ML20042A131
| ML20042A131 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/18/1982 |
| From: | Knotts J DEBEVOISE & LIBERMAN, SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | |
| Shared Package | |
| ML20042A128 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8203230122 | |
| Download: ML20042A131 (6) | |
Text
i e
March 18, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
South Carolina Electric
)
Docket 50-395 OL
& Gas Company, et al.
)
)
(Virgil C. Summer Nuclear
)
Station, Unit 1)
)
APPLICANTS' REPLY TO "NRC STAFF PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION" ON SEISMIC CONTENTION Applicants, South Carolina Electric & Gas Company 1
and South Carolina Public Service Authority, in accordance with 10 C.F.R.
S 2.754, submit the following reply findings of fact and conclusions of law.
1.
Applicants' reply is limited to the proposed findings of fact and conclusions of law submitted by the NRC Staff as the Intervenor, Mr. Bursey, did not file proposed findings on the seismic contention.
l 2.
Applicants do not propose additional findings of fact and conclusions of law, but rather stand on their proposed findings filed February 16, 1982 as to the inferences and conclusions to be drawn from the record.
Applicants do propose to clarify a few points in the Staff's proposed findings so as to more accurately reflect or characterize r203230122 820318 PDR ADOCK 05000395 O
t 4 the record.
Applicants offer the following specific replies in regard to the record and elaborate on certain other matters covered by the Staff.
3.
At page 28, paragraph 53, the Staff states:
"Dr. Trifunac suggested that the anchor point of the RIS spectra should not be less than 0.15g...".
The testimony would be more accurately reflected if the foregoing statement were limited in two respects: (1) Dr. Trifunac did not focus on RIS and did not specify an anchor point for RIS alone, as opposed to overall seismicity, which included RIS events but according to Dr. Trifunac was dominated by tectonic events (See Applicants' Proposed Findings, para. 83-85 and references to the record there provided); and (2) for an earthquake of up to magnitude 5 or Intensity VI, (thus including the Staff's maximumm RIS event of magnitude 4.3 at normal depths), Dr. Trifunac indicated that 0.15g was adequate (Trifunac Report at 3, following Tr. 4707).
For completeness, it should be added that Dr. Trifunac indicated that 0.15g as an anchor point for the SSE spectrum would be too small for f
Intensity VII or magnitude 5.5 at the site (Id.).
We have l
explained in our proposed findings (paras. 185 - 187) why such large magnitudes / intensity events, which might be l
l predicted based on Dr. Trifunac's assumptions and (in our l
view) flawed probability work, should not be accepted.
l l
l
e s 4.
At page 31, footnote 7, the Staff cites the March 3, 1982 Appeal Board decision on seismic issues in Seabrook. l/
This decision may have some bearing on a number of the issues raised in this proceeding.
In connection with the discussion on probabilistic studies, including combining of regions ( Applicants' Proposed Findings, para. 185-187) see Seabrook, Slip Op. at pages 5, 14, 18, 27, 34-35, 36, 39-40, and 50-54.
In connection with effective acceleration (Applicants' Proposed Findings, para. 174-183) see Seabrook, Slip. Op.
at 43.
5.
At page 34, paragraph 65, the Staff states "If the assumptions (as to depth) are incorrect, Dr. Luco testified that the RIS spectrum could be exceeded by more than the 30% margin suggested by the Applicant."
We think it would be clearer to refer to exactly what Dr. Luco said.
At Tr. 4728-29, Dr. Luco stated that if the Staff distance assumptions do not hold up, the "RIS spectrum could be exceeded I think by factors larger than the 30% margin that they (the Applicants] indicate at the beginning."
It should be recalled that Dr. Chen explained the SSE spectrum could be exceeded in certain narrow frequency ranges without SSE design stress being exceeded.
(Applicants' Proposed Find ings, par a. 216 ).
For example, for piping, when the root-sum-square response of the entire system was examined,
~1/ Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), ALAB-667, 14 NRC __ (March 3, 1982).
e e
3 it was shown at all modes that RIS piping stress was less than SSE piping stress (Id.).
6.
At page 35, paragraph 69 and pages 70-71, paragraph
- 158, the Staff summary with regard to damping and equipment analysis of the record would be more complete if reference were also made to the testimony of Dr. Chen concerning the Applicants' analysis of equipment located at the foundation level.
(Applicants' Proposed Findings, para.
225) (Chen, Tr. 5434-35, 5440).
7.
At page 37, paragraph 74, regarding the spatial extent of seismicity at Monticello, the Staff states that "These bounds were reached quickly (within one and a half years)...."
It would more accurately reflect Dr. Alexander's testimony to state that after a 6 month lag following impoundment, the spatial extent of seismicity was reached within one year.
(Alexander, Tr. 5012-13).
8.
At page 42, paragraph 84, the last sentence should conclude with the phrase, "in the frequency range 20-25 Hz."
(See Martin Test. (Plucking Test) at 4, following Tr.
5522).
8.
At page 58, paragraph 126, the Applicants did not calculate the rms stress drops stated as suggested by the Staff.
The stress drops shown were calculated by the Staff.
The Applicants propose tle following new paragraph 126 ss a
. clarification on this point.
" Based on the Applicants' calculation of average rms' stress drops for the six events having significant ground motion recorded thus far at Monticello (magnitude 2.2 - 2.8), which calculation incorpo-rated a reduction factor, the Staff recalculated stress drops without the reduction factor as follows:
approximately 12, 19, 23, 42, 7, 48 bars.
Forty-eight bars is associated
= 2.8 earthquake which also with the October 16, 19 79 Mg, had the highest peak acceleration (Staff Test. at 32-33, following Tr. 5758)."
10.
At page 61, paragraph 135, the Applicants believe the last sentence in that paragraph would be more accurate if it were reworded as follows: "The Staff stressed that the primary difference between eastern and western U.S. earthquakes is that the area of perceptibility of ground motion from eastern earthquakes is larger, because of attenuation at greater distanceu in the east than the west.
(See also l
Applicants' Proposed Findings, para. 135-136)."
l l
11.
At pages 61-62, paragraphs 136, 137, the Staff refers to the "model" spectrum.
We understand this "model" to mean what was referred to during the proceeding as the Applicants RIS spectrum anchored at 0.22g.
i
, CONCLUSION The Applicants' proposed findings of fact and conclu-sions of law on seismic contentions and Board issues should i
be adopted as amply supported by the record.
When the Applicants' proposed findings and the Staff's proposed findings are in agreement, we obviously do not oppose the substance of the Staff's findings.
When different inferences are drawn from the record, we stand on our proposed findings.
Respectfully submitted, Q j,L vt:t. k-s Joseph B.
Knott,s, Jr.
l Jdb C. Sanford Debevoise & Liberman 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9800 Attorneys for Applicants of Counsel:
Randolph R. Mahan, Esq.
South Carolina Electric
& Gas Company P. O.
Box 764 Columbia, S.
C.
29218
.