ML19345G384
| ML19345G384 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 04/03/1981 |
| From: | Bachman R, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | FRIENDS OF THE EARTH |
| Shared Package | |
| ML19345G382 | List: |
| References | |
| ISSUANCES-SC, NUDOCS 8104070131 | |
| Download: ML19345G384 (33) | |
Text
_... _ _ _ - _ _ _ _ _ _. _
Q 4/3/S1 0:41TED STATES OF AttERICA fiUCLEAR REGULATORY C0t4:11SSI0'4 In.the 14atter of GEfiERAL ELECTRIC C3.
)
)
Docket tio. 50-70 (Vallecitos fluclear Center -
)
(Show Cause)
General Electric Test Reactor,
)
Operating License fio. TR-1)
)
fiRC STAFF RESP 0:13ES TO Ii4TERROGATORIES OF FRIEiDS OF THE EARTH Pursuant to the tienorandun and Order of the Atonic Safety and Licens-ing Board dated February 3,1981, the !4RC Staff herein files its responses 3
to interrogatories propounded by Intervenor Friends of the Earth on March 16, 1931.
In responding to the interrogatories, we assune that when you refer-ence "the Applicant" you in fact mean the Licensee or General Electric Co.
Affidavits identifying the individuals who contributed to the prepara-
+
tion of the responses verifying then are attached to the responses, with the exception of Interrogatory number 12, which called for a legal conclusion.
The undersigned counsel for the !4RC Staff prepared that response. Copies r
of the signed affidavits of Willian E. Vesely, Christian C. fielson, and David 3. Slexions will be sent to you as soon as they are available.
. Respectfully submitted 4
3 hcz+
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7 Daniel T. Swanson t-Counsel for fiRC Staff b
Richard G. Bachman
' Counsel for flRC Staff 8104070j$$
, Interrogatory 1 Explain in detail the " Current Staff Position" as stated on page four of the Staff SER NRC Geosciences Branch Review,1980, where you state "The information developed for this site does not completely meet the investi-gative requirements of Appendix A to 10 CFR Part 100".
Explain how this primary conclusion in your SER could be a justification for reopening the GETR.
Explain what additional investigative requirenents would need to be net for a reactor in an active fault zone in California.
Response
This. conclusion is stated for information and not is justification for reopening the GETR. Appendix A to 10 CFR Part 100 sets forth seismic and geologic considerations 'for the evaluation of proposed nuclear power plant sites. This regulation is not applicable to test reactors such as GETR hut is applicable only to pover reactors. However, becau e of the highly conservative Staff approach, the criteria lof Appendix A to 10 CFR 103 was used as a reference point for the Statt's evaluation of GETR for this Shos Cause Proceeding.
Additional investigations would have to be perforned for a new power reactor being proposed to be located in an active fault zone in California, pursuant to the following sections of 10 CFR Part 100, Appendix A:
IV(a)(6), lV(a)(7), IV(a)(B), IV(b)(7), V(b) and (b)(1) and VI(o)(3).
Interrogatory 2
' Will the NRC Staff require the Applicant to conduct "better micro-earthquake instrumental coverage" as suggested in USGS80-515,- by USGS seismologists? If the NRC Staff has not required GE to do this research, justify-the. lack of these investigative requirenents imposed by. the NRC on GE.
Response
No..In order to account for: uncertainties, the Staff assumed that the faults which-affect.the design are active, are capable of generating
.=
, earthquakes as described in the SER and night sustain surface displacement as described in the SER.
Interrogatory 3 Justify your lack of consideration of a.75 g with a sinvitaneous one neter of offset. Why do you separate.75 g from a.6 g with a neter of offset?
Response
We considered.759 froa the Calaveras with a simultaneous one neter of offset from the Verona and rejected that conbination for design pJrposes.
We separate.75g (Calaveras) fron.69 with a meter of offset (Verona) because in our judgment it is unlikely that the Calaveras event would occur simultaneously with;a Verona event.
' Interrogatory 4 Do you contend that a it.7 to 7.5 earthquake on the Calaveras Fault
.would not cause secondary or synpathetic faulting on the Verona Thrust Fault Zone which_ could result in a.75 g and one neter offset sinulta-
'neously? Explain your response in detail.
Response
No. We' contend that such a cause' and effect relationship to the extent stated in the interrogatory. is unlikely.
Our estination that such an ' interaction of' faulting and sinultaneous.ettects as postulated in the interrogatory is unlikely'is based on; our consideration that a _-series of.
paraneters, each having a ' probability distr 1bution enters into the judgnent process.
. Response The significant portions of these data used in the evaluation include t
the cases of Pacoina Dam (1971), Ancona, Italy (1972), Parkfield (1966),
and Melendy Ranch (1972).
References tollo.!:
1.
W.K. McCloud, " Intensity Map and Structural Danage, Parkfield, Ca n-fornia Earthquake of June 27, 1966", Bull. Seisn. Soc. of America, Vol. 57, No. 6,1967, pp.1161-1178.
'2.
"Managna, Nicaragua Earthquake of December 23, 1972", Earthquake Engineering Research Institute Reconnaissance Report, May 1973.
3.
"Tne San Fernando, California, Earthquake of February 9, 1971:
A prelininary report published jointly by the U.S. Geological Survey and the National Oceanic and Atnospheric Adninistration", U.S.G.S. Profes-1 sional Paper 733, 1971.
4
" Reconnaissance Reports - Imperial Valley Earthquake, October 15, 1979",
NRC Reconnaissance Team, November 1979.
5.
" Reconnaissance Report, Mikagi - Ken-0ki, Japan Earthquake, June 12, 1978", Earthquake Engineering Research Institute, December 1978.
6.
" Engineering Features of the San Fernando Earthquake, February 9, 1971",
Paul C. Jennings, ed., California Institute of Technology, Earthquake Engineering Research Laboratory,-Report, EERL 71-02, June 1971.
-7.
Sulletin of the. Seismological Society of Anerica, Seisnological Notes, Vol. 63, No.1, February 1973, pp. 336-337.
8.
Bulletin of the Seisnological Society of America, Vol. 63, No. 3, June 1973, p. 117.
Interrogatory 7
-Justify the NRC Staff adoption of "effect1ve accelerations" for seismic design criteria.
(a) Has~ the NRC Staff adandoned, partially or conpletely, its reliancefon the instrunental recordings of earthquake ground notions?
If_so, please' explain why.
Response
LThe NRC. Staff has not, at this time,' abandoned its reliance on or consideration of-instrumental 1 recordings of earthquake. ground notions.
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t 4-Interrogatory 5 Explain the difference between the NUREG-CR-0098 deterninistic criteria and the "probabilistic approaches to seismic design" which Drs. Newnark and Hall state that they prefer to usa, as stated in the Staff SER, Appendix A.
Response
i The deterninistic approach to seismic design utilizes a defined input loading, based on expected naxinua values, and establishes a fixed set of allosable bounds for acceptance criteria. The probabilistic approoch considers the. probability of a given load level and the probability that such loads sill produce adverse effects. These joint probabilities are then maintained within the pre-established bounds.
Earthquake occurrence with respect to time (i.e., date, location, nagnitude, ground nation ~ effects measured) is probabilistic in nature.
However, the data base for these itens is limited, thereby precluding the use-of rigorous probability analysis as the sole base of arriving at design paraneters. Thus, the current design approaches are based pria'2rily en our knowledge of observable infornation, reinforced by probabilistic analyses as they become available, and by our assessment of their applicability.
Interrogatory G On page 3 of the Nesnark and Hall Appendix A in the SER, Newmark and Hall-justify the use of " effective" peak accelerations by stating that "thsre--is a well defined body of data (emphasis added) indicating that the response of structures and the_ danage to the structures... corresponds to a smaller acceleration than that recorded instrunentally. in the free filed.
(sic) Please provide that'"well-defined body of, data" to the Intervenors.
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, Instrumental recorcings provide part of the basis used to arrive at design acceleration values. However, " effective acceleration" values used for design purposes incorporate our knowledge of ground motions and tneir characteristic effects on structural response and thus are nore appropriate.
Interrocatory 8 Explain the 'neaning.of the statenont by Robert !1 orris to Bob Jackson in the USGS to fic,C letter of April 22, 1980, which says, "!1uch of that naterial (presented by GE to ACRS on flovember 14,1979), never has been fornally docketed by the. applicant, a situation that has nade it difficult for the USGS to perfora its review in the normal nanner".
List and provide the docunents that are not dacketed.
Response
The naterial in: question refers principally to age determination and aspects of fault novement. The naterial was provided as vu-graphs and verbal discussion during ACRS subcommittee meetings which were not docketed at that time.
However the naterial was submitted to the Staff by GE letter dated July 16, 1980, and was subsequently docketed.
Interrogatory 9 Explain the role.that Dr. William Vesely had in the WASH-1400 Rasmussen Report. Describe Dr. Vesely's particular influence in that report.
Response
.Dr. Vesely was -a: principal. analyst in the Rasmussen study and had responsibility for overseeing the quantifications of the fault trees and event trees. He. reviewed the nodeling, data analyses, and quantification
. procedures which were being considered and.nade recommendations Lto the management;of the study.
Dr. Vesely had an important_. influence in the
fault tree and event tree evaluation approaches which were used in the
. s tMy.
i interrogatory 10 l
Explain the 71RC policies regarding the use of probabilistic risk assessment nethodology in the licensing or operation decision-making procedures (including this OSC Proceeding) regarding nuclear reactors near a:tive earthquake faults in California.
' Response, The NRC Staff is naking limited use of probabilistic methods in conjun-tion with the-nore traditional empirical-deterninistic nethodolo-gies.
In the GETR review probabilistic estimates were used to supplement classical geological nethodologies and judgnents with respect to fault evaluations.
Interrogatory 11:
Why. docs-the NRC have "No regulation or policy prohibiting the siting
-of nuclear reactors near known_ active earthquake faults in California?
' Response:
Objected to.*
i*
Objections to certain of these1 interrogatories are cor.tained in "NRC' LStaff Objections to Intervenor, Friends Sf the Earth's : Interrogatories" dated March 25. 1981, and are not repeated herein.
a Interrocatory 12 In your February 25, 1981 update to Intervenor's question 1-2, your response states, "The present review does not rely upon the original bases, calculations and references stated in tne response to 1-1 and we do no' intend to use then in the Show Cause Proceeding". Do you contend that the original design bases, calculations, etc., should not be allowed into these proceediegs as an issue or conter. tion? If so, justify your contentian in detail.
Response
The Staff position is that the original design bases, calculations, etc. should not be allowed into this proceeding as an issue in this pro-ceeding absent = showing by the party seeking to introduce this information that it is relevant and material to the issues in the proceeding.
Interrocatory 13 Define these terms:
A.
" effective accelerations" B.
" instrumental accelerations" C.
" free-field accelerations"
\\
Response
A.
Effective, or. design,-acceleration -is that acceleration nost l
closely related to structural. response and to the damage potential of an j
In addition, it' reflects the value used to anchor the-zero P
. period part 'of.the design response spectrun used in analysis and des.ign.
l B.
Instrunental accelerations.are those accelerations recorded during the earthquake notion by a' reliable strong-motion instrument situated in-
. the free-field or what' may be considered. in the free-field because it should not be significantly affected by scil-structure interaction or by topographic. conditions.
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Free-field acceleration is that acceleration which represents
. ground notion uninfluenced by man-nade struct res.
Interrogatory 14 Explain.how the concepts of " effective" and instrunental" and " free-field" accelerations are interpreted and used in fiRC regulations policies and procedures and guidelines to licensee's reactor operators.
Response
The concepts of ins unental, free-field and effective acceleration are not used in NRC regulations, guidelines, etc. for reactor operators.
Interrogatory 15 Explain how at the GETR site you have managed to lower the inst-u-nental accelerations of above one g to " effective" accelerations of.6 and
.75g? -
Interrocatory 16 Explain how you can reduce ground accelerations of greater tnan 19
. resulting fron a nearby earthquake of M7 to 7.5 to only.75 g.
(a)L What horizontal and vertical ground accelerations and responso' spectra were each of the GETR syster.s. structures, and components essential to protecting public health and safety originally designed for during the construction of.the reactor.
. Response to 15 and 16
' As discussed in response to interrogatory 13 and' appendix A-to.the
- Staff'.s October 27,1980.SER, a single instrunental peak of large' ampli-
.tude, short duration acceleration ~ does. not contribute significantly to the -
danage potential;of'an earthquake. Thelsignificant amplifications-in notion, as ' reflected in response spectra, are' associated with repetitive
. _ _._-._. _ ___ _ ~
i 1
notions in the frequency ranges of consideration.
Effective acceleration is used to assess earthquake ground nation and structural response for the purpose of developing design paraneters. By this nethod, an acceleration v31ue of 0.759 was determined to be proper to anchor the zero period part af the design response spectra for use in analysis and design.
'a) This interrogatory was previously answered in our fiay 1978 response to Q 1-13.
Interrogatory 17 Was the GETR designed to withstand surface rupture beneath it on the Verona Thrust Fault?
4
Response
Based on the analyses perfarned in response to the Show Cause Order, we have deternined that GETR safety-related structures, systens, and conponents hodified as proposed are capable of withstanding the effects of the design basis surface rupture specified in the Staff'S itay 23, 1980 SER, section C, page 2.
Interrogatory 13 What proof or guarantees do y'ou have-that any structural nodifications would-be adequate.to protect the public health' and safety in the event of a surface-ructure beneath the GETR on a thrust fault?
Response-
. There are rx) guarantees -that there would be.no adverse effects in the
-event of an earthquake.
However, the acceptance criteria.used in the
- Staff's evaluation are-consistent with-those.necessary to satisfyfl0 CFR
~
.~.
, 50, Appendix A, Criterion 2, and specify that the integrity of essential structures, systems, and components required to safely shut dodo the GETR and.naintain it in a safe shutdown condition during and after the design seisnic events be assured. The seismic design criteria, analyses, nethods and criteria employed are based on accepted engineering principles used to design such structures, systems, and components, and are generally nore stringent than those which would be used to design similar conventional structures. However, experience has shown that well engineered conven-tional structures posses's an aoditional capacity to resist seismic forces.
Accordingly, on the basis of our evaluation of the seisnic design criteria, analyses, netnods and criteria enployed, and the results ootained, we concluderi that there is reasonable assurance that the GETR structures, systems, and co*1ponents inportant to safety, nodified as proposed, uil!
remain functional / operable, considering the seisnic design bases deternined proper by the Staff.
t Interrocatory 19 Explain wny did the NRC not require GE to estinate the probability that for each future earthquake on the Calaveras or Verona faults, that there _would'be precursor shocks 'in tine' to activate the seismic trip systen and insert control rods before the naximua ground nations and surface rupture.
Response
Activation of the seismic scram system by precursor. shocks is not necessary to mitigate the effects. of a design basis ' seismic event. The scran system is designed to-activate at the low levels-of acceleration-l which occur at the onset-of the~ design basis seismic event.
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Interroaatory 20 Does the fir: Staf f agree tnat toe Calaveras Fault could experience a fiagnitude 7 to 7.5 earthquake "at any tine" as explained by one of tr.e tRC staf f scier.tists af ter the shutdown of the GETR in 1977?
If not, please provide the formula used to nake the deterninstion.
Response
It is our position tnat tne Calaveras Fault could experien:e a magni-tude 7 to 7.5 earthquake. Ne do not kna.1 the conte.<t of the quote no-did you identify tne author. Inerefore, we cannot address w'letner tais response is "as explained by one of the 'RC Staff scientists..."
Interrogatory 21 Does the 'MC Staff have any evidence or reason to believe that tne probability of a aajor quake on the Calaveras Fault has (a) decreased or (b) increased during the time since the shu^down of the GITR in ;377? Explain yaar response in detail.
Response
(a) ido.
(b) 14 0. We have no evidence or reason to believe that since the shutdown of GETR that the probability of a najor quake on the Calaveras has increased or dacreased. The basis for our assessnent of tne hazard from tne Calaveras has not changed since 1977.
. Interrogatory No. 22:
Explain in detail why the NRC recently ordered several nuclear reactors in the Eastern USA shutdown because of inadequate seismic design.
Response
Objected to.
Interrogatory 23:
Have you or your consultants ever conducted or requested GE or its consultants to conduct an analysis of the ground notions that would result at the GETR site from directivity of rupture propagation or seisnic focusing as described by Dr. James N. Brune in Testinony on Ground Motions at the Diablo Canyon hearings that could cause synpathetic ground notions on the branches of the Verona Thrust Fault Zone and higher than expected ground accelerations?
If not, justify your lack of investigative requirenents, in detail.
Response
Objected to.
Interrogatory 24 D; you agree that seismic focusing or directivity or rupture propa-gation is a natural and coanon phenomena that has been observed during several Californio earthquakes?
If you do not agree then justify and explain your position.
Respense Yes.
i
D Interrocatory 23 Explain your current position on the tectonics of tne Vallecitos Valley and the Livernare Valley, in terns of the structural and tectonic relationships bet.seen the dozen active faults in the area.
P s2cnse A
Our current position on the tectonics of the Vallecitos Valley ana cnc Livernore Valley, i: terns of the structural and tactonic relationships between the active faults in the area, is essentially that expoundel by tne USGS in the liay 23, 1983 SER, Appendix B, pp. 64-57, and Appendix C.
Interrogatory 26 What would ce the effect on the GETR structores, systeas, and co.1ponents inportant to safety if ground notions (effective accelerations) larger than
.6 g with one neter offset or.75 g with no offset were to occur during future earthquakes on the Verona and Calaveras Faults? Explain in detail your response and provide us with the tormala used to nake this deternination.
Rasponse The Staff's evaluation of the GETR was based on the design paraneters identified in this interrogatory, nanely 0.6 g with one neter offset and 0.75 g with no offset. Therefore, without additional analyses, which vie have not perforned, it is not possible to quantify the response of tne GETR to ground notions greater than tnose specified. However, the "R" Staff's approach to seismic design requirenents introduces nany conservatisms into the various stages of the seismic design process.
These conservatisns, which include considerations of the loadings associated with the design event, the netnodologies for seismic analysis, and physical structural and nechanical resistance, are difficult to quantify; however they indicate
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that carefully engineered structores, systecas and components (such as exist i
at GETR) possess an additional capacity to resist seismic forces.
interrogatory 27 Wnat would be the effect on the GETR structures, systens, and components important to safe.ty if the vertical accelerations at the GETR site are similar to those observed during the Imperial Valley 1979 quake and during the Victoria Baja quake of June 19807 Explain in detail your response and provide us with the fornula used to nake this determination.
Response
~
Tne Staff has considered the appropriate data available from other seismic events in its evaluation of the GETR.
Specifically, the GETR vertical design'spectrun essentially envelopes the Imperial Valley vertical spectra in the frequency ranges of~ interest. Sufficient data are not available on;the Victoria Baja earthquake to consider that event. There is no fornula, rather the determination is based on the engineering judgnent of experts.
Interroaatory 23:
Explain how the concept of " effective accelerations" is being used in
. the licensing of-other reactors near active faults in California, including the Diablo Canyon site and the San Onofre site.
Response
Objected to.
-interrogatory 29 Who developed'the concept of " effective accelerations" and when did the NRC Staff ~begin to use " effective accelerations" in reactor site
-analyses for California reactors near -active faults?
.-.- - ~ -
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, Response a
j The concept that structural response and danage are not concensurate c
f with observed peak acceleration values has been discussed in the engineer-ing connanity since the late 1960s. The basis for the use of the concept of " effective acceleration" for nuclear facilities was discussed in NRC l'
Report NUREG/CR-0093 (1976), and in the Staff's Safety Evaluation for the j
Diablo Canyon facility.
The NRC Staff began to use the concept of " effec-tive acceleration" in approxinstely that tine frane.
Interrocatory 30 Do you agree that focal mechanism studies for smaller nagnitude earthqaakes are ambiguous, uncertain and subject to opinionated interpre-tations?. If you do not agree, please explain, in detail, why.
Response
Yes, ambiguity.is implicit in focal mechanism determinations and knowledge of the geologic structures and state of stress is required to resolve the-anbigaity.
Interrocatory 31 Do you agree that.it is possible that the Verona Fault,.the Las Positas Fault and the Calaveras Fault near the GETR site have othar subparallel branches that have not.yet been ma'pped?-
Response
Yes,-it is possible that the Verona fault',- the Las Positas Fault and the Calaveras Fault near theGETR site have other subparallel branches that.
have not been discovered and therefore are unmapped.-
o
. Interrogatory 32 Do you agree that acc.nulated stresses on major faults can be transferred to secondary faults or to enechelon (sic) strands or branches?
Response
Yes. We agree that accunulated stress on major faults can be trans-ferred with a variety of mechanisms, such as by branching, conjugate faulting or by distributive fracturing to secondary faults, to en echelon faults or to branches.
Interrogatory 33 Do you agree that the Calaveras Fault is a major branch of the San Andreas Fault and therefore is a aajor feature of the plate boundary tectonics in Northern California?
If not, describe in detail your under-standing of the tectonics of the Calaveras Fault.
Response
.Yes.
Interrogatory 34 -
Explain in detail.your concepts and understandings of the structural relationships between the Calaveras Fault, the Verona Fault, the Williams Fault, the Pleasanton Fault and the.Las Positas Fault.
Response
i Our concept and understanding of the structural relationships among tne' faults: named are based principally on the geologic and seismologic studies of -the USGS elabo ated -in their reports, (Appendices B and C to the
-tiay 23, 1980 SER). The-Las Positas is apparently conjugate to the Calaveras and likely responds to-the stress.' field acting on the Calaveras. - The Las p
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Positas and the Verona apparently intersect in the vicinity of the La Costa tunnel; the Williams fault may terminate against the Las Positas; the extent and structural relationships of the Pleasanton fault are not well known.
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Interrocatory 35 hat source of data was relied upon to calculate or estimate the
. ground notions at the GETR of.75 g and.6 g? Please list all sources used j
to arrive at these values.
t'
Response
4-Exanples of data sources evaluated as part of our review are provided 1
in our October 27, 1980 SER, Appendix A.
See also response to Interrogatory 6.
J
. Interrogatory 36 i
Do you bel.ieve that you have adequate data to predict future seisaicity on the Verona or Calaveras ' Faults by analyzing historic rect eds?
Response
- Because we do not:n'ake predictions (i.e., statenents regarding date, time, location of future seismic events) of future seisnicity we can't answer. this question directly.. llowever, we can determine appropriate
. levels _ of ground motion to be considered in the design ofl GETR. This-is done in part by analyzing historic records, n
l Ir.terroga tory :37-
. How far would you estinate to be the extent of ground strains and land -
.. deformations associated with the San Andreas Fault Systen?
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. Response
!!e have not undertaken a study that would lead to an estimate of ground strains and land deformations associated with the San Andreas Fault Systen. Such an estinate is not necessary because it is not within the state-of-the-art to use this method for making specific decisions on siting of nuclear power plants nor is it required by the Commission's regJlations.
Interrogatory 30 What evidence do yoJ have to disprove the hypothesis that faults subparallel to the San Andreas Fault, such as the Calaveras and Sreenville Faults, absorb stress fro,a the seismic notions on the plate boundary?
Resoonse We nave not addressed the hypothesis you nentioned.
The Staff does not ordinarily prove or disprove hypotheses, though we revies and evaluate hypotheses raised by applicants and licensees. The Staff recognizes that tne Calaveras and Greenville Faults apparently absorb some of the relative notion across the plate boundary.
Interrogatory 39 How deep would you estimate to be the hypocenter of a postulated earthquake on the Calaveras or Verona Fault near GETR?
Response
Hypocenters on the Calaveras-Sunol and Verona faults are expected to lie from near the surface to slightly acre than 15 km beneath the surface (Appendix C, to the May 23,1980 SER).
. hter_rogatory 40 Explain your analysi: of the relationships between the hypocenter, epicenter, surface ruptures, and peak ground acce12 rations in the San Fernando earthquake?
Response
The Staff has n0t analyzed the relationships referred to.
l_nter_rog_t_oy 41 Have you or jour consultants predicted ground accelerations at the GETR fro.1 an earthquake on the Calaveras Fault witn a nagnitude of M7.0?
To 7.57 Explain how you arrived at thcse figures.
Response
'n'e have not predicted ground accelerations at the GETR, as making predictions is beyond the scope of our mission.
It is the Staff porition, hosever, tqat peak accelerations slightly in excess of 19 can be expected fran a :ag. 7.0 to 7.5 earthquake on the Calaveras. The approach of Page and others,1972, U.S. Geological Survey Circular 672, has been used to substantiate the Staff's position.
Interrocatory 42 Has the NRC done a site-specific Class 9 Meltdown Accident Analysis for the GETR?
Response
No. The Staff calculated that the release of a small fraction of the fission product inventory due to fuel danage in the GETR core would exceed the 10 CFR Part 100 exposure guidelines.
. Interrogatory 43 What evidence draes the NRC Staff have to disprove the hypothesis that the Calaveras Fault is part of a seisnic gap?
Response
We are not aaare of a seisnic gap hypothesis for the Calaveras.
See also response to number 73.
Interrogatory 44:
Does the NRC Staff believe that an adequate data base e<isted at the time tne AEC issued the construction pernit for siting nuclear reactors at tne Vallecitos site to deter.aine or predict the ground :'ations that could occur at tne site?
Response
Objected to.
Interrogatory 45 Does the NRC Staff agree with scientists that it was not until 1959 that the theory of plate tectonics was widely accepted as the most logical explanation of earthquakes that occur around the Pacific Ocean rin?
Responsa The Staff agrees that the theory of plate tectonics is presently widely accepted as a logical explanation of earthquakes that occur around I
the Pacific risa. We are not certain if 1969 is the exact date that this theory be;ame widely accepted.
Interrogatory 46 Does the NP,C Staff agree that the Calaveras Fault is structurally related to the !!ay.4ard Fault Zone?
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We agree that the Calaveras and Haydard faults are connected on a nap
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of epicenters by a more or less continuous zone of seismicity and are likely to be structurally related.
(Secltay 23, 1980 SER, Appendix C, i
- p. 17; Satun, 1930, Bull. Seism. Soc. America, Vol. 70,flo. 4, pp. 1131-97).
1
!_nterrocatory 47 1
Does the l;RC Staff agree thst the Hayward Fault Zone is an active fault which is capable'of causing strong ground notions at the GETR site?
Respon:e The tem " active fault" is used in different ways by different agencies i
and geologists. The Hayward Fault is active in the sense that it has caused vibratory ground notion at tiETR.
For exanple, on 3/3/81 a flag. 4.1 event occurred 9 mi SW of GETR and caused peak acceleration of.0669, SE
- onponent on the second floor, and lesser accelerations in other directions.
i Because of its closer proximity to the GETR then the Hayward, and the compar6ble magnitudes of these two faults, the Calaveras represents t:1e
-controlling seismic event for the site.
Interrocatory 43 Will the fiRC Staff ask Gt to initiate a res'earch contract with a.
consultant to analyze the. gri";nd motions at the site of the GETR that would result fron a itagnitude 0.0.t.arthquake on the verona Fault zone?
Response-No, our conclus' ions do not warrant such action.
?
. Interrogatory 49 Will tne NRC Staff reqJest the Applicants to initiate a research contract with a consultant to analyze the ground notions at the site of GETR that would result froa a ltagnitude 6.5 earthquake on the Verona Fault?
Response
No, see response to as.
Interrocatorv 50 Has tne ilRC Staff considered toe possibility that the GETR and Vallecitos fa:ilities are not designed to withstand an earthquake on the Verona Fault of Magnitude 6.5? If so, explain.
Response
Ine ilRC Staff's evaluation of the GETR structures, systens and components inports1t to safety was based on design paraleters resulting from an earthquake of nagnitude 6.0 to 6.5 on the Verona Fault.
Interrogatory 51:
If the Applicants had not yet constructed the GETR, would the NRC Staff opprove of an application for a construction permit to construct a reactor at Vallecitos considering the seisnic hazards at that site?
Rasponse:
Objected to.
Interrogatory 57.
Given the Northern California tectonic setting, would the NRC Staff agree that there is a component of stress on the Calaveras a,d Verona Faults?
i
e Response Yes.
Interrogatory 53:
What evidence does the ilRC Staff have that personnel at the GETR, during future operations, could perform necessary energency procedures during and following a severe earthquake, when their lives are being threatened by the circunstances?
Response
Objected to.
Interrogatory 54:
What psychological studies can the flRC Staff cite that support their arguments that operating personnel could respond effectively to earthquake circunstances at the GETR?
Response
Objected to.
Interrogatory 55' What were the peak instrunental and effective ground accelerations (g values) for which the spent fuel pools at the GETR was designed and built?
Response
-The spent fuel pool and the new spent fuel pool tanks have been evaluated to' the criteria specified in ' Issue 1, i.e., effective accelera-tion of 0.75g.for use in anchoring' Regulatory. Guide 1.60 spectra. This-effective' acceleration is. associated with a peak acceleration slightly'in excess of 1.0 g.
I
25 -
_I__nterroaatory 56 Have the MRC Staff contracted with consultants to analyze the direc-
.tivity and focusing effects observed in the seismic wave propagations and
' instrumental data in the records for each of the following earthquakes:
a.
The Long Beach earthquake of 1933; b.
The Santa Barbara earthquake of August 31, 1973; c.
The Coyote Lake earthquake of August 6, 1979; d.
The Imperial Valley earthquake of October 15, 1979; 1
e.
The Livermore Valley earthquake of January 24, 1983;
- Response 40.
Interrogatory 57-Explain the Staff'.Geosciences Branch understanding of each of those
- quakes and consideration of their evaluations and seismic hazards to
. California-reactors.
- Response-LThis das partially objected to. To answer.the interrogatory aith respect to GETR would require a study 'that has not yet-been done.
t Interrogatory 53 Why1did the NRC shutdown the GETR-in 1977?J
Response
The bases for the referenced action are those set forth in section Ill 2
of the Order to Show Ca'use dated October 24, 1977.
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m 1 Interrogatorv 59:
Why did the NRC shut down the Humboldt Bay Reactor?
Response
Objected to.
Interrogatory 60:
- Why has the NRC delayed operations at the Diablo Canyon Reactors froa
-1973 until the preseat?
Response
Objected-to.
Interrogatory 61 Does-the NRC Geosciences Branch agree with the following statenent nade by NRC Staff Seismologist in a meeting with earthquake engineers and geophysicists in San Diego County on February 14, 1978, as published with the title "The Needs of the NRC in the Field of Strong !!ation Seismology":
"The most difficult problem we face today is estinating strong notion in the vicinity of the earthquake source, i.e., the near-field.
No nuclear power plant is intentionally placed near a known earthquake source 'of
" capable" fault but subsequent investigations bave revealed new faults and resulted in reassessnent of some old faults.
The Humboldt Bay, Diablo Canyon, San Onofre, and Vallecitos sites in California are the prima exanples.
In order to determine whether facilities at these sites are sufficiently safe as designed, need to be upgraded or-need to be abandoned,
- requires an assessment of motion near earthquake sources wnere we have a few neasurements nost of which are froa small earthquakes".-
Response
This statement is correct.
It should be noted, however, that there.is no regulation or policy which precludes siting nuclear power plants near
~
known capable faults.
b
- ?7 -
Interrogatorv 62 List the "varioJs organizations" that NRC Staff consultant David 51ecc.aons worked for at 7 power plant sites in 5 states.
PfaPanSe David 3. Slemnons has worked, or is working, as a consultant to the AIC/NaC for the :talibu, GETR, and San Onofre site reviews. He worked as a consultant to Woodward-Clyde Consultants on revieas regarding flatagordo, Hadson River, and Stanislaus sit (s.
He also was a consultant to Sierra Pacific Power Co. for a review of siting in northwestern Nevada, for Fugro, Inc. regarding the Palo Verde plant, and for United Constructors and the Washington Public Power Supply Sy:2 ten in connection with the Hanford Reservation review ~in Washington.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
)
)
GENERAL ELECTRIC COMPANY
)
Docket No. 50-70
)
(Show Cause)
(Vallecitos tiuclear Center -
)
General Electric Test Reactor,
)
Operating License No. TR-1)
)
AFFIDAVIT OF MILLARD L. WOHL STATE OF MARYLAND
)- SS COUNTY OF MONTG0MERY )
I, Millard L. Wohl, being duly sworn, depose and state:
1.
.I am a nuclear engineer in the Accident Evaluation Branch, Division of Systems Integration, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
2.
A copy of my professional qualifications was previo:. sly provided as an attachment to " Updated NRC Staff Responses to Interrogatories of Friends of the Earth", dated February 25, 1981.
3.
I have contributed to the response to interrogatory number 42 and I hereby certify that the answers given are true and correct to the 'best of my knowledge.
%']etGr i k. A1] k Millard L. Wohl Subscribed and sworn to before ne tni s ; '- -(
day of April,1981
._s
, r. :;./.:.
- ! ' s s
+- -. -
Notary Public
'y,
.j[ L My Commission expires:
/
St
UtlITED STATES OF A:1 ERICA liUCLEAR REGULATORY C0:111SSIO~1 BEFORE THE ATO:ilC SAFETY A JD LICEriSI!;G BOARD In the liatter of
)
)
GE iERAL ELE:TRIC C0 IPA:1Y
)
Docket :lo. 50-70
)
(Sno's Cause)
(V311ecitas:b;1e5-Ceat'er -
)
Gener21 Electric Test Reactor,
)
Operating License flo. TR-1)
)
AFFIDAVIT OF PHILIP S. JUSTUS STATE OF !!ARYLA::D
)
33 C0U 4TY OF l10 4TGO tERf
)
I, Philip S. Justus, being duly sworn, depose and state:
1.
I an a Staff Geologist, Geosciences Sranch, U.S. iluclear Regulatory Coniission, Washington, DC 20553.
?
I have contributed to the attached responses to interrogatary nunbers 1-4, 8, 20, 21, 23-25, 30-34, 35-41, 43, 45-49, 52, 56, 57, and 61 and I hereby certify that the responses given are true and correct to the best of ny knowledge.
r g..
(l 'i' b'
S>
Pnilip 3. JJst' 2 k
Subscribed and sworn to before me this 3rd day of April,1981 m
s liotary Public s
ii fly Commission expires:
U:lITED STATES OF AMERICA
!!UCLEAR REGULATORY CO*!'ISSIO:i BEFORE TH_E ATO:11C SAFETf At;D LI,C_EiiSI:!G BOARD In the flatter of
)
)
GC1ENL ELECTRIC C01P4 :Y
)
Docket 'to. 60-70
)
(Sqca Cause)
(V311ecitos iiuclear Center -
)
General Electric Test React 3r,
)
Operating License !!o. TR-1)
A:FIDAVIT OF JOSEPH A. i1ARTORE STATE OF IIARYLA:iD
)
SS COUiTY OF MC,7,1 M )
I, Joseph A. !:artore, being duly sworn, depose and state:
1.
I an a Project llanager, Division of Licensing, U.S. iluclear Regulatory Connission, !!ashington, DC 20555.
2.
A copf of ny professional qJ3lifiC3tions.48s previoJsly prMided 35 61 attschnent to " Updated fiRC Staf f Resposnas to Interrogatories of Feiends of the Earth", dated February 25, 1981.
3.
I have contributed to the responses to interrogatory nunbers 3, 6, 7, 13, 14, 15, 16, 17, 18, 26, 27, 29, 35, 50, 55 and I hereby certify
- r. net the answers given are true and correct to the best of ny knowledge.
)), l(i n._4.L_
. _ _ _ ; L z !' ',.
Joseph A. Martore
/
Subscribed and sworn to before ne this 3 JJ day of Apri' 1981
~
i
. p
,f '
.l O TO
.s
,i;otary Public
'If C;;r.ission expires:
~
_g
~
UtilTED STATES OF A:tERICA flUCLE AR REG!!LATORY C0't:11SSIO:1 SEFORE THE ATO'11C SAFETY A:iD LICFriSIfiG BOARD In the itatter of
)
)
GCiERAi. ELECTRIC C01PAliY
)
Docket ilo. 50-70
)
(Snow Cause)
(Vallecitas I;u lear Center -
)
General 'llectric Test Reactor,
)
Operating License ilo. TR-1)
)
AFFIDAVIT OF DAVID B. SLE:ii10'iS STUE OF 11ARYLAriD
)
bb COU:iTY OF !10'iTG0!iERY
)
I, Javid 3. Slennons, being duly sworn, depose and state:
1.
I a1 a Professor of Geology and Geophysics at the University of fievada at Reno, fievada, and an a consulting geologist for the U.S. fluclear Regulatory Connission in connection with the referenced proceMing.
2.
I nave contributed to the praparation of the response to interrog-atory number 62 contained in the "!lRC Staff Responses to Interrog-atories of Friends of the Earth" dated April 3,1981, and I hereby certify that the response is true and correct to the best of ny knowledge.
David B. Slennons Subscribed and sworn to before ne this 3rd day of April, 1981
!Iotary Public fly Cor.nission expires:
VilITED STATES OF A!! ERICA fiUCLEAR REGULATORY C051:11SSIO:s BEFORE THE AT0! IC SAFETY A!!D LICEi:SII:3 B03.D In the 11atter of
)
)
GE!!ERAL ELECTRIC C0' IPA:!Y
)
Docket :;o. 50-70
)
(SqoiCause)
(Vallecitos iluclear Centar -
)
General Electric Test Reactor,
)
Operatin] License ilo. TR-1)
)
AFFIDAVIT OF WILLIA:1 E. VESELY staid 0F 11ARYLA:;D
)
--DD C00'iTY OF l10'1TG051ERY )
I,.4illia, E. Vesely, being duly sworn, depose and state:
1.
I aa Acting Chief, ilethodology Branch, Division of Systens and Reliability Research, U.S. liuclear Regulatory Coaaission, liashington, DC 20555.
2.
I have contribated to the attached responses to interrogatory nJ7bers 9 and 10, and I hereby certify that the responses given are trae and correct to the best of ny knoviledge.
William E. Vesely Subs:ribed and sworn to before..e this day of April,1981 liotary Public 11y Commission expires:
UilITED STATES OF A:1 ERICA fiUCLEAR REGULATORY C0't:11SSIO:i 3EFORE THE AT0*1IC SAFETY A'43 LICEiiSIfiG BOARD in the flatter of
)
)
GE:iERAL ELECTRIC C0'IFA;Y
)
Dockat 10. 50-70
)
(Snow Cause)
('!allecitos iluclear Center -
)
General Electric Test Reactor,
)
Operating License ilo. TR-1)
)
AFFIDAVIT OF CHRISTIA:4 C. iiEL50*1 STATE OF 11ARYLA!C
)
N C00/iTY OF [10'4TG0:1ERY
)
I, Christian C. ;4elson, being daly sworn, depose and state:
1.
I an a Project :1anager, Division of Licensing, U.S. iluclear Regulatory Connission,tlasnington, DC 20553.
2.
I have contributed to the attached respanses to interragatory nac.be's 1, 10,19, 42 and 53 and I nereby certify that the responses given are trua and correct to the best of ny knowledge.
W istian C. ilelson Suascribed and sworn to before ne tnis day of April, 1931 liotary Public 11y Commission expires: