ML20054E715

Motion to Add Lucks as Witness on Shoreham Opponents Coalition Contention 19(e).Lucks Can Provide Discussion of Scientific & Technical Bases of Plant Design Response Spectra.Prof Qualifications & Certificate of Svc Encl

ML20054E715
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/08/1982
From:	Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8206140100
Download: ML20054E715 (7)

Text

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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing' Board, In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

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(Shoreham -Nuclear Power Station, )

Unit 1) )

J MOTION OF LONG ISLAND LIGHTING COMPANY TO ADD DR. ' STANLEY LUCKS AS A WITNESS ON SOC CONTENTION 19(e)

The Long Island Lighting Company respectfully requests permission to add Dr. Stanley Lucks as a supple-mental witness on ' SOC Contention 19 (e) . On May 27, 1982, the Board ruled that the Contention did not involve the issue of how the design response spectra interacted with other considerations to produce an adequately conservatively seismic design (a perspective which Dr. Wong is well able to provide). Rather, the Board indicated that it wished an in-depth discussion of the scientific and technical bases of the Shoreham's design response spectra. Transcript .

at 2442 43. Dr. Lucks can provide that discussion.

As Chief Geotechnical Engineer at Stone & Webster, he is responsible for that firm's. geologic, seismologic, geotechnical and geophysical engineering work, including that for Shoreham. In this capacity, Dr. Lucks has developed (b

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design. response spectra and is an expert on how the scienti-fic and technical inputs affect the spectra. Moreover, he and his colleagues have s!.udied Shoreham's soil characteris-tics and published their findings in "The Effect of Change in the Effective Stress on STP-N Values," (June, 1981). He has also authored or co-authored other papers on seismic design.

Dr. Lucks is an expert regarding the Shoreham design response spectra and can aid in providing the Board with a detailed explanation of the scientific and technical bases that underlie the spectra. Accordingly, the Long Island Lighting Company requests that he be added as a witness on SOC Contention 19(e).

Respectfully submitted,

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> '%g Donald P. Irwin Daniel O. Flanagan HUNTON & WILLIAMS Post Office Box 1535 Richmond, Virginia 23212 DATED: June 8, 1982

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'r PROFESSIONAL QUALIFICATIONS A. Stanley' Lucks Chief Geotechnical Engineer STONE & WEBSTER ENGINEERING CORPORATION My name is Stanley Lucks. My business address is 245 Summer Street, Boston, Massachusetts, 02107. I am employed by Stone & Webster Engineering Corporation as Chief Geotechnical Engineer responsible fo r the management of the Geotechnical Division. Geotechnical Division staff are responsible for all geologic, seismologic,-geophysical and geotechnical engineering work for Stone & Webster projects. I have held this position since April 1978. My responsibilities include providing review and technical guidance for geotechnical work, including that involving Long Island Lighting' Company's Shoreham Project. My respon-sibilities have included the development of design response O

spectra.

I received my Bachelor of Science degree, with first

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class honors in civil engineering, from Heriot-Watt University,

! Edinburgh, Scotland, in 1963; Diploma of Imperial College in l

Soil Mechanics from Imperial College, London, England, in 1964; and Doctor of Philosophy in geotechnical engineering from the Massachusetts Institute of Technology in 1970.

Prior to joining Stonu & Webster Engineering Corporation, I was a Project Soils Engineer with Lambe Associates, Concord, Massachusetts,-from 1970 to 1972.

From 1966 until 1970, I was a Research Assistant at MIT and a Consultant to T. W. Lambe and Associates. My research inc,luded conducting studies and analyses of the shear strength of granular soils. From 1964 until 1966, I was a Civil Engineer with R. H. Cuthbertson & Associates, Edinburgh, Scotland.

I joined Stone &' Webster Corporation as a soils engineer in June 1972. In November 1973 I was promoted to Senior Soils Engineer and Group Supervisor. In these posi-tions I was responsible for geotechnical work on several projects. This work included geologic, seismologic and geotechnical engineering studies for several nuclear power plant siting and design projects. In November 1976 I was promoted to Assistant Chief Geotechnical Engineer responsible for the supervision of geotechnical work on several projects as well as the operation of the Geotechnical Testing Labora-tory and the review of Technical Procedures for the control of Geotechnical Division work. In April 1978 I was promoted to Chief Geotechnical Engineer responsible for the manage-ment of the Geotechnical Division.

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. .n I have coauthored several professional papers and reports in the field of geotechnical engineering.

These papers have included the assessment of seismic hazard, the sliding and stability of structures during earthquakes, the seismic stability of soil deposits and criteria for the design of retaining walls to withstand earthquakes. One paper, which I coauthored, was an analysis of certain soil characteristics at Shoreham:

"The Effect of Change in the-Effective Stress on STP-N Values," 10th International Conference on Soil Mechanics and Four.dation Engineering (1981).

I am a Registered Professional Engineer in Massachusetts, a member of the American Society of Civil Engineers and the Boston Society of Civil Engineers Section, the International Society of. Soil Mechanics and Foundation Engineering. I am also a'n Associate Member of the Institu-tion of Civil Engineers (London). I am a member of the Embankment Dams and Slopes and Publications Committees of the American Society of Civil Engineers.

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

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(Shoreham Nuclear Power Station, )

Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of '(1) Professional Qualifications of A. Stanley Lucks, Chief Geotechnical Engineer, Stone & Webster Engineering Corporation, and (2) Motion of Long Island Lighting Company to Add Dr.

Stanley Lucks as a Witness on SOC Contention 19(e) have been served this date upon each of the,_following,by, hand (as indicated by an asterisk) or by deposit in the U.S.

Mail, first class, postage prepaid:

Lawrence Brenner, Esq.* Dr. James H. Carpenter

• Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Peter A. Morris

• Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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l Atomic Safety and Licensing MHB Technical Associates Appeal Board Panel 1723 Hamilton Avenue U.S. Nuclear Regulatory Suite K I Commission San Jose, California 95125 Washington, D.C. 20555 Stephen B. Latham, Esq.

Atomic Safety and Licensing -

Twomey, Latham & Shea Board Panel 33 West Second Street U.S. Nuclear Regulatory P. O. Box 398 Commission Riverhead, New York 11901 Washington, D.C. 20555 I Ralph Shapiro, Esq.

Bernard M. Bordenick, Esq.* Cammer and Shapiro, P.C.

David A. Repka, Esq. 9 East 40th Street U.S. Nuclear Regulatory New York, New York 10016 Commission Washington, D.C. 20555 Howard L. Blau, Esq.

217 Newbridge Road .

David J. Gilmartin, Esq. Hicksville, New York 11801 Attn: Patricia A. Dempsey, Esq. .

County Attorney Matthew J. Kelly,.Esq.

Suffolk County Department of Law New York State Energy Office Veterans Memorial Highway Agency Building 2 Hauppauge, New York 11787 Empire State Plaza Albany, New York 12223 Herbert H. Brown, Esq.*

Lawrence Coe Lanpher, Esq. Mr. Jay Dunkleberger Karla J. Letsche, Esq. New York State Energy Office Kirkpatrick, Lockhart, Hill,- Agency Building 2 Christopher & Phillips Empire State Plaza 8th Floor Albany, New York 12223 1900 M Street, N.W. ,

, Washington, D.C. 20036 1

l l Mr. Mark W. Goldsm.th

, ', Energy Research Group 400-1 Totte. Pond Road Waltham, Massachusetts 02154 I

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Donald P. Irwin Hunton & Williams l 707 East Main Street l P. O. Box 1535 l Richmond, Virginia 23212 l

DATED: June 8, 1982 l

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