ML19345E043
| ML19345E043 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/26/1980 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| NUDOCS 8012230010 | |
| Download: ML19345E043 (5) | |
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NUCLEAR REGULATORY COMMISSION
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ATOMIC SAFETY AND LICENSING APPEAL BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos. 50-443 HAMPSHIRE, et al.
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(Seabrook Station, Units 1 and 2)
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INTERROGATORIES OF PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE TO NECNP TO BE ANSWERED BY DR. CHINNERY UNDER OATH Pursuant to the Commission's Rules of Practice and the Appeal Board's-Memorandum and Order of November 6, 1980, Public Service Company-of New Hampshire (PSCO) herein poses the following interrogatories to NECNP to be answered under oath by Michael A. Chinnery, Ph.D.
I.
The following questions, Nos. 1-10, refer to the
" Statement of Dr. Michael Chinnery Submitted by The New England Coalition on Nuclear Pollut!o. with Figure 1 attached which was marked as NECNP Exbit.t P cefore the Licensing Board in.
this matter.
s 1.
Please describe the so-called " Boston-New Hampshire area" or " seismic zone" referred to in NECNP No. 10.
Pg 8 0.1223o010
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2.
Please explain in detail why this, as opposed to a larger portion of New England,is a valid choice of area from which to form the statistical base used in Figure 1.
3 For each data point in the " Boston-New Hampshire 1800-1959" curve on Figure 1, please list by name, date and epicen-tral intensity on the Modified Mercalli scale each earthquake-included in that data point.
4 For each data point in the " Mississippi Valley 1833-1961" curve on Figure 1, please list by name, date and epicen-tral intensity on the Modified Mercalli scale each earthquake included in that data point.
5.
For each data point in the " Southeastern U.S. 1870-1970" curve on Figure 1, please list by name, date and epicen-tral intensity on the Modified Mercalli scale each earthquake included in that data point.
6.
Please describe the geographic area of the " Mississippi i
l Valley" seismic zone referred to on Figure 1.
l 7.
Please explain in detail your justification for treat-ing that area described in your answer to No. 6 as a discrete seismic zone in your analysis.
8.
Please describe-the geographic area of the " South-
. eastern U.S."
seismic zone' referred to on Figure 1.
9.
Please explain in detail your justification for treat-ing that' area described in your answer to No. 8 as a. discrete i
j seismic zone in-your analysis.
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10.
Please justify the validity of drawing conclusions based upon reviews of data from various areas which has been compiled over time periods of different lengths.
II.
The following question Nos. 11-16 refer to the letter of October 23, 1980, from Michael A. Chinnery, Ph.D.
to the Applied SeJ mology Group and Ms. Ellyn R. Weiss which was attached to the "NECNP Request that Dr. Chinnery be Called as a Board Witness and Memorandum on Related Issues",
11.
Please state precisely where in the " Power Company's Site Investigation Report" it is stated that "an intensity VIII earthquake [in the tectonic region containing.the Seabrook site]
was inconceivable" as you state in your letter.
12.
What is the " tectonic province containing the Seabrook site" which you advocate should be adopted for analysis of the Seabrook seismic design?
13 Please explain in detail your justification for the choice expressed in your answer to No. 12.
14 Please enumerate each and every study you have per-formed to develop the basis for the choice expressed in Para-graph 12, in particular, setting forth the date of each such study and where, if anywhere, it has been published.
15 Is the validity of your theory as to Seabrook depen-dent upon selection of the " tectonic province" you have described in your answer to interrogatory No. 12?
16.
If your answer to No. 15 is anything other than a simple negative, please explain in detail. e e
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Q 17.
What changes do you wish to make in Appendix A to 10 CFR Part 1007 18.
Please explain in detail the basis for your state-ment that "we know remarkably little about earthquakes in the New England area".
19.
Which " expert number" are you in NUREG/CR-1582 Vol. 3, Seismic Hazard Analysis Solicitation of Expert Opinion TERA Corporation?
20.
Is it your position, regardless of what you think of 10 CFR 100, Appendix A, that the present design of the Seabrook Station if followed in construction is such that Seabrook will be " unsafe"?
21.
Please explain in detail the basis for the opinion you have given in No. 17 including, if you choose,.the concept of " unsafe" you have utilized in forming that opinion.
22.
If your theory as to earthquake probability is f
correct, on what basis, if any, can one justify selecting as j
the SSE for a nuclear power plant intensity IX, i.e., why, j
given the lack of a historical record of thousands of years, i
an SSE of XII be 'equired for all nuclear power should not r
plants in the U.S.A.?
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By its attorneys, l
Thomas G. Dignan, Jr.
l R. K. Gad III Ropes & Gray L
Thomas G. Dignan, Jr.
R. K. Gad III l
Ropes & Gray l
November 26, 1980 l l t
e CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the applicants herein, hereby certify that on November 26, 1980, I made service of the within document by mailing copies thereof, postage prepaid, first class or airmail, to:
Alan S. Rosenthal, Chairman Ellyn R. Weiss, Esquire Atomic Safety and Licensing Harmon & Weiss Appeal Board Suite 506 U.S. Nuclear Regulatory Commission 1725 I Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20006 Dr. John H. Buck Robert A. Backus, Esquire-Atomic Safety and Licensing O'Neill Backus Spielman Appeal Board 116 Lowell Street U.S. Nuclear Regulatory Commission Manchester, New Hampshire 03105 Washington, D.C.
20555 Stuart K. Becker, Esquire Dr. W.
Reed Johnson Maxine I.
Lipeles, Esquire Atomic Safety and Licensing Assistant Attorneys General Appeal Board Environmental Protection Division U.S. Nuclear Regulatory Commission Department of the Attorney General Washington, D.C.
20555 One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Ms. Elitabeth H. Weinhold 3 Godfrey Avenue Roy P.
Lessy, Jr., Esquire Hampten, New Hampshire 03842 Office of the Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Office of the Attorney General 206 State House Annex Concord, New Hampshire 03301 Thomas G. Dignan, Jr.
Thomas G. Dignan, Jr.
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