ML20196F981

Declaration of Gh Liang.* Provides Support of Motion for Summary Disposition of Contention Utah M in Listed Proceeding

ML20196F981
Person / Time
Site:	07200022
Issue date:	06/28/1999
From:	Liang G AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20196F927	List: ML20196F923 ML20196F981 ML20196G007
References
ISFSI, NUDOCS 9907010022
Download: ML20196F981 (16)

Text

{{#Wiki_filter:esarm u.m-w m ~. - e u n. ~ ( i UNITED STATES OF AMERICA ) NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 1 In the Matter of ) ) PRIVATE FUEL STORAGE L.L.C. ) Docket No. 72-22 ) (Private Fuel Storage Facility) ) DECLARATION OF DR. GEORGE H. C. LIANG Dr. George II. C. I.iang states as follows under penalties of perjury: i 1. I am currently employed by Stone & Webster Engineering Corporation as a Progmm Manager. In this position,I am responsible for the determination and evalua-tion of stormwater runoff and flood events at power facilities being designed by Ston: & Webster. I am providing this declaration in support of a motion for summary disposidon of Contention Utah M in the above captioned proceeding to show that Private Fuel Stor-age L.L.C. ("PFS") has conservatively estimated the Probable Maximum Flood ("PMP") levels fcr the Private Fuel Storage Facility ("PFSF") and appropriately designed struc-turcs important to safety to protect against flooding. My professional and educational experience is summarized in the resume 2. attached as Exhibit I to this declaration. I have extensive experience in the analysis of hydrologic processes, including over 15 years experience in the calculation and evalua-tion of flood events and PMFs. Through my involvement in the majority of the flooding evaluations of nuclear facilities performed by Stone & Webster during this period, I am intimately familiar with the NRC requirements and standard industry practice for calcu-lating 100 year and PMF flood events. l 9907010022 990628 PDR ADOCK 07200022 C PDR .].

m_ __-.,_,u~ I 3. The PMF is dermed as the most severe flood that is considered possible at a site as a result of the hydrologic and meteorological conditions. Unlike calculations for the 100 year flood and other flood events, which are probabilistic determinatior,s bared on recorded rainfall data, the PMF is an estimateC flood event based on theoretical con-ditions. Thus, the PMF represents a worst case event that is unlikely to ever occur. 4. I am knowledgeable of the location of the PFSF, the hydrologic and me-teorological conditions of that arca, and the arca's topography. I am also knowledgeable about the facility's flood protection efrorts and the design of the facility's flood diversion berms. 5. The PFSF is located in the Skull Valley in Tooele County, Utah, on the Reservation of the Skull Valley Band of Goshute Indians. The restricted area in which structures, systems and camponents important to sefety are located consists of 99 acres with cicvation ranging from 4,476 A. on its southeastem comer to 4,462 A. on its north-eastem comer. The lowest finished elevation (top of concrete) of the northem most row of concrete storage pads - which will be the lowest structurcs impostant to safety on the PFSF - will bc 4,463 ft The potential for flooding at the site has been evaluated for two drainage basins, Dasin A, to the cast of the site, which covers 270 sq. mi., and Basin B, generally to the north and west of the site, which covers 64 sq. mi. Basin A stretches j 29.8 miles from the access road to Lookout Mountain to the f outh, and is dermed by Hickman Knolls to the west, the Stansbury Mountains to the east and the Ccdar Moun-t'ains to the south. Basin B is defined by Hickman Knolls to the east and the Lower Cedar Mountains to the west and the south. Sec SAR Figure 2.4-1 attached as Exhibit 2 to this declaration. 6. Based on the visual inspcetion of the area's topography, PFS initially used a drainage area of 26 sq. mi. to calculate a PMF of 34,577 cubic feet per second ("cfs"), as described in its June 19971.icense Application. In the bases for Contention M, as ad-mitted by the Licensing Board, the State alleged that PFS had failed to accurately esti-mate the PMF in that the drainage area for Basin A of 26 sq. mi. in the License Applica. tion was incorrectly determined, and that as a result of the inaccurate estimate, structures 2-i

important to safety may be inadequately designed. The State alleged that the drainage area should have been at least 240 sq. mi. and, based on that drainage area, calculated a PMF of 57,600 cfs. The State did not raise any issue in regards to PFS's evaluation of flooding for Basin B.~ Therefore, the remainder of my declaration will focus on Basin A.

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' After concems were raised by both the State and the NRC Staff, PFS reex-amined the drainage arca and revised its calculations for Basin A to reflect a drainage ba-sin of 270 sq. mi. PFS's revised calculations resulted in a PMF of 53,000 cfs and a 100 year flood of 2,430 cfs. The State has explicitly accepted the 270 sq. mi. drainage area as an appropriate drainage area for calculating the potential for flooding at the PFSF and has revised its estimate of the PMF to 64,500 cfs based on the 270 sq. mi. drainage area. $ss State of Utah's Second Amended Responses and Supplemental Responses to Applicant's First Set of Formal Discovery Requests, Cont. M, Req. for Admn. No.1, Inter. No.1. Thus, the State no longer challenges the adequacy of the drainage area used by PFS for ) calculating flooding at the site. 8. Based on subsequent discussions with the NRC, PFS adopted very conscr-vative assumptions for the time of concentration and the infiltration rate within Ba ' ' A. As described in the May 19,1999 License Amendment, PFS further revised its calcula-tions to reflect these assumptions, resulting in a design PMF of 85,000 cfs. See PFSF SAR at 2.4-12. This design PMF is extremely conservative and is more than 31% larger than the 64,500 cfs peak discharge calculated by the State. 9. The State had taken issue with the time of concentration used by PFS in its - calculation of the PMF. The time of concentration is the total time it takes rainfall to j reach the outlet imm the farthest point in the basin. The smaller the time of concentra- { I tion, the greater the flood event. Another influential variable that can greatly aircet the I i size of the flood is the infiltration rate used in calculating the PMF. The infiltration rate determines how much rainfall is absorbed by the ground instead of contributing to the storm flow. Infiltration is accounted for by cither assuming a constant infiltration rate or l using the Soil Conservation Service's (now the National Resources Conservation Serv-l i c,_ -~ -. m -,, ~ ~ ice) curve number (CN) method. The higher the CN, the less absorption of water by the ground and the greater the PMF. 10. The State in its PMF calculation used a smaller time of concentration than PFS did, which would increase the PMF event. However, for calculating its 85,000 cfs j design PMF, PFS used a CN of 96 for calculating infiltration. A CN of 96 results in very little absorption of water by the ground and is much more conservative in this mspect than the infiltration rate of.15 used by the State in its PMF calculation. It therefore greatly incremacs PFS's calculated PMF compared to that of the State's. The much more conservative assumption by PFS on the lack ofinfiltration more than offsets the State's more conservative time-of-concentration, thus resulting in PFS's PMF design basis of 85,000 cfs being more than 31% larger than the peak PMF discharge of 64,500 cfs cal-culated by the State. I 1. Using the design PMP of 85,000 cfs, PPS calculated the elevation of the flood weters based on the basin's natural topography. As shown in Exhibit 3 attached to this declaration, the level of the flood waters in Basin A, which is east of the site, range from 4.468.8 A ( 6.2 R below the site's elevation) at the facility's southeastern comer to 4,456.7 A ( 5.3 R below the site's elevation) at the northeastern corner. Nowhere would the flood waters impinge on the PFSF site. Corresponding to the State's lower PMF cs-timate of 64,500 cfs, the State's estimate of flood levels would be approximately 0.5 fl. below PFS's estimate. Likewise, therefore, the PMF as calculated by the State would not iesult in the flooding of any portion of the PFSF site. 12. PFS then calculated the effect of the access mad on the water elevation which will traverse part of Basin A up-gradient of the PFSF site. See Exhibits 2 and 3. In accordance with standard engineering practice, the access road will only be designed to pass the 100 year flood, not the PMF. Therefore, for the 85,000 cfs design basis PMF, water will accumulate behind the road to a peak elevation of 4,506.4 A., resulting in wa-ter overtopping of the access road by 4.45 (L After the waters overtop the access road, they will return to their natural flow pattern, as described in the paccding paragraph. Because the floodwaters will not reach the facility, the PFSF will remain flood-dry. 13. A diversion berm will be built to the cast of the PFSF to prevent the flooding of the facility by the water that accumulates behind the access road, and to pre-vent water from crossing between the two basins. This berm will have a north-south alignment and will span 1,928 ft., extending from Hickman Knolls to several hundred feet past the access road. See SAR Figure 2.4 4, attached as Exhibit 4 to this declaration. From Hickman Knolls to the access road, the berm's clevation will be 4,507.5 ft, which be at least one foot higher than the peak elevation of 4,506.4 ft of the water accumulated behind the access road for the 85,000 cfs PMP. 14. In the State's Amended Response to the Applicant's Second Discovery Request, dated May 12,1999, the State questions how the access road will cross the di-version berm and whether that crossing will allow flood waters to reach the PFSF The design of this intersection is such that no path is available for flood waters to nach the facility. As shown on SAR Figure 2.4-4 (Exhibit 4), the access road will slope upwards to an cicvation of 4,507.5 ft as it approaches the diversion berm and will slope down-ward after it passes over the herm. Thus, the clevation of the diversion berm will con-tinue to be at least one foot above the level of the floodwaters. 15. In summary, the PMF calculated by PFS is extremely conservative and greatly exceeds the flood flows calculated by the State. Because the PFSF is designed to address this conservatively estimated PMF, there will be no impact to public health or safety. I declare under penalty of perjury that the foregoing is true and correct. Executed on June M 1999 0 SurwNL%a Dr. George'H. C. Lianfj,

8 9 l l l l LIANG Exhibit 1

-0 t l l l RESUME OF GEORGE H.C. LIANG i l l l [ l

George H.C. Liang Senior Principal Environmental Engineer i Experience Summary Dr. Liang is a Senior Principal Environmental Engineer in the Ensironmental Sciences & Engineering l Department. He has over 26 y ears of experience in siting, environmental assessment. deseloping and I managing environmental protection programs, and licensing of power plants and industrial facilities. He also has extensive experience in mathematical modeling, numerical analysis, and computer applications l in environmental engineering / design related problems. He is currently a Program Manager and has previously been a Lead Environmental Engineer on major projects in nuclear / fossil power plants and industrial projects, w hich involved environmental impact studies, federal / state / local permitting applications, managing engineering / design, procurement and installation of water and wastewater treatment systems, conceptual design of the heat dissipation / chemical discharge system, studies of alternative cooling systems, groundwater dispersion, hydrological analysis of power plant sites and thermal / water quality impact analysis of power plant discharge. As Supervisor of Water Quality and Hydrology, Dr. Liang has supervised many water quality and bydrology related tasks for power plant projects. He established the technical guideline for flood analysis at power plant sites. He managed the environmental impact assessment of a fluidized bed power plant i site and prepared its permit application. He established the exclusion criteria for siting a Low Level Radioactive Waste disposal facility in Maine, to assure compliance with federal and state requirements. He evaluated existing permit requirements to determine the potential environmental impacts of rerating a nuclear power plant. Dr. Liang completed the conceptual design of a surface run-off detention pond for a proposed N PR site in Idaho, a cooling pond for a proposed power plant site in Florida, a multiport diffuser for a cogen plant in New York and a combined cycle power plant in England, U.K. He has developed the water quality monitoring program and conducted the hydrothermal / water quality modeling for numerous power plant projects. Dr. Liang has been a lead environmental engineer on major projects in nuclear, fossil, and industrial i plants. Dr. Liang has been an expert in mathematical modeling of surface water, groundwater, water quality, j hydrological and hydrothermal analysis. Dr. Liang has been intimately familiar with EPA's National Pollution Discharge Elimination System (NPDES) permit application regulations and the requirements of section 401 of the Water Quality Act (WQA), which amended Clear Water Act (CWA) section 402(l)(2). He has assisted many major utility clients as well as independent power producers in obtaining the NPDES permit. l Dr. Liang has participated in numerous siting studies for various type of power generation projects and Low Level Radioactive Waste disposal facilities. He has designed and supervised many environmental monitoring programs for siting studies, and prepared permit applications and supporting documentations. l As a member of ICE team, Dr. Liang has participated in evaluating DOE's Environmental Restoration l and Waste Management Five-Year plan. He has assisted DOE in environmental cleanup activities at Handford site, and managed environmental studies for the U.S. AMTL research reactor decommissioning l project. .tfay I998 PageI

Resume of George H. C Liang Dr. Liang des eloped a comprehensive environmental protection program at a nuclear power plant construction site. He monitored project construction activities for regulatory compliance in air and water quality, noise, wetlands and wildlife refuge protection, and solid waste disposal. Dr. Liang integrated the i environmental protection program with the quality assurance and safety / health programs to measure j program performance. He provided the irrpetus to implement similar programs at other nuclear power j plant sites. Dr. Liang has performed a technical review of the existing environmental operating limit permits and supponing documentation (316a and 316b demonstrations) and assessed the impact of the power uprate on the plant's ultimate heat sink. In 1994, Dr. Liang managed a consulting services project for improving the technical ability of 22 senior engineers from East China Electric Power Design Institute, dealing with the requirements for a Conventional Island design associated with a nuclear power plant. i Since 1995 Dr. Liang has been working as Lenders' engineer for several fossil power plant projects in i China. Working as an Independent Technical Consultant (iTC), he has been responsible for the due diligence effort which includes technical review of engineering / design of the major plant systems, review i and evaluation of fuel sources and cost, project performance parameters and guarantees, environmental parameters for compliance with PRC's regulations and World Bank guidelines; construction progress monitoring for funding drawdown certi6 cation, start-up/ test procedure review, and witnessing the 72-hour and 24-hour test runs, and certi6 cation of completion of seseral fossil power plant projects in China. Recently Dr. Liang has been in charge of developing EPC cost data base for fossil power plant in China. Education Ph.D., Civil Engineering - University of Connecticut Storrs, Connecticut - 1972 M.S., Civil Engineering - University of Connecticut, Storrs, Connecticut - 1967 National Taiwan University, Taipei, Taiwan, Republic of China Training ' Chi'n'a Forum - since 1995, a lunch-time seminar series, meeting once every other month, covered the topics of information, challenges, strategies, recent development, and successful projects in m arketing in i China, sponsored by the Of6ce of International Trade & Investment, the Commonwealth of Massachusetts, Foley, Hoag & Eliot LLP, and others. i The Princeton Course / Groundwater Pollution and Hydrology - 1993 l Hazardous Materials Management, American Management Association - 1991 Site Se'ection and Design of Sediment and Detention Basins, Southern New England Environmental Regt ' Course, Executive Enterprise, Inc. - 1987 MIT Viceo Course on Finite Element Methods, Massachusetts Institute of Technology - 1984 Water Resources Lecture Series - Rainfall /Run-off Modeling using HEC-1, Stone & Webster Engineering Corporation - 1982 Sediment Transport in Rivers and Estuaries, University of Southern California - 1974 l Licenses, Registrations, and Certifications Professional Engineer - Connecticut,09789 - 1975 Active %y I998 Page 2 l l

r I Resume of George H. C. Liang l l Professional Affiliations American Geophysical Union, Member The Society of the Sigma Xi, Member Publications Liang. G.H.C., "New Technologies in Sulfur Removal in the Refining Process in a Refinery." National Conference for Environmental Managers of Petrochem: cal Plants, May 1995 Liang, G.H.C., "Use of Groundwater Analytical / Numerical Models for Evaluating Pollution Control Measures at Hazardous Waste Disposal Facilities." New England / Republic of China Technical Exchange Symposium, May 1990. 1 Liang, G.H.C.. " Summary of Hydrographic and Hydrothermal Studies at Millstone Nuclear Power Station, 1969-1985." Millstone Ecological Advisory Committee Meeting, Waterford, Connecticut.1986. Liang, G.H.C.: Lee, V.M.: and Torbin. R.;" A Data Acquisition and Analysis Technique for a Sediment Transport Field Study Prograra." COASTAL ZONE 78, San Francisco, Califomia,1978. Liang, G.H.C. and Lin. J.D., "Effect of Pressure Gradient on Wind-waves in a Laboratory Channel." 2nd U.S. National Conference in Wind Engineering Research, Colorado State University, Fort Collins, Colorado,1975. Liang, G.H.C.," Wind-generated Waves With and Without Pressure Gradients." University of Connecticut, Storrs, Connecticut,1972. Liang, G.H.C. and Lin, J.D., " Laboratory Win-waves Generated With and Without Pressure Gradients." American Geophysical Union Fall Annual Meeting, San Francisco, Califomia,1972. l Liang, G.H.C., " Numerical Calculation of the Source Term for a Vertical Line Source Under Linearized Free Surface." University of Connecticut, Storrs, Connecticut,1967. 1 1 l l l ] i i i Page 3 May I998 f l E

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