ML20003D584
| ML20003D584 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 03/25/1981 |
| From: | Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20003D580 | List: |
| References | |
| ISSUANCES-SC, NUDOCS 8103270699 | |
| Download: ML20003D584 (8) | |
Text
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O 03/25/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0f!IC SAFETY AND LICENSING BOARD In the liatter of
)
)
GENERAL ELECTRIC C0.
)
Docket No. 50-70
)
(Show Cause)
(Vallecitos Nuclear Center -
)
General Electric Test Reactor,
)
Operating License No. TR-1)
)
NRC STAFF OBJECTIONS TO INTERVEN0R FRIENDS OF THE EARTH'S INTERR0GATORIES Pursuant to the Memorandum and Order of the Atomic Safety and Licensing Board dated February 3,1981, the NRC Staff herein files its objections to Intervenor Friends of the Earth's Interrogatories 11, 22, 23, 28, 44, 50, 51, 53, 54, 57, 59, and 60 dated March 16,1981.
Interrogatory No. 11:
Why does the NRC have "No regulation or policy prohibiting the siting of nuclear reactors near known active earthquake faults in California?
Objection:
The Staff objects to this interrogatory because it seeks inforn;ation irrelevant to the issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence. The interrogatory questions the adequacy of the Commission's siting ~ regulations and such challenge to the regulations falls outside the scope of this proceeding.
C1 0sgy oto W
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~
. Interrogatory No. 22:
Explain in detail why the NRC recently ordered several nuclear reactors in the Eastern USA shutdown because of inadequate seismic design.
Objection:
The Staff objects to this interrogatory because it seeks information irrelevant to the issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence.
The issues in this proceeding concern the seismic and geologic design bases of the GETR facility and the design of the test reactor's structures, systems and components important to safety in light of those bases.
This interrogatory seeks information relating to seismic design of power reactors, not the subject of this proceeding, having no relation to the issues in this proceeding concerning GETR, a test reactor located in the western part of the United States.
Interrogatory No. 23:
Have you or your consultants ever conducted or requested GE or its consultants to conduct an analysis of the ground motions that would result at the GETR site from directivity of rupture propagation or seismic focusing as described by Dr. James N. Brune in Testimony on Ground Motions at the Diablo Canyon hearings that could cause sympathetic ground notions on the branches of the Verona Thrust Fault Zone and higher than expected ground accelerations?
If not, justify your lack of investigative requirements, in detail.
Objection:
The Staff objects to this interrogatory because it seeks information irrelevant to the issues in this proceeding and is not reasonably calculated to lead ' to the discovery of admissible evidence.
. Interrogatory No. 28:
Explain how the concept of " effective accelerations" is being used in the licensing of other reactors near active faults in California, including the Diablo Canyon site and the San Onofre site.
Objection:
The Staff objects to this interrogatory because it seeks information irrelevant to the issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence.
The analyses used in the licensing of other power reactors at the specified sites are irrelevant and beyond the scope of the issues in this proceeding.
Interrogatory No. 44:
Does the NRC Staff believe that an adequate data base existed at the time the AEC issued the construction permit for siting nuclear reactors at the Vallecitos site to detennine or predict the ground motions that could occur at the site?
0bjection:
The Staff objects to this interrogatory because it seeks information
~
irrelevant to the issues in this proceeding and is not reasonably calculated
~
to lead to-the discovery of admissible evidence.
The Staff's opinion as to the adequacy of the original data base available when the construction permit was issued for the GETR is irrelevant to the issues in this proceeding. The
. Staff's deternination as to.the ground motion that could occur at the Valle-
'citos site is no longer based on the original data base but is based on a data base derived from information currently available,
4_
Interrogatory No. 50 Has the NRC Staff considered the possibility that the GETR and Vallecitos facilities are not designed to withstand an earthquake on the Verona fault of Magnitude 6.57 If so, explain.
Obiection:
The Staff objects to that portion of this interrogatory which requests infor. nation concerning "Vallecitos facilities" other than the GETR because such informatien is irrelevant te the issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence.
Such other "Vallecitos facilities" are beyond the scope of this proceeding.
Interrogatory No. 51:
If the Applicants had not yet constructed the GETR, would the NRC Staff approve of an application for a construction permit to construct a reactor at Vallecitos considering the seismic hazards at that site?
Objection:
The Staff objects to this interrogatory because it seeks information irrelevant to the issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence. The show cause proceeding does not involve issues related to initial licensing of a facility which is the subject of the hypothetical question contained in this interrogatory.
Interrogatory No. 53:
What evidence does the NRC Staff have that personnel at the GETR, during future operations, could perform necessary emergency. procedures during and following a severe earthquake, when their lives are being threatened by the circunstances?
5-1
' Interrogatory No. 54:
4 What psychological studies can the NRC Staff cite that support their arguments that operating personnel could respond effectively to earthquake circumstances at the GETRI Objection:
1 The Staff objects to these interrogatories because they seek infor-mation irrelevant to the issues in this proceeding and are not reasonably calculated to lead to the discovery of admissible evidence. They request information concerning the qualifications of operating personnel at GETR, which is beyond the scope of the issues in this proceeding.
Interrogatory No. 57:
Explain the Staff Geosciences Branch understanding of each of those quakes and consideration of their evaluations and seismic hazards to California reactors.
- Objection::
The Staff objects to that portion of this interrogatory which requests information concerning " California reactors" other than the GETR because
' such information is irrelevant to the issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence.
-Interrogatory No. 59:
Why did -the NRC shut down the Humboldt Bay Reactor?
T h
n
, Interrogatory No. 60:
Why has the NRC delayed operations at the Diablo Canyon Reactors from 1973 until the present?
Objection:
The Staff objects to these interrogatories because they seek information irrelevant to the issues in this proceeding and are not reasonably calculated to lead to the discovery of admissible evidence.
The actions taken at reactors other than the GETR are beyond the scope of the issues in this proceeding.
Respectfull submitted Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 25th day of March, 1981
UNITED STATES OF AMERICA NUCLEAR REUGLATORY COMMISSION to f BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
in the Matter of
)
- IO81am, GENERAL ELECTRIC C0 Docket No. 50-70
)
(Show Cause) fe$g, y g
-O (Vallecitos Nuclear Center -
)
General Electric Test Reactor,
)
Y Operating License No. TR-1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF OBJECTIONS TO INTERVENOR DELLUtiS' REQUEST FOR PRODUCTION OF DOCUMENTS", "NRC STAFF OBJECTIONS TO INTERVEN0R DELLUMS' SUPPLEMENTAL DOCUMENTS REQUEST" and "NRC STAFF OBJECTIONS TO INTER-VENOR FRIENDS OF THE EARTH'S INTERR0GATORIES" in the above-captioned proceed-ing have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comnission's internal nail system, this 25th day of March,1981:
Herbert Grossman, Esq., Chainnan*
The Honorable Phillip Burton Administrative Judge ATTN: Mary Atomic Safety and Licensing Board 2454 Rayburn House Office Bldg.
U.S. Nuclear Regulatory Commission Washington, DC 20515 Washington, DC 20555 Glenn W. Cady, Esq.
Mr.~Gustave A. Linenberger*
Law Offices of Carniato & Dodge Administrative Judge 3708 Mt. Diablo Blvd., Suite 300 Atomic Safety and Licenisng Board Lafayette, CA 94549 U.S. Nuclear Regulatory Commission Washington, DC 20555 George Edgar, Esq.
Morgan, Lewis & Bockius Dr. Harry Forenan 1800 M Street, N.W.
Administrative Judge Washington, DC 20036 Box 395, Mayo University of Minnesota Jed Somit, Esq.
Minneapolis, MN 55455 100 Bush Street - Suite 304 San Francisco, CA 94104 The Honorable Ronald V. Dellums ATTN:
.H. Lee Halterman, Esq.
Edward A. Firestone, Esq.
201 13th Street, Room 105 General Electric Company
~ Oakland, CA 94617 Nuclear Energy Divisions 175 Curtner Avenue Ms. Barbara Shockley San Jose, CA 95125 1890 Bockman Road (Mail Code 822)
San _Lorenzo, CA 94580 0
6
/
5
..... The Honorable John L. Burton Docketing and Service Section (7)*
1714 Longworth House Office Bldg.
Office of the Secretary Washington, DC 20515 U.S. Nuclear Regulatory Commission Washington, DC 20F,55
' Atomic Safety and Licensing Board Panel
- U.S. Nuclear Regulatory Commission Washington, DC 20555-Atomic Safety and Licensing Appeal Panel (5)*
U.S. Nuclear Regulatory Commission Washington, DC 20555 m
/
e Richard G. Baciinann Counsel for NRC St e
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