ML19347D763
| ML19347D763 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 03/16/1981 |
| From: | Cady G FRIENDS OF THE EARTH |
| To: | GENERAL ELECTRIC CO. |
| References | |
| ISSUANCES-SC, NUDOCS 8103270479 | |
| Download: ML19347D763 (3) | |
Text
3.16.1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of p>c 2 GB) k e
- g. 9tf C GENERAL ELECTRIC COMPANY No. 50-70 f
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Chg;g:.y.rdu !Q
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(Vallecitos Nuclear Cente
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4 fg General Electric Test Rea I5r
- g i,g, Operating License No. TR-Q 4g N
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.y INTERVENORS6DLURR0 GATOR TO LICENSEE Pursuant to 10 C.F.R. 62.
O n
of the Earth (Intervenor) hereby files the following interrogatories to General Electric Company (Licensee),
answered separately and in writing and under oath or affirmation.
1.a. Describe in detail the structural modifications which would preclude the fifteen ton crane from falling into the GETR reactor core, experimental capsules or spent fuel canal during the maximum credible and SSE earthquakes near the GETR on the Verona and Calaveras Faults, with associated surface rupture.
- b. What guarantee does GE provide to Northern Californians that the crane will not be damaged during the quake described?
2.
Explain in detail at what level of horizontal and vertical ground accel-l erations with simultaneous surface rupture, would the GETR nipes and piping l
restraints and modifications be damaged or exceed their material deformation capabilities?
3.
How can GE guarantee that the structures, systems and components important to protect public health and safety will not be seriously damaged or compro-mised during a seismic event at the GETR site during the following postulated seismic ground motion scenarios:
a.
One meter of offset with.66g effective ground acceleration.
b.
One meter of offset with.7g effective ground acceleration.
Y Aff One mg.g gf fset with.75g effective ground acceleration.
5 c.
8108270 U h
d.
One meter of offset with above 19 effective ground acceleration.
e.
One meter of offset with 1.74g vertical instrumental acceleration.
f.
One meter of offset with greater than 19 vertical acceleration with a duration of one to three seconds.
g.
Two meters of offset with greater than 19 vertical or horizontal. acceleration.
h.
Greater than two meters of offset with greater than Ig vertical or horizontal acceleration.
4.
If the epicenter of a future Magnitude 7.5 earthquake is on the Calaveras Fault at its closest point to the GETR, what vertical and horizontal ground accelerations does GE estimate would result within one mile of that epicenter?
Please set out and explain the formula used for arriving at this conclusion.
5.
Does GE own any liability insurance to pay for radioactive contamination l
i of public and private property and land that would be a consequence of an earthquake induced accident at the GETR site?
- 6. Is the GETR covered by the Price Anderson Act? Explain how that Act would benefit the four million citizens who would be the potential victims of an earthquake induced accident at the GETR.
How much would each of those four million Bay Area citizens be able to recover on their losses after they evacuate? :
7.
Explain how. the data from the Imperial Valley earthquake of October 1979 would affect the seismic design criteria that GE has used for their proposed modifications to the systems, structures and. components important to safety.
8.
Explain how the data from the Livermore earthquakes of January 1980 would affect the seismic design criteria that GE has used for their proposed modi-fications to the systems, structures and components important to safety.
9.
Explain how the data from the Maunoth quakes of May 1980 would affect the seismic design criteria that GE has used for their proposed modifications to the systems, structures and components important to safety.
i I
.=
- 10.
Explain how the data from the Baja quakes of June 1980 would affect the seismic design criteria that GE has used for their proposed modifica-tions~ to the systems, structures and components important to safety.
- 11. Explain how the data from the Santa Barbara quake of August 1978 would affect the seismic design criteria that GE has used for their pro-posed modifications to the systems, structures and components important to safety.
12.
Explain how the data from the Coyote Lake Quake of August 1979 would affect the seismic design criteria that GE has used for their proposed mod-ifications to the systems, structures and components important to safety.
- 13. Explain your concept of the tectonics of the Vallecitos Valley in terms of right lateral strike slip movements on the Calaveras Fault, thrust faulting on the Verona Fault, and sympathetic faulting on the Las Positas Fault during strike slip movements on the Greenville Fault in 1980.
14.' Justify and explain your decision to exclude as witnesses in these hearings your consultants Dr. Bruce Bolt and Dr. Roger Hansen, who in May 1980 published a report for you entitled " Seismicity of the Livermore Valley in relation to the General Electric Vallecitos Plant."
Respectfully Submitted,
/
Glenn W. Cady, Esq.
Attorney for Friends of the Earth March 16,1981 Oakland, CA 94637 m
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