ML20150E727

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Intervenors' Response to Discovery Requests. Intervenors, Friends of the Earth,Do Not Believe Production of Stolzman Rept Is Req in Response to Any Discovery Requests. W/Supporting Preliminary Rept.Cert of Svc Encl
ML20150E727
Person / Time
Site: Vallecitos File:GEH Hitachi icon.png
Issue date: 11/27/1978
From: Baldwin W
FRIENDS OF THE EARTH
To:
References
NUDOCS 7812210512
Download: ML20150E727 (6)


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NRC PCIOC !XCU'IENT ROCM 4

3 g 1ED co CE_ 0,.mgsct 11/27/78 UNITED STATES OF AMERICA

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i- NUCLEAR REGULATORY COMMISSION

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In the matter of ) 8/ e 1 T '

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l GENERAL ELECTRIC COMPANY )

) Docket No. 50-70 y-g f[g Q i

(Vallet'tos Nuclear Center General Electric Test Reactor,)

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Operating License No..TR-1) ) 4

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1 3 ath ARNCRS' RESPONSE TO DISCOVERY REQUESTS

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Intervenors hereby provide a report entitled " General ,

j Electric Test Reactor / Preliminary Report on Tectonic Environment with Referencec to Recent Trenching" by Robert A.

Stolzman, dated November 27, 1978.

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Intervencrs do not believe that production of the Stolzman

!- report is required in response to any discovery requests properly i

j made to Intervenors in the above referenced case. Intervenors j

} note that license'e General Electric Company has submitted an j interrogatory to Intervenors (Licensee's Interrogatcry No. 1, dated t

s.une 26,.1978) which arguably asks for the Stolzman report, i

l Intervenors believe that said interrogatory is improper, as stated l in Intervenors' objections thereto. Intervenors are nevertheless i

) providing the Stol: man report in the interest of full, fair, and

> speedy determination of the issues in the above-referenced case.

4 Respectfully submitted, LflC CG YL $iDGfij(

" ^"o"*" S*1d"i" 7812210517_

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- UNITED STATES OF AMERICA , ' , -p- <.'h . ./'

HUCLEARREGULATORYCOMMISSION'[r i

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i In the4 Matter of )

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i -GENERAL. ELECTRIC COMPANY ) , Docket No. 50 4 h.) ause order

j. ) Occrating' License No. TR-1 (Vallecitos Nuclear Center _

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General Electric Test Reartor) )

i , CERTIFICATE OF SERVICE

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I hereby certify that the foregoing Intervenors' Response t to discovery requests has been served-as of this date by personal delivery or first class i- mail, postage prepaid, to.the following:

i CJward Luton, Esq., Chairman Docketing & Service Section Atomic Safety and Licensing Board Panci Office of the Secretary U.S Nuclear Regulatory Commission U.S. Nuclear Regulatory Wanhipgton, D.C. 20555 Comnfi s s ion Washington, D.C. 20555 i

Mr. Custave A. Linenberger, Member Atenic Safety and' Licensing Board Panel Daniel Swanson, Esq.

U.S. Iluclear Regulatory Commission

' U.S. Nuclear Regulatory  !

Wathington, D.C. 20555 Commission  !

Washin5 ton, D.C., 20555 )

Dr. Harry Foreman, Member Director of Center for Population Mr. George Edgar Studies Morgan, Lewis.and Bockius University.of Minnenota 1800 M Street, NW Minneapolis, Minnesota 55435 Washington, D'.C. 20036 Hon. Ronald V. Dellums Ma. Barbara Shockley Atten: Nancy Snow 1890 Bockman Road Ceneral. Delivery, Civic Center Sta.

San Lorenzo, CA- 94580 Oakland, CA' 94604 ~

Edward A. Fireston Advisory Committee on Reactor Safeg ards General Electric Company U S.-Nuclear Regulatory. Commission Nuclear Energy Divison Washington, D.C. 20555 175 Curtner San Jose, CA 94125 1

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GENERAL ELECTRIC TEST REACTOR S , Y ,,* 3 l.b C\r N;' ,

,, , <w PRELIMINARY REPORT ON TECTONIC ENVIRCNMENT

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WITH REFERE;:LES TO RECENT TRENCHING

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l Robert A. Stolzman November 27, 1979 l

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i' The General Electric Test Reactor (GETR) at Vallecitos, California is in a highly active tectonic environment. It is 2.3 km east of the Calaveras Fault, directly over the projected surface trace of the Verona Fault of Herd (1977) and less than 3 km from the Las Positas Fault (NRC, 1978)

The Las Positas Fault Zone trends northeast along the south side of the Livermore Valley and is evidenced by a prominent northwest facing scarp in Livermore gravels which is aligned with scarps in terraces of alluvium, linear vege- l tation patterns, and a fault contact between the Cierbo Sand-stone and Livermore Gravel (Herd, 1.977). This fa"It has experienced at least three or four episodes of movement which can be observed in offsets in the Livermore Gravel and younger alluvium. A ground water barrier developed, causing a vegeta-tion change. Th;s indicates that the fault extends to the surface, and most recent movement post-dates soil development.

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According to the NRC (1978), geologic data support the existence of a fault (the Verona) passing approximately 200 ft north of the GETR. Two trenches were dug along the Verona Fault trace of Herd (1977) more than 2 miles apart at locations chosen by GE's consultants. "Both revealed geclogically young thrust faulting of the same sense, character, and age" (Brabb, 1"7 8) . The northwest-trending line of escarpments in Livermore Gravels behind the Vallecitos Reactor and the folding and truncation of beds are all features due to faulting (3rabb, 1978). Brabb also states char using field observations d

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d 1 of General Electric's geologic consultants, Earth Science Associates (ESA), the existence of a northeastward dipping T

thrust fault must be postulated to explain relationships of upper gravels to middle conglomerates. Furthermore, at a trench inspection on October 27, 1978, displacement of beds, caliche deposits and slickensides were observed by the i author in trench B, recently excavated near the GETR, along the previously mentioned trace of the Verona Fault. The I

verona Fault was estimated by NRC (1978) to be capable of a magnitude 6 to 6-1/2 earthquake, with acceleration peaks as  ;

high as 1 g. and a net slip at the surface of 2.5 meters.

ESA (1978) maintains that displaced beds near the GETR do not indicate faulting, but are due to landslides and cites as evidence "two large amphitheater-like structures near the crest of the hills." These structures were not recognized by Milsen (1973) did l geologists previously mapping the area. 1 1

not see these landslide faatures, and he was specifically ]

- l mapping for landslides in the area (Brabb, 1978). ESA cites i

" discontinuous and disrupted ... stratigraphic horizon linea-tions" as evidence for landslides. This is very important to support the ESA theory, especially if the Livermore Gravel is discontinuous across parts of the " amphitheater-like l

structures". ESA does not however, state in its report or show on its map where che supposed dislocations are located (3rabb, 1978). ESA asserts that field work has located  ;

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" probable main and secondary slip surfaces in the $. sad scarp area" but there are no data or locations cited to support this  !

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statement. Also, aerial photos show beds to be continuous across the alleged landslide boundaries (Brabb, 1978).

Moreover, displacement of beds and slick surfaces were also observed by the author in trench A on the October 27th trench inspection. Displacement of beds was observed by the author in trench E on the October 31, 1978 trench inspection.

Trenches A and E are outside the boundaries of the landslide I postulated by ESA.

Furthermore, the youngest soil is cut by tne same faulting  !

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that offsets the Livermore Gravel and younger deposits. This I evidence disputes ESA's argument of an age of 10,000 to 40,000 l years for the landsliding since it would take this much time to account for the extent of erosion in the landslide debris. l l

l This erosion of debris is critica'. because there are virtually no geomorphic features that can be used to support the landslide theory (Brabb, 1978). Trench D sas dug lccking for the scarps l l

of the supposed landslide complex. On the October 27th tre ach . l inspection, the author observed extensive undisturbed cross-bedded sediments in trench D (evidence of an absence of sediment disturb-l 1

ance since sediment deposit) . No offset beds or other direct evi- 1 1

dence indicating the existence of a landslide headscarp was observed in Trench D.

l The Las Positas and Verona Faults are not the only faults of l concern. The maximum vibratory ground motion at the site 9: auld result from a 7 to 7-1/2 Richter magnitude earthcuake on t.he Calaveras Fault with acceleration peaks at a free-field surface possible exceeding 1.0 g (NRC, 1978). These figures were derived from observatiot of similar faults. ,

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REFERENCES Brabb, E., 1978, Geologic Investigation, General Electric Test Reactor Site, Vallecitos, California, Docket Number 50-70, Preliminary Report , USGS.

Earth Science Associates, 1978, Geologic Investigation, General Electric Test Reactor Site, Vallecitos, California.

Herd, D., 1977, Geologic map of the Las Positas, Green-ville, and'Verona Faults, Eastern Alameda County, California: USGS Open File Map 77-689.

Nilsen, Thor H., 1973, Preliminary'photointerpretation map of landslide and other surficial deposits of the Livermore and part of the Hayward 15-minute ,

quadrangles, Alameda and Contra Costa Counties, I

Californ.a: USGS Misc. Field Studies MF-519, 1:62,500.

1 Nuclear Regulatory Commission, 1978, Show Cause Proceeding, l l

Safety Evaluation Report Input, GE Test Reactor Site /

Vallecitos Nuclear Center, August, 1978. ,

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