ML20050V745

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Substituted Page 41 to NRC 820412 Response to Intervenor Brief Supporting Exceptions
ML20050V745
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 04/13/1982
From:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20050V598 List:
References
NUDOCS 8204150062
Download: ML20050V745 (1)


Text

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-- would, through use of the slip-rate methodology, support their position that the appropriate SSE would be magnitude 7.5.

(Brief at 35-36.)

Intervenors ignore, however, the Licensing Board's finding, and the substantial testimony supporting it, which justify excluding the San Miguel fault from the slip-rate approach because of the significant uncertainties regarding the ability to derive a slip-rate for it (PID FFs 111-113 at 95-98; see also, Slemmons, Tr. 6290, line 8 - 6293 line, 8).

This argument, then, should be viewed as based on nothing more than unfounded speculation and rejected.

In conclusion, the Licensing Board gave proper weight to the slip-rate methodology as one of several approaches used to confirm the acceptability of a magnitude 7 event on the 0ZD as the SSE.

c.

Intervenors, in several places, complain that the bounding line is controlled by but a few data points.

Intervenors miss the point. The slip-rate methodology has taken account of all relevant world-wide data and the HEL and MEL bounding lines are just that - lines which in fact bound all the data; they are not regression lines.

Conservatism is inherent in the MEL in that the bounding line drawn includes an assumed error in both slip-rate and magnitude; while the slip-rate on the NIZD is about 0.5 mm/ year, the MEL is drawn for a slip-rate of 0.68mm/ year and while the magnitude of the controlling event is M =6.3, the MEL is drawn for a magnitude 6.5 event (Slemmons. Tr.

3 6295-6297, line 14).

In light of the fact that all relevant data are accounted for and the bounding line drawn for the MEL includes a double element of conservatism, Intervenors', concern is without substance.

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