ML20003C154
| ML20003C154 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 02/25/1981 |
| From: | GENERAL ELECTRIC CO. |
| To: | Dellums Rv FRIENDS OF THE EARTH, HOUSE OF REP. |
| Shared Package | |
| ML20003C152 | List: |
| References | |
| ISSUANCES-SC, NUDOCS 8102260719 | |
| Download: ML20003C154 (78) | |
Text
.
2/25/81 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 SUPPLEMENTAL RESPONSES TO FRIENDS OF THE EARTH'S INTERROGATORIES DATED APRIL 20, 1978 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing
. Board's Order, dated February 3, 1981, General Electric Com-
- /
pany (the Licensee or GE) hereby supplements its responses-
--*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirements of l
10 C.F.R. 5 2.740(e) and has purposefully limited its I
objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that j
the information sought by all of the subject inter-rogatories is relevant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 (Cf. Tr. 86-87), to which the inquiry in this procee3Fng is limited, or l
l (b) that this information is even reasonably calculated to lead to the discovery of admissible evidence.
Cf.
10 C.F.R. 5 2.740(b) (1).
When no supplemental response l
l is provided herein, GE's prior answer, including any previous supplemental answers or responses, remains unchanged.
h e original response.was filed on May 5, l
1978.
l 810226078
r
- to the interrogatories propounded by Friends of the Earth 197& / and received by counsel (FOE) under date of April 20, for the Licensee on April 25, 1978 as follows:
1.
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE will place. primary reliance in regard to the subject matter of a particular response or issue in the Show Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
1 - Ib.
What types of earthquake motions did the AEC and GE expect the original design to withstand? Answer in t'. cms of Richter magnitudes, Modified Mercalli intensities, and ground accelerations.
A:
The types of earthquake motions which the original design was expected, at a minimum, to withstand are stated
- /
GE has previously supplemented its answers to FOE's May 1, 1978 (May 8 service) interrogatories on two occasinas:
- 1) Licensee's Supplemental Answers to Intervenor's Interrogafories and Request for Production of Documents, dated June 7, 1978; and 2) Licensee's Supplemental Answers to Intervenor's Interrogatories, dated July 31, 1978.
- /
The person who prepared the-responses is identified in the attached affidavit.
e
_3-in Change Notice GE-17, Seismic Analysis, R. M. Parsons Com-pany, revised November 22, 1957.
Richter magnitudes and Modified Mercalli intensities were not stated.
3.
Q:
1 - Id.
What engineerirt criteria were used in construc-tion of the GETR to design it to withstand the expected earthquakes?
A:
The engineering criteria which were used in con-struction of the GETR to design it to withstand, at a min-imum, the expected earthquakes are set forth on Drawing S-1 General Electric Test Reactor Facility, Structural, General Notes and Typical Details, R. M. Parsons Company, and implied but not specifically stated in specifications for the construction of the Generel Electric Test Reactor at Pleasanton, CA, September 1957, R. M. Parsons Company.
4.
Q:
1 - 3a.
to sub-Upon what person or persons do you rely?
stantiate your case on Issue number one A:
Richard Harding, Richard Jahns, John Reed, Richard Meehan, Robert Kovach, Garrison Kost, Roland-Sharpe, Jack Benjamin, Charles Richter, and Dwight Gilliland.
5.
Q:
1 - 3b.
Identify which persons you intend to call as wit-nesses in this proceeding.
A.
Richard Harding, Richard Jahns, John Reed, Richard Meehau, Dwight Gilliland, Robert Kovach, and Charles Richter (if available).
4-1 6.
Q:
1 - 3c.
Provide the addresses and educational and profes-sional qualifications, and the employment records (including consulting) on any persons named in 1 3 a. or b.
A:
Addresses, educational and professional qualifica-tions and the record of employment of each individual listed in 1 - 3 a. or b. above are attached.
7.
Q:
1 - 3d.
Identify which of those persons identified in b.
above that you anticipate will appear voluntarily and which under subpoena.
A:
Those persons identified in 1 - 3b. above will appear voluntarily.
8.
Q:
1-4 Provide summaries of the views, positions or pro-posed testimony on Issue 1 of all persons named in response to Interrogatory Number 1 - 3, that you intend to present during this proceeding.
i A:
Summaries of the proposed testimony on Issue l
l Number 1 of all persons named in response to Interrogatory 1 l
- 3 that GE intends to present during this proceeding are set.forth in the following supplemental responses to Inter-rogatories 1 - 5 through 1 - 7.
In regard to Issue 1, GE intends to present its testimony in two parts and present its witnesses in two panels addressing:
- 1) the site geology and design basis for-surface displacement (see 1 - 5 below)
-- Jahns, Harding, Reed, Meehan and Gilliland, and 2) the design bases for vibratory ground motion, and the L
combination of vibratory ground motion and surface 6 and 1 - 7 below) -- Kovach, Richter di alacement (see 1 (if available), Kost (if necessary to answer specific questions at the criteria / analytical interface) and Gilliland.
9.
Q:
1-5 What do you recommend as the proper design basic for surface displacement at the site?
A:
The NRC staff's position is that the proper design basis for surface displacement at the site is one (1. 0) meter of reverse-oblique net slip along a faalt plane which could vary in dip from 10 to 45 degrees and which could occur on a Verona fault strand (splay) beneath the GETR during a single earthquake event.
GE's position is that the NRC's value is conservative.
Since GE's analyses of the structure and of installed or planned modifications show that the structures, components and systems required for the l
safe shutdown of the GETR will remain functional under the l
l conditions of surface rupture and offset as conservatively formulated by the NRC staff, GE does not intend to contest the steff's position in the Show Cause proceeding.
GE's proposed testimony cm surface displacement can be summarized l
as consisting of four elements:
- 1) an overview of the sit; geology to establish an appropriate perspective for I
assessment of geological risk, 2) A review of the historical l
record of' displacements at the GETR site and a comparative L
l
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 (assuming that displacements of tectonic origin can occur), 3) the probability analyses performed by GE to demonstrate that the likelihood of any surface rupture offset of any size displacement under the reactor foundation is extremely small (assuming that displacements of any size could occur), and 4) a review of soil / structure analyses performed by GE to demonstrate that even if a displacement originates such that its projection would have the potential for intersecting the reactor foundation, it will in fact not intersect the foundation.
The primary bases for this testimony are set forth in detail in references 3 - 5, 7, i
31, 32, 33, 34, 35, 38, 41, 46, 52, 53, 54, 63, 71, 72, and the NRC staff's Safety Evaluation Report.
10.
Q:
1-6 What do you recommend as the proper design basis for vibratory ground motion at the site?
l A:
The NRC staff's position is that the proper design basis for maximum vibratory ground motion at the site is 0.75g, and that for purposes of analysis this value be anchored to the Regulatory Guide 1.60 spectra.
This value l
-is correlated with motion on the nearest reach of the Calaveras fault.
The position of General Electric Company is that the staff's value is conservative; an appropriate L
e
maximum ground acceleration would he 0.6g anchored to Regulatory Guide 1.60 spectra (this ground motion at the site is correlated with an event on the Calaveras fault).
Since General Electric Company has used the NRC staff's values in performing analyses of the struccure and of installed or planned modifications that show the structures, components and systems required for the safe shutdown of the GETR will remain functional under the conditions conservatively formulated by the NRC staff, GE does not intend to contest the staff's position in this regard in the Show Cause proceedings.
GE's proposed testimony on maximum vibratory ground motion will also address and include the combined effects of ground motion and surface displacement (see 1 - 7 below).
GE's testimony can be summarized as consisting of three elements:
- 1) an overview of the regional seismicity to establish a perspective for assessment of seismic risk _at the GETR site, 2) an l
evaluation of the available near field strong-motion data such as the Imperial Valley and (1979) Tabas, Iran (1978) and Gazli, Russia (1976) earthquakes to establish the j
conservatism of the NRC staff's vibratory ground motion criteria for postulated events on the Calaveras and Verona faults, 3) an evaluation of earthquake magnitide-siesmic i
i moment considerations to assess the conservatism of the-t NRC's criteria for events on the Calaveras and Verona l
l E
. faults.
The primary bases for the testimony are set forth in detail in references 6, 15, 31, 49, 55, and 56, and the NRC staff's Safety Evaluation Report, and "On Moment -
Magnitude Scale", S.K. Singh and J. Havskov, Bulletin of Siesmological Society of America, Vol. 70, 379-38, Feb.
1980; Expected Earthquake Magnitude from n Fault", S.K.
Singh, E. Bazan, and L. Esteva Id., 903-914, June 1980; In re Pacific Gas & Elec. Co. (Diablo Canyon), Docket Nos. 50-275 and 50-323, Aug. 8, 1980, PGE Response to Appeals Board Questions, Evaluation of Peak Horizontal Acceleration Associated with the Hosgri Fault at Diablo Canyon Nuclear Power Plant, Appendix B, DCNPP Data Base.
11.
Q:
1-7 What do you recommend as the proper design bases for the combined effects of surface displacement and vibratory ground motion? Include in this response the time sequence of these events that you postulate.
A:
The NRC staff's position is that the proper design basis involving the effects of surface displacement and vibratory ground notion should combine a vibratory ground motien of 0.6g anchored to the Regulatory Guide 1.60 spectra with a fatlt displacement of one meter as described in the updated response to Interrogatory 1 - 5.
The position of General Electric Company is that the staff's position is conservative; an appropriate value for ground acceleration would be 0.4g anchored to Regulatory Guide 1.60 spectra for
9-vibratory motion induced at the site by an event on the Verona fault and no fault displacement would be combined with this vibratory ground motion.
In regard to the time sequence of events, the structural analysis postulates that surface displacement and vibratory ground motion are simultaneous.
Since General Electric has performed analyses which encompass the conservative values stated by the NRC staff, and the results show that the structures, systems and components required for the safe shutdown of the GETR con-tinue to function properly, GE does not intend to contest the staff's position in the Show Cause proceedings.
GE's proposed testimony in this regard is summarized in 1 -6 above.
12.
Q:
1 -8 What magnitude and frequency for vertical and horizontal ground accelerations, what Mercalli intensity, and what Richter magnitude do you postulate for the GETR to experience during the maximum credible earthquake on the Calaveras Fault with the epicenter near the GETR?
A:
The previous responses remain unchanged except that updated information relating to the prior responses to this interrogatory is contained in references 6, 55-2 and 56-1.
13.
Q:
1 - 10 What is your probability estimate that for each of the above postulated earthquakes there would be precursor shock activity of the necessary size to activate the seismic trip mechanism in time suf-ficient to insert the control rods and scram the
_ 10 -
GETR reactor operations before the larger magni-tude quake strikes the site?
A:
The previous responses remain unchanged except that additional updated information regarding the character of the early segments of vibratory ground motion is con-tained in reference numbers 64, 67 and 69.
14.
Q:
2 - la.
Upon what person or persons do you rely to sub-stantiate your case on Issue 2?
A:
Garrison Kost, John Reed, Richard Meehan, Roland Sharpe, Dwight Gilliland, and Harold Durlofsky, 15.
Q:
2 - Ib.
Identify which of the persons identified in a.
you intend to call as witnesses in this proceed-
-ing.
A:
GE plans to call Dwight Gilliland, Garrison Kost, and Harold Durlofsky.
16.
Q:
2 - Ic.
Provide the addresses and education and profes-sional qualifications and employment history (e.g., consulting contracts) of any persons named above.
A:
Addresses, educational and professional qualifica-tions, and employment history of each individual named in 2
-la. and b. above are attached.
.17.. Q:
2 - Id.
Indicate which of the persons identified in b.
above that you anticipate.will appear voluntarily and waich under subpoena.
~
- 11 A:
Those perso::s identified in b. above will appear voluntarily.
18.
Q:
2 - le.
Specify the amount and source of salary or com-pensation that each of these persons will be receiving for preparation and participation in these hearings and proceedings.
A:
General Electric is the sole source of ralary for Mr. Gilliland.
General Electric is the source of compensa-tion for the consultants identified above to the extent that their services are rendered in connection with the subject matter of the Show Cause proceedings.
Information concern-ing the amount of salary or compensation is not reasonably designed to lead to relevant information in this proceeding, and to that extent General Electric objects to this interrogatory.
19.
Q:
2-2 l
Provide summaries of the views, positions, or pro-posed testimony on Issue 2 of all persons named in response to Interrogatory Number 2 - 1, that you intend to present during this proceeding.
l A:
Summaries of the positions and proposed testimony l
on Issue Number 2 of all persons named in the response to Interrogatory 2 - 1 that GE intends to present as witnesses during this proceeding are set forth in the following answers to Interrogatories 2 - 3 through 2 - 5.
GE intends to present tect. irony and a_penel of witnessec consisting of Dwight Gilliland, Garrison Kost, and Harold Durlofsky in L
support of its position on Issue 2.
20.
Q:
2-3 Which specific GETR structures, systems and com-ponents important to safety require design modif-ication considerating the seismic and design bases that you postulate in response to Interrogatories 1 - 3, 1 - 4, and 1 - 5?
In each case indicate the nature, extent and the types of modifications that you recommend.
Also in each case specify the earthquake engineering design criteria that will allow these modifications to withstand the maximum credible Richter magnitude and ground accelerations.
A:
The proposed testimony will summarize the existing base of information developed by GE to address this point.
GETR structures, systems and components important to safety that are proposed to be modified based on the seismic design bases were originally described in the Response to the NRC t
i Order to Show Cause dated November 11, 1977 (see reference l
3).
The nature, extent, basis for, and type of proposed modification for each item is also described therein.
The earthquake engineering design criteria for these modifications are those stated in rerponse to Interrogato. ries 1 - 5, 1 - 6, and 1 - 7.
An update of the design of the structures, systems and components which are proposed to be modified was set forth in those documents listed in Licensee's Supplemental Answers to Interroga-tories, dated 7-31-78 (see reference 22); and further updated information is contained in reference numbers 60-5,
13 -
67 and 69.
See also the references listed in che answer to 2-18 below.
21.
Q:
2-4 State the bases, calculations and references used for supporting the positions specified in response to Interrogatory 2-3 as to the following:
a.
Why each structure, system and component specif4 d is important to plant safety.
b.
Why each structure, system and component specified needs modification.
A:
The proposed testimony will summarize the existing base of information developed by ( ' to address this point.
The basis, calculations and references, as appropriate, supporting the position specified in response to Interrogatory 2-3 as to why each structure, system and com-ponent specified is required for safe shutdown and why each needs modification are described in the Response to the Order to Show Cause dated Novembr.r 11, 1977, and in the l
additional information referenced in 2-3 above.
Also, see i
the answer to Interrogatory 2-18.
22.
Q:
2-5 Is it your pasition, or do you anticipate that it a.
will be your position at the hearing, that the l
i modifications specified in response to Interroga-tory 2-3 can.be made so that GETR structures, systems, and components important to safety can renain functional in light of the design bases determined in Issue 1; l
b.
If the answer to a. is yes, state the specific bases, calculations, and references which support p
this conclusion.
i i
_ 14 _
i A.
The proposed testimony will summarize the existing base of information by GE to address this point.
It will also include an evaluation of the conservatisms embodied in the analysis (see, e.g., reference 56-4).
The specific bases, calculations and references that support the conclusion that the GETR structures, systems and components and their modifications will remain functional in light of the design bases stated in answers to Interrogatories 1-5, 1-6 and 1-7 are given in Table 1 of the Updated Response to NRC Show Cause Order dated July 20, 1978 (reference 22), and the NRC staff's Safety Evaluation Report.
Additional information is referenced in 2-3 above, and in the answer to interrogatory 2-18.
23.
Q:
2 - 13 Analyza the effects on the GETR and the experiment areas of Earthquake-produced damages to each of the containment penetrations, including an anal-l l
ysis of effects from the maximum credible ground acceleration.
A:
The previous answer remains unchanged except that updated information relating to the prior answer to this interrogatory is contained in reference numbers 23-2, 27-9 and 36-3.
24.
t 2 - 15 Provide a detailed analysis of potential seismic damage to all electrical and mechanical devices and circuitry in the GETR area.
' A:
A detailed analysis of potential seismic damage to all electrical and mechanical devices and circuitry in the GETR has not been done, The alectrical and mechanical devices required for safe shutdown in a postulated seismic event have been described in the Response to the NRC Order to Show Cause dated November 11, 1977 (reference 3), and are further described as indicated in the answers to Interrogatories 2-3 through 2-5.
This information shows that all structures, systems and components required for safe _ shutdown in the design basis siesmic event will remain functional through the seismic event or until the required function is performed.
Damage to any other devices would not affect the ability of the plant to withstand the seismic event.
Additional updated information relating to the prior answers to this interrogatory is-contained in reference numbers 30, 64, 67 and 69.
25.
Q:
2 - 18 In response to questions 2-6 through 2-17, please l
provide detailed ste;-by-step calculations wtich l
will document that the structural components already in place or presently propased will pro-i vide sufficient structural integrity to withstand the stresses which will accompany an earthquake of the maximum credible cagnitude.
A:
Documentation that the structural components (in place or as modified) required for achieving and maintaining safe shutdown of the GETR in the case of a seismic event
'will provde sufficient structural integrity to withstand the
- stresses is set forth in the references noted in Interrogatory 2-3 and, additionally, in reference numbers 19, 22, 23, 24, 27-1,
-2,
-3,
-4,
-5,
-6,
-9,
-10,
-11,
-12,
-14, -16, -17, -18, 36, 42, 45, 49-1, 51, 56, 57, 59, 60, 61-3, 63, 71 and 72.
The detailed step-by-step calculations for tha above structural components will remain available for inspection and copying at the offices of Engineering Decision Analysis Company (EDAC), 46J California Avenue, Palo Alto, California pursuant to the prior responses.
The
. detailed step-by-step calculations for the missile impact system and canal storage tank will be available at the offices of Structural Mechanics Associates (SMA).
Inspection and copying may be arranged by contacting Roland Sharpe (EDAC), 326-0383, or Harold Durlofsky (SMA), 408-734-1734, as appropriate, and providing a three-day advance notice of each specific structural component for which inspection and copying of calculations is requested.
Copying services will be made available at Engineering Decision Analysis Company's or Structural Mechanics Associates' customary rates.
i 26.
Q:
3-1 -- 3-3 Upon what person or. persons do you rely to sub-3-1 a.
stantiate your case on Commission Issue Number 3?
/
4 v
- b.
Identify which of the persons identified in a.
you intend to call as witnesses in this proceeding.
c.
Provide the addresses and educational and profes-sional qualfications and employment history (including consulting contracts and fees) of any persons named above.
d.
Indicate which of the persons identifed in b.
above that you anticipate will appear voluntarily and which under subpoena.
3-2 Provide summaries of the views, positions, or pro-posed testimony on Commission Issue Number 3 of all persons named in rates.
3-3 State the specific bases, calculations and refer-ences upon which the persons named in response to Interrogatory No. 3-1 rely to substantiate their views regarding Commission Issue 3.
A:
At the present time GE does not intend ta present a direct sase on Issue 3 at the forthcoming hearings.
Instead, at the present time GE intends to present its case to resolve issues 1 and 2 and thus achieve removal of the suspension under the licence immediately upon issuance of a favorable decision by the Licensing Board.
Should future circumstances warrant, GE does not waive the right to seek such remedies as may be available pursuant to issue 3.
27.
Q:
4-1 For all references requested in these interroga-tories, identify them by author, title, date of publi ation and publisher if the reference is pub-lished, and if it is not published, identify the document by the author, title, the date it was written, the qualificationa of the author relevant to this proceeding,~and where a copy of the docu-ment may be obtained.
Include copies of all references,.or make available for Intervenors' inspection and copying, all references.
parties under separate cover, or made available for inspection and copying at the Vallecitos Nuclear Center.
E'
s' 2/25/81 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 SUPPLEMENTAL ANSWERS TO FOE'S INTERROGATORIES DATED MAY 1, 1978 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric (GE)
- /
hereby supplements its responser-to Friends of the Earth's l
--*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirements of i
i 10 C.F.R. 5 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless l
otherwise noted, GE does not concede either (a) that the information sought by all of the subject inter-rogatories is relevant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 (Cf. Tr. 86-87), to which the inquiry in this proceeding is limited, or (b) that this information is even reasonably calcule'ed to lead to the discovery of admissible evidence.
Cf l
10 C.F.R. 5 2.740(b)(1).
When no supplemental response is provided herein, GE's prior answer, including any unchanged. pplemental answers or responses, remainsn e. original res previous su 1978.
1
2-(FOE's) interrogatories, dated Mt; 1, 1978, /
which were received by counsel for GB on May 12, 1978, as follows:- j 1
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference th>se documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of any particular response or issue in the Show Cause proceed-c ings.
Where additional available information.not included on Attachment A will be relief upon, it will also Le iden-
.tified below.
2.
Q:
la - Ib.
I la.
In your opinion, if the Verona fault is assumed to exist, is the Verona-fault connected or not con-nected to the Calaveras fault?
lb.
Please state all evidence supporting your answer to Ia.
The prior responses remain unchanged (not A:
a.
connected).
l'
--*/
GE has previously supplemented its answers to FOE's May 1, 1978 (May 8 service) interrogatories on two occasions:
- 1) Licensee's Supplemental Answers to l
Intervenor's Interrogatories and Request for~ Production
'of Documents,-dated June 7, 1978; and 2) Licensee's Supplemental Answers to-Intervenor's Interrogatories, l
dated July 31, 1978.
- /
1he person who prepared the responses is identified in the attached affidavit.
i
.,g*-
-~~
- -r~=
-e w*-
b.
The prior responses remain unchanged except that updated information relating to the prior answers to this interrogatory is contained in references 31-2, 31-3, 32, 33, 35, 37, 38, 49-2, 53, and 59.
3.
Q:
1e.,
f.,
and g.
le.
Would the conclusions of the report cited in (1) e. above (reference 153b.] be changed by the assumption that the Verona fault is connected to the Calaveras fault?
If.
Would the conclusions of the report cited in (1) c. above be changed by the assumption that the Verona fault is connected to the Las Positas fault?
Ig. - What would the conclusions referred to in (1) e.
end (1) f. be?
A:
The prior response to interrogatory 1(e) was affir. native and was based upon considerations of a fault l
length-offset relationship.
However, subsequent results of the Phase II geological investigations (reference 31) change the prior response.
The answers to le. and If. are no. Age and offset data were obtained from stratigraphic horizons in the Phase II trenches.
This led to the determination of the 1.
amount and rate of slip which could be expected along a postulated Verona fault.
The amount and rate of slip' thus determined is a more reliable bases for determining offset l.
I-E
3 and siesmic activity on a fault system than a fault length-offset relationship.
Thus, GE's conclusions as to the appropriate design basis siesmic criteria are independent of whether the postulated Verona fault is connected to either the Calaveras or postulated Las Positas faults.
4.
Q:
4a - 4b.
4a.
Is the landslide posited by Earth Sciences Asso-ciates capable of movement near the GETR?
4b.
Please state all data, assumptions and calcula-tions underlying the answer to 4a above.
A:
a.
Movement of the landslide posited by Earth Sciences. Associated near the GETR is described in references 21, 31-2, 31-3, 32, 33, 35, 61-1, 61-2 and 66.
b.
The data, assumptions and calculations ur.:er-lying the answer in 4a above are stated in the references identified in 4a above.
5.
Q:
5b.
What amount of surface displacement or ground acceleration will rupture, block, or damage the
[ emergency core cooling water) reservoir described in Sa.?
A:
The tanks (reservoirs) are designed to withstand a surface displacement (offset) of one meter and a ground acceleration of 0.8g.
The maximum amount of eurface displacement (offset) - or ground acceleration which the reservoirs will sustain without failure has not been determined.
O
. 6.
Q:
5f.
Please state where the sections of buried pipe referred to in 5a will be, including a scale dia-gram of the proposed reservoir.
A:
The prior responses to this interrogatory are not changed, except to substitute the name Del France for Mr. Crawford; and substitute the telephone extension 4567 for 4462 as the contact point for arranging to inspect the documents (drawings) referenced and made available by the prior responses.
7.
Q:
Sg.
State all data, assumptions and calculations underlying the answers to Sc, d, e and f.
's :
The data, assumptions and calculations underlying the answers to Sc, 5d, Se and 5f are contained in the Response to Show Cause Order dated November 11, 1977 (reference 3), in the Updated Response to Show Cause Order and associated reports included in reference 22, and those references contained in the answers to these t
interrogatories.
8.
Q:
7c.
Please state all data, assumptions and calcula-l tions underlying ti. answer to 7b.
A: -
The data, assumptions and calculations underlying the answer to 7b are given in the Response to Show Cause i
November-11,1977 (reference 3) and in an update of the
i 6-design of the structures, systems anc components (refer-ence 22).
9.
Q:
8a.
How many seconds could an earthquake on the Calveras fault last?
A:
An estimate was provided in a report by Lindva21, Richter & Associates, and set forth in reference 6.
(See 8b below).
10.
Q:
8b.
How many seconds of strong ground motion at the GETR site could result from an earthquake on the Calaveras fault?
A:
The design tim history for the design basis seis-mic event at the GETi; site is given in Phase II report (reference 19).
11.
Q:
8c.
Please state all data, assumptions and calcula-tions underlying the answers to 8a and 8b.
A:
The data, assumptions and calculations underlying the answers to Interrogatories 8a and 8b are noted in each of the above supplemental answers.
12.
Q:
lla.
Are any GETR control systems, including but not limited to SCRAM,-ECCS, core spray, seismic trip, containment or any other control system capable of single point failure?
A:
The prior response remains unchanged except that updated information relating to the-prior answers to this interrogatory is contained in reference 64-1.
7-13.
Q:
11 la - It, la.
All reports prepared by Earth Sciences Associatec for General Electric for any purpose.
1b.
All reports prepared by Earth Sciences Associates in the possession of General Electric.
Since discovery was initiated in these A:
a.
proceedings, all reports prepared by Earth Sciences Asso-ciates for General Electric with regard to geologic features of the GETR site have been forwarded to all parties at the time of submission to the NRC.
b.
Since discovery was initiated in these proceedings, all reports prepared by Earth Sciences Asso-ciates in the possession of General Electric with regard to geological features of the GETR site have been forwarded to all parties at the time of submission to the NRC.
14.
Q:
II 6a - 6b.
Please make available for inspection and copying the following documents:
I 6a.
All GETR control system elementary diagrams, I
including but not limited to SCRAM, ECCS, seismir trip, containment and core spray systems.
6b.
Any notes, memoranda or other documents identify-ing possible single point failures of any of the systems described in 6a.
I A:
The prior response to these interrogatories made all of the subject documents available for inspection and copying.
Substitute the name Del France for Mr. Crawford; 6
w
i 8-and subst) 2te the telephone extension 4567 for 4462 as the contact point for arranging to inspect the documents made available by the prior response.
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i A
2/25/81 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'T. SUPPLEMENTAL ANSWERS TO CONGRESSMAN DELLUMS' INTERROGATORIES DATED MAY 9, 1978 Pursuant to 10 C.F.R. $ 2.74G(e) and the Licensing Board's Order, dated February 3,1981, General Electric Company (the Licensee or GE) hereby supplements its
- /
responses-to the interrogatories propounded by Congressman
- /
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirements of 10 C.F.R. $ 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that the information sought by all of the subject inter-rogatories is relevant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 (Cf. Tr. 86-87), to which the inquiry in this procee3Tng is limited, or (b) that this information is even reasonably calculated to lead to the discovery of admissible evidence.
Cf.
10 C.F.R. $ 2.740(b) (1 } a.
When no supplemental response is provided herein, GE prior answer, including any previous supplemental answers or responses, remains unchanged.
The original response was filed on.May 22, 1978.
s
't
- Dellums under date of May 9, 197& / and received by counsel 1978 as follows:- /
for the Licensee on May 12, 1.
Gcneral - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the sccceeding responses will cross-reference those documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of a particular response or issue in the Show Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
11.
Could the 15 ton crane fall onto the core or experimental capsules during an earthquake?
Could the crane fall into the canal during a quake?
A:
No.
Structural modifications which preclude the 15-ton crane falling onto the core, experiment capsules or into the canal during the maximum credible earthquake are
--*/
GE has previously supplemented its answers to Congressman Dellums h y 9, 1978 interrogatories on three occasions:
- 1) Licensee's Supplemental Answers to Intervenor's Interrogatories and Request for Production of Documents, dated June ~7, 1978; 2) Licensee's Supple-mental Answers'to Intervenor's Interrogatories, dated July 31, 1978; and 3)' Errata to Licensee's Answers to Intervenor's Interrogatories dated May 9,1978, dated May 24,-1978.
- /
The person who prepared the responses is identified in the attached affidavit.
m m.
1 s
8 described in the GE submittal of February 24, 1978, to NRC (reference 13), a copy of which was provided to the Inter-venors at that time.
This is further discussed in an update of the design of structures, systems and components which are proposed to be modified that has previously been sent to all parties (reference 22).
Additional updated information is provided in references 45-5 and
-6.
3.
Q:
13.
Present an accident scenario for earthquake damage to the canal and to the spent fuel rods and wastes that are stored there.
this scenario should be for the maximum credible earthquake, and should include an analysis of the effects from the canal water flooding the reactor pool area.
A:
The prior responses remain unchanged except that updated information relating to the prior responses to this interrogatory is contained in reference numbers 19, 22, 23, 24, 27-1,
-2,
-3,
-4,
-5,
-6,
-9,
-10, -11, -12, -14, -16,
-17, -18, 36, 42, 45, 49-1, 51, 56, 57, 59, 60, 63, 71 and 72.
4.
Q:
19.
l-Demonstrate proof that comalete loss of elec-tricity at full power in the GETR would not result I
in damage to fuel or in release of fission products.
How could the loss of electricity affect a LOCA caused by an earthquake?
l
\\
L 4-A:
The prior answers remain unchanged, except that updated information relating to the prior answers to this interrogatory is contained in reference 22.
5.
Q:
24.
How hean is the missile shield?
In a severe earthquake, could this shield fall onto the reactor core or onto experiment areas?
A:
The prior answers remain unchanged except that the updated information relating to the prior answers to this interrogatory is contained in reference 22.
6.
Q:
25.
How heavy is the fuel handling platform?
Could it collapse or fall?
A:
The prior answers remain unchanged except that the updcted information relating to the prior answers to this interrogatory is contained in reference 22.
7.
Q:
26.
What is the weight of the water in the canal, and what magnitude of earthquake and ground accelera-tion were the two removable section gates and the wall between the reactor and canal designed for originally?
A:
The weight of the water in the canal is about 160,000 lbs.
Seismic design criteria, as such, for the original designs of the removable section gates placed between the reactor and canal were not requriements<
The engineering criteria which were used in con-struction of the wall between the reactor pool and canal to 4
e
-ew,-
--.e r
--r-
,m-e e
\\
b design it to withstand, at a minimum, the expected earth-quakes are stated on Drawing S-1, General Electric Test Facility, Structural, General Notes and typical Details, R. M. Parsons Company, and are implied but not specifically stated in the Specification for the Construction of the General Electric Test Reactor at Pleasanton, California, September 1957, R. M. Parsons Company.
8.
Q:
29.
What is the design basis earthquake for the 37 nozzle penetrations?
A:
The prior answers remain unchanged except that the updated information relating to the prior answers to this interrogatory is contained in references 22, 23-2, 27-9 and 36-3.
o il.
I a
L
k 2/25/81 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 SUPPLEMENTAL RESPONSES TO CONGRESSMAN DELLUMS' INTERROGATORIES DATED JULY 14, 1978 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric Company (the Licensee or GE) hereby supplements its
- /
responser-to the interrogatories propounded by Congressman
- /
GE is furnishing these supplecental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirementa of 10 C.F.R. 5 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that the information sought by all of the subject inter-rogatories is relevant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 LCf. Tr. 86-87), to which the inquiry in this proceeding is limited, or (b) that this information is even reasonably calculated Cf.
to lead to the discovery of admissible evidence.
10 C.F.R. 5 2.740(b)(1).
When no supplemental response is provided herein, GE's prior answer, including any previous supplemental answers or.esponses, remains unchanged.
The original response was filed on Ju;; J1, 1978.
d Dellums under date of July 14, 1978 and received by counsel for the Licensee on July 20, 1978 as follows: /
1.
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE w11L place primary reliance in regard to the subject matter of a particular response or issue in the Shor Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
2.
Do three axes restraints shown in EDAC 117.04 piping schematics represent pins or anchors?
A:
The prior answers remain unchanged except that updated information relating to the prior answers to this interrogatory is contained in references 22 and 60-5.
3.
Q:
3.
Against what other computer programs has EDAC-PIPE been benchmarked?
- /
The person who prepared the responses is identified in the attached affidavit.
'A
' A:
The prior answers remain unchanged except that updated information relating to the prior answers to this interrogatory is contained in reference 45-3.
4.
Request for Documents - 1.
In addition to the aforementioned interrogatories, please produce the following documents:
The data file and question and answer file associated with each EDAC GETR core cooling pipe analysis, including but not limiting to data notes, specifications, preliminary con-clusions, preliminary results, preliminary reports, assumptions used and justifications therefore.
R:
The response remains unchanged (documents were made available) except that the updated information relating to the prior response to this request is contained in reference 60-5, a copy of which was sent to all parties at the time of submission to NRC.
t
)
t
f 2/25/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
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 SUPPLEMENTAL RESPONSES TO FRIENDS OF THE EARTH'S INTERROGATORIES DATED JULY 24, 1976 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric Com-
- /
pany (the Licensee or GE) hereby supplements its responser-
--*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirements of 10 C.F.R. 5 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that the information sought by all of the subject inter-rogatories i.:3 relevant to any of the three specific
<..ssues identified in the Commission's Memorandum and hrder,datedFebruary 13, 1978 (Cf. Tr. 86-87), to thich the inquiry in this procee3Tng is limited, or i[b) that this information is even reasonably calculated to lead to the di; cove"y of admissible evidence.
Cf.
10 C.F.R. 5 2.740(b)(1).
When no supplemental respohse is provided herein, GE's prior answer, including any previous supplemental answers or responses, remains unchanged.
Le original responses were filed on August 8, 1978 (interrogatories), and August 21, 1978 (documents).
h e
i t
1 I
1
I
- to the interrogatories propounded by Friends of the Earth (F0E) under date of July 24, 1978 and received by counsel as follows: /
for the Licensee on July 26, 1978 1.
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of a particular response or issue in the Show Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
1.
Can the GETR meet a " single component failure"?
A:
The prior response remains unchanged except that updated information relating to the prior response to this interrogatory is contained in reference 64.
3.
Q:
4.
Are the GETR instruments, components, panels and piping seismically qualified per IEEE 374?
--*/
The person who prepared the responses is identified in the attached affidavit.
' A:
The prior response remains unchanged except that updated information relating to the prior response to this inte::rogatory is contained in reterences 64, 67 and 69.
4.
Q:
8.
What is the GETR DBE?
A:
Values recommended by General Electric and addi-tional values established by the NRC Staff for the GETR seismic design bases pursuant to issue 1 of the Show Cause Order are set forth in Licensee's Supplemental Responses to F0E's Interrogatories dated April 20, 1978 (Interrogatories 1-5,1-6 and 1-7), filed by the Licensee under date of February 25, 1981.
5.
Q:
12.
What are the design bases for GETB instrumentation design?
A:
The prior response remains unchanged except that F0E should now contact Del France (415-862-2211 x 4567) in order to make arrangements for inspection and copying of the documents made available in the prior response.
6.
Q:
21.
10.
Are the Seismic 1 and Seismic 2 units them-selves seismically qualified?
21.
If the answer to 20 above is to what
}
levelaretheuntisseismically,qualfes fied?
i A:
Seismic 1 and Seismic 2 units have been qualified at levels above those at which the trip point is set.
Once t
9
\\ these unir-trip, there is no further need for their opera-tion.
For additional updated information, see references 67 and 69.
7.
Document Request Please provide the following documents:
1.
22 A 9219 2.
913 E 191 3.
Scram Piping Diagrams 4.
"GETR Technical Specifications" (June, 1977)
R:
The prior response remains unchanged except that F0E should now contact Del France (415-862-2211 x 4567) in order to make arrangecents for inspection and copying of the documents made available by the prior response.
1 h
2/25/81 UNITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSION In the Matter of
)
)
Docket No. 50-70 GENERh! ELECTRIC COMPANY
)
)
Operating License (Vallecitos Nuclear Center -
)
No. TR-1 General Electric Test Reactor)
)
(Show Cause)
LICENSEE'S SUPPLEMENTAL RESPONSES TO CONGRESSMAN DELLUMS' INTERROGATORIES DATED JULY 25, 1978 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric Com-
- /
pany (the Licensee or GE) hereby supplements its responses-
-*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many 10 stances gone beyond the requirements of 10 C.F.R. S 2.740(e) and he.a purposefully limited its objections only to the mort extreme cases.
Unless otherwise noted GE does not concede either (a) that the information sought by all of the subject inter-rogatories is relevant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 CCf. Tr. 86-87), to which the inquiry in this proceeding is limited, or (b) thar. this information is even reasonably calculated to lead to the discovery of admissible evidence.
Cf.
10 C.F.R. 5 2.740(b) (1).
When no supplemental response is provided herein, GE's pr!or answer, including any previous sunplemental answers or responses, remains unchanged. ' R e original response was filed on August 9, 1978.
I '
to the interrogatories propounded by Friends of the Earth (FOE) under date of July 25, 1978 and received by counsel for the Licensee on July 28, 1978 as follows:
1.
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of a particular response or issue in the Show Cause proceed-ings.
Where additional avai14ble information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
A.I a)8.
What are the locacions of silt lenses and other discontinuous for nations under the GETR?
A:
The prior answer remains unchanged except that updated information relating to the prior answer to this interrogatory is contained in reference 52.
3.
Q:
A.I a)9.
Did the foundation investigation confirm the existence of alluvial deposits meandering through the colluvial deposits?
--*/
The person who prepared the responses is identified in the attached affidavit.
1 A:
The prior answer remains unchanged except that the l
updated information relating to the prior answer to this interrogatory is contained in reference 52.
4 Q:
A.I a)10.
Were silt lenses or other discontinuous formations observed in more recent geologic explorations?
l A:
The prior answer remains unchanged except that the updated information relating to the prior answer to thie.
interrogatory is contained in reference 31-2.
i I
l t
1; if i
\\
2/25/81 s
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 SUPPLEMENTAL RESPONSES TO FRIENDS OF THE EARTH'S REQUEST FOR DOCUMENTS DATED AUGUST 9, 1978 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric Com-
- /
pany (the Lic..isee or GE) hereby supplements its responses-
--*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirements of l
10 C.F.R. $ 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that l
the information sought by all of the subject is rele-vant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 (Cf. Tr. 86-87), to which the inquiry in this proceeding is limited, or (b) that this infor-I mation is even reasonably calculated to lead to the discovery of admissible evidence.
Cf. 10 C.F.R. 5 2.740(b)(1).
When no supplementaT response is pro-vided herein, GE's prior answer, including any previous supplemental answers or responses, remains unchanged.
The original response was filed on August 21, 1978.
t i
U.
g i to Request for Documents by Friends of the Earth (F0E) under date of August 9,1978 and received by counsel for the Licensee on August 11, 1978 as follows:
1.
General - GE intends to rely 2pon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of a particular response or issue in the Show Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will clso be iden-tified below.
2.
Requested Documents 1 - 22.
Pursuant to 10 C.F.R. 5 2.741, Intervenors hereby request General Electric Company (GE) to produce the follow-ing documents:
1.-11.
Drawings for Structural Evaluation of Primary Cooling System Seismic Restraints.
General Electric Company reference drawings:
l 203A6005 Rev. O Double U-Bolt 153C4663 Rev. 1 Primary Pipe l
Restraint (Assy Tri aze) f 178B89876 Rev. 1 kall Pad 178B89877 Rev. 1 Shim 153C4664 Rev. 1 Extension 178B89878 Rev. 1 Shim 153C4665 Rev. 1 Strut 178B9879 Rev. 1 Angle-Vert.
153C4666 Rev. 1 Strut 178B9880 Rev. O Saddle 153C4667 Rev. 1 Strut 178B9882 Rev. 1 Pipe Support 153C4668 Rev. O Angle-Horiz 178B9883 Rev. O Saddle 153C4675 Rev. 1 Ceiling Bracket l
178B9884 Rev. O Adaptor 129D4563 Rev. O Primary Pipe Restraint (Assy 2-10) l l
178B9888 Rev. O Bracket 153C4661 Rev. O Wall Pad 913E173 Rev. 1 Primary Pipe Restraint
g '
12.
Letter from Abbot A. Hanks, Inc. Testing laboratories to ITT Phillias Drill Co.,
Subject:
NWS Concrete Expansion Anc'ior Tests (Wedge Type), A. A. Hanks File No. H2968-SI, Report No. 3016, May 16, 1977.
13.
ITT Grinnell Pipe Hanger Division, "ASME Section III, Subsection NF, Load Capacity Data Sheet for Fig. 216 12" and 14" diameter pipe clamps for Vallecitos Nuclear Center."
14-18.
Drawings for Structural Evaivation of the Reactor Pressure Vessel Lateral Support Assembly.
General Electric Company reference drawings:
115A8054.Rev. O Clevis Pin 655C766 Rev. O Assembly, Lateral Suppcit 196E986 Rev. O Pressure Vessel Parts List for 7177E42 Assembly, system and components tank typa reactor Rev. 14 (Sheet No. 1) 19.
The Ralph M. Parsons Company reference drawing S-16, Rev. 5. Reactor Building Pool Liner Details.
20.
Drawing for modification of elbow support near P101 (Restraint 1-10).
General Electric Company reference drawing:
195F443 Rev. 2.
Primary Pipe Restraint 21.
General Electric Company, Reference Drawing:
293A6010 Rev. O Clevis Pin
Response
Items 1 - 22 listed in the Document Request have, in some cases, been revised.
All documents remain available for inspection and copying by Friends of the Ea'rth at General Electric's offices at the Vallecitos Nuclear L
aj Center pursuant to GE's. prior response.
Contact Del France (415-862-2211,- x 4567) to arrange for inspection and copying.
l t
2/25/81 s
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 Causc '
LICENSEE'S SUPPLEMENTAL RESPONSES TO CONGRESSMAN DELLCMS' INTERROGATORIES DATED AUGUST 3, 1978 Pursuant to 10 C.F.R. 5 2.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric Com-
- /
pany (the Licensee or GE) hereby supplements its responses-
--*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE has in many instances gone beyond the requirements of 10 C.F.R. 5 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that the information sought by all of the subject inter-rogatories is relevant to any of the three specific issues identified in the Commission's Memorandum and Order, dated February 13, 1978 LCf. Tr. 86-87), to which the inquiry in this proceeding is limited, or (b) that this information is even reasonably calculated to lead to the discovery of admissible evidence.
Cf.
10 C.F.R. 5 2.740(b) (1).
When no supplemental response is provided herein, GE's prior answer, including any unchanged. pplemental answers or responses, remainsThe original re previous su 10, 1978 (interrogatories and documents), and super-ceded by the response filed on November 30, 1978 (interrogatories).
i
- to the interrogatories propounded by Congressman Dellums under date of August 3, 1978 and received by counsel for the 7,1978 as follows:-/
Licensee on August 1.
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of a 4
particular response or issue in the Show Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
2.
If the heat generation rate in 1 above is greater than that assumed in the containment analysis (NEDO 12622, p. 9-84), would the resulting peak post accident containment pressure exceed design limits?
A:
The heat generation rate for the containment anal-ysis (NEDO 12622, p. 9-84) is given in response to interrog-atory 1; however,. interrogatory 1 postulates the loss of coolant from the spent fuel cooling system in addition to the reactor and pool.
Analysis has shown that the pool L
canal, reactor vessel and spent fuel storage tank remain
- /
The person who prepared the responses is identified in the attached affidavit.
L
't s intact through the design basis siesmic event.
Further, an additional water supply system (fuel flooding system) will be installed.
Thus, water is kept in the reactor vessel and spent fuel storage tank and the fuel remains covered at all times.
The calculation of containment pressure in NEDO 12622 was based on loss of coolant from the reactor and pool only.
However, loss of coolant from the opent fuel cooling system would be expected to have a negligible effect on contianment pressure.
See the, additional information in references 23-2, 36-4 and 51-1.
3.
Q:
15.
Please describe the in service inspection program for safety-related systems.
A:
The prior response remains unchanged except that the updated information relating to the prior response to this interrogatory is contained in references 36-10 and 42-27.
l l
l r
i 2/25/81 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 SUPPLEMENTAL RESPONSES TO FRIENDS OF THE EARTH'S INTERROGATORIES DATED SEPTEMBER 25, 1978 Pursuant to 10 C.F.R. 52.740(e) and the Licensing Board's Order, dated February 3, 1981, General Electric Com-pany (the Licensee or GE) hereby supplements its responses /
--*/
GE is furnishing these supplemental responses in the hope of expediting this proceeding.
In doing so, GE l
has in many instances gone beyond the requirements of 10 C.F.R. 5 2.740(e) and has purposefully limited its objections only to the most extreme cases.
Unless otherwise noted, GE does not concede either (a) that l
the information sought by all of the subject inter-rogatories is relevant to any of the three specific l
issues identified in the Commission's Memorandum and l
Order, dated February 13,1978 (Cf. Tr. 86-87), to which the inquiry in this proceeHTng is limited, or l
(b) that this information is even reasonably calculated l
to lead to the discovery of admissible evidence.
Cf.
10 C.F.R. 5 2.740(b)(1).
When no supplemental response is provided herein, GE's prior answer, including any remains unchanged. pplemental answers or responses,n e original response was file previous su 6, 1978.
.- to the interrogatories propounded by Friends of the Earth (F0E) under date of September 25, 1978 and received by 1978 as follows:- /
counsel for the Licensee on September 28, 1.
General - GE intends to rely upon those documents listed in Attachment A hereto in support of its case on issues 1 and 2 of the Show Cause Order.
For the convenience of the parties, the succeeding responses will cross-reference those documents on Attachment A upon which GE will place primary reliance in regard to the subject matter of a particular response or issue in the Show Cause proceed-ings.
Where additional available information not included on Attachment A will be relied upon, it will also be iden-tified below.
2.
Q:
5.
l What are the original piping design allowances for corrosion / erosion?
A:
'The original piping specifications are described in the specifications for the construction of the General Electric Test Reactor at Pleasanton, California, September 1957, R. M. Parsons Company.
Piping corrosion / erosion is i
j negligible and not.normally a design factor for aluminum 1
piping carrying demineralized water at low temperatures; l
l f
- /
The person who prepared the responses is identified in the attached affidavit.
l
i allowances for corrosion / erosion for the original piping design are not known.
3.
Q:
7.
Please make available copies of the original GETR l
piping designs.
A:
The piping drawings remain available pursuant to the prior response.
Please contact Del France (415-862-2211 x 4567) to make arrangements for inspection and copying pursuant to the prior response.
4.
Q:
8.
How does the GETE seismic analysis (EDAC) treat rigid-body motion?
A:
The rigid-body motion was considered in the seismic anslysis of the reactor building; the analytical model is described in EDAC report 117-217.03, which has been previously forwarded to all parties.
5.
Q:
11.
At what g value [ sic] would critical junctions in GETR pipes as modified exceed their material deformation capabilities?
Which junctions are i
these?
A:
The GETR piping restraints required to achieve and maintain safe shutdewn of the GETR in the case of the maxi-mum postulated seismic event that have been, or are being, l
installed are designed to assure that piping stresses are within allowable values for the design basis stesmic criteria.
The value of offset and vibratory ground motion at which these components would exceed their material
'i deformation capacities has not been determined.
Additional updated information relating to this interrogatory is contained in reference 60-5.
6.
Q:
15.
Describe in detail the loading factors for the points of penetration where each pipe enters the GETR containment.
A:
The prior response is unchanged except that updated information relating to the prior response is con-tained in references 23-2, 27-9 and 36-3.
7.
Q:
16a.
How are the original pipe supports mounted?
A:
The prior response remains unchanged except that updated information relating to the prior response is con-tained in references 60-5.
8.
Q:
16b.
Are the pipe mounts embedded?
A:
The prior response remains unchanged except that updated information relating to the prior response is con-l tained in references 27-18, 36 2, 36-11, 36-12, 42-7, 42-6, 42-15, 42-20, 42-21, 42-22, 42-23, 42-24, 42-28, 45-4, 51-11, 51-12 and 60-5.
9.
Q:
18.
How are the proposed modification piping supports l
going to be anchored?
l A:
The prior response remains unchanged except that updated information relating to the prior response is a
l
_..~
4 5-contained in the references listed in the response to interrogatory 16b above.
10.
3:
23.
Are there any access parts, windows, or manipu-lators that could be used for photographing pipes and supports in the GETR before or after modifica-tions are installed?
A:
The prior response remains unchanged except for correction of a typographical error.
Delete " personnel operations"; and insert " operations personal".
l l
i m
E rg-e 4
nu e,,- <
-e
s 2/25/81 ATTACIMEttr A TO LICEISEE'S SUPPIREhTAL RESPOISES 10 IhTERVE!DRS' DISCCWRY LISTI!G OF SUBMITTAIS MADE TO THE tRC FRud June 10, 1977 Subject Date 1.
Submittal in Response to Rcquest for Additional Infor-mation Re:
License Renewal - consisting of the follw-ing reports 6/10/77 ioad and Lifetime Study, G.E. IEDO 12624 Criteria and Bases Suamary for Structures, Piping System and Cotponents, EDic 117.08 Primary, Secondary & Pool Cooling Systens, Vol 1, EDAC 117.04 Pool and Canal Energency Recirculation Systeas, EDiC 117.05 Containment Shell & Relatal Structures and Contain-ment Shell Penetrations, EIAC 117.06 Equipment Building, miC 117.02 Miscellaneous System & Cocponents, miC 117.09 Invest: 4 tion of Alternates for Modifying the GEIR 6
- Building for Postulated Earthquake Shear Forces, EDAC 117.13 Analysis of Postulate.i Shipping Cask Drop Accidents l
within the Reactor Building at the GErR Facility, EDAC 117.12 Seismic & Geologic Investigations for the GETR l
Facility, Blume Seismic Analysis of the Reactor Building for the l
GEIR Facility, Blume Investigation ot Reactor Building for Potential Concrete Cracking Under Seismic loading, Blume I
Thermal, Pressure, Dead-load and Seismic Analysis of the Primary Cooling System at the GEIR Facility, Vol.1, Bitune
5 2.
Suhnittal in Response to Request for additional Infor-mation Re:
License Renewal - consisting of the follow-ing r gorts 8/24/77 GETR Safety Analysis Report, IE012622 GETR Environmental Infor::ution Report, !EDO 12623 Coastdown Hydraulic 01aracteristics for GETR, I;EDO 12625 Thermal-Hydraulic Performance of GETR Bnergency Cooling Systen, IE012626 A Coupled lieutron Kinetics-Thermal Hydraulics 2 del for the GEIR Using the REIAP-4 Cocputer Program, I;EDO 12627 Systen Hydraulic Analytical (SIRG) Model Used for Analyzing loss of Flow Events in the GETR, lied 0 12628 GErR Containment leak Test Study, IE012629 GEIR Nitichannel Core Model for Sinulating Internal 11atural Circulation, IEDO 12663 Proposed 11ew GEIR Technical Specifications 3.
Response to the IRC Order to Show Catse, 10/24/77 (consisting of the following) 11/11/77 Attachments tb.1-Sucmary of Geological Investigations 1.
Ibver:ber 9,1977 Ms:orandum
" Discussion of Evide1ce for the Existence of the Postulated Verona Fault liear the GETR Vallecitos Site."
2.
Addendum #1 to 11/9/77 Ms:orandum "Evidaice of the Postulated Verona Fault Ncar the GETR Vallecitos Site."
3.
Addendtzn #2 to 11/9/77 Ms:orandum
" Evidence of the Postulated Verona Fault Near the GETR Vallecitos Site."
4.
Addendum #3 to 11/9/77 Ma:orandum
" Tectonic Evidence of the Postulated Verona Fault 13 ear the GETR Vallecitos Site."
o
Attachment to. 2-Sumary of Seisnological and Structural Assessment Attachment !b. 3-Sunrnry of Thermal Hydra 211e Effects and End Conditions Attachmmt 16. 4-Sumarv of H>difications R(nuired Before Startup 6. 5-Strunty of Radi_ological Assessment 4.
Addendum II to Memorandum of 11/9/77 11/18/77 5.
Addendum III to Msorandum of 11/9/77 12/5/77 6.
Submittal consisting of 1 Attachment 12/16/77 Attach ent - Imtter from Lindvall, Richter &
Associates dated 12/9/77, and Study fcoa E[AC, Seismic Criteria and Basis for Structural Analysis of Reactor Building (Attachment 1) 7.
Submittal Consisting of 4 attachments 1/5/78 Attachmmt 1 - Photographs of the GEIR Foundation Excavation (Six photographs) - Preliminary logging Data for Trench
- 1 and Borings #1, #2, #3 (Final
~ data will be included with the final Reclogic report to be subtrdtted in approximately two weds) l - List of engineering and geologic l
roaorts on file in the office of the En-wia County Geologist which have bem reviewed to detennine their relevancy to the on-going geologic investigation.
i - Msorandum Report Issued by the California Division of hines and Geology, dated Deceber 22, 1977 8.
Submittal consisting of 1 Attachmet 1/6/78 Attachment Ib.1-Seismic Criteria for GETR Reactor I
R111 ding - URC Project Ib. 117-214, 1/6/78 1
i
9.
Submittel consisting of 1 Attachment 1/20/78 Attachment !b.1-Clarifying and/or Amplifying Information Contained in the
!bvsber 11, 1977 Submittal
- 10. Submittal consisting of 1 Attachment 1/30/78 Attachment tb.1-GETR R2el Temerature for Fuel Stored in the Canal in Air, D.C.
Brown, 1/21/78
- 11. Submittal consisting of 1 Attachment 2/3/78 Attachment ?b.1-Seismic Analysis of Reactor Building General Electric Test Reactor, Phase 1 EMC, 2/3/78
- 12. Submittal consisting of 1 Attachment 2/14/78 Attachmmt !b.1-Table, GETR Seismic Scrams 1958-1978
- 13. Submittal consisting of 1 Attachmenc 2/24/78 6.1-Update of Analytical and Modification Infonration, 2/24/78
- 14. Suhnittal consisting of 1 Attachment - Geologic Investi-gation of the General Electric Test Reactor Site, ESA, Feb. 1978 3/3/78
- 15. Submittal consisting of 3 Attachments 3/31/78 Attachment Ib.1-Determination of Vibratcry Loads to be Cmbined with Fault Displacement i
Ioads (EMC 117-217.01)
L 6. 2-Excerpts from References to Show Context of Quotes Used in EMC 117-217.01)
Attachmmt Ib. 3-Three reports under one cover (a) Effects of Earthquake Source and Transmis-sion Path Geology on Strong Ground Motion at GEIR Site (b) Ground Motion and Displacement on Hypo-thetical Vercna Fault I
(c) Geologic and Seisnologic Parameters of Ikar-Field Strong Motion Records
- 16. Submittal consisting of one attachment 4/7/78 Attachment Ib. 1-Addendum I to ESA Geologic Investigation
- 17. Submittal consisting of two attachments 5/1/78 6.1-S11 des Presented to IRC on 4/17/78 Attachment Ib. 2-(Part 1) Original Reactor Building Concrete Strength Data (taken at time of construction - 1957/1958)
(Part 2) Reactor Building Concrete Strength Data (taken in January 1978)
- 18. Submittal consisting of 13 attachments 5/22/78 Copies of Geological Documents referenced in ESA Gelogic Investigation Report 19.
Submittal consisting of one attachment 6/2/78 Attachmmt Ib.1 - EIRC Base II Report
- 20. Submittal consisting of 9 Attachments 7/5/78 Attachments - Miscellaneous Geology reports of l
Pleasanton Area l
- 21. Submittal consisting of one attachment 7/14/78 Attachment - ESA landslide Stability Report
- 22. Submittal consisting of 10 Attachments 7/20/78 l
Attachnents - 10 Update Reports to IRC Order to j
Show Cause l
l!
- 23. Submittal consisting of - Response to IRC Request for 7/26/76 L
Additional Information on the
?
Phase II Report
- 24. Submittal consisting of - Revised pages for previously submitted awC Reports 8/3/78 g
L
e
- 25. Submittal consisting of - Proposed Program for Addi-tional Geological Work 8/18/78
- 26. Submittal consisting of - Changed Program for Addi-tional Geological Work 8/27/78
- 27. Submittal consisting of - Response to IRC's 18 Questions 10/6/78
- 28. Submittal consisting of - Six Sets of Geological Trench Ings 11/2/78
- 29. Submittal consisting of - Iogs of Trenches at or thar VIC 11/29/78
- 30. Submittal consisting of - letter Anplifying and Clarifying Description of Two Redundant Control Units 1/22/79
- 31. Submittal consisting of 3 Attachments:
2/28/79 - List of Submittals Made to the IRC Attachmmt 2 - Geological Investigation-Phase II, General Electric Test Reactor Site, Vallecitos, California - Evaluation of Seismic Hazard at the Geeral Electric Test Reactor Site, Alameda County, California by Richard H. Jahns
- 32. Sulxnittal consisting of - Errata sheets for the Geological Investigation-Phase II report 3/13/79
- 33. Submittal consisting of 1 Attachment 3/27/79 Attachmet - Responses to all cements which were made by the IRC or their consultants in the meeting of 3/20/79 with General Electric Coupany
- 34. Submittal consisting of 1 Attachment 4/13/79 1
Attachment - Probability Analysis of Surface Rup-ture Offset Bmeath Reactor Building -
Geeral Electric Test Reactor Report, EMC-117-217.13 t
i
l, l
1-l l
l
- 35. Submittal consisting of 1 Attachmmt 6/25/79 Attachment - Responses to questions raised regarding the Geological Investigation-Phase 11 Gmeral Electric Test Reactor Site Report
- 36. Submittal consisting of 1 Attachment 7/9/79 Attachment - Responses to questions in letter dated 6/27/79, R. W. Reid (IRC) to R. W.
Darmitzel (GE) regarding structural nodifications
- 37. Submittal consisting of letter to Chris Nelson (IRC) from R. W. Darmitzel (GE) regarding USGS Professional Paper #943.
7/12/79 i
- 38. Submittal consisting of letter to Chris lklcon (IRC) from R. W. Darmitzel (GE) regarding C&fG Report 8/21/79 - Copy of CDG Special Publication #56
(
- 39. Sutraittal consisting of letter to Chris tklson (IRC) from R. W. Darmitzel (GE) regarding Radiocarbon j
Age Data 8/21/79 l
l - Intter dated !bysber 10, 1978 from Krueger Enterprises, Inc. (Geochron Iaboratories to GE) l - Imtter dated Ibvenber 15, 1978 from Teledyne Isotopes to GE l - letter dated Decenber 11, 1978 from Krueger Ehterprises, Inc. to GE
- 40. Submittal consisting of letter to Robert W. Reid (IRC) from R. W. Darmitzel regarding schedule of submittal of General Electric's responses to request for additional information.
8/23/79 l
- 41. Submittal consisting of letter to Chris Nelson (IRC) l from R. W. Darmitzel (GE) regarding GE responses to Dr. Slennons letters of August 8 and 9,1979
~
to Dr. Robert Jackson of the IRC 9/4/79 l
l
9 4
- 42. Sulxnittal consisting of letter to Robert W. Reid (IRC) from R. W. Darmitzel (GE) regarding responses to Itens #6 and #7 of Robert Reid's letter dated June 27,1978 and responses to 28 questions con-tainal in Robert Reid's letter dated July 9,1979 9/5/79
- 43. Submittal consisting of Ictter to Chris 13elson (IRC) from R. W. Damitzel (GE) regarding Dr. Roy Shleton's responses to Dr. David Slemons August 9,1979 letter to Dr. Robert Jackson of the IRC 9/11/79
- 44. Submittal consisting of Imtter to Chris llelson (IRC) fran R. W. Damitzel (GE) regarding Correction of an Error in the Submittal made by GE to the IRC dated 9/4/79 9/12/79
- 45. Submittal consisting of Imtter to Robert W. Reid (IRC) from R. W. Damitzel (GE) in response to request from R. W. Reid (IRC) to R. W. Damitzel (GE) dated August 16, 1979 9/21/79 I
- 46. Submittal consisting of letter to Darrell G. Eisenhut (IRC) fran R. W. Darmitzel regarding attached rq> ort
" Additional Probability Analyses of Surface Rupture Offset Beneath Reactor Building General Electric Test i
Reactor" (JBA-111-013-01 dated March 12, 1980) 3/12/80
- 47. Submittal consisting of letter to Darrell G. Eisenhut l
(IRC) from R. W. Darmitzel in response to the IRC's request for an additional calculation using a soil age of 40,000 years in relation to the additional probability analysis of ' surface rupture offset beneath the GETR building 3/17/80
- 48. Sulxnittal consisting of Imtter to Darrell G. Eisenhut (IRC) from R. W. Darmitzel regarding " Dip Angle for General Electric Test Reactor (GEIR) Site Shears" 3/31/80
- 49. Submittal consisting of Istter to Darrell G. Eisenhut (IRC) fran R. W. Darmitzel regarding " Response to Questions Raised by the GEIR Subcomittee of the Advisory Comittee on Reactor Safeguards Consultants" 1
and a report by Bruce A. Bolt and Roger A. Hansen dated March,1980, " Seismicity of the Livernore Valley in Relation to the General Electric Vallecitos Plant 4/14/80
- 50. Submittal consisting of Imtter to Darrell G. Eisenhut (IRC) from R. W. Damitzel regarding " Proposed GEIR landslide Investigation" 4/17/80 I
- 51. Submittal consisting of Imtter to Darrell G. Eisenhut
(!RC) from R. W. Darmitzel regarding response to structural questions raised by the IRC (Part I) 4/23/80
- 52. Submittal consisting of letter to Darrell G. Eisenhut (IEC) frm R. W. Darmitzel regarding " Analysis of the Gmeral Electric Test Reactor (GETR) Foundation Excavation Photographs" 4/29/80
- 53. Submittal consisting of letter to Darrell G. Eisenhut (tRC) from R. W. Damitzel regarding " Analysis of Slip Rate of Shear Surfaces at the General Electric Test Reactor (GETR) Site" 4/29/80
- 54. Suhnittal consisting of IAtter to Darrell G. Eisenhut (tRC) from R. W. Darmitzel regarding " Responses to IRC Questions on ' Additional Probability Analyses of Surface Rupture Offset Beneath Reactor Building -
General Electric Test Reactor'"
4/30/80
- 55. Submittal consiiting of letter to Darrell G. Eisenhut (IRC) from R. W. Darmitzel and two enclosed reports:
4/30/80 (1) " Probability Analysis for Cocbined Surface Rupture Offset and Vibratory Ground Fbtion -
General Electric Test RC.or" (JBA-111-014-01 dated April 29,1980)
(2)
"A Seis:tological Assessment of the Probable Expectation of Strong Ground Motion at the General Electric Test Reactor Site" by Robert L. Kovach (April 28,1980)
- 56. Submittal consisting of latter to Darrell G. Eisenhut (IRC) from R. W. Darmitzel regarding response to structural questions raised by the IRC (Part II) and four enclosed reports:
5/9/80 (1) " Review of Seismic Design Criteria for the GETR Site" (EAC-117-254.03 dated April 30,1980)
(2) " Additional Investigations to Determine the Effects of Combined Vibratory Motions and Surface Rupture Offset Due to an Earthquake on the Postu-lated Verona Fault" (EEAC-117-253.01, Rev.1, dated May 8,1980)
(3) " Additional Investigations to Determine Effects of Vibratory Motions Due to an Eartlquake on the Calaveras Fault" (EIMC-117-253.02 dated April 30, 1980)
(4) "Conservatisms in the Seismic Evaluations of the GEIR Reactor Building" (E[EC-117-254.02 dated April 30, 1980)
- 57. Submittal consisting of Letter to Robert A. Clark (IRC) from R. W. Darmitzel in response to Clark's letter of June 10,1980, requesting additional information justify-ing ability of the GEIR to meet the loadings associated with the design bases in the IRC's 5/23/80 evaluation 6/24/80
- 58. Submittal consisting of letter to Darrell G. Eisenhut (IRC) from R. W. Darmitzel regarding " Landslide Investigation Program Schedule" 7/7/80
- 59. Submittal consisting of Letter to Darrell G. Eisenhut (IRC) from R. W. Darmitzel with enclosed presentation material used by 1E at the June 16-17,1980, and -
Ibvember 14, 1979, ACRS GETR Subconmittee Meetings 7/16/80
- 60. Submittal consisting of lat.rar to Robert A. Clark (IRC) from R. W. Darmitzel, "InWtigation of the Ability of the GETR to meet the loados Associated with the Design Basis Specified in the 6*ety Evaluation Report of May 23,1980". Includes enclocures as follcus:
7/17/80 I
(1) "Sunmary Report - Structural Seir,mic Investiga-l tions of GETR" (EDAC-117-258.02 dated July 8,1980)
(2) " Additional Investigations to Determine Effects of Vibratory &tions Due to an Earthquake on the Calaveras Fault" (IIRC-117-253.02, Rev.1, dated June 30, 1980)
(3) " Expanded Description of Soil Pressure Analyses" (EDAC-117-253.01, Rev.1, Suppl.1, dated June 27,1980)
(4) " Evaluations for 0.6g Ground Acceleration Case" (EIRC-117.-253.01, Rev.1, Suppl. 2, dated June 30,1980) i:
(5) " Review of Seismic Adequacy of Piping and Equipment l
- GETR" (EDAC-117-258.01 dated June 30,1980) li (6) "Conbined Parameter Probability Analysis - GETR" (JBA-111-017-02 dated July 18,1980) i
61. Submittal consisting of:
7/25/80 t
(1) Imtter to Darrell G. Eisenhut (IRC) from D. L.
Gilliland dated July 25,1980, " Slope Monitoring Program", and attached Msorandum to D. L.
Gilliland frm R. C. Harding dated July 14, 1980, "GETR Iandslide Monitoring Systen" (2) latter to Darrell G. Eisenhut (IRC) from D. L.
Gilliland dated July 25,1980, " landslide Stability Investigation of the GETR Site", and attached Mmorandum to R. W. Darmitzel from D. M.
Yadon dat J July 22,1980, "Sunnary of Field Exploration Ihase, GETR landslide Investigacion" (3) letter to Darrell G. Eisenhut (IRC) from D. L.
Gilliland dated July 25,1980, " Errata Sheet for EDAC Report 117-253.01, Rev.1, Suppl. 2",
and attached Errata Sheet to change Figure 6 j
of letter to Robert A. Clark (IRC)
Submittal consisting,tzel, " Calculated 50-Year Organ Doses 62.
from R. W. Darmi at the Vallecitos Ibclear Center Site Boundary from 10(T/.
Release of the Isotopes in the GETR Pool, Canal and Primary Water", with attached letter to W. H. King from Ben litrray dated August 5,1980, Table 1 (Total Curie levels in GETR Waters During Ibrmal Operations) 1 1-and Table 2 (50 Year Organ Doses at Site Boundary for l
Release of Isotopes in GETR Wacers) 8/6/80 l
l
- 63. Submittal consisting of letter to Darrell G. Eisenhut l
(IRC) from R. W. Darmitzel, " Soil Shear Modulus and l
Bearing Capacity Values for the Soil Bmeath the GETR",
l with attached letter to Dwight Gilliland from Garrison l
Kost (EDAC) regarding GETR Soil Properties, EDAC Project 1
117-258; and attached reference letter to Gary Kost from Richard L. Meehan (ESA) regarding Subgrade Soil Values, GETR, both dated August 8,1980 8/13/80
- 64. Subnittal consisting of letter to Darrell G. Eisenhut (tRC) from R. W. Darmitzel, " Reliability and Response Action Time for the GEER Scram System", with attached 8/14/80 responses to:
L Comnent 1: Discuss the Reliability of the scram circuitry l
L_
9 Coment 2: Discuss hw the scram systs operates in time to conplete the necessary scram action before consequential accelerations are reached
- 65. Submittal consisting of letter to Robert A. Clark (IRC) from R. W. Darmitzel, " Addition of Iodine Isotopes to the Calculated 50-year Organ Doses at the VIC Site Boundary from 1007. Release of the Isotopes in GEIR Pool, Canal, and Primary Water", with attached Tables 1 and 2 8/28/80
- 66. Submittal consisting of letter to Darrell G. Eisenhut (IRC) from R. W. Darmitzel with attachal report, "GETR landslide Stability Analysis" (ESA report dated Augnst, 1980) 8/29/80
- 67. Submittal consisting of Imtter to Robert A. Clark (IRC) from R. W. Darmitzel, " Response to Additional for the GEIF" quest Regarding Seismic Scram Systs Information Re 9/16/80
- 68. Submittal consisting of latter to Robert A. Clark (IRC) from R. W. Darmitzel, " Responses to Questions Regfrd-ing the GETR Riel and Experimental Capsules" 9/23/80
- 69. Submittal consisting of letter to Robert A. Clark (IRC) from R. W. Darmitzel with attached, " Response to Additional Information Request Regarding Seismic Scram Systs for the General Electric Test Reactor" 10/13/80
- 70. Submittal consisting of Ietter to Robert A. Clark (IRC) from R. W. Darmitzel, " Responses to Information Request Regarding the Riel Flooding Systs Flow Rates - GETR" 10/27/B0
- 71. Submittal consisting of Imtter to Robert A. Clark (IRC) from R. W. Darmitzel with attachments:
10/31/80 (1) " Attachment to Response to Additioaal Informa-tion Request Regarding Bearing Capacity Values for Soil Beneath the GETR" (EDAC, dated 10/31/80) 10/31/80)y Effects" (R. L.
(2) " Review of GETR Soil Propert Meehan, ESA, dated
- 72. Submittal consisting of letter to Darrell G. Eisenhut (PRC) from D. L. Gilliland with attachment:
" Analysis of the Subgrade Rupture Mechanism at the GETR" (R. Meehan/
M. Traubenik dated Deceber,1980) 12/3/80
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Docket No. 50-70 GENERAL ELECTRIC COMPANY
)
)
Operating License (Vallecitos Nuclesr 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 Commission 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 l
Commission l
Jeffrey W. Knight, Esq.
Washington, D. C. 20555 Friends of the Earth 124 Spear Street Atomic Safety and Licensing San Francisco, Cal'.lornia 94105 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.
M General Electric Company Georg. Edgar Nuclear Energy Division Attorney for 175 Curtner Avenue General Electric Company San Jose,' California 95125 (Mail Code 822)
Dated:
February 25, 1981 i
BIOGRAPHICAL SKETCH -- RICHARD H. JAHNS Born Los Angeles, California, March 10, 1915. Trained at California Institute of Technology (B.S. 1935, Ph.D. 1943) and Northwestern University (M.S. 1937). Geol 6 gist with-U. S. Geological Survey 1937-65 (fril-time 1939-
- 46) and consultant to USGS since 1967. Taught geology at Caltech 1946-60, and at The Pennsylvania State University 1960-65. Professor of Geology and Dean, School of Earth Sciences, at Stanford University 1965-79; Professor of Geology and Applied Earth Sciences since 1979.
Member of numerous scientific and professional societies, including American Geophysical Union (Fellow) American Institute of Professional Geologists (Charter' Member), California Academy of Sciences (President, 1978- ), Geological Society of America (President, 1970-71), Association of Engineering Geologicts, l
Seismological Society of America, and Society of Economic Geologists. Registered Geologist and Certified Engineering Geologist, State cf California. Member of California State Seismic Safety Commission; Desert Plan Advisory Council and National Public Lands Advisory Council, U. S. Bureau of Land Management. Past service with California State Mining and Geology Board (Chairman, 1972-74);
Advisory Group on Engineering Considerations and Earthquake Sciences, California Legislature Joint Committee on Seismic Safety; Governor's Science Advisory Board, California; Geologic Hazards Advisory Committee, California Resources Agency; Seismic Advisory-no;rd. City of Redwood City (Chairman 1970-71); Engi-neering Geologists Qualifications Board, City of Los Angeles (President, 1958-60);
Mayor's Commit ae on the Geologic Environment, City of Los Angeles (Chairman, 1965-66); and Task Force on Earthquake Hazard Reduction, Office of Science and 4
Technology. Distinguished Alumnus Award, California Institute of Technology, 1970.
Author or co-author of more than a hundred scientific monographs and papers on petrology, mineralogy, and economic, engineering, glacial, and structural geclogy. Consultant to Atomic Energy Commission, National Aeronautics and Space Administration, National Science Foundation, U. S. Bureau of Reclama-tion, public utilities, and private organizations. Major engineering projects have included tunnels and dams of Metropolitan Water District of Southern Cali-fornia, dams of Los Angeles Department of Water and Power and U. S. Water and Power Resources Service, and power plants of Pacific Gas and Electric Company and Southern California Edison Company.
Chief professional interests: geology and the training of geologists.
l l
RICHARD G. HARDING Vice President and Principal Engineering Geologist Earth Sciences Associates 1
Mr. Harding is an Engineering Geologist experienced in environmental and planning geology, ground water geology, construction geology, and design investigations for large engineering projects.
He has specialized in the organization of geologic field investigations -and exploration for dams, tunnels and aqueducts, highways, and power plants. In addition, he has provided consulting services for contractors on dewatering projects, pre-bid geologic investigations, construction problems and claims involving
-geotechnical considerations, and quarry and construction materials evaluations.
Mr.
Ilarding is also Geologic Consultant to the City of San Carlos and advises the City on i
g j
geologic hazards considerations.
l He has performed detailed geologic investigations for four Pacific Gas and Electric Company power plant sites in central and northern California, which involved the mapping and evaluation of seismic and geologic hazards. He also has supervised the compilation of geologic and hydrologie data for studies of large areas in Michigan, Texas, Colorado, Wyoming, Idaho, Utah, Nevada, Montana, Arizona, New Mexico, and California. He was j
involved with seismotectonic stun? of Arizona and New Mexico for the proposed SOHIO pipeline routing studies. Recently he directed geologic and seismic' hazards investigations for a commercial test reactor and 3 resented results at regulatory hearings.
I Mr. Harding has worked on subwa) systems in Washington, D.C., New York, Pennsylvania, and San Francisco; tunnels in CGrado, Arizona, California, and Virginia; large dams in California, Utah, Missouri, and Washington; power plant sites in Utah, Washington, California, and Missouri; and missle sites in North Dakota.
j Education.
E A., Geology, University of California, Riverside,1962.
f Post-graduate study, Geology, University of California, Riverside.
Summer field work, U.S. Geological Survey 1961 and 1962 mapping geologi_c quadrangles in Connecticut and the Sierra Nevada.
. Professional ' Registered Geologist No.116, State of California, with Affiliations Certification as Engineering Geologist No. 229.
Registered Geologist and Engineering Geologist No. 212, i
State of Oregon Association of Engineering Geologists, past Chairman of San Francisco Section.
Society of Mining Engineers of the American Institute of Mining, Metallurgical, and Petroleum Engineers.
Certified Professional Geological Scientist No. 3609.
e g.
Earth Sciences Associates
RICHARD L. MEEHAN President and Principal Civil Engineer Earth Sciences Associates Mr. Meehan is a Civil Engineer specializing in geotechnical engineering who has seventeen years of experience in directing geotechnical investigations for a wide variety of engineering projects, including earth and rock fill dams, nuclear and fossil fuel power plants, building foundations, and other major engineering struc-tures throughout the United States and on several overseas projects.
He is a Consulting Professor of Earth Sciences at Stanford University, where he has developed, and regularly teaches, graduate courses in professional practice of engineering geology and geotechnical engineering. He currently holds a grant from the Hoover Institution to study the role of scientists and engineers in the planning and regulatory process, and nas written on that subject for several newspapers and in a book scheduled for publication in 1981.
During the last decade, Mr. Meehan has been team leader on the analysis of the seismic stability of several existing dams, including Lake Almanor Dam, Butt Valley Dam, Crano Valley Dam, Lake Francis Dam, Woodward Dam, Palos Verdes Reservoir, Balboa Reservoir, Phcenix Lake Dam, Vermillon Dam, and Peters Dam.
He has also designed new or raised embankments for Auld Valley Dam, Mallard Reservoir, Alegria Canyon Dam, and Peters Dam.
Education B.S., Civil Engineering, Massachusetts Institute of Technology,1961.
M.Sc., D.I.C. Soil Mechanics, Imperial College, University of London,1966.
Post-graduate study, College of Environmental Design, University of California, Berkeley.
Professional Registered Professional Civil Engineer, California, Affiliations Hawaii, Nevada, Arizona, Colorado.
Water Rights Surveyor, Nevada.
American Society of Civil Engineers Royal Geographical Society.
Seismological Society of America.
American Geophysical Union.'
Earthquake Engineering Research Institute.
Consulting Professor, Stanford University e
Earth Sciences Associates
Jak R.Donicmin Chairman of tha Occrd t 7-Education B.S., Civil Engineering, University of Wash-ington,1940 M.S., Civil Engineering, University of Wash-Ington,1940 Sc.D., Mass. institute of Technology,1942 Registration Civil Engineer, State of California Memberships American Concrete Institute i
i American Society of Civil Engineers Earthquake Engineering Research Institute Engineering Decision Analysis Company, Inc. (1974 to 1979)
As President, Dr. Benjamin served as a Publications senior consultant on many projects and was Sta tically Indetermina te Struc tures, McGraw-actively engaged in the practical applications Hill,1959.
of probabilistic methodololes to systems ana!ysis and design, includin g risk analysis.
Probability, Statistics, and Decision for Civil Engineers, (with C. Allin Corneil), McGM,w-Hill,1970.
Stanford University (1948 to 1973)
As a Professor of Structural Engineering, President's Medalist, University of Washing-Dr. Benjamin developed and taught courses ton on the application of probabilistic methods and decision theory in civil engineering.
Alfred M. Freudenthal Medal, ASCE While at Stanford he co-authored the stan-dard text and reference on probabilistic Committees methods and decision theory in civil angl-neering. He was the recipient of several NSF ACl Committee 348, Structural Safety grants for research in the field of applied pro-ACI Committee 435, Deflection of Concrete babilistic methods, particularly as they relate Building Structures to problems in structural engineering and ACI Committee 442. Response of Buildings to
-sarthquakes.
I Lateral Forces in the period 1951 to 1956 he conducted S
ewe alan laka% resead on ASCE Task Committee on Lifeline Earth-shear walls and shear wall structures spon-i quake Engineering sored by Sandia Corporation and the United States Army. Fourteen reports and four Experience papers were published on this work.
Jack R. Ber.jamin and Associates,Inc.
(since 1979)
Other Experience As Chairman of the Board of Directors Dr.
Dr. Beajamin has had extensive profes-Benjamin has been in responsible charge of sional experience with his own office, as a many JBA projects, including the develop-consultant to private engineering firms and ment of statistical decision methodologies for governmentaf agencies.
i l,
mitigating multiple hazards on a large municipal utility's water supply system, and Jack R. Benjamin & Assoclaies,Inc.
the upgrading of U.S. Naval Shore Facilities Consulting Eng'neers 9
to withstand natural and man-made hazards.
i Jchn W. Road President h
Education m
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i B.S., Forest Engineering, Oregon State Uni-versity,1963 M.S., Structural Engineering, Stanford Uni-versity,1964 f
Ph.D.,
Structural Systems Engineering, A-I.b l
Massachusetts Institute of Technology,1972 k
+
Registrations Civil and Structural Engineer, States of Call-fornia, Oregon and Nevada Engineering Dec!sion Analysis Company, Inc. (1975 to 1979)
Memberships He served as Project Manager for the sels-American Society of Civil Encineers mic and fire safety evaluation of the Valley Earthquake Engineering Research Institute Medical Center Hospital in San Jose, Cellfor-nia. Structural, architectural, mechanical, Professions! Awords to develop required modifications to qualify The 1975 Raymond C. Reese Research Prize, the hospital buildings for the current Califor-American Society of Civil Engineers niacodes.
j The 1978 Theodore R. Higgins Lectureship As Project Manager, Dr. Reed conducted Award, American Institute of Steel Construc-an analysis of high density fuel storage racks which were installed in two existing nuclear tron power plants. Nonlinear sliding and tilling analyses were performed to determine the Committees structurel behavior during OBE and SSE mo-ns.
Editor, Motion Perception and Tolerance Chapter, Council on Tall Buildings and Urban Habitat Monograph URS/Blume Engineers,Inc.
(1972 to 1975)
Risk Assessment Committee for the Applied Technology Council " Tentative Provisions of Dr. Reed was Manager of the Les Vegas Seismic Regulations for Buildings" office for two years. His duties included
)
ASCE Working Committee for the Seismic sp nse pr je is and the building safeiy pro-Analysis of Nuclear Power Plant Safety Class gram for the effects of ground motions from Structures the Nevada test site underground nuclear explosion program.
Other Experience Jack R. Benjamin and Associates,Inc.
(*I""
fossor at MIT (1971 to 1972) where he taught i
As Principal-in-Charge, Dr. Reed per-civil engineering courses, performed re-formed analysis for calculating the probabili-search on damage caused by the 1971 San ty of a surface rupture offset beneath a Fernando earthquake, and participated in de-nuclear test reactor. He also served as con-veloping optimum seismic protection for new
)
sultant on structural issues in regard to the building construction in eastern metropolitan reatart of operations and made technical pre-areas.
sentations tothe USNRC and ACRS.
Dr. Reed conducted a check of the atross analysis for the primary oo.itainment of a Jack R. Ben)omin & Assoclefes,Inc.
Mark i BWR nuclear power pI*,1'or A/E spe-Consulting Engineers 3
cifications and for ASME code requirements, f
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r i
y EARTHQUAKE SCIENCES AND ENGINEERING LINDVALL, RICHTER & ASSOCIATES 825 COLORADO BOULEVARD, LOS ANGELES, CAltFORNIA 90041 o TELEPHONE (213) 254-5259 CURRICULUM VITAE CHARLES F. RICHTER Birth date:
April 26, 1900; near Hamilt,n, Ohio Business address:
Lindvall, Richter & Associates 825 Colorado Boulevard Los Angeles,. California 90041 Telephone:
213/254-5259 Home address:
594 Villa Zanita Altadena, CA 91001 Telephone:
213/797-4115 Education:
A.
B.
Stanford University, 1920 Ph.D.
California Institute of Technology, 1928 Fellowships:
American Geophysical Union, Geological Society of America, Seismological Society of America, l
Royal Astronomical Society (London).
Fields of research:
Seismology, especially of California, l
Geography of earthquakes, Instrumental earthquake magnitude scale.
Professional societies:
Seismological Society of America (Past President),
Geological Society of America, American Geophysical Union, Association of Engineering Geologists, Royal Astronomical Society (London),
Royal Society of New Zealand, l
3 CURRICULUM VITAE CHARLES F. RICHTER (page 2)
Employment:
Research assistant, Carneg?' Institution of Washington, Seismological Laborator3. Dasadena, 1928-1936.
Assistant professor of seism,.
, California Institute of Technology, 1937-1947; a.4ociate professor, 1947-1952; professor, 1952-1970; professor emeritus, 1970-present.
Member, Board of Directors, Lindvall, Richter & Asr,ociates.
Fulbright research scholar, Tokyo University, 1959-60.
Registered geologist and registered geophysicist, State of California.
Former Member:
California State Board of Registration for Geologists and Geophysicists.
_ Attorney-General's Environmental Task Force (State of California)
Founder of THE RICHTER 'L GNITUDE SCALE used worldwide to measure the size of earthquakes.
STRUCTURAL MECHANICS ASSOCIATES 1183 BORDEAUX DRIVE, SUITE 13 SUNNYVALE. CA 94088 RESUME Dr. Harold Durlofsky, Associate EDUCATION:
Drexel U., Phila., Penna., B.S. in C.E., 1957 San Jose State U., San Jose, Calif., M.S. in C.E.,1965 Stanford U., Stanford, Calif., Ph.D. in Ae.E.,1970 EXPERIENCE:
Seventeen years experience in the areas of stzess analysis, structural analysis, and structural dynamics. This experience includes development of both analytical and finite elenent analysis techniques, and applications in the civil, aeronautical and mechanical ergineering fields.
Areas of extensive experience include s
. Developnent of conputer codes based on Finite Element and Rayleigh-Ritz methods.
. Static and dynamic analysis of piping systens and power plant structures.
. Developnent and application of stress analysis techniques for fiber-leinforced, conposite structuna.
V
. Analysis of aircraft and missile structures.
. Analysis of gears and mechanisms.
(
. Application of ASME Pressure Vessel code.
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REGISTRATION:
Registered Civil Engineer, State of California
GARRIS0N KOST Vice President, Engineering Decision Analysis Company, Inc.
Education B.S. - Civil Engineering, Stanford University (Magna Cum Laude), 1961 M.S. - Structural Engineering, Stanford University, 1962 Degree of Engineer - Structural Engineering, Stanferd University, 1963 Ph.D. - Structural Engineering, Stanford University, 1972 Registration Civil Engineer, California (16842); Str"ctural Engineer, California (1659)
Professional Experience Dr. Kost has extensive experience in the analysis and design of structures, piping systems, and mechanical and electrical equipment for the effects of natural and man-made hazards.
He has been responsible for seismic investigations of numerous types of facilities with emphasis on nuclear power plants and other installations in the nuclear field, such as test reactors, nuclear fuel fabrication and reprocessing facilities, and research facilities.
He has extensive experience in the representation of soil-structure interaction effects and finite-element techniques, and has been responsible for the analysis of above-ground, partly embedded and buried structures.
By means of research for his dissertation and his experience with these analyses, he also has a solid background in nonlinear analysis techniques and the effects of nonstructural components on building response.
l l
He has been responsible for analyses for explosion, hydrogen burn, and other pressure wave phenomena, as well as hydrodynamic effects.
In addition, he as been responsible for the independent review of the analyses and designs of numerous nuclear and related f acilities, including review of l
the adequacy of seismic designs and seismic design criteria of 19 nuclear power plants and I fuel reprocessing plant fer the USAEC Directorate of Licensing.
Dr. Kost has supervised thermal stress and seismic analyses of l
piping systems and components, and was responsible for the development of a l
comprehensive computer program for the static and dynamic analysis of piping systems which is now marketed worldwide.
He has conducted evaluations of structures for effects of ground motions induced by underground nuclear explosions, and for aircraft crash, cask drops and other missile impact effects.
Included in the above investigations have been analyses as well as development of design modifications to resist extreme loadings.
In addition, he was responsible for develcpment of structural analysis programs and evaluation of structural response data to determine the dynamic response of structures to l~
sonic boom shock waves. Dr. Kost has also designed public and commercial y
structures including schools, hospitals, office buildings, parking garages, warehouses, and shopping centers. These designs consisted of steel and concrete frame, shear wall, precast and prestressed concrete, and wood single-and multistory buildings.
1 h
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SUPAARYOFR$SUMk FOR ROBERT L. K0VACH EDUCATION:
Geophysical Engineer 1955, Colorado School of Mines; MA 1959 in Geology, Geophysics, Columbia University; PhD 1962 in Geophysics, California Institute of Technology REGISTRATION:
California (Registered Geophysicist #100)
PROFESSIONAL EXPERIENCE:
Professor of Geophysics: Stanford University, Stanford, California Associate Dean for Research:
Stanford University, Stanford, California Visiting Scientist:
California Institute of Technology, Weizmann Institute of Science, University of Hawaii, Japan Society for the Promotion of Science Senior Scientist: Jet Propulsion Laboratory, Pasadena, Ca-lifornia Research Assistant in Seismology:
California Institute of Technology Dr. Kovach's experience includes serving as a Principal Investigator for seismic experiments on the Apollo moon missions; President, Seismology section, American Geophysical Union; California Earthquake Prediction Evaluation Council; John Sinon Guggenheim Fellow; NASA Medal for Exceptional l
Scientific Achievement; Consultant to -- Engineering Decision Analysis l
Company and California Public Utilities Commission ORGANIZATIONS:
American Association for the Advancement of Science l
American Geophysical Union l
Geological Society of America New York Acadeny of Sciences l
Seismological Society of knerica l
Sigma Ganna Epsilon l.'
Society of Explcration Geophysicists P
Tau Beta Pi P
ROLAND L. SHARPE Principal and Senior Consultant, Engineering Decision Analysis Company, Inc.
Education B.S.E. - Civil and Structural Engineering, University of Michigan M.S.E. - Structural Engineering, University of Michigan Registration California, Civil Engineer, (CE 8352), and Structural Engineer, (SE 745)
Professional Experience Mr. Sharpe has 33 years experience in structural and earthquake engineering and design.
He serves as principal in charge and/or senior consultant on numerous projects including nuclear, industrial, medical and research facilities.
He was project director of a federally-sponsored project to develop nationally applicable seismic design recommendations for buildings and equipment.
Prior to the founding of EDAC he was executive vice president for URS John A.
31ume & Associates, a firm specializing in earthquake and structural engineering services for commercial, industrial, and nuclear f acilities. He also served for five years as a principal consultant to the United States Atomic Energy Commission on the seismic safety of nuclear power plant structures and equipment and was principal in-charge for research on structural response to sonic booms.
In addition he was responsible for the design of over $200 million worth of buildings and structures.
Mr. Sharpe directed and administered all master planning, criteria development, preliminary engineering design, and detailed architect-engineering design for the Stanford Linear Accelerator Center project.
Earlier Mr. Sharpe was responsible for the structural engineering of numerous large projects and supervised structural dynamic research projects for the State of California.
He was also involveo in determining the structural dynamic response of underground structures to blast and seismic forces at TITAN and ATLAS bases.
He is active in several professional organizations and has served the Structural Engineers Association of California as a member of the Board of Directors and chairman of the Seismology Committee (1972-74).
He is a member of the ASCE Structural Division Executive Committee, and served as a member of the Board of Directors of the Earthquake Engineering Research Institute.
He is author or co-author of more than 50 technical papers and publ1 ations in addition to over 40 presentations at professional meetings.
DWIGHT L. GILLILAND General Electric Company EDUCATION:
BS Electrical Engineering, Kansas State University,1952 PROFESSIONAL:
Professional Engineer Certificate of Registration No. NU 1665 California,1977 EXPERIENCE:
Mr. Gilliland has been employed by General Electric Company since 1953, serving in several engineering and operations management positions. His first assignment was in the Aircraft Nuclerr Propulsion Department where he worked in shielding experimentation an/. instrumentation at the Oak Ridge National Laboratory and later supervised the installation and checkout of nuclear power plant instrumentation at the Idaho Test Station. He also managed the Shield Test Facility thera.
It utilized a pool reactor and advanced instrumentation for the testing of experimental reactor shield configurations.
From 1961 to 1965, he managed in succession, two re-entry vehicle projects at Vindenburg Air Force Base for the Re-entry Systems Department.
In 1963, Mr. Gilliland joined the Nuclear Thermionic Power Operations where he was responsible for testing thermionic devices and for the design of the thermionic reactor experiment.
From 1970 to 1973, he managed the development, design and requisition engineering and process development of nuclear sensors, penetration seals, radiation monitoring and source products in the Nuclear Instrumentation Department. Since 1973, Mr. Gilliland has managed the operations and plant engineering for the General Electric Test Reactor and the Nuclear Test
. Reactor. He also manages the activities related to GETR License Renewal.
4 e
5 i-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
Docket No. 50-70
)
GENERAL ELECTRIC COMPANY Operating License No. TR-1 (Vallecitos Nuclear Center -
(Show Cause)
General Electric Test Reactor)
)
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 execute the foregoing Supplemental Responses to the intervenors' discovery.
2.
That the above-mentioned and attached Supplemental Responses to the intervenors' discovery are true and correct to the best of his knowledge and belief.
D4fjht L. Giy111and Subscribed and sworn to before me this dMy M day of
, 1981.
hM
~ L // (NotaryT F /
My Commission expires S/A-(4 GNENIAYuI$,
OFFICI AL SEAL MARY ELLEN HIGHFIELD
. m,mi