ML19345G471
| ML19345G471 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 04/03/1981 |
| From: | GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-SC, NUDOCS 8104070321 | |
| Download: ML19345G471 (21) | |
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In the Matter of
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Docket No. 50-70 GENERAL ELICTRIC COMPANY
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Operating License (Vallecitos Nuclear Center -
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No. TR-1 G'eneral Electric Test Reactor)
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(Show Cause)
LICENSEE'S RESPONSES TO NRC STAFF REQUEST FOR ADMISSIONS AND INTERROGATORIES TO LICENSEE Pursuant to 10 C.F.R. S 2.742, GE (the Licensee) hereby files its Responses to the NRC Staff Request for Admissions and Interrogatories to the Licensee, dated March 16, 1981.
I.
ADMISSIONS l
GE admits or denies each of the NRC Staff's Requests for' Admissions as indicated below.
All such admissions or denials are made and predicated on the explicit assumption, which will not be repeatedly stated below, that the Verona 9 03 5
fault is tectonic in origin.
GE has made this assumption for the purposes of the' Show Cause proceedings and hereby
/[
incorporat'es that assumption in each response below.
As used herein, reference numbers correspond to those set forth in Attachment A to Licensee's Supplemental Responses to Intervenors' Discovery, dated February 25, 1981.
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. A:
1.
Geologic data indicate that the GETR site located within a zone of faulting (the Verona fault) which is at least 2200 feet wide.
R:
1.
Admitted.
A:
2.
Since the Verona fault displaces Holocene (less than 10,000 years old) soils it is a capable fault within the meaning of Appendix A to 10 CFR Part 100 and, therefore, poses a potential for-surface faulting near or beneath the reactor site.
R:
2.
Admitted that Holocene soils are displaced.
Admitted that Holocene soils are less than 10,000 years. Neither admitted nor denied as to whether the fault is a capable fault within the meaning of Appendix A to 10 C.F.R. Part 100, since the admission relates to a matter of law and not a i
relevant matter of fact (see 10 C.F.R. S 2.742(a)).
Admitted that the Verona fault poses a potential for surface faulting near or beneath the reactor site, on the assumption that the
(
term " potential for" is used synonymously with the term
" possibility of".
A:
3.
Future displacements in the GETR site area have a higher likelihood of occurring along existing fault breaks than between them.
R:
3.
Admitted.
A:
4.
131e possible existence of faulting has been identified in photcgraphs of' the GETR excavation.
I L
' R:
4 Denied.
Richard Harding has investigated the photographs and found no basis for the existence of faulting under the foundation (see reference 52).
A:
5.
One meter of reverse-oblique net slip along a fault plane which could vary in dip from about 10 to 45 degrees provides an appropriate description of surface displacement which could occur on a Verona fault strand (splay) beneath the reactor during a single event.
R:
5.
Admitted on the assumption that the term "apprcoriate" is used synonymously with the term " conservative".
A:
6.
Maximum. vibratory ground motion at the GETR site would result from a magnitude 7 to 7.5 earthquake centered on the section of the Calaveras fault nearest the site.
Acceleration peaks at the free-field surface, (i.e., not incorporating factors dependent on soil-structure interaction or the behavior of the structure) could be slightly in excess of 1 g.
R:
6.
The first sentence is admitted.
The second sentence is admittted on the assumption that "could" implies that such acceleration peaks are possible.
A:
7.
The. horizontal vibratory ground motion at the GETR-site resulting from an earthquake of magnitude 6 to 6.5 centered on the Verona fault could contain acceleration peal;s as high as 1 g.
However, the overall level and duration of 8
4-shaking would be less than for a magnitude 7 to 7.5 earthquake centered on the Calaveras fault approximately 2 kilometers from the site.
R:
7.
The first sentence is admitted on the assumption that "could" implies that such acceleration peaks are possible.
The second sentence is admitted except that the Calaveras fault is approximately 3.5 kilometers from the site based upon reference 31-2.
A:
1.
Combined loads caused by fault offset at the surface and vibratory ground motion must be considered to act simultaneously because there is no reasonable way to conservatively forecast the location of rupture initiation, the mode of rupture propagation and the potential source area for radiated seismic energy or the sequence of possible interaction among the Calaveras, the Verona and the Las Positas faults.
R:
8.
Admitted to the extent that it is conservative to assume for GETR seismic and geologic design bascs that combined loads caused by fault offset at the surface and vibratory ground motion induced by movement on the Verona fault act simultaneously.
Denied to the extent that the statement implies that there is no reasonable way to postulate a credible sequence for loads caused by fr.lt offset and vibratory ground motion (see' References 11 and 15-1 and 15-3(b)),
that the combined loads caused by fault offset and vibratory ground motion must necessarily be considered to act simultanecusly, or that the reasons assigned therefor are
. necessarily true.
GE does not believe that the Calaveras fault is connected to the Verona fault (see Refernees 31-2, 31-3, 32, 33, 35, 38, 49-2, and 59) or that the Verona fault is connected to the Las Positas fault (see all of the preceding references plus reference 37).
I
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A:
9.
Although the evidence strongly supports tectonic origin of the offsets observed in the trench exposures at the site, there is also evidence for a potential landslide hazard at the site.
This is based on (1) location of the GETR within a shear zone: (2) evidence for repetitive displacements on these shears; (3) youngest offset during the Holocene; (4) topographic relief adjacent to the site; and (5) potential for J
seismic loading.
R:
9.
Admitted except to the extent that the evidence strongly supports tectonic origin of the offsets.
Although GE believes that the evidence is stronger for a landslide origin (see References 31-2, 31-3, 32, 33, 35, 38, 49-2, and
)
39), GE has elected to assume a tectonic origin for the purposes of the Show Cause proceedings.
II.
INTERROG/._ TORIES Q:
1.a.)
Have.you admitted each statement included in Section I. of this document entitled " Request for Admissions?"
R:
_1.a.)
No.
6-Q:
1.b.)
If the answer to Interrogatory 1(a) is no, identify each statement in Section I. which you do not admit.
R:
1.b.)
See the above responses to Requests for Admissions Nos. 4, 7, 8, and 9.
Q:
2.
For each statement identified in Interrogatory 1(b) give the following information:
a.)
The portion of statement which is not admitted.
b.)
The basis of your disagreement with the statement.
R:
2.a.) and b.)
Same answer as 1.b.) above.
Q:
2.c.)
The expert witnesses, if any you are relying on in disagreeing with the statement.
R:
2.c.)
Richard Harding (4, 7, 8 (fault connection),
and 9).
Garrison Kost (0 (load combinations)).
l Q:
2.d.)
The document, if any you are relying on in disagreeing with the statement.
e.)
The articles, if any, you are relying on in disagreeing with the statement.
R:
2.d.) and e.)
The following documents and articles, as applicable,' were relied upon in disagreeing with the statement:
1.)
Not applicable.
2.)
Not applicable.
3.)
Not applicable.
4.)
Reference 52.
5.)
Not applicable.
6.)
Not applicable.
7.)
Reference 31-2.
8.)
Harding (References 31-2, 31-3, 32, 33, 35, 38, 49-2, and 59); Kost (References 11 and 15-1 and 15-3(b)).
9.)
References 31-2, 31-3, 32, 33, 35, 38, 49-2, and 59.
4 Q:
3.
For each expert identified in Interrogatory 2(c) above provide the following infomation:
a.)
Name and address.
R:
?.a.)
The names of each expert are set forth in R:2c.)
above.
Their respective addresses are:
1.)
Richard Harding - 701 Welch Road, Palo Alto, California 94304 2.)
Garrison Kost - 480 California Avenue, Palo Alto, California 94306.
Q:
3.b.)
Statements in Section I. which the expert disagrees with.
c.)
The basis for the disagreement identified in part b of this interrogatory (include any facts or theories relied on).
R:
2.b.) and c.)
See the above Responses to Requests for Admissions, Nos. 4, 7, 8, and 9.
Q:
3.d.)
'Any articles or studies relied on by the expert in disagreeing with the statements identified in part b of this interrogatory.
R:
3.d.)
See R: 2.d.) and 2.e.) above.
Q:
3.e.)
If expert will be or is expected to be a witness in the captioned proceeding, identify the subj ects on which he will testify.
f.)
The education background of the expert after high school (include all courses taken in area of expertise even if not leading to a degree).
- g. )-
.The work experience of the expert for the last 15 years.
. R:
3.e.)
See Licensee's Supplemental Responses To F0E's Interrogatories dated April 20, 1978, which were filed on February 25, 1981.
f.)
See the Statements of Professional Qualifications attached to Licensee's Supplemental Responses, g.)
Same as 3.f.) above.
Q:
3.h.)
Any published articles written by expert.
R:
3.h.)
The lists of published articles written by Mr. Harding and Dr. Kost are attached.
Q:
4 Ir. answer to Q.1-5 you propose to give testimony to include "a comparative analysis of the postulated Verona fault system to other fault systems, including the San Fernando fault system, to demonstrate the conservatism of the NRC Staff's 1.0 meter design basis..."
Further, you state that the bases for the testi=ony are to be found in a list of references as specified on page 6 of your " Responses".
Please specify the page numbers in the references listed on page 6 of your " Responses" concerning comparative analyses of the Verona fault as well as additional references that you intend to be utilized on this point.
R:
4 The references which GE intends to utilize concerning comparative analyses of the Verona fault are as follows:
The Reference identified in Licensee's Supplemental a.
Answers to Friends of the Earth's interrogatories Dated April 20, 1978 and_ Motion for Addition, dated March 16, 1981.
9 b.
The information presented by Richard Harding at the November, 1979 ACRS Subcommittee rceeting regarding GETR.
c.
The following are the pertinent page numbers in the references listed at page 6 of GE's Supplemental Responses, dated February 25, 1981:
Reference 15 at p. 3 (Report is entitled " Ground Motion and Displacement on a Hypothetical Verona Fault");
Reference 31-2 at pp. IV-7--10; Reference 31-3 at pp. 13-15; Reference 33, Comment 16; Reference al, at p. 3; Reference 53, Figure 1: SER (May 23, 1980), Section A, at p.
19.
Q:
5.
In answer to Q.1-6, you propose to give testimony to include an evaluation of the available near field strong-cocion data such as from the Imperial Valley (1979), Tabas.
Iran (1978), and Gazli, Russia (1976) earthquakes to establish-the conservatism of the NRC Staff's vibratory ground cotion criteria.
Specify the data set, bases, calculations and references which you intend to use in such testi=ony in support of this point.
R:
5.
The data set.and references consist of the Diablo Canyon data base specifically identified in the Licensee's Supplemental Responses, dated February 25, 1981-(answer to 12 1-6).
The bases and calculations consist of regression analyses performed by Dr. Robert Kovach.
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. Q:
6.
In answer to Interrogatory 1-6 you propose to give testimony to include "an evaluation of earthqaake magnitude-seismic moment considerations to assess the conservatism of the NRC's criteria for events on the Calaveras and Verona faults."
You mention several references on moment-magnitude scale.
Specify the data set, bases, calculations, and conclusions for the Calaveras and Verona faults that you intend to use to establish magnitude-comene relationships.
Explain the uncertainties in the results of the above conclusions that you have determined.
R:
6.
The data set, bases, calculations and references consist of a regressional analysis of worldwide data (see Singh and Haskov -- referenced at p. 8 of Licensee's Supplemental 11 2
Responses) using a shear modulus of 3 x 10 dynes /cm.
The conclusion to be drawn is that a 1.0 meter offset is a conservative value for the range of seismic parameters applicable to GETR.
The uncertainty has not been defined in the statistical sense, but sensitivity analyses perfcr=ed by Dr. Kovach indicate that for the range of seiscie parameters which could be postulate.d as maxima for GETR, a 1.0 meter surface offset is conservative.
Thus, the uncertainty of the conclusion would not be significant.
Q:
7.
Is it your position in this proceeding that operation of the GETR should continue to be suspended pending resolution of the first two issues specified by the Com=ission in its February 13, 1978 Order?
11 -
R:
7.
GE has elected to seek resolution of the first two issues in the Show Cause proceeding, and does not presently intend to avail itself of the opportunity to seek interin relief under issue 3.
Should timely resolution of the first two issues not be reasonably forthcoming as contemplated by the current schedule for the Show Cause proceedings, GE may seek interim relief.
Q:
8.
Do you intend to introduce evidence on any issue in this proceeding which contain any modifications to the bases, assumptions, or conclusions which are contained in your latest submittals to the Staff in this proceeding?
R:
8.
No.
For the purposes of this proceeding, GE has assumed that the Verona fault is tectonic in origin, and will demonstrate that the NRC Staff's recommended seismic and geologic design bases are conservative.
Any " modifications" contained in GE's evidence, relative to the body of information contained in GE's prior submittals to the Staff, would not change that information base, its assumptions, or conclusions.
GARRISON KOST LIST OF PUBLICATIONS Kost, G., J. A. Blume, k. L. Sharpe, and J. Proulx, " Response of Structures to Sonic Booms i'roduced by XB-70, B-58, and F-104 Aircraft,"
for National Sonic Boom Evaluation Office, United States Air Force, October 1968.
Kost, G., J. A. Blume, and R. L. Sharpe, " Earthquake Engineering for Nuclear Reactor Facilities," John A. Blume & Associates,1971.
Kost, G., and R. L. Sharpe, " Structural Response to Sonic Booms," Journal of Structural Division, ASCE, Vol. 97, No. ST4, April 1971.
Kost, G. " Nonlinear Dynamic Analysis of Frames with Filler Panels,"
Tnesis, Stanford University, Septercer 1972.
Kost, G., R. L. Sharpe, and J. Lord, "Benavior of Structural Systems Under Dynamic Loads," Building Fractices for Disaster Mitigation, Building Science Series 46, U. S. Department of Commerce, National Bureau of Standaros, February 1973.
Kost, G., G. M. McCue, A. Vernex-Moudon, and J. R. Benjamin, " Building Enclosure and Finish Systems: Their Interaction with the Primary Structure During Seismic Action," presented at tne 1975 United States National Conference on Earthquake Engineering, University of Michigan, Arn Aroor, June 1975.
Kest, G., E. Y. W. Tsui, and h. Krutzik, "Axisymetric Finite Element Analyses of the KKP-II Containment and Reactor Pressure Vessel Struc-tures," Transactions, Vol. 4, Part K, Third International Conference on Structural Mecnanics in Reactor Technology, London, September 1975.
Kost, G., E. Y. W. Tsui, and N. Krutzik, " Finite Element Analyses of KKP-II Containment Structure Using Axisymmetric Techniques," presented at tne International Seminar on Extreme Load Conditions and Limit Analysis Procedures for Structures, Berlin, September 1975.
Kost, G. and J. R. Benj amin, " Balanced ;< gn Criteria for Multiple Hazards," presented at the Second ASCE Specialty Conference on. Structural Design of Nuclear Power Plant Facilities, New Orleans, December 1975.
Kost, G. and R. L. Sharpe " Seismic-Resistant Design of Piping, Equipment, and Appurterances for Offshore Structures," presented at Offshore Tecnnology Conference, Houston, May 1977.
GARRISON KOST LIST OF PUBLICATIONS (continued)
Kost, G., A. Gantayat, and H. Kamil, " Development and Verification of Two-and Three-Dimensional Fluid Finite Elements fer EDAC/MSAP,"
presented at tne SAP Users' Conference and Workshop at the University of Southern California, Los Angeles, June 1977.
Kost, G., H. Kamil, N. Krutzik, and R. Sharpe, "An Overview of Major Aspects of the Aircraft Impact Problem" presented at the Fourth International Conference on Structural Mechanics in Reactor Technology, San Francisco, August 1977.
Kost G., H. Kamil, A. Gantayat, T. Telikamp, and F. Weber, " Automated Generation of Spectrum Compatible Artifical Time Histories," presented at the Fourth International Conference on Structural Mechanics in Reactor Technology, San Francisco, August 1977.
Kost G., " Review of Soil-Structure Interaction Analysis Procedures Using a Sample Study," presented at 5th SMiRT Conference, Berlin, August 1979.
Kost, G., A. Gantayat, H. Kamil, and D. Rutherford, " Investigation of the Influence of Interaction of Two Adjacent Structures on Their Responses,"
presented at 5th SMiRT Conference, Berlin, August 1979.
Kost, G., H. Kam11, N. Krutzik, S. Shankar, and R. Sharpe, " Analysis of Critical Structures and Contained Equipment for Aircraft Impact Loadings," presented at 5th SM1RT Conference, Berlin, August 1979.
Kost, G., H. Kamil, R. Sharpe, M. Das, and T. Wittig, " Soil-Structure Interaction: A Critical Review by Means of a Case Study," ASCE, Boston, 1979.
Kost, G., " Soil-Structure Interaction: A Case Study," ASCE, Boston,1979.
Numerous engineering and engineering research reports.
ls/4544
PUBLICATIONS BY RICHARD C. HARDING 1.
Harding, Richard C.,1969. Landslides - A Continuing Problem For Bay Area Development: In Urban Environmental Geology in the San Francisco Bay Region: AEG Special Publication for the 1979 Annual Meeting, San Francisco, California.
2.
Harding, Richard C. and Douglas H. llamilton,1979. Fault-Like Dislocations of Surficial Origin In Coastal Terraces (abstr.): Geol. Soc. America, Abstracts with Programs for 75th Annual Cordilleran Section Meeting, San Jose, i
3.
Shlemon, Roy J., D.M. Yadon and R.C. Harding,1979. Dating Late Quaternary slip-surface displacement by soil-stratigraphic techniques (abstr.): Geological Society of America, Abstracts with Programs, Vol.11 for 1979 Annual Meeting, San Diego, California.
4.
Wright, R.H., R.C. Harding, and D.M. Yadon,1979. The Las Positas fault, Alameda County California: an example of subsidence and/or tensional tectonics (abstr); Geol. Soc. America, abstracts with Programs for 75th Annual Cordilleran Section Meeting, San Jose, California.
5.
Harding, R.C.,1979. Calaveras Fault-Dublin Area, California: in Recent deformation along the Hayward, Calaveras, and other fault zones eastern San Francisco Bay region, California: GSA Field Trip Guidebook for 75th Annual Cordilleran Section Meeting, San Jose, California,99 p.
S.
Viets, V.F., C.K. Vaughn, and R.C. Harding,1979. Environmental and Economic Effects of Subsidence: Lawrence Berkeley Laboratory Geothermal Subsidence Research Program, Berkeley, California.
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Earth Sciences Associates
UNITED STATE: OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
)
)
Operating License (Vallecitos Nuclear Center -
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No. TR-1 General Electric Test Reactor)
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(Show Cause)
AFFIDAVIT OF RICHARD C. HARDING Richard C. Harding, being duly sworn, deposes and says as follows:
1.
That he is employed by Earth Sciences Associates as Principal Geologist, 701 Welch Road, Palo Alto, California.
2.
That he is duly authorized to execute the foregoing Responses to Admissions numbered 4, 7, 8 (part) and 9, propounded by the Nuclear Regulatory Commission Staff under date of March 16, 1981, on behalf of the Licensee.
3.
That the above-mentioned and attached Responses are true and correct to t:' best of his knowledge and belief.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Ma.ter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
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Operating License (Vallecitos Nuclear Center -
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No. TR-1 General Electric Test Reactor)
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(Show Cause)
AFFIDAVIT OF GARRISON KOST Garrison Kost, being duly sworn, deposes and says as follows:
1.
That he is employed by Engineering Decision Analysis Company as Vice President, 480 California Avenue, Palo Alto, California.
2.
That he is duly authorized to execute the foregoing Response to Admission numbered 8 (part), propounded by the Nuclear Regulatory Commission Staff under date of March 16, '381, on behalf of the Licensee.
3.
That the above-mentioned and attached Responses are true and correct to the best of his knowledge and belief.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
)
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Operating License (Vallecitos Nuclear Center -
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No. TR-1 General Electric Test Reactor)
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(Show Cause)
AFFIDAVIT OF GARRISON KOST Garrison Kost, being duly sworn, deposes and says as follows:
1.
That he is employed by Engineering Decision Analysis Company as Vice President, 480 California Avenue, Palo Alto, California.
2.
That he is duly authorized to answer the Interrogatory numbered 2, propounded by the Nuclear Regulatory Commission Staff under date of March 16, 1981, on behalf of the Licensee.
3.
That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
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0 erating License (Vallecitos Nuclear Center -
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No. TR-1 General Electric Test Reactor)
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(Show Cause)
AFFIDAVIT OF RICHARD C. HARDING Richard C. Harding, being duly sworn, deposes and says as follows:
1.
That he is employed by Earth Sciences Associates as Principal Geologist, 701 Welch Road, Palo Alto, California.
2.
That he is duly authorized to answer the Interrogatories numbered 3 and 4, propounded by the Nuclear Regulatory Commission Staff under date of March 16, 1981, on behalf of the Licensee.
3.
That the above-mentioned and attached Answers are true and correct to the best of his knowledge and belief.
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U Subscribed and sworn to before me this day of 1981.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Patter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
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Operating License (Vallecitos Nuclear Center -
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No. TR-1 General Electric Test Reactor)
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(Show Cause)
AFFIDAVIT OF ROBERT L. K0VACH Robert L. Kovach, being duly sworn, deposes and says as follows:
1.
That he is employed by Stanford University as Professor of Geophysics, Stanford, California.
2.
That he is duly authorized to answer the Interrogatories numbered 5 and 6, propounded by the Nuclear Regulatory Commission Staff under date of March 16,1981, on behalf of the Licensee.
3.
That the above-mentioned and attached Answers are true and correct to the best of his knowledge and belief.
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Subscribed and sworn to before me this 3
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
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Operating License (Vallecitos Nuclear Center -
)
No. TR-1 General Electric Test Reactor)
(Show Cause)
AFFIDAVIT OF DWIGHT L. GILLILAND Dwight L. Gilliland, being duly sworn, deposes and says as follows:
1.
That he is employed as Manager, Reactor Irradiations, General Electric Company, Vallecitos Nuclear Center, Pleasanton, California; and that he is duly authorized to answer Interrogatories 4, 5, 6, 7 and 8, propounded by the Nuclear Regulatory Ccmmission Staff under date of March 16, 1981.
2.
That the above-mentioned and attached Answers are true and correct to the best of his knowledge and belief.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
)
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Operating License (Vallecitos Nuclear Center -
)
No. TR-1 General Electric Test Reactor)
)
(Show Cause)
CERTIFICATE OF SERVICE I hereby certify that the foregoing has been served as of this date by personal delivery or first class mail, postage prepaid, to the following:
Herbert Grossman, Esq., Chairman Richard G. Bachmann, Esq.
Atomic Safety and Licensing Board Panel OELD U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Washington, D. C.
20555 Commission Washington, D. C.
20555 Mr. Gustave A. Linenberger Barbara Shockley Atomic Safety and Licensing Board Panel Ms.
U. S. Nuclear Regulatory Commission 1890 Bockman Road Washington, D. C.
20555 San Lorenzo, California 94580 Docketing & Service Section Dr. Harry Foreman Office of the Secretary Director of Center for U. S. Nuclear Regulato'y r
Population Studies Commission University of Minnesota Minneapolis, Minnesota 55455 Washington, D. C.
20555 (original and 3 copies)
Rep. Ronald V. Dellums, M.C.
Attention:
H. Lee Halterman, Esq.
Atomic Safety and Licensing 201 13th Street - Room 105 Board Panel Oakland, California 94617 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Glenn W. Cady, Esq.
Carniato & Dodge Atomic Safety and Licensing 3708 Mt. Diablo Blvd., Suite 300 Lafayette, California 94549 Appeal Board U.
S. Nuclear Regulatory Commission Daniel Swanson, Esq., OELD U. S. Nuclear Regulatory Commission.
Washington, D. C.
20555 Washington, D. C.
20555 Edward A. Firestone, Esq.
George g Edg"ar ff General Electric Company AttorMy for V
Nuclear Energy Division General Electric Company 175 Curtner Avenue San Jose, California 95125 (Mail Code 822)
Dated:
April 3, 1981