ML20054L297

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Memorandum on ASLB Questions Re NRC 820628 Affidavit Concerning SSE Which Were Discussed During 820701 Telcon
ML20054L297
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 07/02/1982
From: Bechhoefer C
Atomic Safety and Licensing Board Panel
To:
References
ISSUANCES-FTOL, ISSUIANCES-SC, NUDOCS 8207070359
Download: ML20054L297 (4)


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UNITED STATES OF AMERICA Q,

NUCLEAR REGULATORY COMMISSION w

GT JUL 61982 > 9 ATOMIC SAFETY AND LICENSING BOARD Q Office of the Secretan-/

Before Administrative Judges:

- Docketing & Senice go,2, Charles Bechhoefer, Chairman 9

Branch SERYf 0 M Dr. George C. Anderson y"O e

Ralph S. Decker xm

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Docket No. 50-409 FT0L In the Matter of

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DAIRYLAND POWER COOPERATIVE

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Docket No. 50-409 SC

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Prov. Op. Lic. OPR-45 (La Crosse Boiling Water Reactor,

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Operating License and Show Cause) )

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July 2, 1982 MEMORANDUM (Board Questions Concernin Staff's Seismic Affidavit On July 1,1982, the Licensing Board initiated a telephone conference call to identify to the parties certain questions we had concerning an affidavit filed by the NRC Staff on January 28, 1982, concerning the safe shutdown earthquake (SSE) for the La Crosse facility.

Participating in the call were:

Members of the Licensing Board (Mr. Bechhoefer, Dr. Anderson, and Mr. Decker)

Mr. O. S. Hiestand, Jr. for the Applicant Mr. Myron Karman, for the NRC Staff Messrs. George R. Nygaard and Mark Burmaster and Ms. Anne K. Morse, for the Coulee Region Energy Coalition (CREC). Intervenor (Mr. Frederick M. Olsen, III, another Intervenor in the SC proceeding, could not be located; CREC and Mr. Olsen have been consolidated in that proceeding.)

r207070359 820702 PDR ADOCK 05000409 1602

1.

We pointed out that we found what appeared to us to be serious inconsistencies in the Staff's affidavit (together with its attachments).

As a result, without suitable and convincing explanation, we would have to find that affidavit (including attachments) inadequate to determine whether ground acceleration at La Crosse would be greater than 0.12g in the event of an SSE.

We refer in particular to the deterministic study reported on pages 14-16 of the enclosure to Attachment 3, including Tables 1 and 2.

First, there is no indication in the record of who did this study nor of the Staff's views as to its acceptability. Throughout these proceedings, the Staff has consistently held that a magnitude 5.0-5.5 or intensity VII earthquake is appropriate for La Crosse and that this earthquake corresponds to a peak acceleration of 0.129 Yet Table 1 shows for the five reactors in the central U.S. a magnitude 5.3 earthquake but an intensity VII-VIII. Why? More seriously, Table 2 gives the result for 2

La Crosse as 0.135g (132 cm/sec ) which is higher than the 0.12g for which potential liquefaction at ta Crosse has thus f ar been evaluated.

Moreover, Attachment I states that the Anna, Ohio earthquake of 1937 is

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I classed as intensity VII-VIII and that the vibratory ground acceleration corresponding to MM intensity VII-VIII is 0.20g.

Of lesser significance, Table 1 appears to equate magnitude 5.3 to intensity VII for four reactors and to intensity VII-VIII for the others. Why?

Is the solid line labled Western U.S. Trifunac and Brady on Figure 5-2, page C-48, NUREG/CR-1582, Vol. 4, the intensity-acceleration used in this deterministic study?

If so, how does one read a peak acceleration of 0.1359 for an earthquake of intensity Pti VII-VIII? Finally, what is the 1

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Staff's basis for rejecting Dr. Nuttli's view that "For nowhere in the central United States would I estimate the PGA [ peak ground acceleration] to 2

be less than 160 cm/sec " (Page A-10, Vol. 5, NUREG/CR-1582)?

2.

There are several documents which, though not as yet offered, appear to us as important in resolving the question of the proper peak ground acceleration to be used in evaluating the liquefaction potential at La Crosse.

These include:

a.

" Seismic Evaluation of the La Crosse Boiling Water Reactor,"

S5-1162, Dames and Moore, Jan. 11, 1974.

b.

" Response to NRC Concerns on Liquef action Potential at La Crosse Boiling Water Reactor (LACBWR) Site Near Genoa, Vernon County, Wisconsin," Dames and Moore, March 21, 1980.

c.

NUREG/CR-1582, Volumes 4 and 5.

We understand that all parties and Board members have been provided copies of these documents. Without objection, it appears to us that it would be useful for Dairyland or the Staff to offer these documents for the record.

3.

In our Memorandum (Concerning Telephone Conference Call), dated November 13, 1981, we indicated (pp. 3 and 4) that if the SEP (Unified

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Hazard Methodology) approach were to be used, we would require additional information concerning the regulatory acceptability of that approach.

Although the Staff's January 28, 1982 affidavit discusses the technical basis for the SEP seismic review, we are not satisfied with the perfunctory arguments advanced to date concerning the regulatory approval of the SEP seismic methodology (Staff affidavit, p. 7). We therefore invite legal briefs from Dairyland and the Staff (and from Intervenors if they wish) on this matter.

In this respect, a Staff witness mentioned a Commission Paper

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relating to the approach to be taken in the SEP.

If this paper is pertinent, we suggest that it and the Commission response thereto be provided the Board and the parties.

4.

During the conference call, the Board and parties discussed whether an evidentiary hearing would be necessary to resolve the foregoing questions. The Staff expressed ~the desire to review the questions we had raised and determine whether it could resolve them through additional affidavits. We agreed to that course of action. The Staff agreed to notify us shortly after receipt of this Memorandum whether it believed it could adequately respond to our questions through affidavit.

The Board notes that the methodologies and parameters heretofore used by the Staff in ascertaining the appropriate ground acceleration for evaluating liquefaction at La Crosse are quite complex, and that we wish to avoid further affidavits if they are likely to be so general that they leave open significant matters relevant to the determinations we must make to resolve the SSE question before us.

FOR THE ATOMIC SAFETY AND LICENSING BOARD sjw d2N/?.s i J Charles Bechhoefer, Chairman e' ADMINISTRATIVE JUDGE Dated July 2, 1982