ML20063A488

Exceptions to ASLB 820720 Partial Initial Decision & 820804 Suppl on Seismic Issues.Aslb Erred in Concluding That Applicant Ground Motion Model Unreliable.Certificate of Svc Encl

ML20063A488
Person / Time
Site:	Summer
Issue date:	08/20/1982
From:	Knotts J DEBEVOISE & LIBERMAN, SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
ISSUANCES-OL, NUDOCS 8208240358
Download: ML20063A488 (8)

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1. f UNITED STATES OFiAMERICA 07 (ETED NUCLEAR REGULATORY COMMISSIONW E BEFORE THE ATOMIC SAFETY AND LICENSIND APPEALrBOARD '"

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In the Matter of )

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!. ' P'C-I South Carolina Electric -

& Gas Company, et al. Docket 50-395 OL (Virgil C. Summer Nuclear Station, Unit 1)

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LICENSEES' EXCEPTIONS TO INITIAL DECISION ,

On July 20, 1982, the Atomic Safety and Licensing Board in the captioned matter issued its Partial Initial Decision on seis-s mic issues. On August 4, the Licensing Board issued its Supple- ._

mental Partial Initial Decision on the remaining issues in the proceeding. By Order dated July 27, this Board extended ~the time for filing exceptions to August 20. Pursuant'to 10 C.F.R.

l S2.762, -Licensees note the following exceptions. Each of the  ;

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exceptions, as provided by the rule, consists of a statement of the single error of law or fact which is asserted in that excep-tion, and identifies the portion of the decision (or earlier '

order or ruling) to which that exception is addressed. The brief in support of these exceptions will contain, inter alia, refer-ences to the portions of the record relied upon in support of T

these exceptions.

I. Recorded Versus Design Ground Motion

1. The Board erred in comparing the peak recorded acceleration at the soil surface on a concrete l

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directly to the SSE response spectrum anchor 7-N;/ point 'of O.15g for large embedded s~tructures founded on rock. #(Opinion at 5; Finding 3

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~ 2. cT he_ Board erred in characterizing the result

' of the comparison in Exception 1 as an " actual

.2 exceedence." (Opinion at 5; Finding 4 at 18.)

3. The Board erred in comparing the peak recorded

- acceleration at the soil surface on a concrete

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t j~ ' pad for,the August 27, 1978 M g = 2.8 event s'

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'directly to tlie 'RIS response spectrum anchor q -; . -

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pg - (Zero Feriod. Acceleration or "ZPA") of

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0.22g for large embedded structures founded on r' '

, rock. (Opinion at.9; Finding 16 at 25.)

.4. The Board erred'in' characterizing the result

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of the comparison in Exception 3 to the effect b s ,that the 0.22g ZPA had been " exceeded". (Opin-i

, ion at 9; Finding 16 at 25.)

5. Th Boarderredin[6cmparingthepeakrecorded

[' ,. , acceleration'Et th$ soil surface on a concrete l '

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pad for' the October 16, 19.79 M3 = 2.8 event

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. directly to the SSE peak acceleration anchor i ,>

l s point of 0.15g..for large embedded structures p founded on ro.ck. (' Opinion at 14.)

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[. 6. The Board erred in failing to note that the en-velope of.-recorded strong motion data represents t

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motion at the soil surface on a concrete pad a

't the dam abutment instrument site. (Opinion at 15; Finding 86 at 59; Principal Finding 114 at 72.)

7. The Board erred in comparing the envelope of recorded ground motion to the 2.pplicants' SSE design response spectra (Finding 114 at 72. )

8. The Board erred in finding that the envelope referred to in Exceptions 6 and 7 "will exceed" Applicants' SSE design spectra.(Finding 114 at 72.)

9. The Board erred in concluding that no amplifica-tion was shown in the strong motion records at Monticello, without distinguishing various fre-quencies;'at-lower frequencies amplification was not disputed. (Opinion at 14, 15-16; Find-ings 36-40, 42 at 36-41, and 49 at 43-44; Prin-l cipal Findings 112 at 71, and 115 at 72-73.)

10. The Board erred in failing to consider all of the relevant expert opinion evidence in finding that it is "unlikely that there was significant amplification in (the Monticello ground motion) 1 j records due to soil, topography or accelero-l l meter pad-soil interaction effects." (Finding 49 at 50.)

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II. Evidence for Lack of Damage

11. The Board erred in failing to consider the obser-vations of lack of damage to the hydroelectric generation facility near the strong motion in-strument on the dam abutment when it referred to

. . . few opportunities for observations of damage to engineered facilities from shallow earthquakes in the range of interest . . ."

(Opinion at 15, Finding 90 at 61.)

III. Ground Motion and Source Models

12. The Board erred in concluding that the Applicants' (Hanks and McGuire) ground motion model was shown to be unreliable. (Opinion at 13, 16; Findings 28-34 at 31-35, 68 at 56, and 82 at 57; Principal Finding.110 at 70-71, Appendix 87, 88, 98.)

13. The Board erred in stating that the only type of seismicity covered in the original evaluation was shallow RIS. (Opinion at 13-14. )

14. The Board erred in failing to properly distinguish time domain from frequency domain stress drops.

(Opinion at 13; Findings 8-10 at 20-22, 14-16 at 24-25, 27-33 at 30-35; Principal Finding 110 at 70-71.)

15. The Board erred in finding that a stress drop of 100 bars is " reasonable". (Opinion at 13, Find-ing 33 at 34.)

16. The Board erred in failing to properly distin-

'guish between average release of deviatoric stress along the entire rupture surface and the peak re-lease of deviatoric stress at a local point or points and to take into account limiting effects of dynamic friction on stress drops. (Finding 30 at 33.)

17. The Board erred by failing to consider the mul-tiple types of observational evidence that support a 1.0 km limiting source dimension and a corres-ponding limitation on magnitude at Monticello and by instead applying (incorrectly) hypothetical models of rupture propagation to the Monticello site discussed in the record. (Findings 34 at 35, 62 at 49.)

IV. Response Spectra

18. The Board erred in attributing the factor of 0.5 l

used in Applicants' direct scaling to amplifica-l tion (which it discredited) rather than soil-l structure interaction, embedment and foundation effects based on empirical data (which it credited).

l l (Finding 81 at 57.)

19. The Board erred in finding Applicants' direct scaling defective. (Findings 80 at 56-57 and 81 at 57.)

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20. The Board erred in its findings and conclusions that the Johnson and_Traubenik amplification values are lower than those used in Regulatory Guide 1.60. (Finding 35 at 35-36.)

V. Other

21. The Board erred in implying or concluding that Applicants and Staff did not provide timely noti-fication of the October 16, 1979 event. (Opinion

. at 16; Finding 25 at 29; Appendix at 84-86, 95 and n.11 at 86, Finding 2 at 18, Opinion at 4.)

[Please note that the subject matter of this exception is pending on motion for reconsidera-tion before the Licensing Board. ] b!

Respectfully submitted, Of Counsel:

( lk f (1 Joseph B. Knotts,l Jr.

Jeb C. Sanford e se & Liberman t

Randolph R. Mahan 1200 Seventeenth Street, N.W.

General Attorney South Carolina Electric

. Washington, D.C. 20036

& Gas Company (202) 857-9800 A rneys for Licensees o umb , S C. 29218 August 20, 1982 1/ The matters to which we take exception may have formed the basis for the Board's conclusion that the FSAR was

" inadequate" (Opinion at 16, Conclusions at 73). That was error. Since the Board also concluded that any perceived inadequacies were rectified by subsequent development of the record on the seismic issue, we do not take a separate exception to the Board's conclusion regarding the adequacy of the FSAR.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

South Carolina Electric )

& Gas Company, et al. ) Docket 50-395 OL

)

(Virgil C. Summer Nuclear )

Station, Unit 1) )

CERTIFICATE OF SERVICE

, I hereby certify that copies of " Licensees' Exceptions To Initial Decision"'in the above captioned matter, were served upon the following persons by deposit in the United States mail, first class postage prepaid this 20th day of August 1982, or by hand delivery as indicated by an asterisk ("*").

Alan S. Rosenthal, Chairman

• Herbert Grossman, Esq.

Atomic Safety ~ and Licensing

~

Chairman, Atomic Safety and Appeal Board Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Howard A. Wilber

• Dr. Frank F. Hooper Atomic Safety and Licensing Comm. School of Natural Resources Appeal Board University of Michigan

U.S. Nuclear Regulatory Ann Arbor, MI 48109 l

Washington, D.C. 20555 Mr. Gustave A. Linenberger Christine N. Kohl

• Member, Atomic Safety and Atomic Safety and Licensing Licensing Board Panel Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 l

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Chairman, Atomic Safety and Mr. Brett Allen Bursey Licensing Board Panel Route 1, Box 93-C U.S. Nuclear Regulatory Little Mountain, SC 29076 Commission Washington, D.C. 20555 Barbara Hamilton, Esq.

George Fischer, Esq. Assistant Attorney General Vice President and Group South Carolina Attorney Executive - Legal Affairs General's Ofice South Carolina Electric & P.O. Box 11549 Gas Company Columbia, SC 29211 Post Office Box 764 Columbia, SC 29202 Steven C. Goldberg, Esq.

Office of the Executive

, Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Chase R. Stephens Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comaission Washington, D.C. 20555 i

NDP4 Jossph B. Knottq, Jr.

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