ML20137B971
| ML20137B971 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/22/1985 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#485-289 OL, NUDOCS 8511260393 | |
| Download: ML20137B971 (5) | |
Text
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Novemper22, 1985
.h UNITED STATES OF AMERICA S/l l20' NUCLEAR REGULATORY COMMISSION -
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
GEORGIA POWER COMPANY, et al.
)
Docket Nos. 50-424 (OL)
)
50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' MOTION FOR PARTIAL RECONSIDERATION OF MEMORANDUM AND ORDER RULING ON MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 7 On November 12, 1985, the Atomic Safety and Licensing Board issued " Memorandum and Order (Ruling on Motion for Sbmma-ry Disposition of. Contention 7 re Groundwater Contamination)."
Therein, the Board granted in part and denied in part "Appli-cants' Motion for Summary Disposition of Joint Intervenors' Contention 7 (Groundwater)," which was filed on July 15, 1985.
The Board determined that several genuine issues of material fact remained to be heard.
One of these issues is groundwater travel time.
For the reasons discussed below, Applicants re-spectfully move for reconsideration with respect to this limit-ed issue.
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I-e The Board's ruling was based on Savannah River Plant re-ports that Joint Intervenors had cited to suggest that Appli-cants' groundwater travel time methodology might underestimate trivel time.
The reports discussed groundwater velocities com-puted by a one-dimensional model similar to that used by Appli-cants, groundwater velocities computed by a three-dimensional finite-difference model, and groundwater velocities measured by
~
tracer tests.
Based on its review, the Board stated, "the simple one-dimensional model used at SRP gave a maximum estimated ve-locity of 32 ft/yr in the Barnwell Formation, whereas observed values in separate studies had maxima of 69 and 72 ft/yr."
Memorandum and order at 28 (emphasis added).
The Board there-fore concluded that a one-dimensional model may underestimate groundwater velocity and lead to large errors.
Id. at 28-29.
The 32 ft/yr computed velocity, however, was not a maximum.
Rather, it was an average velocity -- one based on "an overall average gradient."
See DPST-83-829, Vol.
I, at 3-24.
See also id. at 3-21 (using the same methodology and equation to calcu-late " average horizontal velocity" in the McBean Formation).
This average velocity was calculated using a uniform, hypothet-ical hydraulic conductivity as an illustration of the hydrologic characteristics of sands in the Barnwell Formation.
The range of measured velocities in the Barnwell Foundation, V=
.s 2.3 to 69 ft/yr, appears entirely consistent with this illus-trative computed average velocity.
A properly computed average velocity multiplied by the flow path distance will produce an accurate travel' time estimate.
Accordingly, the SRP studies cast no doubt on the reliability of the one-dimensional' groundwater flow model em-ployed by Applicants.
Thus, there is no basis to question Applicants' methodology, and consequently no genuine issue of material fact exists.
Applicants therefore request that the Board reconsider its November 12, 1985 order to this limited extent and eliminate groundwater travel time as an issue to be heard.
Respectfully submitted, f
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uGetr'ge7. Wrowbridge, PW.
Bruce W.
Churchill, P.C.
David R.
Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.
Charles W. Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN SANDERS, LOCKERMAN
& ASHMORE Counsel for Applicants Dated: November 22, 1985
. 1
November 22, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
GEORGIA POWER COMPANY, -et al.
)
Docket Nos. 50-424 (OL)
)
50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
CERTIFICATE OF SERVICE T
I hereby certify that copies of " Applicants' Motion for Partial Reconsideration of Memorandum and Order Ruling on'Mo-tion for Summary Disposition of Contention 7," dated November 22, 1985, were served upon those persons on the attached Ser-vice List by deposit in the United States mail, postage pre-paid, or where indicated by an asterisk (*) by express mail, I
this 22d day of November, 1985.
I I
Y u
f David R.
Lewis Dated: November 22, 1985 n
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Ma'tter of
)
)
GEORGIA POWER COMPANY, et al.
)
Docket No. 50-424
)
50-425 (Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
SERVICE LIST Morton B. Margulies, Chairman
- Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U.S. Nuclear Regulatory Commission Atlanta, GA 30306 Washington, D.C.
20555 Mr. Gustave A. Linenberger
- Laurie Fowler Atomic Safety and Licensing Board 218 Flora Avenue, N.E.
U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C.
20555 Dr. Oscar H.
Paris
- Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous U.S. Nuclear Regulatory Commission Georgia Washington, D.C.
20555 175 Trinity Avenue,'S.W.
Atlanta, GA 30303 Bernard M.
Bordenick, Esq.
Office of Executive Legal Director Docketing and Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Commission Bradley Jones, Esquire Washington, D.C.
20555 Regional Counsel U.S.
Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C.
20555 Atlanta, GA 30303 1
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