ML20008F928
| ML20008F928 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 05/07/1981 |
| From: | Bachmann R, Cady G, Edgar G, Swanson D CARNIATO & DODGE, FRIENDS OF THE EARTH, GENERAL ELECTRIC CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20008F927 | List: |
| References | |
| ISSUANCES-SC, NUDOCS 8105120347 | |
| Download: ML20008F928 (9) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
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Operating License (Vallecitos Nuclear Center -
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No..TR-1 General Electric Test Reactor)
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(Show Cause)
STIPULATION Pursuant to 10 C.F.R.
$$ 2.752 and 2.753, all parties to the above-captioned proceedings, through their duly authorized and undersigned Counsel, hereby stipulate to all matters which follow.
A.
Prehaaring Conference -
The parties agree that the Prehearing Conference scheduled for May 12, 1981 by the Board's Order dated April 21, 1981, abould not be held in San Francisco, but rather the parties 4
and the Board should convene by telephone conference on May 12, 1981 to discuss such matters relating to the forth-coming hearings as are not settled herein.
At the present time, the matters remaining for discussion are:
1.
Whether Mr. Barlow is qualified to sponsor expert testimony on Issue 1 of the Show Cause Order (Seismology and Geology).
The intervenors will file a motion to add Mr. Barlow as a witness for this purpose.
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'Although it appears that all remaining discovery issues may be resolved before May 12, 1981, a status report would be desireable.
3.
Discussion of the Stipulation, and Board approval.
4.
Such other matters as the Board may wish to discuss.
B.
l'ssues for Litigation -
For the purposes of this Show Cause proceeding, the parties stipulate and agree that the following are not in issue among the parties, can be accepted by the Board as given in its decision, and need not be litigated in the forthcoming hearings:
1.
At the present time GE does not intend to present an affirmative' case on Issue 3 of the Show Cause Order, and does not intend to seek authority for interim operation pursuant to Issue 3 prior to the Board's decision in the 4
Show cause proceeding.
If future circumstances result in any request by GE for interim operation, all parties L
expressly reserve their rights to contest that request and present evidence in relation thereto.
1.
The following statements of fact:
a.
An average slip rate of.0004 ft/yr (0.012 cm/yr) fits a curve of cumulative apparent dip slip separation versus age of displacement on the Verona fault.
b.
The Verona fault is tectonic in origin.
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Geologic data indicate that the GETR site is located within a zone of faulting (the Verona fault) which is at least 2200 feet wide.
d.
Assuming that alluvial deposits in B-1 extend beneath GETR, the reactor rests on beds older than 70,000-130,000 years and younger than 300,000 years.
e.
The assumption that the San Fernando and Verona fault zones are comparable is a conservative assumption.
f.
The Verona fault, including its northwesterly projection along possible splays of the Pleasanton fault, has an estimated maximum surface length of 12 kilometers, g.
The length of observed surface rupture during the San Fernando event was about 12-15 kilometers; movement was predominantly in a thrust sense with a substantial horizontal component.
h.
Calculated slip vectors along an assumed fault plane in the Orange Grove Avenue and Eighth Street areas of the San Fernando fault that surface ruptured during the 1971 San Fernando event indicate that 2.4 meters of net slip displacement took place.
However, that vertical l
displacement for this location is distributed across l
a zone of breakage 200 meters wide which is complicated by a zone of shearing and thrusting and a zone of extension.
A com ~1ation of direct measurements of net slip on individual surface ruptures is not yet available.
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1.
Concerning the 1971 San Fernando earthquake (based upon data by Barrows et al. 1973):
1.
Regarding the 179 observations of vertical surface offsets occurring during the 1971 San Fernando earthquake, the mean of the observed vertical throw on a given fault break is about 34 centimeters (.34 meters).
ii.
Of the 179 observations, 97% were less than 1 meter and 5 observations equaled or exceeded 1 meter.
iii. The maximum vertical offset noted which exceeds 1 meter is 160 centimeters (1.6 meter).
iv.
One meter of vertical offset exceeds the mean plus two standard deviations for the San Fernando data.
j.
All of the shears exposed in trenches at Vallecitos Center have dips less than 45 degrees; seventy percent of dips measured are thirty degrees or less; two main shears closest to GETR have dips ranging from 0 to 25 degrees.
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The potential earthquake sources that are important in 1
assessing the vibratory ground motion hazard at the l
GETR site are the Calaveras fault and the Verona fault.
Earthquakes occurring on these faults could have l
magnitudes of 7 to 7.5 and 6 to 6.5, respectively.
1.
Strike-slip faults subsidiary to and connected to the San Andreas fault have generated maximum earthquakes r
of magnitude about 7 to 7 1/2 based on the data of Coffman and Von Hake (1973).
-5 m.
The base of the GETR foundation mat, which is located about 20 feet below grade, is underlain by very dense clayey sand and gravel with occasional layers of very dense sandy and/or gravelly clay to a depth of 70 feet.
n.
There is a hard, cemented stratum known as the middle conglomerate unit of the Livermore Gravels, which crops out in hills on the west and south of the site, and which at the GETR site, is more than 70 feet below the surface.
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Standard Penetrar. ion Tests performed for GE on the materials underlying the GETR Foundation mat show blow counts of from 50 to 100 blows / foot penetration, affirming the very dense nature of these soils.
p.
Groundwater levels at GETR were shown to very from 20 feet to 28 feet below plant grade.
q.
All of the safety-related structures, systems and components necessary to shut down the facility and maintain the reactor in a safe shutdown condition during and following the design basis seismic events are identified in Table I, Sect. A of the SER (This is not an admission as to the proper seismic and geologic design bases of the GETR).
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The horizontal virbratory gound motion at the GETR site-resulting from an earthquake of magnitude 6 to 6.5 centered on the Verona fault could contain acceleration peaks as high as 1 g.
However, the overall level and
-6 duration of shaking at the GETR site would be less than for a magnitude 7 to 7.5 earthquake centered on the Calaveras fault.
C.
Schedules -
The parties agree to the following schedules for the appearance of witnesses, cross-examination,I/ and filing of proposed findings of fact and conclusions of law:
Limited Appearance and May 27 (at location near site)
Appearance of GE Offset Panel (Gilliland, Hard-ing, Jahns, Reed, Meehan,.
and Shlemon (backup))
May 28 (at location near site)
GE Offset Panel May 29 (at location near site)
GE Seismology Panel (Kovach, Richter (if available), and Gilliland)
June 1 (this session and all Limited Appearances and subsequent sessions to Glenn Barlow
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be held in San Francisco)
June 2 NRC Staff Geology and Seismology Panel (Jackson, Justus, Devine, Brabb, Herd, Slemmons, Morris, Ellsworth, Greeves, and Pichumani)
June 3 NRC Staff Geology and Seismology Panel
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The order of cross-examination will be:
- 1) for GE witnesses - Intervenors, then Staff; 2) for Staff wit-nesses - GE, then Intervenors; 3) for Intervenor wit-nesses - GE, then Staff.
Board questioning will occur, as deemed appropriate by the Board at any time, but in general it shall occur after cross-examination by the parties.
-7 June 4 NRC Staff Witnesses Dr.-Hall and Mr.
Martore (Effective Acceleration Criteria and Structural Review)-
June 5 Professor Brillinger (Probability)
June 8 NRC Probability Panel (Vesely, Bernreuter, Slemmons, and Wright)
June 9 - June 10 (1/2 day)
GE Structural Panel (Gilliland, Kost and s'
Durlofsky)
June 10 (1/2 day) - June 11
.Intervenor Structural
-(1/2 day)
Witness Rutherford June 11 (1/2 day) - June 12 NRC Staff Structural Panel (Martore, Nelson, and Burdoin)
Record Closed June 26 Transcript Corrections Due July 3 License Proposed Find-ings Due July 17 Intervenor Proposed Findings Due (Intervenors will make express service on the NRC Staff)
July 24 NRC Staff Proposed Find-ings Due July 31 Licensee Reply Due t
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,D.
Other Matters -
The parties agree as follows:
1.
By May 12, 1981 - All pcrties'will present lists of exhibits (documents) which they intend to offer into evidence.
2.
May 19, 1981 - Any objections to admissibility of any exhibit must be filed in writing.
The parties stipulate that any document not objected to will be received in evidence without need for formal authentication and introduction; provided, however, the parties reserve their rights to move to strike based upon examination.
3.
The parties will agree to have Saturday hearing sessions if necessary to maintain the schedule set forth in C above.
Similarly, the parties will use their best efforts to make witnesses available for cross-examination earlier than scheduled in the event that the schedule advances at any time.
4.
GE and the NRC Staff will continue to effectuate service by hand, air express, express mail or other expeditious methods.
The Intervenors agree to make service of their July 17, 1981 proposed findings on the NRC Staff by such expeditious methods.
5.
The parties waive obj ections under 10 C.F.R. 5 2.752(c) as to all matters addressed in this Stipulation.
6.
Each witness may give a five minute oral summary of l
his prepared written testimony; provided, however, that l
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-9 the total time allotted to oral summaries by any given witness panel shall not exceed fifteen (15) minutes.
WHEREFORE, the parties request that the Licensing Board approve this Stipulation and incorporate it into an Order purusant to 10 C.F.R. SS 2.752 and 2.753.
Respectfully submitted, I
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Glenn W. Cady, Lead Counsek for George dgaf
Consolidated Intervenors.'
for Friends of the Earth General Electr Ms. Barbara Shockley Ronald V. Dellums, M.C.
Phillip Burton, M.C.
.j John Burton, M.C.
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T' Danfel Swanson Richard G. Bachmann for cne NRC Staff DATED:
May 7, 1981 t
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