ML19347D355
| ML19347D355 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 03/16/1981 |
| From: | Bachmann R, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Dellums FRIENDS OF THE EARTH, HOUSE OF REP. |
| Shared Package | |
| ML19347D354 | List: |
| References | |
| ISSUANCES-SC, NUDOCS 8103170473 | |
| Download: ML19347D355 (32) | |
Text
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,.I
- Q 03/16/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SATETY AND LICENSING BOARD In the Matter of
)
)
GENERAL ELECTRIC COMPANY
)
Docket No 50-70 (Show Cause)
(VallecitosNuclearCenter-General Electric Test Reactor, Operating License No. TR-1)
NRC STAFF REQUEST FOR ADMISSIONS, INTERR0GATORIES, AND REQUEST FOR DOCUMENTS OFlNT_ERVEN0RS I.
RE00EST FOR ADMISSIONS Pursuant to 10 CFR 5 2.742, the NRC Staff requests Intervenors Friends of the Earth and Congressman Dellums separately and fully, by April 3,1981, to make the following admissions of the truth of the specified relevant matters of fact for the purposes of this proceeding only. These matters have been organized by each of the Commission's issues and for each issue, have been divided to show the Staff document wherein the specific relevant facts are developed for which admissions are being sought.
1.
Commission Issue I A.
Staff SER Dated May 23, 1980, Section A 1.
Geologic data indicate that the GETR site is located within a zone of faulting (the Verona fault) which is at least 2200 feet wide.
82882 70473 j
.- 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.
3.
Future displacements in the GETR site area have a higher likelihood of occurring along existing fault breaks than between them.
4 The possible existence of faulting has been identified in photographs of the GETR excavation.
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.
6.
Maximum vibratory ground r.otion 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 I g.
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 peaks as high as I g.
However, the overall level and duration of shaking would be less than for a magnitude 7 to 7.5 earthquake centered on the Calaveras fault approximately 2 kilometers from the site.
8.
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.
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 ad,iacent to the site; and (5) potential for seismic loading.
10 Slickensides in trenches near GETR show essentially dip-slip movement, with a small component of lateral displacement.
- 11. Boreholes suggest that the Verona thrust fault zone steepens from 14 degrees at the surface to 35-40 degrees with depth.
12 There may be faults that actually surface beneath the reactor.
13.
The evidence gathered by Earth Sciences Associates, GE consul-tants, is both permissive and supportive of fault displacement in the last 2,000 to 4,000 years because the modern soil is formed in colluvium deposited atop the stoneline and the stoneline may be as young as 10,000 years.
14.
There were 2 to 5 feet of thrust movement on trenches on B-1/B-3 and T-1 in the last 4,000 years.
15.
Average slip rate of.0004 ft/yr (0.012 cm/yr) fits a curve of cumulative apparent dip slip separation versus age of displacement on the Verona fault.
- 16. Assuming that alluvial deposits in B-1 extend beneath GETR, the reactor rests on beds older than 70,000-130,000 years and younger than 300,000 years.
- 17. The probabilistic analysis by TERA (App. F of the SER) tends to show that a rupture beneath GETR is a low likelihood event.
Typical values of about 0.5 to 1.0 meters would be a reasonable range to select for offset.
Even if all of the activity on the Verona is assumed to occur on a shear beneath GETR, the probability of occurrence of a one meter displacement (based on the TERA method) would be on the order of 5x10 -5 er year.
- 18. The parameter of one meter of net slip on the Verona fault at the GETR site should be used with engineering judgment as input into the design basis criteria and it should be recognized that probably not all of this slip will occur coseismically.
- 19. The assumption that the San Fernando and Verona fault zones are comparable is a conservative assumption.
20.
The Verona fault, including its northwesterly pro,iection along possible splays of the Pleasanton fault, has an estimated surface length of 12 kilometers.
- 21. The length of observed surface rupture during the San Fernando event was about 12-15 kilometers; movement was predominantly in a thrust sense with a substantial horizontal canponent.
22.
Based on observations of a reverse thrust movement in the trench excavations near GETR and regional stress considerations which would support crustal compression, the Verona fault would be expected to undergo reverse movement as did the San Fernando area faults.
I
23, Calculated slip vectors along an assumed fault plane in the Orange Grove Avenue and Eighth Street areas of the San Fernando that surface ruptured during the 1971 San Fernando event indicate that 2.4 meters of net slip displacement took place However that vertical displacement for this location is distributed across a zone of breakage 200 meters wide which is complicated by a zone of shearing and thrusting and a zone of extension.
A compilation of direct measurements of net slip on individual surface ruptures is not yet available.
Statements 24 through 31 concern the 1971 Ssn Fernanda earthquake.
24.
Regarding the 179 observations of vertical surface offsets occurring during the 1971 San Fernando earthquake, the mean of the observed vertical throw on a given fault break is about 34 centimeters
(.34 meters).
25.
Of the 179 observations, 97% were less than 1 neter and 5 observations equaled or exceeded 1 meter.
- 26. The maximum vertical offset noted which exceeds I meter is 160 centimeters (1.6 meter).
- 27. One meter of vertical offset exceeds the mean plus two standard deviations for the San Fernando data.
28.
Observations of offsets in excess of the above values are due to movement distributed across the fault zone and reflect releveling or are net slip calculations (resultant of the dip-slip and strike-slip movement.
- 29. The mean value of the horizontal movement would be about 40 centimeters (.4 meters).
. 3 0..
Six of the 40 horizontal movement observations noted equalled or exceeded 1 meter with the maximum being 190 centimeters (1.9 meters) 31.
Using one meter of net slip results in approximately 0.7 meters of vertical offset assuming rupture on a fault which dips 45 degrees; 0.7 meters exceeds the mean plus one standard deviation for the observed data for all segments of the fault.
- 32. Detailed observation of the fault displacements in the trench excavations near GETR indicate that the nature of movement on the Verona fault zone occur as episodes of movement of about.7 to 1 meter per event on each recognized fault about every 2,000-8,000 years.
33 The use of one meter of reverse net slip along a fault plane provides a description of the maxinun expected surface slip on the Verona fault under the GETR during a single event.
34.
All of the shears exposed in trenches at Vallecitos Center have dips less than 45 degraes; seventy percent of dips measured are thirty degrees or less; two main shears closest to GETR have dips ranging from 0 to 25 degrees.
- 35. A new fault rupture at GETR would likely dip between 9 and 25 degrees north.
36.
The B-1/B-3 fault zone dips 9 to 31 degrees NE; B-2 and H subsidiary thrusts dip 25 and 27 degrees NE, repectively; and borehole data suggest that the thrust fault at the hillfront steepens from 14 degrees at the surface to 35-40 degrees with depth.
B.
Staff Status Report of September 27, 1979, Section 3 re Seismology
. 1.
The potential earthquake sources that are important in assessing the vibratory ground motion hazard at the GETR site are the Calaveras fault and the Verona fault.
Earthquakes occurring on these faults could have magnitudes of 7 to 7.5 and 6 to 6.5, respectively.
2 Strike-slip faults subsidiary to and connected to the San Andreas fault have generated maximum earthquakes of magnitude about 7 to 7 1/2 based on the data of Coffman and Von Hake (1973).
3.
The GETR site is located 2.3 kilometers east of the Calaveras fault, about 3 kilometers west of the las Positas fault and within the Verona fault zone.
4.
The level of ground motion hazard from the las Positas is considered enveloped (due to its greater distance from the GETR site) within the ground motion hazard from the Calaveras fault.
C.
Staff SER (May 23,1980), Appendix E 1.
Slemmons (1977) is an appropriate data set for relating fault length vs. magnitude and fault displacement vs. magnitude for reverse and reverse-oblique faults.
D.
StaffSER(May 23,1980), Appendix F 1
The Verona fault could be expected to generate 18 earthquakes of magnitude 3 5 every 100 years.
2.
The B-2 and B-2/B-3 shears should experience one-meter displacements with a return period of 19,000 years.
_g_
E.
Staff SER Dated October 27, 1980, Part I 1.
The procedure used to assess the stability of hillside deposits as a result of an earthquake as described in section 2 3, page 3, is appropriate for the purpose of this proceeding.
2 The investigations and reports provided by General Electric regarding landslides satisfy the requirements of 10 CFR Part 100, Appendix A Section V, Seismic and Geologic Design Bases ((d)
Determination of Other Design Conditions; (2) Slope Stability).
In addition these investigations and reports are in agreement with Standard Review Dlan Section 2.5.5, Stability of Slopes.
3.
An earthquake-induced slope displacenent (landslide) of I n is conservative.
4.
Ground surface displacements resulting from these ~ slope covecents would be expected to occur near the toe of the slope, in the vicinity of the observed shear zone, and at some distance (approximately 300 feet) from the GETR plant. Therefore, ground surface displacements due to the postulated landslide must be considered in the design of safety related equipment located near the toe of the slope (e.g., fuel flooding system piping) but need not be considered in the design of the GETR reactor structure.
F.
Staff SER (October 27,1980), Appendix A Report of W. J. Hall and N. M. Newmark dated September 29, 1980 1.
There is a rather well definec and growing body of data which suggest that the response of structures and equipment located close to an earthquake source corresponds to effects associated with smaller ground
9_
accelerations than the peak values recorded instrumentally in the near free-field.
2.
Near-field effects (as deduced from measurements and observations) as affected by the type and geometry of the structure, by soil-structure interaction and feedback, by the incoherent and complex seismic wave field, and by damping and energy dissipation mechanisms, on motions transmitted to the structure, typically have led to " design" or
" effective" (acceleration) coefficients in the lower levels of buildings that are less than the peak near-field instrumental values.
3.
The significant amplifications in motion, as reflected in response spectra, are associated generally with sustained repetitive motions in the fraquency ranges of consideration.
A single peak of large amplitude, short duration acceleration does not contribute significantly to the damage potential of an earthquake. That is, the instrumentally recorded peak acceleration (especially in the near-field) is a poor indicator of the severity (damaging potential) of the motion.
4.
The Imperial Valley (M 6.9) instrumental data available s
indicate 0.36g mean, and a mean plus one standard deviation value of about 0.55 g for all recordings within 20 km (16 stations) of the fault trace, and 0.40 g and 0.57 g respectively within 13 km (13 stations) of the fault trace.
G.
Staff SER (January 15,1981), Enclosure 1 re:
Appendix B Evaluation of Soil Properties and Pressures and Analysis of the Subgrade Rupture echanism at the General Electric Test Reactor
9 1
. 1.
The base of the GETR foundation mat, which is located about 20 feet below grade, is underlain by very dense clayey sand and gravel with occasional layers of very dense sandy and/or gravelly clay to a depth of 70 feet.
2.
There is a hard, cemented stratum known as the middle
~
conglomerate unit of the Livermore Gravels, which crops out in hills on the Jest and south of the site, and which at the GETR site, is more than 70 feet below the surface.
3.
Standard Penetration Tests performed for GE on the materials underlying the GETR foundation mat show blow counts of from 50 to 100 blows / foot penetration, affinning the very dense nature of these soils.
4.
Groundwater levels at GETR were shown to vary from 20 feet to 28 feet below plant grade.
5.
The soil parameters for design, drained strength parameters of c' = 0 and O' = 36* and an undrained shear strength of 4000 psf for soils fully saturated, are reasonable bounding values for the analysis of fault plant behavior.
6.
Use of the fault plane analysis utilizing the Rankine wedge concept results in the conclusion that the preferred fault failure planes (those requiring minimum passive pressure) do not fall beneath the reactor or within the zone that may create a cantilever span of the reactor mat.
7.
Soil deposits similar to those beneath GETR exist beneath the Banco Central Building in Managua, Nicaragua.
Surface faulting occurred on a trace of the fault that passed under the Banco Central Building.
. However the rupture deviated from the active trace, and the building's foundation survived intact.
8.
The use of Figure C-1 in Section II of the October 27, 1980 SER is a conservative limit on the load combinations from the specified design basis event on the Verona fault.
~
H.
Staff SER Dated May 23, 1980, Section B 1.
In estimating probabilities of earthquake occurrences, locations and rupture sizes, it is proper to treat times between earthquake occurrences as having an expotential probability distribution (giving the Poisson distribution for number of occurrences).
2 The range of parameter values listed in the table on page 7 of Section B produce offset probabilities beneath the GETR from 1.0x10-6 per year to 1 7x10-5 per year using the JBA model identified on page 1 of Section B.
3.
The probability of offset occurring under the reactor building is expected to lie in the range of 1x10-6 per year to 1x10-5 per year with 1x10-4 per year being a conservative upper bound.
4.
The probability results for the GETR are credible and should be used to supplement the detenninistic evaluations in making a final decision.
2.
Comission Issue II A.
Staff SER Dated October 27, 1980, Section A GETR Structures, Systems and Components Important to Safety 1.
The assumptions made by the Licensee, as stated below and on p.
A-2 of the SER, are reasonable and acceptable for purposes of analysis of the GETR response to design basis seismic events (This is not an L
. admission as to the proper seismic and geologic design bases of the GETR).
The assumptions made for evaluating this postulated accident include-1) the worst postulated earthquake occurs with reactor trip initiated by the seismic scram system; 2) simultaneous non-mechanistic rupture of the primary system piping; and 3) heat transfer and decay heat rates based on 25 day power run of the reactor operating at 50 MW.
The assumptions made for evaluating this fuel storage situation include:
1) the seismic event occurs six hours after shutdown from a 25 day run a't 50 MW.
2) the temperature of the canal water is assumed to be 130 F; 3) heat transfer calculations for the stored fuel are based on decay heating equivalent to an infinite irradiation of a single core at 50 MW with a 6-hour decay prior to the seismic event; and 4) the primary pipe rupture discussed above is assumed to occur due to the seismic event.
2.
The most limiting accident during the seismic event, for determination of cooling requirements to irradiated fuel, is the double-ended break of the primary piping.
[
a
. 3.
To prevent radioactive release in excess of regulatory limits, it is sufficient to shut down the reactor and keep the fuel in the reactor vessel and canal fuel storage tanks imn.arsed in water.
4.
All of the safety-related structures, systems and components necessary to shut down the facility and maintain the reactor in a safe shutdown condition during and following the design basis seismic events are identified in Table I, Sect. A of the SER (This is not an admission as to the proper seismic and geologic design bases of the GETR).
5.
The capabilities of components listed below and on pp. A-5 and A-7 of the SER would, if able to function as described, be sufficient to shut down the facility and maintain the reactor in a safe shutdown condition during and following the design basis seismic event (This is not an admission as to the proper seismic and geologic design basis of the GETR).
a.
Passive components that must not fail structurally due to a seisaic event and for which is no backup system.
1.
Reactor pressure vessel and internals.
(noleakage) 2.
Reactor pool and liner.
(leakage to 60 gph) 3.
Reactor vessel bottom head penetrations, control rod drives, pool and reactor vessel drain lines and drain line valves.
(no leakage) 4.
Fuel storage tanks.
(noleakage) 5.
Fuel storage tanks.
(leakage to 400 gph) b.
Components that must not fail structurally due to potential impact on essential equipment.
1.
Third floor missile impact system.
. 2.
Permanent pool shielding restraints.
3.
Canal floor missile impact system.
4.
Primary coolant system restraints.
c.
Passive canponents that must not fail due to a seismic event for which there is redundancy.
1.
Fuel flooding system tanks.
2.
Fuel flooding system piping.
3.
Emergency cooling standpipes.
d.
Components that must operate actively during the initial low magnitude tremor and must not fail passively during the main shock.
1.
Dnergency cooling valves PRI 130 and PRI 150.
2.
Fuel flooding systen flow control valves.
3.
Pressurizer isolation valve PRI 110.
4.
Pressurizer nitrogen supply valve GNI 112.
5.
6.
Seismic Reactor Scram Circuit.
(No operability or integrity requirementsafterreactorscramandvalveoperation) e.
Components that must remain operable following the main shock.
1.
Primary cooling check valves PRI 140 and PRI 160.
2.
Anti-siphon valves PRI 190 and PRI 191.
3.
Fuel flooding system check valves.
4.
Fuel flooding system anti-siphon devices.
5.
Liquid poison check valve.
6.
Capsule coolant anti-siphon valves.
7.
Canal Emergency recirculation system anti-siphon valves.
. B.
Staff SER Dated October 27, 1980, Section B GETR Electrical, Instrumentation and Control Sys: ems 1.
The seismic scram system and the fuel flooding system control units are redundant and fail safe on loss of power (with th0 exception of the seismic triggers in the case of loss of power).
2.
The seismic triggers and power supply units (DC battery and charger) are seismically qualified to.5g.
3.
The seismic triggers are designed to initiate trip signals at 0.019 4
The timing of automatic operations from initiation of trip signals by the seismic triggers is as stated below and on pp. B-8 and B 0 of the SER.
The GETR scram system operates when (among other events) the seismic switches close.
The reactor control rods are disengaged from the drive mechanism 180 milliseconds after either of these two seismic switches make electrical contact.
That is, all the electrical and electronic scram circuitry have operated and the control rod magnetic latch circuit has been interrupted and the control rod begun its drop by the end of the 180 millisecond period.
The control rod then drops by the forces of gravity and primary coolant flow so as to be fully inserted from a 36-inch withdrawn position within 500 milliseconds from the time the control rod is disengaged from the drive.
Based on available rod drop data, it is conservatively estimated that within 300 milliseconds from the time the control rod is disengaged from the 36-inch withdrawal starting position, or 480 milliseconds from seismic switch trip, the control
rots will be at or below the 12 2-inch wi'Sdrawn position whereupon the reactor is considered to be shut down.
The energency cooling power-operated valves, pressurizer valves and fuel flooding system admission valves are the only valves for which initiating action is by seismic trip or scram circuitry.
The emergency cooling power-operated valves and the fuel flooding system admission valves begin to open and the pressurizer valves to close within 190 milliseconds after triggering of the scram system.
The renainder of the valve operation is cu1plete within a total of one se:ond from scram seismic trip.
5.
Tne data set used in the Staff evaluation on p. C-12 of the SER is a reoresentative sample of acceleration data in the magnitude and distance range of interest.
6.
Tqe peak acceleration values anticipated within one second after recording 0.01g during a seisnic event at the GETR are approxinately 0.25g.
7.
The Staff's conclusions stated below and on p. B-9 (nos.1-3) of the SER are correct.
1.
The electric instrumentation and control equipnent, modified as proposed, will perform the necessary automatic actions of reactor scram, pressurizer isolation, energency cooling valve operation and FFS initiation; 2.
The reliability of the scram and valve actuation circuitry provides reasonable assurance that the necessary automatic actions will be performed when required; and
[
17 3
The response times for the scram action events and the safe-shutdown of the reactor are reasonable for use in evaluating the status of equipment during significant seismic loadings.
C.
Staff SER Dated October 27, 1980, Section-C Seismic Design of GETR Structures, Systems and Components Important to Safety 1.
If the structural and mechanical requirements listed below and on p C-2 of the SER (nos.1-3) are satisfied, the reactor is capable of being maintained in a safe shutdown condition after the seismic event (This is not an admission as to the accelerations or offset produced by the seismic event).
1.
The structural integrity of the massive concrete structure which supports other systems and components important to safety, such as the spent fuel canal and the reactor pool, must be maintained.
2.
The structural integrity of the reactor vessel and the canal fuel storage tanks must be assured.
3.
A source of water, including the associated piping system, must be available after the seismic event to provide water to the spent fuel canal storage tanks and the reactor pressure vessel to replenish that lost through boil off and evaporation in the process of cooling the fuel, assuming that the fuel cooling system piping and associated heat exchangers have failed.
2.
The load combinations listed below and on p. C-3 of the SER (nos. 1-3) are appropriate to evaluate the adequacy of the GETR structures and components important to safety for the seismic events, t
f
- = _ -
1@.
1.
Concrete Core Structure and Miscellaneous Systems and Components (a) Normal Service i)D+L 1 S (b) Maximum Credible Accident 1)
D+L+E 1 U
- 11) D + L + W 1 U 2.
Reactor Pressure Vessel Shell and Internals (a) Nomal Service i)D+T+P 1 S (b) Maximum Credible Addicent i) D + Ta + Pa + E 1 U 3.
Piping (a)
Nomal Service 1)
D+P 1 S
- 11) 1) T 1 Sa or 2) D + P + T 1 Sh + Sa (b) Maximum Credible Accident
- 1) D + Pa + E 1 2.4 Sh The load symbols above are defined by GE as follows:
sustained vertical loads which include the dead loads D
=
of the structures and pemanent loads such as water in the piping systems and equipment weight.
live loads which consists entirely of snow load L
=
applied only to the roof areas of the equipment builing and Control Room. This loading was that defined by the Unifom Building Code for the region which includes the GETR site.
Nomal operating pressure P
=
i
l l
. Pt test pressure
=
maximum accident pressure Pa
=
Normal operating tenperature T
=
Tt test temperature
=
Maximum accident temperature Ta
=
Criterion wind load which is considered to be a 100 W
=
year return period fastest mile wind velocity of 80 miles per hour.
Criterion earthquake loads which consist of the most E
=
adverse loadings resulting from the surface rupture and the maximum vibratory ground motion postulated at the site, including the most adverse and physically consistent combination of these events.
3.
The seismic review analysis of the GETR structures, systems and components import to safety are in conformance with accepted codes and criteria.
4.
The analysis techniques described below and on pp. C-6 and C-7 of the SER are appropriate state-of-the-art methods for determining the response of the GETR to the seismic event.
1.
Time histories which envelope the Regulatory Guide 1.60 defined response spectra anchored at the appropriate accele' ration levels as defined.
2.
Three dimensional linear elastic time history dynamic analysis utilizing a spring-mass model, with soil spring constants based on Reference 2 and 3, which incorporate the effects of the approximately 20 feet embedment of the building.
3.
Consideration of the influence of torsion on response.
i
- 20 4
Parametric studies of the effects of shear modulus, foundation contact areas, and variations of model damping ratio, due to soil-structure interaction, on the response of the linear elastic model.
The material damping coefficients used for the concrete and steel were 7 to 3 percent, respectively, which confonn to the positions in Regulatory Guide 1.61.
5.
Nonlinear time history dynamic analyses to investigate the effects of nonlinearities associated with potential uplift and sliding of the reactor building slabs and the behavior of the building on the structural response of the GETR.
6.
Stress analyses of the concrete core portions of the core structure, arising from the seismic loadings iniposed on the structure, using a three dimensional finite element program.
7.
A combined surface rupture offset and vibratory notion analysis, to account for the effects on the structure due to the.
design criteria hazard.
5.
If a design time history represents the strong motion portion of a seismic event and a structure is designed to elastic analyses criteria, the response of the structure will not be significantly affected if the duration of the time history was lengthened.
6.
Allowable strengths are adequate to accommodate the effects of the seismic design criteria postulated by the NRC Staff, with considera-tion of standard linear analysis techniques.
7.
The valves and control units of the GETR structures, systems and components important to safety will function during and after the design basis seismic events postulated by the NRC Staff.
21 -
8.
If the seismic events produce the accelerations and surface offset as postulated by the Staff in Issue #1, the proposed modifications discussed on pp. C-10 and C-11 of the SER, including the fuel flooding system, are sufficient to enable the U.TR structures, systems and components important to safety to remain functional..
t I
.e
--W
.. II. jfLTERR0GATORIES.
Pursuant to 10 CFR i 2 740b, the Staff serves the following inter-rogtories to the intervenors to be answered separately and fully in writing under oath or affinnation.
In accordance with the provisions of 10 CFR
$ 2.740b(b), the answers are to be signed by the person making them.
Pursuant to the Memorandum and Order issued by the presiding Atonic Safety and Licensing Board, dated February 3,1981, answers to these interrogatories are to be filed by April 3, 1981.
Instructions and Definitions 1.
Infonnation sought in these interrogatories shall include infor-mation within the knowledge, possession, control or access of any agents, employees and independent contractors of the separate Intervenors, as well as the intervenors themselves.
2 As used herein, " documents" includes, but is not limited to, construction plans and specifications, papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, interagency memorandum or written communications of any nature, recordings of conversations either in writing or upon any mechnical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books,
.. punchcards and computer printout sheets, computer data, telecopies trans-missions, directives, proposals, and all drafts, revisions, and differ.ng versions (whether formal or infomal) of any of the foregoing, and also all copies of any of the foregoing which differ in any way (including hand-
~
written notations or other written or printed matter of any nature) from the original.
3.
References in the interrogatories are to response numbers in your February 25,1981.4oint updated answers to NRC Staff interrogatories (designated as S.I.1, etc.) and to your ;ioint updated answers to the Licensee's interrogatories of the same date (designated as L.1, etc.).
1.a.)
Have you admitted each statement included in Section I. of this document entitled " Request for Admissions?"
b.)
If the answer to Interrogatory 1(a) is no, identify each statement in Section I. which you do not admit.
2.
For each statement identified in Interrogatory 1(b) give the following infomation:
a.) The portion of statement which is not admitted.
b.) The basis of your disagreement with the statement.
c.) The expert witnesses, if any you are relying on in disagreeing with the statement.
d.) The documents, 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.
.. 3 For each expert identified in Interrogatory 2(c) above provide the following infomation:
a.) Name and address.
b.) Statements in Section I. which the expert disagrees with.
c.) The basis for the disagreement identi'ied in part b of this interrogatory (include any facts or theories relied on).
d.) Any articles or studies relied on by the expert in disagreeing with the statements identified in part b of this interrogatory.
e.)
If expert will be or is expected to be a witress in the captioned proceeding, identify the sub.iects 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.
h.) Any published articles written by expert.
4.
Re. S.1-6 What specific NRC and USGS reports of 1977-1980 do you intend to rely on in support of your conclusions that the proper seismic and geologic design bases for the GETR should include surface rupture displace-ment of 2.5 meters minimum occurring simultaneously with peak ground accelerations of greater than 1.74g vertical and 1.15g horizontal.
Provide page references to the documents.
l-5.
Re. S.1-6 (a) What data set and -reports by USGS are you referring to regarding the San Fernando earthquake of February 1, 1971; specify the
.e components of the data set and reports by title, author and date published.
Specify the page number of each document upon which you rely to substantiate your conclusion that the earthquake caused 2.4 meters of surface rupture for 12 km.
(b) What is your basis for concluding that surface displacement of the GETR greater that 2.5 meters is possible?
6.
Re. S.1-6 (a) What data set, analyses and reports regarding the Imperial Valley earthquake of October 1979 are you incorporating? Specify the components of the data set, and reports by title, author and date published.
Provide page references if only a portion of a document is relevant to the Imperial Valley earthquake.
(b) Specify the conditions under which the reading of 1.749 acceleration was obtained during the Imperial Valley earthquake, and the 1.15g acceleration obtained during the San Fernando quake.
Specify how those conditions are similar to those occurring at the GETR site.
7.
Re. L.3 (a) What specifically do "the Verona Thrust Fault zone and its structural relationship with the Calaveras Fault and the las Positas Fault" control?
(b)
Explain the relationship that you contend exists between the structures referenced in 7(a).
(c) Explain how the SSE can be based on two different earthquakes with different magnitudes.
(d) What is your basis for concluding that the Calaveras Fault can produce a magnitude 7.5 +.5 earthquake?
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. (e) What is your basis for concluding that peak ground acceler-ations car. be sustained for 30 to 90 seconds duration?
(f) Wht is your basis for concluding that peak ground acceler-ations during the ea.-thquake would occur prior to the onset of the seismic scram systems?
8.
Re. L.3 Identify the title, author and date of publication.
For each document either published or under preparation, referred to on page 16 regarding the Imperial Valley earthquake that are not otherwise identified in response to Interrogatory no. 6(a) herein.
(a)
Provide the basis, including all references relied upon, for your conclusion that the January,1980 earthquake in the Livermore Valley was "a strong confinnation" of the natural seismic phenomena of seismic focusing or directivity.
(b) How did the phenomena of focusing referenced in (a) cause amplification of groundmotions in the direction of seismic rupture propagation?
Cite all references relied on in support of this conclusion.
(c) How could this phenomena contribute to higher ground accelerations at the GETR site during a future earthquake? Cite all references relied upon for this conclusion, giving title, author and date of publication for each document.
9.
Re. L.3 What is your basis for concluding:
(a) that the Calaveras is in a state of seismic gap?
(b) that the probability of that fault producing a quake is higher now than it has been since the 19th century?
i
. Give references relied on for your basis including title, author, and date of publication of each reference.
10.
Re. S.1-5 What methodology, if any, do you utilize to convert the free-field accelerations into design accelerations for use in response to Commission Issue I? Give references relied upon for your answer including title, author, and date of publication, for each reference.
11.
(a)
Is is your position that the 1.icensee and/or the NRC must prove or guarantee there will be no structural damages to the GETR in order to provide reasonable assurance that the health and safety of the public will not be endangered?
(b)
If the answer to (a) is in the affinnative, state the basis for your position.
12, (a) What is the basis for your statement that there are no possible design modifications to the GETR which could be adequate to protect the public health and safety?
(b) Specify in detail all analyses, calculations and references used for supporting your position in (a).
In the case of references provide the page and/or section numbers.
13.
(a) Given the Staff's seismic design bases, do you contend there are no possible design modifications which can be made so that the GETR structures, systems and components important to safety can remain functional?
(b)
If the answer to (a) is positive, what level of acceleration alone and combined with surface faulting do you believe the GETR structures, systems, and components can be modified to withstand and remain functional.
. 14 (a) Do you contend that no building or structure can be designed to safely resist fault rupture of any amount, no matter how small?
(b)
If the answer to (a) is negative, indicate the amount of fault rupture you believe a building or structure can be designed to resist.
15.
(a) What are the highest vertical and horizontal accelerations you postulate as occurring within one second after.Olg is instrumentally recorded during the seismic event?
(b)
State the basis for your conclusion in (a), including historical data r.ets of earthquakes you rely upon for your answer.
16.
Specify the sections of the Staff's SER to which testimony of intervenors' proposed witness Dr. Brillinger concerning probability analysis will apply.
17.
With respect to intervenors' proposed witnesses Gary Gray, Jim Caid and John Rutherford, please provide the following information:
(a)
Professional qualifications, as they relate to earthquake engineering, geology and seismology.
(b)
Past and present employment since undergraduate school.
(c)
Identify any books or papers published in the area of earthquake engineering, geology and seismology.
With respect to John Rutherford, please provide a list of the hundreds of geologic investigations in which he was involved, and indicate the nature, extent and dates of his involvement.
J a
. 18. With respect to proposed Intervenors' witnesses Mr. J. Glenn Barlow and Dr. David Brillinger, please provide the following information:
(a)
Professional qualifications establishing his expertise, if any, in the areas of geology, seismology, geotechnical and structural engineering.
(b) Educational attainments in the areas indicated in 18(a).
(c) Papers and books publisned in the areas indicated in 18(a).
(d) Membership in professional organizations in the areas indicated in 18(a).
(e)
For Dr. Brillinger, identify which publications he has made which involved the application of statistics to geological, seismological, geotechnical, or structural engineering analyses.
19.
What age or range of ages would you consider the last movement on the Verona fault system to be? Explain.
20.
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 Commission in its February 19,1978 order?
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, III.
RE0 VEST FOR DOCUMENTS Pursuant to 10 CFP. 5 2 741, produce for inspection and copying the following documents:
1.
Any documents referred to in response to the interrogatories in Section B of this document which are not published.
2.
Any unpublished documents referred to in response to interrog-atories in Section 8 of this document.
3.
The following two publications by Gary Gray:
a.
" Effects of Girder Flexibility and Plastic Action on Dynanic Response Multi-Story Building":
U.S. Anny Corpos of Engineers, Arned Forces Special Weapons Projects; b.
" Pre-Fabrication Assembly and Architecture of Steel Space Trusses-Four Examples": written with Ephraim G. Hirsch, from tne Proceedings of the International Asscciation of Shell and Spatial Structures, Haifa, 1973.
Respectfully submitted, c-Daniel T Swanson Counsel for NRC Staff c
Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 16th day of March, 1981
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UNITED STATES OF A'iERICA g
NUCLEAR REGULATORY COMMISSION NN!
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s %' y 15 BEFORE THE ATOMIC SAFETY AND LICENSING B0 g
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In the !!atter of
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Docket No. 50-70
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(Show Cause)
(Vallecitos Nuclear Center -
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General Electric Test Reactor,
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Operating License No. TR-1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF REQUEST FOR ADMISSIONS AND INTERROG-ATORIES TO LICENSEE" and "NRC STAFF REQUEST FOR ADMISSIONS, INTERROGATORIES, AND REQUEST FOR DOCUMENTS OF INTERVENORS", in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by a double asterisk, via Federal Express, this 16th day of March, 1981:
Herbert Grossman, Esq., Chaiman*
The Honorable Phillip Burton Administrative Judge ATTN:
Mary Atomic Safety and Licensing Board 2454 Rayburn House Office Bldg.
U.S. Nuclear Regulatory Commission Uashington, DC 20515 Washington, DC 20555 Glenn W. Cady, Esq.**
Mr. Gustave A. Linenberger*
Law Offices of Carniato & Dodge Administrative Judge 3708 Mt. Diablo Blvd., Suite 300 Atomic Safety and Licenisng Board Lafayette, CA 94549 U.S. Nuclear Regulatory Commission Washington, DC 20555 George Edgar, Esq.
Morgan, Lewis & Bockius Dr. Harry Foreman 1800 M Street, N.W.
Administrative Judge Washington, DC 20036 Box 395, !!ayo University of flinnesota Jed Somit, Esq.
flinneapolis, MN 55455 100 Bush Street - Suite 304 i
San Francisco, CA 94104 The Honorable Ronald V. Dellums **
ATTN:
H. Lee Halteman, Esq.
Edward A. Firestone, Esq.**
201 13th Street, Room 105 General Electric Company Oakland, CA 94517 Nuclear Energy Divisions 175 Curtner Avenue Ms. Barbara Shockley San Jose, CA 95125 1890 Bockman Road (Mail Code 822)
San Lorenzo, CA 94580
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The Honorable John L Burton Docketing and Service Section (7)*
1714 Longworth House Office Bldg.
Office of the Secretary Washington, DC 20515 U S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board Panel
- U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Panel (5)*
U.S. Nuclear Regulatory Commission Nashington, DC 20555 l
Richard G. Bachmann Counsel for NRC Staff f
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