245 ar2-11 1
-- or the level at which these triggers will be operated 2
by seismic event -- how that level is routinely detemined?
3 A
well,' as I unde rst and it, these triggers are 4
qualified up to.5g.
2 5
Q Right.
j 6,
A There is different methods of qualifying them.
7l These being small devices, they can put them on a shaker
~
table and shake them.
e 9
Q Excuse me, Mr. Burdoin.
I don't like to interrupt a
a 4
10 you, but really what I want to get at is, I am assuming i
5 11 i that the triggers have beeni c2alified before insta11at ion L3 5
12 i up to.5g by the manuf acturer.
They are installed.
E 13 Somehow the electronic circuitry is designed to trip to W
y 14
.0lg, but that set point
- is detemined by an adjustment of
=3 15 an amplif.ier; is that correct?
E 16 A
Yes.
2 M
17 Q
My question is, what assures us that that f
'S setting at which the triggers will operate will always be ti 19
.Olg?
Do you understand my question?
I 2
E 20 A
Well, these things are periodically checked E
j 21 and calibrated to determine that the setting is still set e~
'2 at that proper position.
l l
23 Q
Okay.
Now how is that done?
That is my question, Ek 24 A
I can' t give you the exact mechanics of it.
l 25 It's done periodically -- and when I say periodically, as I f.czasen = rem se c:MPANY. INC.
ar2-12 2246 I
recall,. it's checked annually and calibrated annually.
2 The setting, I think, is checked more f requently than that.
3 Q
Do you think that that's a point that we all 4
should be concerned about?
2 5
A No, I don' t think it's a point that we should be 5
6!
too concerned about. I den't think you're going to find 3
7 this equ(7 ment drifting that much.
You will find 8
electronic equipment will drif t slightly, but it's not g
9 going to drif t' from say.0lg up beyond.5g.
a 4
10 '
0 And what's the basis of that statement, s ir?
ig 11 '
A Well, the basis of that statement is that I have E
j 12 :
been in this business a long time, and I know what drifts s
13 in electronic e ouipment can amount to, and you can expect
~
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14 5 to 10 percent drif t.
==
15 0
I see.
2 E
16 If a component in an amplifier in fact fails, p
3 17 that would exceed the normal drif t that you are speaking
'S about; is that correct?
It would not respond?
l g
19 A
Possibly, yes.
Not in every instance of a b
20 f ailure would the drift ex ed that, but depending upon E
21 certain components.
'2 Q
There is a component that you can envision that
~
23 would f ail and cause the drift to be more than that; is 24 that correet, more than. Sg?
25 A
I suppose so.
i
/, gqdcN ME.SclC*MC COMPANY. INC.
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2247 ar2-13 1
Q Well, let's assume that that one f ails, and that's the case that I'm concerned about, and that point 2
seems to indicate to me that it's important to calibrate 3
4 thes' struments regularly or periodically, to use your j
5 word, and I was really concerned about how that was done.
6l But is it your testimony that you cannot in j
7 f act testify to that?
3, A
As to how it's done, no, I can't.
3 g
Q Is there anyone on the panel who can?
10 '
A I doubt it.
f 11 i Q
okay.
What will be in NRC's licensing and 2
- 12. ;
inspection by the licensing and inspection team to be Q
5 certain that this is done?
13 W
E 14 A
Well, the te ch specs require thist the calibration be done annually, and as I stated earlier, the checking is i
15 n
b 16 done more frequently.
Tech spec requirement is just that, I
i 17 a requirement, in that the Licensee has to conform to it.
And records are checked periodically in.' audits by the n.
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19 NRC to determine that these things indeed are done.
N If they are f ound that they are not done, then l
t; 20 l
I E
they are in noncompliance and they are not in accordan l
21 3 n!
with tech specs, and then they are subject to action.
l 23 Q
I think that's a very general statement, and i
l i
I can' t disagree with it, Mr. Burdoin, but I'm a little l
24 ;
1 uneasy, I guess, at this particular point to feel or to l
25 1
/.i ERicN RE.*cft""Ne COMP ANY. NC.
2248 ar2-14 1
understand that no one here can tell us in fact how that 2
calibration is done.
I am concerned about it.
I thi s it 3
is an important point.
4 A
(Witness Nelson)
Excuse me, your Honor.
I'd j
5 like to just add something.
I can' t add that specif ic
~
j 6
datai as to actually how the coils are moved annually, but j
7 that is what would be required to check the output, whether g
8; it is done by shaking or other means.
That would be at the 3
9 annual check.
a a
ci 10 Periodically, at every reactor shutdown, which is
=
2 11 '
on the order of two to three weeks, they would check the 3
5 12 balance of the system beyond the detector, and I know 5
13 that; they have obtained equipment f rom the manuf acturer 1
3 14 of these things to, do that. anntial check.
I just don't know a
15 exactly how they move the coils.
[
16 Q
I would think, Mr. Nelson, that a certain motion 2
M 17 of the coil must give a certain output from the amplifier,
'S and that presumably is related to the acceleration.
l 19 All right, let me ask one question.
We are l
.=
E 20 going back now to the ' boiling of the water, the evaporation l
E 21 of the water af ter a seismic event, and the core has been l
' '2 '
shut down.
There are several statements in the SER that
.$ 23 indicate that water must be replenished at a certain rate.
' 5 24 I think the SER rays that the replenishment rate must be
/
l 25 1.96 or scxnething like that gallons per minuta.
I could l
l l
/." :ERicN RE.ScR7"MG COMPANY. INc.
l 1
2249 ar2-15 1
possibly find that if I thumb through this quickly, but 2
does anyone on the< panel have that number?
3 A
Yes, sir.
It's 2.44 g allons pe r minute.
4 Q
Where will I find that in the SER?
3 5,
A It's in Section 2-A of the October 27th SER.
l 5
6 I'll get the page number shortly.
3 7
0 Well, I have page A-2 of the Octobe r 27' SER, but g
I don' t see that number two point whateve r it was you gave 9
us.
a a
d 10 A
The number is on Section E on page A-5.
Also ig 11 the number is -- there are two components to that number.
E j
12 i There are two things which add up.
That is the makeup 5
13 required for the reactor core itself,
.8 gallons per minute,
~
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14 which is on page A-2, and che makeup required for the l
a 15 fuel s.torage canal, which is 1.64 gallons per minute.
I'm i
16 trying to locate that page right now.
2 i
l M
17 Q
That, I believe, is on A-2.
[-
'S A
Yes, sir.
But those values must be added togethe; l
g 19 to find the system requirements for the fuel loading system,;
l 1
i x
U 20 and that is to be supplied by each of two redundant systems. '
I E
21 Q
Correet me if I'm wrong on this, but I thought
'M the Licensee's experts indicated that the fuel flood system I
~ 23 was capable of supplying two gallons pe r minute.
l
~
l 24 A
I'm not aware of that.
25 JUDGE FERGUSON:
Mr. Edgar, do you have anyone --
I l
l
/.cg.9dcN ?.E.ScRT*Nc COMPANY. !NC.
4 ar2-16 1
MR. EDGAR:
Mr. Gilliland can answer that right 2
away, I think.
3 What is the capacity, flow capacity of the fuel 4
flooding system total, and then per tank?
j 5
MR. GILLILAND:
Flow capacity?
6 JUDGE FERGUSON:
The replenishment capacity j
7l which may be equal to the flow capacity.
8l MR..GILLILAND:
Let me state two values.
The 3
A 9
design flow is in the ' vicinity of eight to nine gallons per a
d 10 minute.We haven'tmeasured the system because it's not been f
11 installed, so we don' t actually know what the value is.
!L E
12 We believe it will be higher than that, as 13 And the capacity of the reservoir is 100,000
~
W E
14 gallons for each of the two sy, stems.
The re are two 50,000 E
3 15 gallon tanks.
There are two 50,000 gallon tanks in each of i
g 16 two locations.
So each leg has 100,000 gallons capacity, 9
i 17 each leg supplies a design flow rate of that value, although f.
3 the required value is much lower than that.
And we will d
19 be reducing the flow, controlling the flow, to meet the l
M i
a 20 design requirement as appropriate.
E 21 '
JUDGE FERGUSON:
The replenishment rate is about 3 u' 9 gallons per minute, did you say?
23 MR. GILLILAND:
The design value, that is pipe
> $' 24 sizing and so forth, were based on that requirement, and 25 the flow will be adjusted to meet the demand.
f;,=g.mn nr.=ca-na c:MPa?W. INC.
2251 ar2-17 1
JUDGE FEPGUSON:
I understand.
2 MR. GILLILAND:
That is, it will be fixed, but 3
onm we get the system in place and test it, then we'll be 4
in a position to --
3 5
JUDGE FERGUSON:
So it will more than adequately
'?
j 6
satisfy the 2.44 gallons?,
j 7'
MR. GILLILAND:
Yes, sir.
8, JUDGE FERGUSON:
Fine.
E 2
9<
BY JUDGE FERGUSON:
a 4
10 Q
Now that 2.44, let's focus on that for just a i
E 11 brief minute.
That, you say, on page A-5 is the maximum M
j 12 evaporation rate f rom irradiated fuel subsequent to the s
13 postulated canal and pool drainage.
I E
14 Was that a correct reading of what's on page A-5?
E3 15 cnd 2 i
16 I
3 17 E.
13 m
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5 E
20 1
=
6-21 3
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2252 JWBsach 43 1
A (Witness Nelson)
Yes, it is.
2 O
My question is:
When does that maximum --
3 I guess that flow rate is determined by the rate at 4
which water is evaporated?
Is that correct?
}
5 A
Yes, it is, sir.
g 6
g And when is that maximum evaporation 3
7 understood to occur after shutdown, after scram?
8 A
The point at which maximum evaporation is g
9 required and makeup is required to compensate for that
~
a i
d 10 '
evaporation is the point where the water level reaches 4
E 11,
the top of the core, or the stop of the stored fuel in s
5 L2 '
the storaae canal, which for the fuel stored in the 5"
~
~.
13 storage canal is approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after shutdown,
'I j
14 or about 24 or 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> after the seismic event.
And
- a 15 for the core, it is approximately 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> after the 2
y 16 seismic event.
M 17 4
Yes, but I don't think that really answers
'3 my question.
Perhaps I should ask the question again.
(
19 My question is:
When will the maximum boiloff, or l
C 20 evaporation take place after shutdown?
a I
5 21 A
The maximum evaporation would be -- the l
~
maximum heat input is immediately after shutdown.
12
.$ 23 g
Immediately after shutdown?
h 7 24 A
Yes, air.
And it decays from there.
But it t
i i
25 is not needed as far as determining the required makeup l
ggg3scN p,!?cfC*NG COMP ANY. INC.
2253 3-2 jwb 1
rate because there is already sufficient inventory of 2
coolant in the system.
3 JUDGE FERGUSON:
All right.
Thank you.
I 4
have no further questions.
JUDGE GROSSMAN:
Judge Foreman?
I 6
JUDGE FOREMAN:
I don't have any questions of 7
2 this panel.
BY JUDGE GROSSMAN:
9, 4
Mr. Martore, one question.
You are familiar
.u 10 '
~*
with the soils under the reactor, are you?
E 11 '
y A
(Witness Martore)
To the extent that they 12 i g
affect the soil / structure interaction analysis, yes, sir.
13 f
G How would you describe the soils?
f-A The soils are Livermore gravels, I believe.
I 15 What I looked at was the properties that were given to a
me by the geotechnical engineers, and then used that to U
17 determine the spring constant properties that are used
=
ig d
in the analysis.
So that I do not get directly involved b
1'~
with the type of soils, but use the properties that are a
1 l
E 20 given to me by the experts.
l 21 G
I see.
And how would you describe Livermore e
", 12 gravels?
E5hE55 3 A
I'm not sure I understand the question.
r g
24 0
Well, are they soft, hard?
Is there any 25 other way of describing them?
l
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3-3 jwb 2254 1
A Excuse me.
2 (Witnesses conferring.)
3 MR. BACHMANN:
Chairman Grossman, may I make 4
a comment here, p' lease, sir?
5 JUDGE GROSSMAN:
Certainly.
3 MR. BACEMANN:
I don't believe that j
7 Mr. Martore's expertise lies in descriptions of soils 8
as such, but merely in their interaction description by 9
means of mathematical engineering models.
I might a
a d
10 point out, though, that on page five of the' stipulation i
11 in Section M and N, there is a stipulated -- well, E
j 12 there'is a stipulation, for instance, "The base of the s
~
UI GETR foundation mat which is located about 20 feet below I
5 14 grade is underlain by very dense clay, sand, and gravel E=
15 with occasional layers of very dense sandy and/or
.=
E 16 gravely c:ay to a depth of seven feet."
l 9
i 17 Now if that is the type of qualitative i
e
[-
'3 description, all parties have agreed to that.
l g
19 JUDGE GROSSMAN:
That's fine, then.
I
=
3 20 withdraw the question, Mr. Martore.
G 21 Redirect?
e 12 MR. BACHMANN:
May we have a short, five-zgggg; 23 minute break to see if we need any redirect?
I 24 JUDGE GROSSMAN:
Certainly.
e j
25 MR. BAChMANN:
Thank you.
l f.;;;g;tscN RE.scIC*NG C:llMP ANY. INC.
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(Recess.)
2 JUDGE GROSSMAN:
Mr. Bachmann?
3 MR. BACHMANN:
Yes, sir.
~
4 REDIRECT EXAMINATION
,g 5*
BY MR. BACHMANN:
6-lll (L
Yes, sir.
Previously Judge Ferguson had f
7' asked Mr. Burdoin about the seismic triggers, and I 8
would like to adtress that in a brief question to him.
9' Mr. Burdoin, you indicated to Judge
~
,u i
10 Ferguson certain confidence levels you had in the seismic
=
11 triggers at the GETR reactor.
Would you please expand a 5
Ui bit on that?
There seemed to have been some question as s
~
13 to reliability.
l 14 A.
(Witness Burdoin:
With regard to the confi,-
I E
16 dence that I have in the operation of these devices, O
l g
16 Southern Cal Edison has had these devices in operation i
2 M
17 at some 100 locations for a period of 10 years.
In that Sg W
time, they have never experienced one failure for the 1
19 device to operate when it was required to. operate.
l 20 They were using these devices primarily to 21 operate -- to trigger and initiate the recorders.
l e
Y Basically, that is my basis for confidence in them.
.g 23 Secondly, we have two of these mounted there 24 at GETR, and if one fails to operate the other is 25 available to operate.
- .gg,qscn ?.??cR* NG CCMPANY. ;NC.
3-5 jwb 2256 1
The third issue, these are checked quarterly 2
and if there is a failure in the amplifier, it will be 3
picked up at that time.
4 That's all I have.
5 FURTHER BOARD EXAMINATION 6:
BY JUDGE FERGUSON:
3 7'
4 How will it be picked up, Mr. Burdoin?
8 A
(Witness Burdoin)
When they make their 3
9' quarterly check of the system, they will determine that a
a d
10 '
the amplifier is not working.
ig 11 3
That's a calibration procedure, right?
E j
12 i A
Well, no.
That's a checking procedure.
5 13 Calibrations are annually.
.'i 5
14 g
Well, let's not be confused by semantics, r
3 15 First of all, let me say that I appreciate your additional l
h 16 statement.
I hope my concern was clear.
They may be l
E l
M 17 very reliable.
' was interested in the level at which f
'3 the device is tripped, and the assurance that one has g
19 that that level is in fact what we think it is.
l
=
20 A
In the calibration that determines the level
[
H" E
21 at which it trips, they use the calibrated voltage at 12 the input to the amplifier to calibrate the amplifier, Egggg; 23 and the point at which it will trip at.01g.
I'<s 24 (Witnesses conferring.)
25 g
Did you have something further, Mr. Burdoin?
l 1
- .wgnscn Rz?ctc'NG c;MP ANY. INC.
l 2257 3-6 jwb 1
A Well, at the calibration which I mentioned, 1
2 which is an annual operation, they use this calibrated 3
voltage input to the amplifier to set the end trip set.
4 They also check the operation of the seismic switch itself 5
by blowing on it or moving the device so that it will l
j 6
operate, and then initiate an operation.
7 At that time, the entire circuit is operating.
G Well, I don't want to prolong this.
Did 8
- =
9 you have something to add, Mr. Nelson?
u 4
10 A
(Witness Nelson)
Yes, sir.
I would just ig ll i like to try to clarify the sequence and timing of E
r l
5 12 testings to verify reliability of set points in this s
].
13 case, the seismic triggers.
Annually they will verify 5
14 that input motions comparable to a.Olg will move this
~=
=
15 detector or these coils.
l 16 G
What is the driving force for those motions?
2 M
17 A
This is a piece of equipment that the 53 manufacturer supplies.
J 19 0
I see.
l 20 A
And more frequently they check that that l
E l
21 motion, the output from that motion, is the correct 22 value of signal to scram the reactor.
And that is done Eg 23 quarterly and, to a certain extent, after each shutdown N 24 two to three weeks.
25 g
So the picture is that there is some Agg;tscN RE-cR"'NC COMPANY. lNC.
I l
I
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1 mechanical signal generator, so to speak, that will i
2 move the coils given amount; and that then is measured in terms of the output signal?
Is that correct?
4 A.
Yes, sir.
K 5
JUDGE FERGUSON:
Thank you, Mr. Nelson.
I 6-t l
Mr. Edgar, did you have anything that you 1
3 7
l wanted to add?
0 MR. EDGAR:
No, sir.
I think that is the I
sum and substance of what Mr. Gilliland had advised me.
u 4
10 JUDGE FERGUSON:
I see.
Thank you.
ic 11 I
JUDGE GROSSMAN:
Mr. Bachmann?
E U
MR. BACHMANN:
I have no other questions, 5
].
13 your Honor.
=
g 14
~
JUDGE GROSSMAN:
Mr. Cady?
I 15 MR. CADY:
No questions.
16
?
JUDGE GROSSMAN:
Mr. Edgar?
U 17
=
MR. EDGAR:
I have one clarifying question.
9 RECROSS-EXAMINATION 1
g 19 BY MR. EDGAR:
l C
20 Mr. Martore, earlier on yoa were asked about i
0 i
h 21 soil properties and the input you get from your geotech-j i
i g
l nical experts.
In regard to the structural analysis that j
~ 23 i
+-
GE performed, that analysis performed by Dr. Kost, you 24 were the principal reviewer?
Is that correct?
25 A.
(Witness Martore)
Of the structural analysis, f,-sqscn p1=cftT*NG C:l:MP ANY. ;NC.
.. _ ~
. ~.. -,. _ _ -
3-8 jwb 2258
~
1 yes.
2 G
And in regard to the soil-bearing capacity 3
values used in that analysis, would your conclusions in 4
regard to the validity of the analysis be in the j
5 affirmative if soil-bearing capacity value of a larger 6
value of 30 ksf were used?
3 7
A If a larger value than 20 ksf?
8, G
No, if a value of 30 ksf were used.
3 9<
A Yes.
My understanding is that the type of a
4 10 analysis that were done was a reasonable and adequate ig 11 analysis.
The question was brought up as to the strength 9
j 12 i of the soils, and I would agree that if a soil strength 5
~
13 that was acceptable to the geotechnical experts of the
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14 staff was used, that the type of analysis and procedures
- 3 15 would be acceptable for the structurgl. review.
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16 MR. EDGAR:
Thank you.
9 3
17 JUDGE GROSSMAN:
Does that conclude the
'3 direct and cross?
$$ 19 WITNESS MARTORE:
Your Honcr, I had one E
20 other clarification, if you require.
Judge Ferguson t
I f
5 21 had asked on Friday if we could specify what the vertical 1
12 accelerations were and the amplification through the i
23 structure.
I did get that information.
I am not sure Y'C 24 whether it is still of interest?
s 25 JUDGE FERGUSON:
Please.
Please give it to i
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us if you have it.
2 WITNESS MARTORE:
As we said on Friday, for 3
the Calaveras event the vertical input acceleration 4
was two-thirds of the'.75g.
That then is amplified
}
5 through the structure to a small amount, to.8g as a f
6l peak floor acceleration at the highest floor level; and 3
7 then the spectral accelerations are accordingly 8
amplified.
g 9
BOARD EXAMINATION
~
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10 '
BY JUDGE FERGUSON:
4 a
11 4
The numbers you have just given us, except E
E 12 i for the measured value on the Calaveras, are all "s
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13 calculated numbers?
E 5
14 A.
(Witness Martore)
Yes, sir.
The input is 3
15 a design input which was specified.
And then the y
16 speak floor acceleration of.8g was calculated E
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I see.
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In addition, the spectral numbers are also l
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20 calculated.
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If I remember correctly, there was a
'2 measurement taken on the third floor, was there not, of g 23 an acceleration?
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Yes, sir, during a recent event.
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I see.
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2 A
No.
That would not agree because the input
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magnitude or the same frequency content.
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I meant proportional.
That is, if you 6
scaled up' presumably the value, would you get the.8?
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4 Mr. Martore, I am always trying to associate 21 calculated numbers with instrumental values, but you say ee~
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in this case there is no relationship, or none was qg 23 investigated?
A That's true.
At the General Electric Test l
25 there was an instrument at the upper level, but
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you are suggesting.
4 The other point that I was trying to make 5
is:
If we did have that lower level instrumental value I
6 and tried to ratio it up, my judgment as an expert would i
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be that the calculated numbers that we are showing would 8
indicate a higher amplification in the calculations a
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4 10 input that we are requiring in our analysis.
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4 So the.8g is a conservative number?
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Yes, sir.
5 14 JUDGE FERGUSON:
Thank you, Mr. Martore.
r3 15 BY JUDGE FOREMAN:
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3 I have a quick question, sort of a catch-up M
17 question not directly related to the subject this morning, 3
d and it might better have been addressed to Dr. Vesely, f-19 but I think Mr. Nelson might be able to speak to it.
.O This deals with the statement that
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But when the probability dropped 24 down to 10-then attention was directed to these matters.
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the thinking was this.
2 My question of you then, is:
Have you had 3
occasions where in your site analyses, analysis of sites 4
or other kinds of analyses in which you had to deal with --
y5 in which the probabilities for tectonic events indeed 6
were 10,3.j
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(Witnesses conferring.)
8 A.
(Witness Nelson)
Your Honor, I don't think 9
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I have enough information to answer that question for u
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Mr. Martore might be able to discuss i
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5 12 '
Q.
I really don't want a long answer.
I just 5
[a-13 wanted to know whether that ever really happens, for 5
14 example.
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A.
(Witness Martore)
The only point that I would i
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is of a return period on the order of 1000 years, some-l h
19 thing in that range, which would be 10 And if you l
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'2 magnitude events on the Calaveras and Verona were on 23 the order of a return period of 1 in 1000.
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One in 1000?
Or 1 in 10,000?
25 A.
One in 1000.
The magnitudes were on that
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I guess I don't understand that.
3 A
(Witness Nelson)
That number can't be
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considered the likelihood of offset underneath the a
5 6
reactor.
71 JUDGE. FOREMAN:
I see.
JUDGE GROSSMAN:
Thank you, gentlemen.
You
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are excused.
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(Panel excused.)
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JUDGE GROSSMAN:
I believe now we are up to Mr. Meehan's testimony?
13 MR. EDGAR:
Yes.
We would like to call f
5_
Mr, Meehan and Dr. Kost to the witness stand, and
-3 15 Mr. Harding, if h5 would join them.
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Whereupon, U
17 GARRISON KOST,
'3 RICHARD HARDING, d
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E 20 RICHARD MEEHAN E
were recalled as witnesses on behalf of the Licensee and, 21 3
' 12 having been previously duly sworn, were examined and
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N 24 JUDGE GROSSMAN:
Could you please state your 25 names for the reporter, again?
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WITNESS KOST:
My name is Garrison Kost.
I 2
am with Engineering Cecision Analysis Company, Palo Alto, 3
4 WITNESS EARDING:
Richard Harding, Earth 5
Sciences Associates, Palo Alto, California.
6 WITNESS MEEHAN:
Richard Meehan, Earth 3
7' Sciences Associates, Palo Also.
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JUDGE GROSSMAN:
Judge Foreman?
Y 9
BOARD EXAMINATION a
4 10 BY JUDGE FOREMAN:
f 11 '
4 Mr. Meehan, first of all, I want you tc M
j 12 know that I am aware that you have been flying all night 5
13 and I am sorry that it happened.
I should 'ay that for
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been more comfortable, and it wouldn't have mattered 15 i
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16 had you not arrived early this morning; later in the day Ey 17 would have been all right.
But in any event, I do i
13 appreciate your coming -- we do.
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19 I would like to start our discussion by l;
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Your findings, at least 5
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In a sense, I thought they were pretty y*C 24 startling, personally, and significant, and also I believe s
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It is true that we have information from f
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probabilistic studies that the likelihood of an event 2
under the reactor is very low, but it is useful and 3
I think important to have that backed up by information 4
that is generated partly from data that is gathered j
5 empirically and analyzed on a theoretical basis.
j 6
And in that sense, I consider at least,.
and i
7 I think our other Board members do, that your tectimony 8
is very, very important.
We talked about this a great 4
2 9
deal among ourselves, and from time to time during the a
d 10 course of this proceeding after you had provided your f
11 information at Livermore.
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12 We had asked in various ways -- sometimes S
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15 conclusions, and admittedly only one of these is a soils i
16 engineer, Dr. Pichumani, but a number of the others were 2
M 17 experienced geologists who were accustomed to observing f
'S faults and were sensitive to fault descriptions and the f
19 like, and we never were able -- at least to my mind -- to I'
b 20 get a clear understanding that any, perhaps there might I
E 21 have been one, that any of these experienced geologists 3
were aware of the kind of analysis that you have done, 22 23 and I hope you will speak to that.
And except for the I ' 24 one instance of the Banca Sandrol in Nicuaraga, no one 25 had every had occasion to observe the phenomena.
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Now I am not surprised that they didn't, 2
because I realize the probability of a fault occurring 3
underneath the building, a large building, over the 4'
world could be low, and occurring in very wide areas of
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the world it wouldn't attract attention necessarily to
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And so we felt, particularly I felt, we'd like 2
to have more clarification as to how you came to your 3
findings and your decisions, dnd in saying this, I hope 4
you recognize that we are laymen, and so that we may not be 5
able to ask directly pertinent searching questions to j
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3 7
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a place of specific questions that we ask of you.
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10 Now in going on, let me tell you very briefly ig 11 my understanding of your analyses and of the circumstances 3
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that you have described.
First. of all, the phenomenon of 5
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14 I think it's clear to me and you have made it quite clear 5
15 that to.ta very large extent that's a, function of the soil
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17 A
(Witness Meehan)
Yes, that's true.
'3 Q
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produces planes, that in reference to a whole series of
, '2 I other planes beneath the structure are planes of least j
23 resistance, and therefore the thrust that develops is i
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25 A
Yes.
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Q Let me just lay out a few things and then I' d 2
like you to sort of talk on uninterruptedly, and when you 3
are done, I will have other questions for clarification, and 4
maybe also my fellow Board members.
5 Your analysis to identify these planes of least 6
resistance -- and we didn' t get this from you, but we got j
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it from Dr. Pichumani -- involved a construct of a system
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At least he indicated that that was a method I
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5 15 Anyway, one of the statements that trigge red my V
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17 a. statement on page 92 of your testimony.
This is Exhibit
'3 22 of General Electric -- Exhibit 1, excuse me, of General d
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2269 ar4-3 1
so forth.
2 Well, with that kind of background, please 3
enlighten us in the f ashion that you feel will be helpful to 4
us in our understanding, starting anywhere.
You needn' t j
5 directly speak to the query I made in the beginning, unless 5
6 you choose to.
3 7
A Perhaps I could address two questions.
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8; to attempt to explain in simple terms what the physics of 9
this phenomenon are, in conneetion with my statement about a
4 10 it not applying to lighter structures; and the other, to ig 11 i talk about the availability or absence of other field M
5 12 case histories that one might use to confirm the theoretical 5
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14 In connection with the question of what was
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this pitcher of water here in front of me might serve to d
19 be a nuclear reactor, if you can visualize that, and let 20 us imagine that beneath this tablecloth there are two tables >
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And let us say that Mr. Harding
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My analysis is no more than attempting to look 2
at the physics of that and to ask the question of whether 3
the water pitcher would be willing to cantilever itself 4
such that part of it is hanging in air and the other part 5
is on the higher table or not.
6 My findings were that it depended on what the 7
table was made of.
If the table were made out of what it 8
j is made out of, there would be no question, a hard I
substance, perhaps a rock-like substance that is strong i
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11 i on the other hand, I find it easy to imagine U
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U 17 My analysis is no more than an attempt to apply
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some sophomore physics to that problem, and ask the equation 19 if which result is produced.
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In fact, I think it's also f airly easy to realize 21 that if this were not full of water, but rather empty, that perhaps the sand would produ the cantilever cond' tion.
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the material that we know exists underneath the GETR, and 2
asked those equations whether or not tne optimum failure 3
plane is under the re actor or not.
4 The answer we got -- I set this up on a little 5
computer, because I wanted to look e+: a, couple of hundred f6 different f ailure planes and differer load ccabinations, I
3 7
and I was never able to cause the plane to ecme up under g
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You might think of it as stair steps always that a
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That's another way to visualize the process.
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similar heavy structures, the kinds of analogies that I
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That would do 25 fine.
That woulf be an appropriate analogy.
Or, likewise, i
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perhaps rather than picking a fault, let us pick the toe 2
of the landslide, which for all intents and purposes is 3
a thrust fault, at least in the immediate vicinity of
- 4 the toe.
che ground of the structure doesn't know the 2
5 differen
, basically, and we made some attempt to try 6
to find toes of landslides that may have come up underneath j
7 heavy structures or heavy boulders or anything.
8 We were not too successful.
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are not a large number of documented case histories.
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16 was a water tank -- but apparently a f.ai:rly heavy structure,
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17 and looking at the photograph of this, it appeared that j-
'3 there was a diversion of the thrust surf ace around the tank.
I would hardly call it a conclusive experiment,
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20 and I had no other information aside f rom looking at the E
21 photograph.
It's possible we have that photograph with us.
'?2 O
That was the landslide and it came along the 23 surface.
It didn' t occur beneath the building, i
2 2A A
The landslide toe went underground and then it 25 rose up.
The landslide, perhaps in the position of Mr.
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Harding, created a thrust f ault-like feature here that to 2
my mind was analogous to the f ault condition we have.
3 I don't want to confuse this by talking about 4
landslides.
It has nothing to do with landslide vs. fault.
5 0
No, I realize that, but I guess I don't picture
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That's a thrust that occurred bene ath
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the surf ace of the earth?
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A Yes.
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It disturbed the soils beneath the earth and sg 11 '
thrust below?
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I'm not sure'how to go about showing you 1 l
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Okay, I don' t need that.
3 15 A
Oh, yes, therefis a figurd in my testiment, or
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Ey 17 A
(Witness Harding)
It's actually my testimony, I
'3 believe, page 15.
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19 A
(Witness Meehan)
There's a picture of a diagram j 20 of the landslide.
In the particular case that I had in mind, l
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21 there was a similar landslide and there happened to be an
, '2 oil tank sitting on one of those things called a thrusting toe..
So I saw a certain analogy there.
The thrusting of l
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25 This was my best success in terms of trying to l
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1 find an analogy for the case that --
2 Q
And you' re saying indeed the thrust was dive rted 3
by the oil tank?
4 A
It appears that way from the picture.
That's 5
what we felt upon looking at the picture.
The tank was not h6 tilted or seemed to be undisturbed.
It's an aerial photo-3 7
graph.
8 Q
Was the force created by the landslide of such g
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Are they forces comparable to a force i
5 11 generated by an earthquake thrust?
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A Yes.
In both cases you might consider the force S
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The structure itself would not in either
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Well, go ahead with your story.
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That is my attempt to summarize the mechanics of 19 the process and to summarize the results of my attempt to a
20 find analogous physical cases that might apply here.
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21 Q
Does it bother you for me to interrupt?
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Not at. all.
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Because maybe things would go faster and smoother
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It helps me think, anyway, f
25 Are there many instan s of thrusts occurring
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o 2275 ar4-9 1
in cities where there are heavy buildings?
2 A
Not that I'm aware of.
The San Fernando earthquake 3
was a thrust f ault.
In fact, in many ways it was comparable 4
to this.
It occurred -- much of it occurred in areas that 5
were underlain by soil, probably similar to the kind of d
6 soil we have in this situation.
It came up under quite a 5
7' few buildings.
They were principally houses, streets, 8,
curbs,relatively light buildings.
3 9-In all cases the f ault was not troubled at all
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It would simply go right i
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5 12 half.
s 13 This was exactly what I would expect.
If I had
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14 done a similar analysis using the same equations, my answer
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It's equivalent to perhaps t
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l '.2 Q
Well, I mentioned that because in view of your
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Has it been applied in other places 25 and so forth?
That's the sense in which I'm asking.
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A The issue did arise, I believe, in connection 2
with either licensing or licensing studies several years 3
ago.
There was an attempt to analyze the burial of a large 4
ring-like reactor structure, and the question was if there 5
were a strike-slip f ault and this were buried in soil, 0
5 6
rather than rock, would tihe rigidity of the reactor contain-3 7
ment be sufficient to cause the strike-slip fault to migrate O
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around the containment?
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It's a tempting analogy.
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12 4 and I believe they were conducted in support of a possible s
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I mentioned city because in view of your interest
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That would be a place to look, wouldn' t it,
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2277 ar4-ll 1
in various urban areas?
2 A
We don't have many thrust f aults in urban areas 3
that I'm aware of.
I think San Fernando is probably the 4
best one.
We certainly reviewed the literature to find 5
some analogies.
'i j
6 0
Excuse me.
Go ahead.
3 7
A I didn' t understand.
~
~
g 1
Q I interrupted you asking about whether you'd 8
- =
9 looked in urban areas, for example.
Can you pick up your a
d 10 train of thought?
ig 11 i A
We reviewed the literature for both thrust f aults E
j 12 i and strike-slip faults, but we did not find anything that 5
[i 13 we considered applicable.
E 14 I believe the Staff also made some review, and
==
15 they certainly urged us to try to find examples, too,. but h
16 neither group was successful in coming up with anything that 2
l M
17 fits this case exactly.
1 1
l 2
'3 0
Do you want to go ahead, or do you want me to ask d
19 another question then?
Which would be helpful to you?
l b
20 I think I've run out of an answer at this time.
A
~.;
21 Q
I see.
Okay.
, '2 I would, I guess at the risk of making things
. Qg difficult for myself, I would ask you to be a little more 23 24 technical in describing your analysis, the wedge analysis an 25 how it works, and then tell us why these analyses -- this l
l l
l ggg;tscN ng.scMT*NG TOMP ANY. !NC-
2278 ar4-12 1
analysis is specific for the GETR.
2 A
Perhaps I could do that with a reference to 3
one of the figures in my testimony; if I may have about 4
15 seconds, I'll try to find that.
5 (P ause. )
d 6-Figure 51 on page 91 of my initial testimony.
3 7
One might imagine this as a simple experiment that could be 8
done in the laboratory.
Unfortunately, it is not easily 2
A 9
done in the laboratory, for various complicatend scale d
4 10 factors.
ig 11 If you were to visualize this as.ia block of E_
j 12 sand and gravel being squeezed by a vice, applying force F 5
1
~.
13 to its two sides, in the absence of there being a structure i
E E
14 such as the GETR, the preferred or optimum plane of failure
=
15 might well be the plane marked 2350.
i
=
2 y
16 Q
Say that again.
Why would it be the preferred l'
E W
17 plane?
f
'S A
We might analyze 2000 different planes of I[-
19 orientation and ask the analysis which plane takes the l
i 2
l 5
20 least amount of force F to f ail.
When we have identified i
i::
21 the one that takes the least amount of force, we have 3
identified the plane that actually will fail.
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- /$ 24 identified that most f avorable f ailure plane, most likely l
25 failure plane, we might change the ground rules of the l
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2279 ar4-1]
analysis by applying the weight of the structure, as I've 1
shown here, at the location of the GETR, repeat the same 2
f thing, and ask the analysis what now is the most f avorable 3
l 4
plane, and this is what we've done by computer.
We have simply repeated the analysis for hundreds 3
5 of planes, and my approach'was to try to find one that 6
1 came up under the reactor, given the properties of the soil, 7;
to try to produce an unf avorable result.
8 "a
This was the best I could do, in terms of
=
9 10 playing devil's advocate.
The one I have illustrated here is the least favorable case f rom the standpoint of the GETR i
11 e-9 that I came up with, and I've shown only a few of the many g
g; "e
planes that were analyzed and the numbers that are written 13
'i next to the planes are the number of thousands of pcunds E
14 f f rce F that are required to cause the soil to move i
15 e
16 al ng those planes.
3I 17 The highest force, twenty-three hundred fifty
- s thousand pounds, 2 million pounds plus, is the one that ig m
comes up under the GETR.
f 19 20 The lesser force is required to cause movement
=
along any of the other planes shown, and I might have shown 21
- e a lot more.
a g
Therefore, I conclude from this, this being 23 the least f avorable case, that I am unable to find a case 24 where the preferred f ailure plane is under the reactor.
25
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No matter how I locate the reactor anywhere on that diacjram.
2 That, in a nutshell, is the basis for my conclu-3 sion.
4 Q
I guess a couple of things come to mind.
3 5
First of all, 'tell us a little more.
Then you j
6 didn't use the so-called Rankin wedge analysis to do this?
j 7
What I'm asking you is how did you arrive at 8
these numbers?
What sort of analyses?
I know you fed a 9'
program it.to the computer, but what did you feed into the a
d 10 computer to get out the result?
What sort of analysis?
ig 11 What sort of considerations were involved in the analysis 8
j 12 i other. than just the weight of the reactor bearing against i
s
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E 5
14 A
The analysis was actually a standard analysis r5 15 in soil mechanics, because we often wish to know the amount E
16 of force F it will cause, that will be necessary for 2
M 17 something to move in the ground.
'3 We have run into this in many applications.
If g
19 we try to push a wall against the soil, and that happens 20 in civil engineering design in some cases.
5 21 Q
You mean down?
3
~
9.2 l A
No, sideways.
-Q, e 23 0
okay.
N N 24' A
We need to know what F is required to cause the 25 wall to start moving.
Sometimes we bury things in the i
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ground, we don' t want them to move.
We want to know how 2
much resistance they have against moving.
The problem of 3
the tipping over of the telephone pole that's buried in 4
the ground is a similar problem to this.
You need to know 2
5 what force F is required before the buried part of the 7
6:
pole begins to rotate.
I 3
7; So the analytical technique is one that's been
~
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8 used for about 150 years in soil mechanics.
It's a 2
9 relatively common analysis.
a 4
10 '
The application of this particular problem is ig 11 <
not common, of course.
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l
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14 What we need to perform the analysis is not only l
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g 16 respect to the soil properties, too.
We need to know whether 9
3 17 the soil is saturated or unsaturated with groundwater.
f.
13 We need to know whether the load that's being applied, F l
d 19 is being applied very rapidly or very slowly.
We need to l
a 20 know what the strength characteristics of the soil are.
E 21 That's a very important consideration.
What we call the 3
l 3
friction angle of the soil is.
This is a key consideration.
. ~ 23 Its significance, I think, is evident if you consider these 24 blocks to be sliding blocks, and the f riction angle of the 25 soil would be equivalent to coefficient of friction between
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2282 ar4-16 1
blocks.
I think you could almost visualiz-this as a 2
f reshman physics problem in mechanics.
3 Q
I guess what puzzles me is why it isn't the I
4 friction between the particles of soil, rather than blocks j
5 of soil.
~
d 6
A It is the friction between the particles of soil.
3 7
I used the block analogy, too.
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It's not just chunks of earth beneath the reactor i
3 9
it's the individual particles that comprise the material a
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Both their cohesiveness and their friction.
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The science of e
i 14 h'ow soil behaves is extremely well developed.
There are r
15 probably 10 professional journals, and 50,000 p.rofessionals
=
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It's a very large 9
5 17 part of the civil engineering curriculum.
The entire
'3 technique and science has been in existence for about 50
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It is a major and fairly we11 developed field, f
19 l
10 the issue of the behavior of soil under various kinds of E
21 loading conditions.
U There are many textbooks.
It's probably 20 to
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40 percent of studknts in any civil engineering graduate 1
. $, 23 I
Y N 24-school engineering program who specialize in this field.
25 Q
You were laying out the various parameters i
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the analyses.
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A Yes.
2 G
And I stopped you at one, the friction 3
between the blocks.
4 A
I should have said, between the soil j
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6 0
I'm sorry.
.I wasn't challenging you; I was 3
7 just trying to understand.
8; And then are you going on then to lay cut
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more?
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4 10 A
No.
Those are the principal properties i
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12 4
And in that particular field, knowing those s'. 13 properties one can make calculations that lead to 3
j 14 predictions of behavior with a high degree of certainty?
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It depends on how well you know the l
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I would say, the degree of 17 certainty in the field of soil mechanics is less than it i
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25 G
But they are sufficiently reliable so that l
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they are useful and can be used, I guess applying I
conservatisms, for putting buildings in and things like 3
that?
I gather that must be so, because people do build 4
buildings and analyze soils and things do stay together.
j 5l Am I right, then?
6 lll A.
Yes.
The foundations of all major buildings k7 in many cities are on very soft soil, and their success I
is pretty much dependent on the results of analyses e
9'
[
like this.
The entire City of Boston, for example, is u
10 underlain by 200 feet of soft clay, and without these 11 i kinds of analyses it would be very difficult to design 5
12 i buildings.
E 13 G
Just out of curiosity, what underlies San E
14
-Francisco?
I 15 A.
San Francisco is underlain in.some areas by 16
.j hard zoek; in other areas, by very soft mud.
I 17 0
Well, to get back -- I was making some notes,
(
but I was so intent in what you were saying that I can't 19 read back my writing.
It was the first of the parameters f
C 20 that you said, or factored in in soil analyses, and it 21 begins with a "g"-something.
Do you recall what it was?
g A.
Groundwater level.
The level of the ground-l water.
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4 G
Groundwater.
That's right.
Now what is the 25 likelihood of groundwater and groundwater changes in the 1
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5-3 jwb 2286 1
GETR area influencing your conclusions?
Is the hydrology 2
well-enough known, and is the groundwater -- are the 3
groundwater levels s able over long periods of time so 4
that the changes need not be of concern in their effect j
5 on the soil characteristics beneath the GETF' k
6-0 A.
I performed the analysis for both the I
h7 existence of groundwater and the absence of groundwater.
8 I get less favorable but still acceptable results for
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That is a less favorable
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11 The case I have shown here I believe is for Ul no groundwater.
However, it is highly probable that
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In
'I 14
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5 fact, the groundwater is within a foot or two of the I
15 base of the foun'dation.
We did have one record from the l
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16 several years ago, when there was a drought, when
- past, I
2y 17 it dropped as low as I believe 9 feet below the base of i
5 i3
(
vi the GETR.
That is not low enough to put it in the
?
g 19 category of the "no groundwater" case.
In the no if 20 groundwater case the groundwater table would have to drop t
e-21 30 or 40 feet below the level of the GETR.
[ '2 I doubt whether in any historical time that
. { 23 such a thing has ever occurred.
It may have occurred in 24 ancient geologic time when climatic conditions were 25 1
different.
I don't feel that the groundwater is a -- I i
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5-4 jwb 2287 1
don't feel that I am dependent on a certain set of 2
groundwater conditions to establish in my own mind the 3
adequacy of this analysis.
4 g
Okay.
Then pursuing further into the direction j
5, that I felt I was going, you have outlined the parameters j
6 that are involved in this soil analysis --
b 7
A.
Yes.
8; G
-- in order to make calculations with reupect to i
9' the forces that are involved, the forces generated by the a
d 10 '
weight of the GETR for example.
i 11 How do these interrelate?
What sort of U'
equations, or what sort of relationships do you develop
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13 in order to come out with numbers relating to the forces 5
14 that you describe here?
Can you give us some idea?
In 15 other words, I am asking you to go into a little more 3
.=
16 technical detail than you have.
i 17 A.
Would it be helpful or appropriate to refer ts vi to Reference 72?
Is that part of the testimony?
h II MR. EDGAR:
It is Exhibit No. 20 in the 2
20 Licensee's Exhibits.
9 7i:[
21 JUDGE GROSSMAN:
Mr. Meehan, I don't think U
we want to be unfair to you, but you have been up all g 23 night on the plane.
If that is already in the exhibits, N 24 I don't think we ought to make you repeat it.
Is it all 25 found there in that exhibit?
3-y3cn nssom NG ccMPANY. INC-
5-5 jwb 2288 1
WITNESS MEEHAN:
I think perhaps Dr. Foreman 2
said he wanted to get a feel for the kind of calculation, 3
and if he referred to the -- I believe it is Appendix --
4 it is the appendix to that exhibit, and the equations j
5 are written out there in I think fairly straightfcrward 6
terms.
They are really not very difficult to follow, I 3
7 don't think.
l g
8; JUDGE GROSSMAN:
Okay.
That's fine for our I
9 purposes.
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10 JUDGE FOREMAN:
Well, I am not entirely sure 11 that it is.
M E
12 i BY JUDGE FOREMAN:
S
. 13 0
Is there any way for you to summarize then i
E 14 in a sense to give me some understanding as to those
=
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E i
5 16 A
(Witness Meehan)
They would be the comparable 9
3 17 kinds of equations that one would use if I were to tilt f
53 the table and try to pull these things (indicating) or d
19 push them up the hill or down the hill.
They would M
M 20 contain resolution of forces.
It would be a matter of I
r*
j 21 combining imposed forces and gravitational forces, and 12 solving the equation of equilibrium to find the unknown, g
23 which would be the force that would be required to push
&*C 24 this thing, or cause the soil to move.
s 25 g
Just go through briefly those four forces, i
l 4-gg,ucn as-ca-Nc ccMPANY. INC.
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5-6 jwb 2289 gravitational forces -- what were the others?
2 A
Weight of the soil, and the strength 3
properties of the soil, the location of the groundwater 4
table, the' weight of the reactor.
Those would be the 3
5 inputs.
j; 6
The output would be the force F shcan on j
7' Figure 1 required to -- on Figure 51, I'm sorry --
~
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8 required to cause a movement for any one of the planes.
You would have to repeat it again and again for each 9<
a i
10 '
plane.
f 11 0
okay.
I think that gives me the general 2
g 12 i idea.
In fact, that is exactly what I wanted.
I don't s
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E 14 them particularly,,as you would explicitly in your E
15 equations.
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16 Now would you go ahead, then, and speak to E
5 17 why these conditions are specific and GETR and don't f.
13 apply to other structures?
d 19 A
The principal special condition that exists l
5 E
20 at GETR in my view is the weight of the reactor.
The E
21 weight of the reactor is 4000 pounds per square foot.
i 12 The results are dependent on that.
If they were 2000
~
23 pounds per square foot, the analysis would probably give I
' 24 you an entirely different result.
That information I 25 obtained from the structural engineers, and probably
- g34cN s.E. tort *MG C*.MP ANY. lNC.
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5-7 jwb 2290 1
Dr. Kost could comment better than I could on the 2
reliability of that sort of number.
3 Would you care to comment, Gary?
4 A
(Witness Kost)
I think we know the weight 5
of the building very well.
It is an easily calculated 6
number.
7 A
(Witness Meehan)
The other parameters, the I
l groundwater I have previously discussed.
The soil 3
I properties we obtained from both the results of laboratory u
d 10 '
the results of field tests, and also we can back-
- tests, i*
11 g
figure the soil properties by looking at the orientation j
12 '
of failure planes that we can observe in the trenches 1
=
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where faults were observed.
1 '4 So we have basically three kinds of wdys of 5r a
15 inferring the strength properties *of the soil.
=
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To the extent that these conditions are p
i 17 appropriate for the GETR, would this sort of analysis I
'I be used for other nuclear power plants, given the soil II conditions that approximate those at GETR7 l
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20 A
I think they well might..As I mentioned 21 previously, I think some attempt has been made to use a l
22 similar analysis in connection wi~h buried -- to try to c
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to determine whether buried plants migh: be immune from 24 Saulting under certain circumstances.
25 I am not -- it probably hasn't been used a f.ggggcN RE.scM-"Mc c::MP ANY. INC.
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great deal because ordinarily in siting new plants the 2
attempt is made to provide such a level of assurance 3
against the potential for faulting that no special 4
considerations have to be made of faulting.
j I
5 g
g They don't need the assurance that the I
6 ll:
rupture will not occur beneath the plant?
Is that what h7 you're saying?
8'i A.
They would be required to settle the issue e
I I
on geologic grounds, thereby eliminating the need for u
4 10 doing any special structural analyses.
That has been my 11 '
experience.
U g
So in that sense, this is why -- that is why U
this is the first time that it has come up in the hearings k
14 such as this, because there hasn't been the need, or no I
15 one has felt the necessity of making that sort of C
16 calculation?
i 17 I believe that's true.
A.
53 d
g And then once again, as I understand it, and
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19 I think correctly, that this all ettes abcut from well C
20 i
recognized, long applied methods that are used for soil I
h 21 analysis?
'2 A.
Th'at's true.
23 S
And that another competent, or other competent soil engineers such as yourself would come up with the same 25 kind of analysis and consider that appropriate, that
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5-9 jwb 2292 1
analysis appropriate, and would come up with the same 2
kinds of numbers as you?
I am not doubting you at all.
3 I would just like to have this in the record, so to speak.
4 A
I think that would be the case.
I believe j
5 the NRC Staff took a rather independent look at this.
My 6
understanding is they came up with similar results.
In 7
y, fact, I think they tried some other variations in the 8
analysis that I had not tried.
3 I'
G I thought that what their contribution was u
l 10 was they reviewed what you did, and they talked about a 2
h 11 Rankin wedge analysis that I think was attributed to I
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your theory, but apparently it' isn't.
I may have misread 0
their testimony.
And then they applied other parameters.
14
~
They gave different boundary conditions or if they i
1c weren't boundary conditions, other numbers and found 16 that the conclusions that you drew would come out the U
17 That is my impression.
=
same way.
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A I think that's correct.
O.
Well, as far as I'm concerned, I am s.2tisfied l
11 20 l
with what you had to say, and I thank you.
g 2i JUDGE GROSSMAN:
I have no questions.
t"
.,3 Judge Ferguson?
23 BY JUDGE FERGUSON:
24 Q.
Just a brief question, Mr. Meehan.
Ne l
l 25 can conceive of an offset occurring beneath a building or l
l l
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1 a structure in'two ways.
It can occur as an impulse, f
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impulsively; or it can occur over a very long period of 3
time.
I would like to consider the impulsive type of 4
appearance as a result of ;n earthquake, cracking due to l
5 a sudden fault caused by an earthquake; and the other l
l 5
6 one due to creeping motion.
j 7
Do you feel that in the simple physics 8
i equations that you referred to earlier that time would 9
['
be a parameter that should be considered?
d 10 A.
(witness Meehan)
It quite definitely would i
11 be a parameter te be considered in a case where there j
12 was groundwater present, which I believe is the main s
[*
13 case here.
5_ '14 G
Why would the occurrence or not of.the 15 presence of groundwater affect what we're talking about?
a g
16 A
Because the soil that is saturated with 9
i 17 groundwater --
5 s3 W
G Excuse me.
I don't want to interrupt you l
4 19 too often, but I think I can understand that that of l
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20 course will affect the nature of the soil.
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21 A
Yes.
e i
4 The yielding property of the soil.
I don't
?.2 IkhEES 23 want to talk about that.
I want to assume that there is 2"C 24 a soil of some consistency, and I simply want to ask l
s j
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- .*cg3gcM RE7CCNG COMPANY. lNC.
5-11 jwb 2294 1
give you different results in the analysis that you 2
described using the simple physics equations that you 3
referred to.
4
.t In the case of a dry soil, there would be 5
a very slight difference, perhaps not more than a few 6
In the case of the wet soil, the properties of percent.
f7 the soil as you just pointed out would be affected by the 8
presence of water, and that would make it sensitive to 3
I' the rate of loading.
u d
10 g
Did you in fact consider those separate cases 11 '
in your analysis?
5 12 A.
Yes.
5 JUDGE FERGUSON:
Okay.
Thank you.
I have
"*f 14 nothing further.
3 15 JUDGE GROSSMAN:
Mr Edgar?
16 MR. EDGAR:
I have one item.
i 17 REDIRECT EXAMINATION q
d BY MR. EDGAR:
(
19 G
Mr. Meehan, one item.
Have you done any l'
5 20 additional analyses in the seils area in regard to 21 examining soil bearing capacity value at about -- at 30 ksf?
23 A.
(Witness Meehan)
Yes, I have done considerable 2 % 24 work on that.
Initially I attempted to approach this 25 entire problem by looking at it as a bearing capacity ggg,qgcN sg, cMT'NG COMP 4NY. lNC.
2
5-12 jwt 2295 1
problem, and I achieved ::imilar results to what I 2
obtained by the Rankin wedge approach.
I felt that 3
these results were convincing to me.
However, the NRC 4
Staff had reservations about certain aspects of that j
5, approach.
So I abandoned it as a means of dealing with lr 6
this particular question.
f7 However, bearing capacity is also applicable, 8
as I understand it, to certain elements of the structural 9'
analysis.
So much of that work that I did was also
,u f
10 applicable in many discussions back and forth between 11 ourselves and the Staff with respect to appropriate j
12 !
values of bearing capacity.
So I have done a great deal 5
13 of work.
4
,5 14 Q.
Have you done any. work, and do you believe 15 that 30 ksf is an appropriate value for soil bearing E
16 capacity?
2 s
17 A.
I personally believe that the bearing 13 capacity is quite a bit lower than 30 ksf.
For J
19 structural purposes I understand that 30 ksf is a conser-20 vative number.
I believe that it is definitely a 21 conservative number.
I think the bearing capacity is 1
m
'2 lower than 30 ksf.
23 (Pause.)
i 2
24-MR. EDGAR:
I have no further questions.
I 25 JUDGE GROSSMAN:-
Mr. Cndy?
l ALlllERdCN RE?cENc COMPANY. INC-l t
5-13 jwb 2296 1
MR. CADY:
I have no questions.
2 JUDGE GROSSMAN:
Mr. Bachmann?
3 MR. BACHMANN:
Yes, sir, just to clear up one point on the record.
RECROSS-EXAMINATION g
ll BY MR. BACHMANN:
O 7
Mr. Meehan, in answer to one of Judge g
4 a'
Foreman's questions, the way it was answered, which I I'
believe was in the negative, indicated that your fault u
d 10 '
plane analysis did not uti'lize the concept of a Rankin
_=
11 wedge, and I believe it dces.
Is that correct?
A.
(Witness Meehan)
It quite definitely does.
MR. BACHMANN:
Thank you.
No further a
I4 questions.
]
15 JUDGE GROSSMAN:
Thank you, gentlemen.
The
.E 16 panel is dismissed and excused.
Thank you.
k 17 (Panel excused. )
Sg JUDGE GROSSMAN:
We have some housekeeping --
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19 JUDGE' FOREMAN:
Thank you, personally.
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hated to do this to you, but I do appreciate it.
21 JUDGE GROSSMAN:
Okay.
We do have some ee
'2 housekeeping matters before we conclude.
You had a i
1
%~] 23 schedule in your stipulation which we adopted, and I 24 assume we are going to adhere to that schedule?
25 M2. EDGAR:
On our part, yes.
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MR. SWANSONY-The parties did agree to 2
that schedule.
3 MR. CADY:
Yes.
4 JUDGE GROSSMAN:
Okay.
The record will be.
2 5
closed June 26th.
The Licensee's proposed findings, I
6 July 23rd.
Intervenor's proposed findings, July 17th.
7 2
NRC Staff's proposed findings, July-24th.
And the j
Licensee's reply on July 31st.
Is that correct?
That is what is listed in u
d 10 the stipulation.
11 MR. EDGAR:
Yes.
5 I2 '
MR. SWANSON::
That's cor 2ct.
5
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13 MR. CADY:
Yes.
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MR. SWANSON:
And we pointed out that in order I
15 to meet those time limits, some sort of express mail nd 16 service would have to be used to ensure that the U
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succeeding parties had a chance to respond and would in 2
is fact have a fair amount of time to do so.
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JUDGE GROSSMAN:
Okay.
That's fine.
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Then the next housekeeping matter is
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21 Staff's Exhibit No. 7, I believe.
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MR. SWANSON:
Yes.
That was receiv'ed last qq pg; 23 '
Friday.
However, at that time I had indicated to the 2*C 24 parties that there was a difficulty in reproducing s
25 exactly the chart that we have used as Staff Exhibit No. 7 l
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during this proceeding.
It was impossible tc photococy 2
it.
It was pasted to a solid sheet of cardboard.
So 3
as I had indicated to the parties and the Board 4
previously, Dr. Herd and Dr. Brabb redrew lines as 5
accurately as they could to reproduce what in fact was 6
lll drawn during the hearing, and the reproduction of that 7'
copy is what I passed out today as Staff Exhibit No. 7.
0 Now perhaps the parties would not want to --
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I don't know if there is a problem with the parties u
4 10 agreeing to the drawing of lines now, or perhaps we E
11 could set a date such as a week from now for the parties g
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to respond as to whether or not they have any problems hU with it.
4 5
I4 MR. EDGAR:
I would prefer to do that.
I r3 15 haven't reviewed it.
.I would ask one question.
There is
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16 a little legend up in the top left-hand corner which U
17 says " approximate distances."
Dr. Brabb testified that vg that included a mathematical absurdity.
My question is:
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20 MR. SWANSON:
I believe so.
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21 MR. EDGAR:
That is as per the original?
2 MR. SWANSON:
Yes.
The only thing that 23 could be slightly different is in the redrawing of lines.
2 % 24 There was a fair amount of drawing of lines on the 25 easel, I guess, during the proceeding, and they have I
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5-16 jwb 2299 1
tried to reproduce those lines as accurately as poss'ible.
2 My concern is that someone might try to 3
take measurements that were not testified to during the 4
hearing, and if there is a slight difference in the j
5 lines, that could result in perhaps a different number.
S 6
So I guess what I would propose is that we set a date, 7
perhaps the time the transcript corrections are due, S;
to indicate whether or not the parties have any objections
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to the form of this exhibit.
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JUDGE GROSSMAN:
Do all parties agree?
h 11 MR. CADY:
Yes, sir.
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12 MR. EDGAR:
Yes.
E 13 JUDGE GROSSMAN:
Okay.
Fine.
That is what
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14 we will do, then.
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'MR. SWANSON:
And then of course the Staff E
16 has I believe two other exhibits that we still have to E
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3 17 furnish copies of:
the photographs of the Exhibit No. 5 2
is series; and reproductions of the colored plates, in d
19 plates 1 through 11 of Figure 13 of the USGS input into 20 the Staff's Safety Evaluation of May 1980 that we have j
E 21 yet to reproduce.
We will do so upon returning.
T' JUDGE GROSSMAN:
Okay.
My recollection is 23 we admitted those subject to your producing the requisite 24 copies.
25 MR. SWANSON:
That is correct.
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JUDGE GROSSMAN:
Are there any other problems 2
with regard to exhibits, first?
3 MR. EDGAR:
Yes.
Two' housekeeping items.
4 I would like to make an offer of two exhibits which our 2
5 review of the transcripts indicated we hadn't offered.
d 6
One is Exhibit No. 42, which is Dr. Kovatch's chart j
7 illustrating velocity gradients of the Imperial Valley.
3 The second is Exhibit No. 43, which is a California l3 2
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Division of Mines and Geology memorandum which reflects a
d 10 a trip report of October '77 to T-1.
Incidentally, the f
11 California Division of Mines and Geology Report of W
5 12 ;
Geology is attached to Staff Exhibit No.
1-A, which is S
13 the original SER.
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14 JUDGE GROSSMAN:
Mr. Cady?
5 15 MR. CADY:
Intervenor has no objection tio 16 the introduction of those exhibits.
9 3
17 MR. SWANSON:
No objection.
3 13 JUDGE GROSSMAN:
My recollection on Exhibit a
d 19 No. 43 was that the only foundation laid was a somewhat s
t; 20 skeptical one with regard to that California report.
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g feel that the report was of almost no value?
~ 23 MR. EDGAR:
Well, no.
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24 JUDGE GROSSMAN:
Or of less than no value?
25 MR. EDGAR:
I wouldn't leap to that conclusion.
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It depends upon the purpose for which one uses the report.
2 Dr. Brabb expressed some skepticism about the people 3
writing. the report, I believe.
I don't want to go into 4
that and characterize it, but it is there.
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Another question is the statement was made j
6 in testimony that there was a concensus.
Everybody in 5
7 the trenches agreed that there was an offset of the A-2, g
8; and this if it is admitted, if nothing else than for 9'
the purpose of the fact that the statement was made that a
4 10 this memorandum along with Dr. Jackson's clearly indicates ig 11 the opposite.
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12 l JUDGE GEOSSMAN:
Well, since there is no 5
~. 13 objection, we will admit both exhibits.
1 3
14 (The documents referred to, r3 15 previously marked as g
16 Licensee Exhibit Mos. 42 and 9
5 17 43 for identification, were
'3 received in evidence.)
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19 MR. EDGAR:
I had another question for l
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20 Judge Grossman.
Do you have a preference or a convention G
21 for forms of citations to trial records?
Some Boards 12 will say they want it Licensee's Exhibit X, or the qgg2g;23 witness's name, but do you have a preference as to how end Y"C 24 you would like to see that in the ' findings?
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- 6 ar6-1 2302 JUDGE GROSSMAN:
I can't focus right now on g
the alternatives.
Ao lor.g as they are descriptive, I 2
don't bold you to any particular form, as long as they 3
identify what you are refe rring to.
4 MR. CADY:
I believe we still have open the j
5 6
question of Glenn Barlow's testimony.
Is the Board going to make a ruling on this at this time?
Or is that going to 7
e come at a later date?
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JUDGE GROSSMAN:
I believe we have made our 9
ruling as to this hearing, and we indicated that we would 10 reconsider af ter the hearing, but I didn't mean at this 11 i E
time.
I meant when we are reviewing the briefs or the E
12,
ar proposed. findings, so that our ruling stands.
The testimony 13 is not admitted at this time.
14 MR. CADY:
Is that not adnitted as an expert?
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16 Is there a possibility it could be admitted on less than 8
g 17 expert reliability?
S JUDGE GROSSMAN:
As I understand it, there may
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be some factual statements in there that might be admitted.
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W uld you care to respond to that, Mr. Swanson?
Or Mr.
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Well, I don' t see a distinction 12 conceptually, if it's in the record and admitted, it's 23 there for whatever it's worth.
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dif f eren ce.
If the Board does not consider Mr. Barlow to 2
be an expert and has excluded the testimony on those 3
grounds, at le ast for the time being, I don' t see how the 4
admission of that on the grounds of some -- or_ che theory 5
that it is simply a statement of f act is proper.
5 6
It seems to me there is some inconsistency, that 3
7 it's almost mutually exclusive, so that our inclination would
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We have raised
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the cbjection, but it would quite frankly not give us 3
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JUDGE GROSSMAN:
Okay.
We certainly don' t mean E
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15 that that's his opinion.
That's.just in ef fect back-dooring
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But there may be some matters of f act in 2
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But
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21 that the parties -- the other parties were not aware might 12 be a&nitted into the record.
23 Mr. Swanson?
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24 MR. SWANSON:
Yes.
I do see a distinction, 25 that being that -- although I am not prepared to argue it l
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in detail at this point.
Boards in the past have drawn 2
distinctions between experts and nonexperts, and the liberties t
3 that they may take in interpreting other expert opinion, 4
particularly in statements from other experts, inte rpreting 5
and relying upon, for example, scientific journals and 6
treatises.
Experts have been accorded leeway in relying 3
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on other experts au interpreting other expert opinion.
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9 accorded the status of experts, they are allowed to in a
4 10 effect take great liberties with hearsay because of the ig 11 reliance of Boards upon their ability to make informed 2_
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13 Now Mr. Barlow, of course, went through his I
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20 allowed to.
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would have to get into detail and study his testimony again.
2 JUDGE GROSSMAN:
There's no question but that 3
the Board does have those distinctions in mind.
Certainly 4
what would be classified as expert testimony, in which j
5 an expert can rely on other opinion, would still not be j
6 admitted under the Board's current ruling.
3 7
MR. SWANSON:
I guess my point is, I'm not sure 8;
there would be anything lef t if we started excluding those A
9' things.
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10 JUDGE GROSSMAN:
I'm not sure there is, either, i
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9 17 MR. CADY:
Yes, sir, as far as Intervenors are
'S concerned, it's all taken care of.
Thank you.
f 19 M R.
EDGAR:
Nothing here, thank you.
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Mr. Swanson?
E 21 MR. SWANSON:
Nothing.
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'!2 JUDGE GROSSMAN:
Okay.
I guess that concludes
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Thank you very much, gentlemen.
The hearing 2
is concluded.
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3 (Whereupon, at 10.: 50 a.m., the hearing l
4 was concluded.)
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