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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] Category:PLEADINGS
MONTHYEARML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20236W0931998-07-30030 July 1998 Reply to Staff & Naesco Objections to Joinder of Necnp & to Naesco Objection to Standing.* Advises That Jointer Issue Involves Only Question of How Pleadings May Be Captioned. W/Certificate of Svc ML20236U4221998-07-27027 July 1998 North Atlantic Energy Svc Corp Supplemental Answer Standing Issues.* Request for Hearing & Petition to Intervene,As Applied to Sapl & New England Coalition on Nuclear Pollution,Should Be Denied.W/Certificate of Svc ML20236T5201998-07-27027 July 1998 NRC Staff Response to 980709 Submittal by Seacoast Anti- Pollution League & New England Coalition on Nuclear Pollution (Necnp).* Board Should Deny Intervention by Necnp. Staff Does Not Contest Sapl Standing.W/Certificate of Svc ML20236J1111998-07-0202 July 1998 North Atlantic Energy Svc Corp Answer to Supplemental Petition for Hearing.* Util Will Respond to Any Further Petitions on Schedule Directed by Licensing Board Memorandum & Order of 980618.W/Certificate of Svc ML20249B9151998-06-24024 June 1998 NRC Staff Answer to Seacoast Anti-Pollution League (Sapl) 980605 Request for Hearing & to New England Coalition on Nuclear Pollution 980618 Request for Intervention.* Board Should Not Grant Sapl 980605 Request.W/Certificate of Svc ML20249B7631998-06-18018 June 1998 Supplemental & Amended Petition for Institution of Proceeding & for Intervention Pursuant to 10CFR2.714 on Behalf of Seacoast Anti-Pollution League & New England Coalition on Nuclear Power.* ML20249A9501998-06-12012 June 1998 Supplemental Petition of Great Bay Power Corp for Determination of Reasonable Assurance of Decommissioning Funding ML20199K3861998-01-29029 January 1998 Petition for Determination That Great Bay Power Corp'S Acceleration of Decommissioning Trust Fund Payments Would Provide Reasonable Asurance of Decommissioning Funding Or,In Alternative,Would Merit Permanent Exemption ML20217P7781997-12-18018 December 1997 Petition to Suspend Operating License Until Root Cause Analysis of Leaks in Piping in Train B of RHR Sys Conducted, Per 10CFR2.206 ML20140B9601997-06-0404 June 1997 Suppl to Great Bay Power Corp Petition for Partial Reconsideration of Exemption Order to Submit Requested Cost Data & to Request,In Alternate,Further Exemption ML20135A1051997-02-21021 February 1997 Petition of Great Bay Power Corp for Partial Reconsideration of Exemption Order.* Seeks Reconsideration of Staff'S Preliminary Finding That Great Bay Is Not Electric Utility as Defined by NRC in 10CFR50.2 ML20094N4021992-03-27027 March 1992 App to Appeal of Ofc of Consumer Advocate (Nuclear Decommissioning Finance Committee) Appeal by Petition Per Rsa 541 & Rule 10 ML20076D1281991-07-17017 July 1991 Licensee Motion to Dismiss Appeal.* Appeal Should Be Dismissed Based on Listed Reasons.W/Certificate of Svc ML20073E1301991-04-22022 April 1991 Opposition of Ma Atty General & New England Coalition on Nuclear Pollution to Licensee Motion for Summary Disposition.* Board Should Reopen Record,Permit Discovery & Hold Hearing on Beach Sheltering Issues ML20070V3311991-03-29029 March 1991 Licensee Motion for Summary Disposition of Record Clarification Directive in ALAB-939.* Licensee Request That Motion Be Moved on Grounds That Issues Herein Identified Became Moot & Thus Resolved.W/Certificate of Svc ML20070V4061991-03-25025 March 1991 Massachusetts Atty General Response to Appeal Board 910311 Order.* License Should Be Vacated Until There Is Evidence of Adequate Protective Measure for Special Needs Population. W/Certificate of Svc ML20076N0831991-03-21021 March 1991 Massachusetts Atty General Response to Appeal Board 910308 Order.* Opposes Licensing Board Issuance of Full Power OL Based on Reliance of Adequacy of Plan.W/Certificate of Svc ML20076N1861991-03-19019 March 1991 Intervenors Reply to NRC Staff & Licensee Responses to 910222 Appeal Board Order.* NRC & Licensee Should File Appropriate Motions & Supply Requisite Evidentiary Basis That Will Allow Board to Make Decision.W/Certificate of Svc ML20070M5151991-03-18018 March 1991 Licensee Response to Appeal Board 910308 Order.* Listed Issues Currently Being Appealed Should Be Dismissed as Moot. W/Certificate of Svc ML20076N0671991-03-15015 March 1991 Licensee Response to Appeal Board 910311 Order.* Controversy Re Special Needs Survey Resolved.Next Survey Will Be Designed by Person Selected by State of Ma & Licensee Will Pay Costs.W/Certificate of Svc ML20070M3781991-03-11011 March 1991 Licensee Response to 910222 Appeal Board Order.* Response Opposing Suspending or Otherwise Affecting OL for Plant Re Offsite Emergency Plan That Has Been Twice Exercised W/No Weakness Identified.W/Certificate of Svc & Svc List ML20070M2101991-03-11011 March 1991 Reply to Appeal Board 910222 Order.* Response Opposes ALAB-918 Issues Re Onsite Exercise Contention.W/Certificate of Svc ML20029B6061991-02-28028 February 1991 Response of Ma Atty General to Appeal Board 910222 Order.* Questionable Whether Eight Issues Resolved.To Dismiss Issues Would Be Wrong on Procedural Grounds & Moot on Substantive Grounds.W/Certificate of Svc ML20070E7741991-02-25025 February 1991 Opposition to Licensee Motion to Dismiss Appeal of LPB-89-38.* Believes Board Should Not Dismiss Intervenors Appeal Because There Was No Hearing on Rejected Contentions. Board Should Deny Licensee Motion.W/Certificate of Svc ML20066H0831991-02-12012 February 1991 Licensee Motion to Dismiss Appeal of LBP-89-38.* Appeal Should Be Dismissed Either as Moot or on Grounds That as Matter of Law,Board Correct in Denying Hearing W/Respect to Contentions at Issue.W/Certificate of Svc ML20066H0021991-02-0808 February 1991 Licensee Response to Appeal Board Order of 910204.* W/Certificate of Svc ML20067C5081991-02-0101 February 1991 Ma Atty General Response to Appeal Board Dtd 910122.* Identifies Two Issues That Potentially May Be Resolved. State Will Continue to Investigate Facts Re post-hearing Events That May Effect Pending Issues.W/Certificate of Svc ML20029A0451991-01-28028 January 1991 Licensee Suggestion for Certified Question.* Draft Certified Question for Appeal Board Encl.* W/Certificate of Svc ML20029A0431991-01-28028 January 1991 Licensee Response to 910124 Memorandum & Order.* Common Ref Document Derived from Copying Respective Portions of Emergency Response Plan & Associated Documents Provided.W/ Certificate of Svc ML20070U4811991-01-24024 January 1991 Motion Requesting Limited Oral Argument Before Commission of City of Holyoke Gas & Electric Dept New Hampshire Electric Cooperative Mact Towns ML20029A0091991-01-24024 January 1991 Response to Appeal Board 910111 Order.* Atty General Will Continue Ad Intervenor in Facility Licensing Proceeding. Changes to Emergency Planning for Facility Forthcoming. W/Certificate of Svc ML20029A0121991-01-24024 January 1991 Motion for Substitution of Party.* Atty General s Harshbarger Moves That Secretary of NRC Enter Order Substituting Him in Place Jm Shannon as Intervenor to Proceeding.W/Certificate of Svc 1999-08-03
[Table view] |
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, . . . --
.O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'BEFORE THE-ATOMIC SAFETY AND LICENSING APPEAL BOARD
-In the Matter of )
-PUBLIC' SERVICE COMPANY ) Docket No. 50-443 0F NEW HAMPSHIRE, ET.-AL ) 50-449 (Seabrook Station, Units 1'& 2 -)
' COMMENTS by Prof. Mihailo D. Trifunac i
March 20,1981
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INTRODUCTION The proposed characteristics of strong earthquake ground motion for seismic design of the Seabrook nuclear i;wer plant may be summarized as follows:
- 1. Safe Shut Down Earthquake (SSE) will not exceed MI=VIII at the site.
- 2. Maximum. peak acceleration which will result from MI=VIII at the site is 0.256 (where g=981 cm/sec2 ),
- 3. Design Response Spectrum shapes are consistent with the Reg.
Guide 1.60 spectra recomended by the U.S.N.R.C.. At short periods _(high frequencies, f230 Hz) these spectra approach
^
the peak absolute ground acceleration equal to 0.25g.
- 4. _From geological view point the site can be classified as a rock site.
. In its recent ' order, CLI-80-30,12 NRC 295, 298 (1980), the Atomic Safety and Licensing Appeal Board states:
"The Appeal ' Board shall also reopen the record to take more evidence
^
, on the consistency of Appendix A and-staff's methodology for cor-relating vibratory motion with the SSE. In particular, the parties should provide a discussion of th relation between the mean of the maximum ground acceleration and the maximum effective ground acce-
'leration."
_In response to this order, in the following I will discuss some as-pects of selecting.the seismic design criteria at this site and will try 4
e yr ,V - y- g w y w ,-,ir- -
9
2 to test the adequacy of tne above proposed desijn levels. As will be seen from the subsequent pages I will analyze the end product only by using the methods thich to c:e, at present, appear to be the most suit-able. In this respect I will employ my own interpretation of the r..ini-mum requirements contained in the Appendix A.
. 3 SELECTED COMMENTS ON A DETERMINISTIC INTERPRETATION OF APPENDIX A AND THE ASSOCIATED DIFFICULTIES.
By some, Appendix A (together with the associated Regulatory Guides) is interpreted to lead to detailed step by step instructions on how the future strong earthquake is to be estimated for the design of nuclear power plants. With this viewpoint, it is possible to compartmentalize all required operations and to develop " standard" procedures, which, if carefully documented, may precisely outline the needed tasks and their ultimate output, the design response spectra. From an administrative, licensing and design-viewpoints this approach at least formally, appears inviting, since, through precisely documented procedurer , it leads u. rect'y to the results. Such precisely outlined and executed procedures, however, may not always lead to an accurate description of the physical nature of the problem; if the uncertainties associated with various operations are not properly reflected in the distribution of the estimated output values.
-For Eastern U.S., for example, a typical analysis essentially begins by specifying "the largest credible" earthquake shaking at a site (usually measured in terms of the Modified Mercalli Intensity, MMI). The diffi-culties associated with this first step sometimes result from a naive expectation that the past seismicity, geology and tectonics in the area can-somehow be employed to compute the largest credible site intensity.
I believe that many licensing difficulties could be avoided by recognizing that it is' sufficient to evaluate the maximum intensities by means of a distribution function, rather than through a selection of a precise yet not necessarily an accurate point estimate.
The next task'then consists of relating the assigned site intens 3
4 of shaking to an amplitude of peak ground acceleration. Here one finds a considerable spread of the recorded peak acceleration for the same site intensity,shown in Figure 1. This figure illustrates how the distrioutions of peaks P(as ag ) might look like. The dashed straight lines, approximating this unknown distribution, have been plotted here by using the Table VI in Trifunac (1976). It is seen, for example, that the 80% confidence interval for. recorded peak accelerations for the site intensity MPI=VIII is from
'0.15g to '0.70g. The point to be noted here is that when a peak accelera-tion is presented it must be viewed with this wide distribution in mind.
In Figure 1 and elsewhere in this discussion " peak acceleration" will mean the largest absolute amplitude of acceleration function versus time recorded during the complete strong earthquake motion. For linear response analysis using response superpositicq technique this is the only correct use'of peak acceleration, since the computed response spectra asymptotically approach this peak value as the period of the single degree of freedom oscillator approaches zero. I believe that the term " effective peak acce-1eration" should not be considered at all, since, so far, no one has pre-cisely defined what is meant by this expression. From the past experience, I .found that it is usually smaller than the recorded acceleration, that its interpretation varies from one experts to the next, and that it some-how reconciles the past analyses with recent or new recorded data. From several cases of its usage that I have seen it appears that it avoids the
. physical basis of the problem and allows unwarranted freedom for expert judgement.
The third and often the last step in specifying the design earth-s-
quake motians at a site is to use-the appropriate peak acceleration to
, . _ . ~ _ , _. . _ - . , . . ~, , - , - . ,
5 scale the amplitudes of the standard shape of the response spectrum given by the Regulatory Guide 1.60. Unfortunately the shape of this response spectrum does not represent the correct average plus one standard deviation or average spectrum envelope, since, prior to analysis for spectral shapes, all spectral a-nlitudes have been normalized by i ' the ' corresponding peak acceleration. 'his normalization leads to the zero standard deviation of spectral amplitudes at the short period end.
When multiplied by the average peak ground acceleration the resulting spectrum amplitudes are close to the average spectral amplitudes at the short period end, and as T increases approach the average plus one standard deviation spectrum from below. If multiplied by the average plus one standard deviation the resulting spectra overestimate the actual average plus one standard deviation of spectral amplitudes at all T. In spite of these difficulties, the above procedures can yield an adequate
_ seismic design _ basis in_ the range of intermediate and small response amplitudes where the detailed and more refined analysis is not essential.
ItL is further noted _that in the critical re-evaluation of the existing design spectra, the detailed review and justification of the tasks involved in the above step by step methodology cannot be expected to resolve all difficulties, since this methodology. itself represents an approximation.
EA PROBABILISTIC INTERPRETATION OF APPENDIX A To formulate an_ independent basis for evaluation of the seismic design response spectra at Seabrook site (Reg. _ Guide 1.60 spectra with short period amplitudes at 0.25g)Lthe following procedure is considered:
.l.- Describe seismicity at and surrounding the plant site by a
6 stationary uniform Poisson sequence of earthquakes in time and space, such that the number, N , of earthquakes of given maximum (epicentral) intensity, I, is given by log 10 N = a -bI where e and b are constants that can be evaluated for the site.
- 2. Compute the Uniform Risk Spectra (URS) at the site for the seismicity given by 1 above and for the local site specific geologic conditions, following the procedures presented by Anderson and Trifunac (1977).
- 3. Compare the derived URS amplitudes with the proposed Seabrook design spectra, evaluate the differences and discuss the adequacy of the proposed design spectra.
Figure 2 presents the data on the expected number of earthquakes (per year) with different epicentral intensities I on MMI scale, in the 2
area of about 27000 km . identified as Boston-New Hampshire region (Chinnery,1979). -The.outside (left) scale on the vertical axis gives
-the logarithm of the number of earthquakes per year for the entire region 2
-of 2700L km . The right (inside) scale on the y-axis gives the logarithm 2
'of. the nt mber of earthquakes per year per 1000 km assuming the total area of 27000 km . Open circles represent Nc (number of earthquakes greater than and equal to.I). The full circles represent N the number of earth-quakes of. intensity which corresponds to the x-coordinate of the point.
-The seismicity model
' log 10 cN = 2.15 - 0.59I (1)
7 corresponds to the one discussed by Chinnery (1979). The model log 10 "c = 1.52 - 0.481 (2) represents an example of a " pessimistic" interpretation of 109 10 Ic versus MMI data, available so far, in that it mcst probably overestimates the frequency of earthquake occurrence for earthquakes with MMI2 VII.
For calculation of URS following Anderson and Trifunac (1977), equa-tion-(1) is transformed to log jg N = 0.59 - 0.591 . (3)
Perusal of figure 5 on the page 763. of Chinnery (1979) shows that the distribution of- epicenters within the zone corresponding to the Boston-New Hampshire region is not uniform. To further add to the " pessimistic" nature of the model-(2) I will assume, arbitrarily, that all these 2
everts'have occurred'in a small area A = 13500 km . With this, equation (2) leads- to log 10 N =. 0.22 - 0.481 (4)
To apply the method of Anderson and Trifunac (1977), it is convenient to choose the maximum intensity which can occur in each source region.
By perfonning'a series of calculations for different maximum intensities it-is possible to show how.this parameter influences the end result.
To compute the URS at the site I assumed that the whole region 1
surrounding the site can be represented by a unifona diffused zone as '
defined by Anderson and Trifunac-(1977). In the case of model (3) this is. equivalent to a" redistribution of the past seismicity into a uniform seismicity:per area surrounding the site. For' the model (4) this h equivalent 'to postulating a future ' seismicity per unit area'which is,
8 a
comparable to the most active sub areas of the Boston-New Hampshire region during the past 50 to 150 years. Since the model (4) assumes that this will occur uniformly at the Seabrook site and all surrounding areas, this model represents a " pessimistic" prediction of future-seismicity, which would be considerably higher than what has been observed there so far.
Figures 3 and 4 summarize the results of computed URS of Pseudo Relative Velocity (PSV) at a rock site (h=0 km, where h represents the depth of sediments beneath the site), for horizontal ground motion and j for structural damping of c =0.05. Each figure shows two groups (each consisting of three URS spectra) of curves for p=0.05 and p=0.30. Here p represents the probability that these spectra will be exceeded at least once during the next 50 years. Each group contains three URS curves corresponding to the three cases analyzed and for the maximum intensity in_the area assumed to be VIII, X or XII. Both figures also show the SSE spectra proposed for the Seabrook site and corresponding to 0.25g peak acceleration and G =0.05.
Figure 3 shows that these calculations suggest the probability of exceecing the proposed Seabrook design spectra during the next 50 years is less than 0.05, assuniing no limit on the maximum epicentral intensity in the region. _ Assuming that the largest possible intensities are X and.then VIII the probability of exceeding the SSE spectra for Seabrook is-further reduced. This also means that for the seismicity represented by the model i n equation _(3),' during the next 50 years the probability that the peak acceleration equal to 0.25g will be exceeded is less than (Imax.= VIII and X) or equal to'0.05 (if I max =XII).
Results in Figure 4 show that-if. the site seismicity is equal to
9 a
i
[ ' that described by equation (4) that the probabilities of exceeding the proposed SSE. spectra at Seabrook Site are as follows:
Maximum area intensity Probability of exceeding Seabrook Spectra I max < 0.05
( = VIII L =I =X < 0.15 max 4
I max
=.XII < 0.30 The differences between the shapes of URS for this site and the pro-T1 posed SSE spectra exemplify the ability of the URS method to reflect the site specific conditions which in this case are primarily influenced by
.the nature of the rock site (this tends to increase the high frequency
~
URS _ amplitudes relative to the fi, sed shape of Reg. Guide 1.60 spectrum) and the nature of the log 10 N versus'MMI.
s 4
s e
10 CONCLUSIONS
-The above probabilistic calculations suggest that the pr; posed SSE design spectra for Seabrook site (corresponding to 0.259 peak acceleration) may be acceptablL. However,.before I can finalize this
- conclusion,-I would have to' carry out additional-and more detailed
. calculations to fina whether the above model of seismicity in equation
- (4)'is indeed a "sufficiently pessimistic" representation of possible 1 seismicity during .the next 50 years.
t
+
11 l
2 REFERENCES Ande son, J.G. and M.D. Trifunac (1977). On Uniform Risk Functionals which Describe Strong Earthquake-Ground Motion: Definition, Nume-rical Estimation and an Application to the Fourier Amplitudes of Acceleration, Dept. of Civil Engineering Report 77-02, U.S.C. ,
Los Angeles (also NUREG-0405 Vol. 2, p. E1 - E100).
LChinnery, M.A. (1979). A Comparison of the Seismicity of Three Regions
- of the Eastern United States, Bull . Seism. Soc. Amer. , 6][,757-772.
- Trifunac, M.D. (1976). A Note on the Range of Peak Amplitudes of Re-l' corded Accelerations Velocities and Displacements with respect to I
theLModified Mercalli Intensity Scale, Earthquake Notes, Vol. 47, No. 1, 9 - 24.
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4
. UNITED STATES OF A" ERICA l NUCLEAR REGULATORY C0" MISSION
$ BEFORF THE ATOMIC'SAFFTY AND LICENSING APPEAL, BOARD
. In the Matter of- )
)
PilBLIC SERVICE C0"PANY OF ) Docket Nos. 50-443 NEW HAMPSHIRE, et al. 50-444 (Seabrook Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of Letter from M.D. Trifunac to R.P. Lessy enclosing COMMENTS BY PROF. . MIHAILO D. TRIFUNAC" 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, throuch deposit in the-Nuclear Regulatory Commission's internal mail system, this 23rd
- day of March,1981:
Alin S. Rosenthal, Esq. , Chai rman* Joseph F. Tubridy, Esq.
Atomic Safety and Licensing 4100 Cathedral Avenue, N.W.
Appeal Board l Uashington, DC 20016 U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Ernest O. Salo Professor of Fisheries Research
'Dr. John H. Buck *' Institute
- Atomic -Safety and Licensing College of Fisheries Appeal Board University of Wash'ngton U.S. Nuclear Regulatory Commission Seattle, Washingtoa 98195 Washington, DC 20555 Dr. Kenneth A. McCollom Dr. W.: Reed Johnson
- 1107 West Knapp Street Atomic Safety and Licensing Stillwa tar, Oklahoma 74074
- Appeal Board '
'J.S. Nuclear Regulatory Commission Robert A. Backus, Esq.
Washington, DC -20555 0'Neill, Backus, Spielcan, Little 116 Lowell Street '
Ivan W. Smith, Esq.* Manc' ester, NH 03101 Atomic Safety 'and Licensing Board Panel . Ellyn -R. Weiss, Esq.
. U.S. Nu'elear Regulatory Commission Harmon & Veiss-l Washington, DC 20555 1725.1 Street, N.W.
Suite'506 Hashington, DC -20005
- ~ = .r- -- , , ,,. . - . . -*
+av-*- - + ' -
- Thomas G. Dignan, Jr., Esq. Ms. Elizabeth H. Weinhold John A. Ritsher, Esq. 3 Godfrey Avenue Ropes & Gray Hampton, NH 03842 225 Franklin Street Boston, MA 02110 D. Pierre G. Cameron, Jr., Esq.
General Counsel Norman Ross, Esq. Public Service Company of 30 Francis Street New Hampshire Brookline, MA 02146 1000 Elm Street l'anchester, NH 03105 E. Tupper Kinder, Esq.
Assistant Attorney General Francis S. Wright, Asst. Atty. Gen.
Office of Attorney General Laurie Burt, Esq. , Asst. Atty. Gen.
State House Annex Commonwealth of Massachusetts Room 208 Environmental Protection Divis'.an Concord, NH 03301 One Ashburton Place,19th Floor Boston, MA 02108 William C. Tallman Chairman and Chief Executive Atoc.tc Safety and Licensing Officer Board Panel
- Public Service Company of U.S. Nuclear Regulatory Commission Washington, DC
~
New Hainpshire 20555 1000' Elm Street Manchester, NH 03105 Atomic Safety and Licensin._
i Appeal Board
- Docketing and Service Section* U.S. Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555
/
Roy P. Lessy Deputy Assistc @/ Chief Hearing Counsel
.- . _ ,-_ .