ML19347D773

Interrogatories Directed to NRC Requesting Info Re Seismic Design Criteria.Related Correspondence

ML19347D773
Person / Time
Site:	Vallecitos File:GEH Hitachi icon.png
Issue date:	03/16/1981
From:	Cady G FRIENDS OF THE EARTH
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8103270548
Download: ML19347D773 (9)

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mrrgn CORRESPONDENCE 3/16/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD r

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ocoKETED In the Matter of

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Docket No. 50-70 20M > ;

GENERAL ELECTRIC COMPANY

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Operating License Office sithe Senatsy 'Il (Vallecitos Nuclear Center -

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No.TR-1 Dodating & Senks General Electric Test Reactor)

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(Show Cause) 4 b

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INTERVENORS' INTERROGATORIES TO STAFF Pursuant to 10 C.F.R. 5 2.d0b, Friends of the Earth (Intervenor) hereby files the following interrogatories to the NRC Staff, which must be answered in writing and under oath or affirmation.

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 investigative requirements of Appendix A to 10 CFR Part 100." Explain how this primary concif.on in your SER could be a justification for reopening the GETR. Explain what additional investigative requirements would need to be met for a reactor in an active fault zone in California?

2'. Will the NRC Staff require the Applicant to conduct "better microcarthquake instrtrnental coverage" as suggested m USGS80-515, by USGS seismologists? If the NRC Staff has not required GE to do this research, justify the lack of these investigative requirements imposed by the NRC on GE.

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3. Justify your lack of consideration of a.75 g with a simultaneous one meter of offset. Why l

do you separate.75 g from a.6 g with a meter of offset.

4. Do you contend that a M.7 to 7.5 earthquake on the Calaveras Fault would not cause secondary or sympathetic faulting o'n the V ault Zone which could result in a.75 g and one r

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meter offset simultaneously? Explain your. response in detail.

5. Explain the difference between the NUREG-CR-0098 deterministic criteria and the "probabilistic l

approaches to seismic design" which Drs. Newmark and Hal: state that they prefer to use, as stated 1

in the Staff SER, Appendix A.

6. On page 3 of the Newmark and Hall Appendix A in the SER, Newmark and Hall justify the use of " effective" peak accelerations by stating that "there 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 instrumentally in the free filed. Please provide that I

"well-defined body of data" to the Intervenors.

7. Justify the NRC Staff adoption of " effective accelerations" for seismic design criteria.

(a) Has the NRC Staff abandoned, partially or completely, its reliance on the instrumental i

recordings of earthquake ground motions? If so, please explain why.

8. Explain the meaning of the statement by Robert Morris to Bob Jackson in the USGS to NRC letter of April 22,1980, which says,"Much of that material (presented by GE to ACRS on November 14,1979,) never has been formally docketed by the applicant, a. situation that has made it difficult for the USGS to perform its review in the normal manner." List and provide the documents that are not docketed.

9. Explain the role that Dr. William Vesely had in the WASH-1400 Rasmussen Report. Describe Dr. Vesely's particular influence in that report.

10. Explain the NRC policies regarding the use of probabilistic risk assessment methodology in the licen67g or operation decision-making procedures (including this OSC Proceeding) regarding i

nuclear reactors near active earthquake faults in California.

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11. Why does the NRC have "No regulation or policy prohibiting the siting of nuclear reactors near known active earthquake faults in California?

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 the response t

to 1-1 and we do not intend to use them in the Show Cause Proceeding." Do you contend that t

the original de. sign bases, calculations, etc., should not be allowed into these proceedings as an l

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13. Define these terms A. " effective accelerations" B. " instrumental accelerations" C. " free-field accelerations"

14. Explain how the concepu of " effective" and " instrumental" and " free field" accelerations are interpreted and used in NRC regulations policies and procedures and guidelines to reactor operator's.

15. Explain how at the GETR site you have managed to lower the instrtrnental accelerations of above one g to " effective" accelerations of.6 and.75 g.?

~16. Explain how you can reduce ground accelerations of greater than I g resulting fron. s nearby earthquake of M 7 to 7.5 to cnly.75 g.

(a) What horizontal and vertical ground accelerations and response spectra were each of the GETR systems, structures, and components essential to protecting public health and safety originally designed for during the construction of the reactor.

17. Was the GETR designed to withstand surface rupture beneath it on the Verona Thrust Fault?

18. What pro'of or guarantees do you have that any structural modifications would be adequate to protect the pulic health and safety in the event of a surface rupture beneath the GETR on I

a thrust fault?

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19. Explain why did the NRC not require GE to estimate the probability that for each future earthquak, on the Calaveras or Verona faults, that there would be F cursor shocks in time to activate the seismic trip system and insert control rods before the maximtrn ground motions and surface rupture.

20.Does the NRC Staff agree that the Calaveras Fault could experience a Magnitude 7 to 7.5 i

earthquake "at any time" as explained by one of the NRC staff scientists after the shutdown of the GETR in 19777 If not, please provide the formula used to make the determination.

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21. Does the NRC Staff have any evidence or reason to believe that the probability of a major quake on tle Calaveras F alt has (a) decreased or l

l (b) increased during the time since the shutdown of the GETR in 1977? Explain your response l

In detail.

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22. Explain in detail why the NRC recently ordered several nuclear reactors in the Eastern U.S.A.

shut down because of inadequate seismic design.

23. Have you or your consultants ever conducted or requested GE or its consultants to conduct an analysis of the ground motions tilat would result at the GETR site from directivity of rupture propagation or seismic focusing, as described by Dr. James N. Brune in Testimony on Ground Motions at the Diablo Canyon hearings that could cause sympathetic ground motions on the branches of the Verona Thrust Fault Zone and higher than expected ground accelerations? If not, justify your lack of investigative requirements, in detail.

s 2A. Do you agree that seismic focusing or directivity or rupture propagation is a natural and common phenomena that has been observed during several California earthquakes? If you do not agree chen justify and explain your position.

25. Explain your current position on the tectonics of the Vallecitos Valley and the Livermore Valley, in terms of the structural and tectonic relationships between the dozen active faults in the area.

26. What would be the effect on the GETR structures, systems, and components important to safety if ground motions (effective accelerations) larger than.6 g with one meter offset or.75 g with no offset were to occur during future earthque.es on the Verona and Calaveras Faults?

Explain in detail your response and provide us with the formula used to make this determination.

27. What would be the effect on the GETR structures, systems, and components important to safety 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 de+ ail your response and provide us with the formula used to make this determination.

(a)' Has the staff requested GE to do such an analysis? If not, why.

28. 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.

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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 f aults?

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30. Do you agree that focal mechanism studies for smaller magnitude earthquskes are ambiguous uncertain and subject to opinionated interpretations? If you do not agree, please explain, in detail why.

Do you agree that it is possible that the Verona Fault, the Las Positas Fault and the Calavera 31.

Fau!t near the GETR site bave other subparallel branches that have not yet been mapped?

32. Do you agree that acc'snulated stresses on major faults can be transferred to secondary i

l or to enechelon strands or branches?

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33. Do you agree that the Calaveras Fault is a major branch of the San Andreas Fault and th is a major feature of the plate boundary tecto-es in Northern California? If r ot, describe in detail your understanding of the tectonics of the Calaveras Fault.

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34. Explain in detail y'our concepts and understandings of the structural relationships between the Calaveras Fault, the Verona Fault, the Wil!iams I a.11t, the Pleasanton Fault and the Las P Fault.

35. What source of data was relied upon to calculate or estimate the ground motions at the GE of.75 g and.6 g.? Please list all sources used to arrive at these values.

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36. Do you believe that you have adequate data to predict future seismicity on the Verona or Calaveras Faults by analyzing historic records?

37. How far would you estimate to be the extent of ground strains and land deformatio with the San Andreas Fault System?

38. What evidence do you have to disprove the hypothesis that faults subparallel to the Fault, such as the Calaveras and Greenville Faults, absorb stress from the seismi motion the plate boundary?

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39. Ho.v deep would you estimate to be the hypocenter of a postulated earthquake on the Calaveras or Verona Fault near GETR7

40. Explain your analysis of the relationships between the hypocentet, epicenter, surface ruptures,

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and peak ground accelerations in the San Fernanco earthqude?

41. Have you or your consultants predicted ground accelerations at the GETR from an earthquake f

l on the Calaveras Fault with a magnitude of M7.0? To 7.57 Explain how you arrived at those figures.

42. Has the NRC don'e a site-specific class 9 Meltdown Accident Analysis for the GETR?

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43. What evidence d es the NRC Staff have to disprove the' hypothesis that the Calaveras Fault i

is part of a seismic gap?

44. Does the N AC Staff believe that an adequate data base existed at the time the AEC issued-the construction permit for siting nuclear reactors at the Vallecitos site to determine or predict the ground motions that could occur at the site?

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45. Does the NRC Staff agree with scientists that it was not until1969 that the theory of plate i

tectonics was widely accepted as the most logical explanation of earthquakes that occur around the Pacific Ocean rim?

46. Does the NRC Staff agree that the Calaveras Fault is structurally related to the Hayward l

Fault Zone?

47'. Does the NRC Staff agree that the Hayward Fault Zone is an active fault which is capable of causing strong ground motions at the GETR site?

48. Will the NRC Staff ask GE to initiate a research contract with a consultant to analyze the ground motions at the site of the GETR that would result from a Magnitude 8.0 earthquake on the Verona Fault zone?

49. Will the NRC Staff request the Applicants to initiate a research contrau with a consultant to analyze the ground motiors at the site of GETR that would result from a Magnitude 6.5 earth-quake on the Verona Fault?

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50. Has the NRC Staff considered the possibility that the GETR and Vallecitos facilities are not designed to withstand an earthquake on the.Verona Fault of Magnitude 6.5? If so, explain.

51. If the Applicants had not yet constructed the GETR, would the NRC Staff approve of an ap-plication for a construction permit to construct a reactor at Vallecitos considering the seismic hazards at that site?

52. Given the Northern California tectonic setting, would the NRC Staff agree that there is a component of stress on the Calaveras and Verona Faults?

53. What evidence does the NRC Staff have that personnel at the GETR, during-future operations, could perform necessary emergency procedures during and following a severe earthquake, when their lives are being threatened by the circumstances?

54. What psychological studies can the NRC Staff cite that support their arguments that operating personnel could respond effectively to earthquake circumstances at the GETR?

35. What were the peak instrumental and effective ground accelerations (g values) for which the spent fuel pools at the GETR was designed and built?

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56. Have the NRC Staff contracted with consultants to analyze the directivity and focusing effects observed in the seismic wave propagations and instrtrnental data in the records for each of the following earthquakes:

a. The Long Beach earthquake of 1933;

b. The Santa Barbara earthquake of August 31,1978; 1

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c. The Coyote Lake earthquake of August 6,1979;

d. The Imperial Valley earthquake of October 15,1979;

e. The Livermore Valley earthquake of January 24,1980.

57. Explain the Staff Geosciences Branch understanding of each of those quakes and consideration of their evaluations and seismic hazards to California reactors.

58. Why did the NRC shutdown the GETR in 19777 e

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59. Why did the NRC shutdown the Humboldt Bay Reactor?

60. Why has the NRC delayed operations at the Diablo Canyon Reactors from 1973 until the present?

61. Does the NRC Geosciences Branch agree with the following statement made 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 Motion Seismology":

"The most difficult problem we face today is estimating strong motion in the vicinity of the earthquake source, i.e., the near-field. No nuclear power plant is intentionally placed near a known earthquake source or " capable" fault but subsequent investigations have revealed new faults and

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resulted in reassessment of some old faults. The Humboldt Bay, Diablo Canyon, San Onofre, and Vallecitos sites in California are the prime examples. In order to determine whether facilities at these sites iue sufficiently safe as designed, need to be upgraded or need to be abanconed, requires an assessment of motion near earthquake sources where we have few measurements most of which are from small earthquakes."

62. List the "various organizations" that NRC Staff consultant David Slemmt = s worked for at l

l 7 power plant sites in 5 states.

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Respectfully Submitted,

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Glenn W. Cady, Esq.

Attorney for Friends of the Earth s

March 16,1981 Oakland, California

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