ML20138D371
| ML20138D371 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/11/1985 |
| From: | Staley G Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20138D364 | List: |
| References | |
| OL, NUDOCS 8512130203 | |
| Download: ML20138D371 (6) | |
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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GEORGIA POWER COMPANY
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Docket Nos. 50-424
--et al.
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50-425
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(0L)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
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AFFIDAVIT OF GARY B. STALEY IN SUPPORT OF
" APPLICANTS' MOTION FOR PARTIAL RECONSIDERATION OF MEMORANDUM AND ORDER RULING ON MOTION FOR
SUMMARY
DISDOSITION OF CONTENTION 7" I, Gary B. Staley, being duly sworn, do depose and state:
1.
I am an employee of the U.S. Nuclear Regulatory Commission. My present position is Hydraulic Engineer, Engineering Branch, Division of PWR Licensing-B, within the Office of Nuclear Reactor Regulation. My responsibilities include review and evaluation of surface water and groundwater hydrologic conditions used in the design of structures, systems and components of nuclear power plants. A statement of my professional backgrpund and qualifications is attached to this affidavit.
2.
The purpose o'f this affidavit is to assess the matters set forth in " Applicants' Motion for Partial Reconsideration of Memorandum and Order Ruling on Motion for Summary Disposition of Contention 7" (Motion) which is dated November 22, 1985.
8512130203 851211 PDR ADOCK 05000424
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As discussed in Applicants' motion, the Board's November 22, i
1985, Memorandum and Order with respect to groundwater travel time was based on Savannah River Plant (SRP) reports that Joint Intervenors had cited to suggest that Applicants' groundwater travel time methodology might. underestimate travel time. The reports, relevant portions of which I have read, discussed groundwater velocities computed by a one-dimensional model similar to that used by Applicants, groundwater velocities computed by a three-dimensional finite-difference model, and groundwater veloc.itiei measured by tracer tests.
4.
Based on its review, the Board stated, "the simple I
one-dimensional model used at SRP gave a maximum estimated velocity 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 therefore concluded that a one-dimensional model may underestimate groundwater velocity and lead to large errors.
Id. at 28-29. As stated by Applicants, the 32 ft/yr computed velocity, however, was not a maximum. Rather, it was an average velocity -- one based on "an overall average gradient." SeeDPST53-829,Vol.I,at 3-24.
See also id_..at 3-21 (using the same methodology and equation to calculate " average horizontal velocity" in the McBean Formation).
I agree with Applicants t' hat this average velocity was calculated using a uniform, hypothetical hydraulic conductivity as an illustration of the hydrologic characteristics of sands in the Barnwell Formation. The range of measured velocities in the Barnwell Foundation, 2.3 to 69 ft/yr, appears entirely consistent with this illustrative computed average
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i velocity. Thus, a properly computed average velocity divided into 1/ the flow path distance will produce an accurate travel time estimate.
5.
I concur with Applicants' conclusion that the SRP studies cast no doubt on the reliability of the one-dimensional groundwater flow model employed by them and there is no basis to question Applicants' methodology as regards estimating groundwater travel time.
(L& } f f' n
Garp B. S tdley'
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Subscribed and sworn to before me this d day of December,1985 911J M0 d /M M Notary Public~
My commission expires: 7///86 1/
The Applicants used the phrase " multiplied by" in their motion.
I have used the phrase " divided into" because travel time equals distance divided by velocity. This difference in phraseology does not affect my substantive conclusion.
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i PROFESSIONAL QUALIFICATIONS GARY B. STALEY I am employed by the U.S. Nuclear Regulatory Connission as a Hydraulic Engineer on the staff of the Engineering Branch, Division of PWR Licensing-B.
My formal education c6nsists of study in civil engineering at South Dakota State University, where-I received a B.S.C.E. in 1960.
I also completed 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of graduate Work in water resources engineering at the University of Nebraska in the period of 1965 to 1973.
My present employment with NRC dates from September 1974 in the areas of hydrologic engineering for consultation on siting of materials utilization facilities and on environmental matters. My responsibility in the licensing review of nuclear facilities is in the area of flood vulnerability, adequate water supply, thermal analyses of ultimate heat sinks and surface and groundwater acceptability of effluents.
In addition, I participated in the development of the technical bases for Safety Guides and Standards in the area of interest.
I am also responsible for preparing safety and environ-mental related testimony for hydrologic related matters on facilities under my review.
From 1973 to 1974, I was a Hydraulic Engineer in the Coastal Engineering and Hydraulie Design Branch of the North Central Division of the Corps of Engineers in Chicago, Illinois.
I was responsible for the hydrologic review of multi-purpose dams, navigation locks, flood control projects, and coastal engineering development. The projects included those of five districts located in the States of Minnesota, Wisconsin, Iowa,: Illinois, Indiana, Ohio, Nev York, Pennsylvania, Michigan, and including the Great Lakes.
From 196l to 1973 I was a Hydraulic and Civil Engine'er with the Omaha District of the Corps of Engineers in Omaha, Nebraska.
I worked on design of hydraulic structures, model studies and general hydrologic engineering on multipurpose dams and flood control projects.
I was assigned for several years of this time to the Missouri River Basin Comprehensive Study where I served as a Task Force Chairman and was involved with long range planning for water yield, water use and flood control.
I am a member of the American Society of Civil Engineers and subscribe to the Journals of the Hydraulics Division and the Geotechnical Engineering Division as a means of keeping abreast of current developments in my fields of interest.
I co-authored a technical paper entitled, "Radionuclide Migration from Low-Level Waste: A Generic Overview." This paper was presented at the Low-Level Waste Management Symposium in Atlanta, Georgia, May 23-27, 1977.
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UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
GEORGIA POWER COMPANY, Docket Nos. 50-424
--et al.
)
50-425
)
(OL)
(Vegtle Electric Generating Plant, )
Units 1 and 2)
)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO ' APPLICANTS' MOTION FOR PARTIAL RECONSIDERATION OF MEMORANDUM AND ORDER RULING ON MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 7'" and Supporting Affidavit in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this lith day of December,1985.
Morton B. Margulies, Esq., Chairman
- Mr. Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris
- Bradley Jones, Esq.
Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel Suite 3100 U.S. Nuclear Regulatory Comission 101 Marietta Street Washington, D.C.
20555 Atlanta, GA 30303 Bruce W. Churchill, Esq'.
Douglas C. Teper David R. Lewis, Esq.
1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 1800 M Street, N.W.
Washington, D.C.
20036 l
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o Atomic Safety and Licensing Laurie Fowler, Esq.
Board Panel
- 218 Flora Ave. NE U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C.
20555 Docketing and Service Section*
Atomic Safety and Licensing Office of the Secretary Appeal Board Panel
- U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James E. Joiner, Esq.
Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc.
& Ashmore P.O. Box 2625 127 Peachtree Street, N.E.
Birmingham, AL 35202 Candler Building, Seite 1400 Atlanta,,GA 30043 NRC Resident Inspectors P.O. Box 572 Tim Johnson Waynesboro, GA 30830 Executive Director Campaign for a Prosperous Georgia 1083 Austin Ave. NE Atlanta, GA 30307 A
Bernard M. Botdenick Counsel for NRC Staff 1
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