ML19350A297
| ML19350A297 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 03/05/1981 |
| From: | Edgar G GENERAL ELECTRIC CO. |
| To: | Dellums R HOUSE OF REP. |
| Shared Package | |
| ML19350A295 | List: |
| References | |
| NUDOCS 8103130430 | |
| Download: ML19350A297 (6) | |
Text
{}
3/5/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Docket No. 50-70 GENERAL ELECTRIC COMPANY
)
)
Operating License (Vallecitos Nuclear Center -
)
No. TR-1 General Electric Test Reactor)
)
(Show Cause)
LICENSEE'S INTERROGATORIES TO CONGRESSMAN DELLUMS (SECOND SET)
Pursuant to 10 C.F.R. 5 2.740b, General Electric Company (the licensee or GE) hereby files the following interrogatories to Congressman Dellums, which must be answered in writing and under oath or affirmation.
1.
Please provide the current occupation, employer, title, job description, business address, and history of employment (including job descriptions) for a) Gary Grey, b) Jim Caid, and c) John Rutherford, respectively.
2.
Please provide professional educational qualifications.
(undergraduate and/or graduate schools attended, and degrees awarded) for Jim Caid.
3.
With regard to Mr. Rutherford's experience, please list separately, - describe the subj ect matter and location of (the investigation or evaluation), and summarize Mr. Rutherford's role in each:
a) of the " hundreds of geological investigations" 810818'0 %
. (see Intervenors' Joint Updated Answers to Licensee Interroga-tories, dated February 25, 1981 [ hereinafter " Updated Answers"]
at 6); b) " Seismic risk evaluations": (see Updated Answers at 6); and c) " geological fault investigations" (Updated Answers at 6), in which Mr. Rutherford has been involved.
4.
Please provide a description of the expertise (professional education, training, and experience), if any, possessed by Messrs. Grey, Caid, Rutherford, and Professor Brillinger, respectively, in each of the following disciplines (if none, so indicate):
(1.) nuclear reactor engineering, (2.) thermal hydraulic hydraulic analyses of nuclear reactor systems, (3.) geology, (4.) seismology, (5.) probabilistic risk assessment.
5.
Please provide the specific, detailed bases for Mr. Caid's apparent conclusion that the GETR is located in an area of "high seismic risk" (Updated Answers at 8).
6.
Please identify, list, and provide a sur.uary description of each of the " assumptions used in developing input factors for the probability equation" which Professor Brillinger believes to be." debatable" and which "must be considered in greater depth" [see Updated Answers at 10].
7.
In regard to Mr. Barlow, please list each undergraduate and graduate level course taken, identify the institution at L
which each such course was taken, and provide a summary description of the subject matter of each such course, if any, in each of the following disciplines:
(1. ) mathematics,
(2.) geology, (3.) seismology, (4.) stress analysis, (5.) nuclear reactor engineering, (6.) thermodynamics, (7.) thermal hydraulics, (8.) physics, (9.) chemistry, (10.) probability analysis, and (ll.) earthquake engineering.
t (if no courses were taken in any of the foregoing disciplines, so indicate for each of the foregoing disciplines.).
S.
Provide a sum =ary description of the professional training and experience, if any, of Mr. Barlow in regard to each discipline listed in 7. above.
(If none for any given discipline, so indicate.).
9.
Please provide a description of Mr. Bonilla's direct involvement in the geological and seismological investigations undertaken by the USGS for the GETR site (if intervenors are aware of none, so indicate).
10.
Please identify the specific sources and provide a citation fcr the specific data sets from a) the San Fernando earthquake
-of 1971, and b) the Imperial Valley Earthquake of October 1979, which support the positions stated at page 15, second full para-graph of the Intervenors' Updated Answers, dated February 2.5, 1981.
11.
Provide the specific and detailed bases for the statement that "the peak ground accelerations during these earthquakes
. would occur prior to the onset of the seismic scram systems" (see Intervenors' Updated Answers at 10].
12.
Provide the specific and detailed bases for the statement that the January, 1980 quake " adjacent to the Vallecitos Valley" was " strong confirmation of the natural seismic phenomena of seismic focusing or directivity which can cause amplification of strong ground motions in the direction' of seismic ground rupture propogation."
Also provide a description of whether, how, and through what witness or witnesses or documents the intervenors intend to present evidence in support of this statement at the hearings.
13.
Please provide a complete and detailed description of Dr..Trifunac's "significant consultations" to the NRC-ACRS proceeding (see Intervenors' Joint Update to NRC Staff Interrogatories, dated February 25, 1981 [ hereinafter " Joint Update"] at 2).
14.
Provide the intervenors' opinions and the specific bases for those opinions as to a) the maximum fault length, and b) the expected fault rupture length of the Verona fault under the design basis conditions recommended by the intervenors.
15.
Provide the intervenors' opinion on and the specific bases for the probability per reactor year that a " major quake on the Calaveras could occur between the Board's decision on this OSC hearing and the Board's decision at the relicensing L.
- - hearings" (see Joint Update at 7).
Provide the corresponding opinion and bases, if any, for the Verona fault.
16.
Do intervenors intend to present prepared written testimony by each of the following:
1.) Mr. Rutherford; 2.) Mr. Gray; 3.) Mr. Caid; 4.) Dr. Brillinger?
Provide a su= nary of each major element of each item of testimony identified above, and identify the witness or witnesses who will sponsor each such element.
17.
Why were none of Intervenors' Updated Answers answered under oath or affirmation as required by 10 C.F.R.
$ 2.740b?
Please identify the author or authors of each answer submitted on behalf of the intervenors in Intervenors' Joint Updated Answers to Licensee's Interrogatories and provide affidavits affirming each answer.
Respectfully submitted, set- -.
GeorgeL[SIf~.
g Attorney tor General Electric Company OF COUNSEL Morgan, Lewis & Bockius 1800 M Street, N. W.
Washington, D. C.
20036 202/872-5121 Dated:
March 5, 1981
\\
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Docket No. 50-70 GENERAL ELECTRIC COMPAh"I
)
)
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 Atomic Safety and Licensing Board Panel Ms. Barbara Shockley U.
S. Nuclear Regulatory Commission 1890 Bockman Road Washington, D. C.
20555 San Lorenzo, California 94580 Dr. Harry Foreman Docketing & Service Section Director of Center for Office of the Secretary Population Studies U. S. Nuclear Regulatory University of Minnesota Co= mission 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 Glenn W.
Cady, Esq.
Washington, D. C.
20555 Carniato & Dodge 3708 Mt. Diablo Blvd., Suite 300 Atomic Safety and Licensing Lafayette, California 94549 Appeal Board U. S. Nuclear Regulatory Daniel Swanson, Esq., OELD Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 Edward A. Firestone, Esq.
h, General Electric Company George L g cgar g
Nuclear Energy Division Attorney for r
175 Curtner Avenue General Electric Company San Jose, California 95125 (FMil Code 822)
Dated:
March 5, 1981