ML20196G007
| ML20196G007 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/28/1999 |
| From: | Cooper J AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20196F927 | List: |
| References | |
| ISFSI, NUDOCS 9907010029 | |
| Download: ML20196G007 (24) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22
)
(Private Fuel Storage Facility)
)
DECLARATION OF JERRY COOPER CITY OF ENGLEWOOD
)
) SS:
STATE OF COLORADO
)
I, Jerry Cooper, being duly sworn, state as follows:
1.
I am the Project Engineer with Stone & Webster Engineering Corporation (Stone & Webster) for the Private Fuel Storage Facility (PFSF). Stone & Webster is the architect-engineer for the PFSF. As Project Engineer for the PFSF, I am responsible for directing the multidiscipline engineering and design activities of the PFSF project. I am providing this affidavit in support of a motion for partial summary disposition of Conten-tion Utah M in the above captioned proceeding to describe the impact of the Probable Maximum Flood on the operations and structures of the PFSF.
2.
I have participated in and am knowledgeable of the design and layout of the PFSF. My professional and educational experience is summarized in the curriculum vitae attached as Exhibit I to this affidavit. I have 28 years of experience in the engi-neering, design, construction, operation, and maintenance of naval nuclear power plants, 9907010029 990628 PDR ADOCK 07200022 C
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l-commercial nuclear plants, spent fuel storage facilities, and environmental remediation projects.
3.
In Utah M and its responses to PFS's discovery requests, the State claims that the Applicant's inaccurate estimate of the PMF could result in potential damage to structures iiig=1.ut to safety. The State supports this contentioa by claiming that the access road may flood or wash out. Any hazard that the PMF might pose to the access road is of no consequence, in that the access road is not a structure, system or component important to safety. As Section 3.4 and Table 3.4-1 of the PFS SAR show, the fuel casks, the fuel canisters, the storage pads, and the canister transfer building (including compo-nents inside the building) are the only " structures, systems, and components important to l
safety"(defined by 10 C.F.R. { 72.3) at the PFSF. The NRC defines as such those sys-tems that 1) maintain the conditions required to store spent fuel safely, 2) prevent damage to the spent fuel container during handling and storage, and 3) provide reasonable assur-l ance that the spent fuel can be handled or stored without undue risk to the public. The access road meets none of these criteria. 'Ihe access road is not mlied upon in any man-ner to maintain conditions necessary to store spent fuel safely; it is not relied upon in any manner to prevent damage to the spent fuel container during handling and storage; and it is not relied upon in any manner to provide reasonable assurance that the spent fuel can be handled or stored without undue risk to the public. Thus, the access road is not a structure, system or component important to safety.
l 4.
The State claims that the flooding or washing out of the access road would prevent necessary PFS personnel or emergency service providers from reaching the site which would result in PFS not being able to cope with emergencies. The flooding or washing out of the access road would, however, have no adverse impact on public health and safety. Such loss of the access road would pose no threat to the integrity of the stor-age casks, and could not result in the release of radioactive material, in that the flood waters from the design basis pMF would not impinge on the site itself. Therefore, there would be no release of radioactivity that would require emergency action. Further, ap-L 2
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i propriate security and operations staffwould be maintained at the site throughout the de-sign basis PMF event to ensure the safe operation of the facility at all times. After the I
design basis PMF event, the facility would be accessible to foot taffic and four wheel drive vehicles, and, until the access road were repaired, facility operations would be minimized.
5.
The access road is not built to withstand the effects of a PMF event be-cause the road is not a structure important to safety for the reasons described above. The access road is designed to withstand the effects of the 100 year flood, not the PMF, which exceeds standard engineering practice. Interstate highways, are typically designed to withstand a 50 or 100 year flood, not a PMF. In addition, the Utah Department of Trans-portation requires that bridges built within the State be designed for the 50 or 100 year floods. Likewise, limitations on other building structures, even ones considered impor-tant for public health or safety (such as hospitals or prisons) are typically based on the 100-year flood and not the PMF. Because the PMF is an extraordinary event that is ex-tremely unlikely to occur, the NRC does not require that structures which are not impor-tant to safety be built to withstand its effects.
I declare under pensity of perjury that the foregoing is tme and correct.
17.xecuted on June 28,1999
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COOPER Exhibit 1
p Jerry L. Cooper Lead Senior Engineer Experienee Summary Mr. Cooper has 28 years experience in the Engineering, Design, Construction, Operation and Maintenance of Nuclear Power Plants. He is a Lead Senior Engineer in the Mechanical Division and has been with Stone & Webster Engineering Corporation for 23 years. He has over 19 years experience with the Duquesne Light Company's Beaver Valley Unit Nos. I and 2 Nuclear Plants.
Mr. Cooper is currently assigned as Project Engineer for the Private Fuel Storage Facility project (PFSF).
His responsibilities include directing the engineering and design activities in support of the project license application.
Mr. Cooper returned to Stone and Webster in April 1997 after spending 15 months working for Lockheed Martin Advanced Environmental Systems on the Pit 9 Remediation Project. The Pit 9 project was an environmental remediation project using state of the art technology to retrieve and process buried transuranic waste from the Subsurface Disposal Area at the Idaho National Engineering and Environmental Laboratory. Mr. Cooper served as the Offsites/ Treatment Manager responsible for engineering and design of the Treatment Facility Building and the Offsites Support Area.
Prior to this Mr. Cooper was the Assistant Project Engineer for the Continuing Services activities for the Beaver Valley Power Station Unit Nos. I and 2. He was responsible for the organization, administration and direction of all Engineering Disciplines to ensure proper technical interface with the Duquesne Light Nuclear Engineering Department. Specific responsibilities included the preparation of Design Change Packages for plant modifications, engineering calculations, equipment procurement specifications and resolution of detailed engineering problems. Additionally, he has served as the Mechanical Enginy on the Evaluation Team for the Safety System Functional Evaluation of the Recirculation spray Systu and the Residual Heat Removal System.
He was assigned to the Beaver Valley Unit No. 2 Site Engineering Office in 1981 as an Engineer in the Nuclear / Mechanical Group. His responsibilities included engineering support of such major construction activities as turbine erection, turbine lube oil flush, main condenser erection, fuel handling crane erection and operation, and ASME XI In-Service Inspection for piping welds. He also served as the piping engineer responsible for all major piping installation. In 1984, he was assigned to the Integrated Construction Support Group. This group was established to work directly with construction and contractor personnel to provide technically acceptable and construction conscious solutions to field problems. In 1987, Mr. Cooper became the Principal Engineer, supervising all Mechanical Division activities of this group. During start-up testing and initial operations, he served as Principal Engineer responsible for all Mechanical Division activities of the Site Engineering Group and later as Assistant Superintendent of Engineering responsible for Mechanical, Structural and Engineering Mechanics disciplines as well as administration and direction of the Site Engineering Group's policy and procedures.
Prior to his site assignment, Mr. Cooper spent six years in Stone & Webster's Boston Office assigned to the Beaver Valley Power Station Unit No. 2 Nuclear Project in both the Piping Engineering Group and the Nuclear Group. His duties included: responsible engineer for all NSSS systems and equipment; preparation of specifications for cartridge type liquid filters, valves, strainers and steam traps; coordination of purchase orders with vendors; review and approval of vendors' equipment drawings; and resolution of N&Ds from the Vendor Surveillance Group or the Site Quality Control Group.
Prior to joining Stone & Webster, Mr. Cooper spent five and one-half years in the U.S. Naval Nuclear A
Page1
Resume ofJerry L. Cooper I
Power Program where he served as a Mechanical Operator on an SSW Poseidon submarine. His duties included maintenance, operation, training, and testing of nuclear fluid, ships propulsion, and various i
support systems.
1 1
i Education 1
B.S., Engineering - Geneva College U.S. Navy Nuclear Power Program A
Page 2 L
EXCERPTS FROM DEPOSITION OF DAVID B. COLE
CERTIFIED COPY 1
l 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 In the Matter of
) Docket No. 72-22
) ASLBP No. 97-732-02-ISFSI 5
PRIVATE FUEL STORAGE
)
L.L.C.
)-
6
)
(Private Fuel Storage
) DEPOSITION OF:
7 Facility)
)
) DAVID B.
COLE 8
)
9 10 The deposition of DAVID B.
COLE, a witness in 11 the above-entitled cause, taken before LANETTE 12 SHINDURLING, Registered Professional Reporter and Notary 13 Public in and for the State of Utah, at the law offices 14 of PARSONS, BEHLE & LATIMER, 201 South Main, suite 1800, 15 Salt Lake City, Utah, on the 26th day of May, 1999, 16 commencing at 1:30 p.m.
17 18 19
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1 20 21 22 23 25 ASSOCI ATED P RO F ESSIO N A L R E P O R T E R S, L. C.
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'T 15 i
i did?
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2' A.
Yes, for the very first one.
3 Q.
This was done in fall of 1997, correct, 4
acproximately?
5 A.
Or even before.
I'm not sure.
6 Q.
It was done in 1997?
7 A.
Yeah.
8 Q.
And in your initial calculation, what drainage 9
area did you use for the flooding at the PFS site?
10 A.
240 square miles.
Not at the site, I'm sorry, 11 that was the access road.
12 Q.
The access road area?
13 A.
Uh-huh (affirmative).
14
-Q.
What area had PFS used in its initial 15 application?
16 A.
I don't remember the exact number.
It was
, 17 much less than that, in the 20's..
18 Q.
About 25, :26, somewhere in there?
19 A.
Yeah, somewhere in there.
20 Q.
You took issue with that, I take it?
21 A.
Yes.
That was one thing I questioned.
22 Q.
That was a major issue you took with the 23 initial flooding calculation done by the PFS--
24 A.
Yes, it was.
25 Q.
-- was the drainage area?
i i
16 l
A.
Uh-huh (affirmative).
t 2
Q.
Now, is it true that the Private Fuel Storage 3
has redone its storage calculation using a larger
)'
4 drainage area?
5 A.
Yes, it is.
6 Q.
And they have now used a drainage of I believe 7
270 square miles?
8 A.
That's what I remember, yeah.
9 Q.
I take it, my understanding is the State 10 acknowledges that's an appropriata drainage. area for 11 calculating the flooding at the' site?
12 A.
I would say it was conservative, yeah.
13 Q.
So that's no longer an issue between us, 14 correct?
15 A.
No, I don't think so.
16 Q.
Besides drainage areas, what other factor' are 17 relevant to calculating potential flooding?
18 A.
Well, one of them is the time that the water 19 takes to accumulate, which is the concentration tirte.
20 Q.
That's the time of concentration?
21 A.
Uh-huh (affirmative).
22 Q.
So that's the time that it takes for the water 23 to accumulate up to a--
-24 A.
Well, it's from the farthest reach of the 25 watershed to the outlet, is the measure of the time.
1 F
17 1
Q.
That's the time of concentration?
2 A.
Uh-huh (affirmative).
3 Q.
What other factor is there that you use in
)
4 calculating flooding?
5 A.
Well, it's the loss rate.
How fast the rain 6
is absorbed into the soil and how much of it runs off as 7
the result of that.
i l
8 Q.
And what is the loss rate?
9 A.
Okay.
For the large flood we used an 10 infiltration rate, and it's how fast-- how many-- if the il rain is falling so many iIches per hour, it's how many 12 inches per hour are being absorbed or lost by 13 infiltration into the soil or other so that it doesn't i
14 become part of the runoff.
15 Q.
So if I look at Exhibit 4, which I take it 16 Exhibit 4 reflects factors that you used in your first 17 flooding calculation that was done in 199'l, correct?
18 A.
Yes.
19 Q.
So you used the infiltraticn rate of.15 for 20 that calculation?
21 A.
Inches por hour for the large floods.
22 Q.
That represents.15. inches per hour?
23 A.
Yes.
24 Q.
When you talk about the large flood, wnat are 25 you referring to?
{
13 1
A.
Well, I'm referring to the flood by the access 2
road.
1 3
Q.
There's another basin or area that PFS 4
calculated flooding for?
5 A.
That was the site itself.
6 Q.
It just kind of comes off of Hickman Knolls or 7
something?
8 A.
Hickman Knolls, yeah.
And there we used the 9
curve number, which is another measure or another way to 10 calculate losses.
11 Q.
So that's a different way of calculating 12 losses of water that doesn't accumulate as part of the 13 runoff?
14 A.
Yeah, it doesn't become part of the runoff.
15 Q.
What does the curve number represent?
16 A.
The curve number, and we used a curve number
'17 of 70 there.
The curve number method was developed by 18 the Soil Conservation Service, they've become the 19 Natural Resources Conservation Service, and there's a 20 whole set of procedures and equations that relate to the 21 precept and how much is being lost to this curve number.
22 Q.
So the number, again, is another measurement 23 of how much water is part of the runoff that accumulates 24 as part of the flood?
25 A.
Yes.
=-
1 13 1
Q.
Does the curve number represent a percentage?
2 A.
Not a direct percentage, but the larger the 3
curve number the more the runoff.
4 Q.
The larger the curve number, the more the 5
runoff that is available to accumulate as part of the 6
flooding?
7 A.
Yes.
8 Q.
So curve number and infiltration rates are two 9
ways to model the same factor, in a sense?
10 A.
Yes.
But what we do is we use the curve 11 number on small watersheds and short duration storms, 12 really.
We don't really use it over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
13 Q.
Why is that?
14 A.
We don't feel like it accurately reflects the 15 loss.
After a short period of time the curve number 16 method fills up and it doesn't show any more loss.
So 17 if you run into a 72-hour storm as opposed to a 6-hour 18 storm we don't use the method, the curve number method 19 on the long duration storms.
20 Q.
Okay.
Just so that we're clear now, we 21 identified there was two basins or two areas which PFS 22 did flooding calculations for?
23 A.
Yes.
24 Q.
One was kind of like the site itself and the 25 other one was for the access road?
1 1
1 i
i 20 1
1 A.
Uh-huh (af firmative).
2 Q.
And I understand the State does not take issue 3
with the flooding calculation that PFS has done with 4
respect to this smaller basin or the area that is I
5 directly above the site?
6 A.
Yeah, we didn't.
7 Q.
And you do not?
8 A.
We do not.
9 Q.
Take issue with that, correct?
10 A.
Uh-huh (affirmative).
i 11
'Q.
So it's with the larger drainage area, the 12 270-square mile drainage area that affects the access 13 road, that's the one you take issue with PFSs 14 calculation?
l 15 A.
That's the one we did, yes.
1 l
16 Q.
And that's the one you do take issue with 17 today; is that correct?
18 A.
Yes.
I 19 Q.
So looking at this sheet right here real 20 quick, I see a couple of numbers on the bottom after the
}
21 line.
Okay?
22 A.
Yes.
i 23 Q.
I see SVNWa 100 Dat, 44 cfs.
I take it that's i
24 something for the smaller basin with which you don't 25 take issue?
o 27 1
Q.
You don't take issue with the 100-year 2
calculation that Private ruel Storage did?
3 A.
No,_I don't.
j 4
Q.
What's-the difference between a 100-year l
5 flood calculation and the probable maximum flood 6
calculation?
7 A.
They represent two different size of storms.
8 Q.
Let's talk about the 100-year flood 9
calculation first.
What is that. supposed to represent, 10 as far as you understand it?
11 A.
As far as I understand it, it's the type of 12 flood you would expect to occur with the probability of 13
.01, or once in a hundred years.
14 Q.
A chance in a hundred years.
And what is the 15 PMF flood, probable maximum flood?
16 A.
That's the largest flood that would be 17 expected on that, the largest precip.
PMP is probable 18 maximum precip.
So it's the largest precip and the 19 largest flood'resulting from that that could be expected 20 at'that.
21 Q.
And how do you determine the largest precip?
22 A.
The National Weather Service Report, Hydromet 23 49, they've got principles in that for esiculating the 24 probable maximum precip.
25 Q.
And what was the probable maximum precip for
51 1
1 MS. CHANCELLOR:
Objection, he doesn't know 2
how the berm is construe ed.
3 Q.
(BY MR. GAUKLER)
Assuming, hypothetically, 4
the berm is constructed to protect the site from the 5
flood then you would have no issue with this part?
6 MS. CHANCELLOR:
Same objection.
7 Q.
(BY MR. GAUKLER)
You may answer if you can.
8 MS. CHANCELLCR:
Certainly.
You.can answer it 9
if you;can.
i 10 THE WITNESS:
If the berm was constructed 11 correctly and the road gets-- there's a way for the road 12 to get past the berm without breaching its purpose then 13 yes.
14
'Q.
(BY MR. GAUKLER)
Wouldn't the berm just be 15 like a speed bump in the road?
16 A.
I don't know.
It may be.
You'll have to tell 17 me.
18 Q.
Okay.
19 MS. CHANCELLOR:
That was my objection.
20 Q.
(BY MR. GAUKLER)
Going back to your recent 21-calculation, you again used an infiltration rate of.15?
22 A.
Yes.
23 O.
You did not use a CN number for this?
24 A.
Not for the calculation of large drainage, 25 long duration storms.
52 1
Q.
Because?
2 A.
Because we con't feel like the curve number 3
represents the loss rate on the long duration storm.
4 Q.
So you've used the infiltration rate instead 5
for your calculation?
6 A.
Yes.
7 Q.
In lieu of a CN number?
8 A.
In lieu of a CN number.
9 Q.
I understand.
Off the record for a second.
10 (Discussion held off the record.)
11 MR. GAUKLER:
Let's take a five-minute break 12 since we've been going about an hour.
13 (Short recess.)
14 Q.
(BY MR. GAUKLER)
Back on the record.
I would 15 like to have you look at Exhibit 7 again, which is the 16 PFS flood analysis with the larger drainage basin area i
17 of 270 square miles.
We identified earlier that the 18 time of concentration as one area in which you took 19 issue with the calculation.
Are there any other areas 20 with which you take issue with respect to this 21 calculation, Exhibit 7?
22 A.
Well, they've really-- I mean, in some ways 23 this is almost like an art form, but I feel like they've 24 overestimated the time of concentration and by using the 25 curve. number they've actually underestimated the loss j
]
53 1
so--
2 Q.
The curve' number?
3 A.
It's my understanding they've used curve 4
numbers in these runoff calculations.
So, I mean, 4
5 there's a difference.
But one is one direction and the 6
one is the other.
7 Q.
One is what?
What do you mean by one is one 8
direction?
9 A.
Well, a longer time of concentration gives a 10 smaller flood where using.the curve. numbers instead of 11-the constant infiltration rate is actually increasing 12 the size of the flood plain.
So there's a little bit 13 of--
14 Q.
So using a. curve number of 70 actually 15 increases the size of the flood?
16 A.
On a large.
17 Q.
On a large?
18 A.
On a large duration flood like this.
19 Q.
So using the curve number of 70 is better than 20 using the infiltration rate of 1.5 that you used?
'21 A.
Yes, it would be.
22 Q.
So there's offsets?
23 A.
Yes.
24 Q.
So if you went up and used a higher curve 25 number yet, for example, of 96, that would increase it
54 l
1 much more yet, correct?
2 A.
Not a great deal because the curve number 3
actually fills up in the first part of the flood and i
4 then there's no more infiltration.
So there's a limit 5
to how effective that is.
6
-Q.
You did something different, but what Private 7
Fuel Storage did in their calculation is actually more 8
conservative than you did on this second point?
4 9
A.
Yes, on at second point.
10 Q.
Anything else that you identified?
11 A.
No, that's it.
12 Q.
Now, on your calculation, look at Exhibit 2, 1,3 the first page.
Just the very first page.
14 A.
Okay.
15 Q.
You calculated, I guess, a peak PMF flow of 16 64500 cfs?
17 A.
Yes, using this calculation.
18 Q.
And PFS calculated a maximum PMF flow of 53000 19 cfs?
20 A.
Yes.
That's what I extracted from here.
21 Q.
And that results in a difference in elevation 22 of less than a foot, as you point out in the first page 23 of Exhibit 2, correct?
24 A.
Yes.
25 Q.
Have you reviewed a recent filing by PFS
55 1
following up on some questions in terms of flooding at 2
the site?
I show you a document dated May 18, a letter.
3 Have you seen this document?
4 A.
I don't know whether I've seen this cae.
I 5
don't believe I have.
6 MS. CHANCELLOR:
Have we gotten copies of 7
this, Paul?
8 MR. GAUKLER:
You should have.
You're on 9
here.
You're on the cc list, anyway.
I've been trying 10 to make sure they do that.
11 MS. CHANCELLOR:
Yes, they have been very 12 good.
It often takes-- the 18th.
What day was that?
13 MR. GAUKLER:
I think the first couple of 14 page's, I can mark this as an Exhibit-- let's mark it as' 15 Exhibit 9.
16 (Exhibit 9 marked for identification.)
17 MS. CHANCELLOR:
It often takes up to five 18 days from this date to get to us s0 ne probably hasn't 19 seen it.
20 THE WITNESS:
Yes, I haven't seen it.
21 Q.
(BY MR. GAUKLER)
The first page of the 22 enclosure refers to the fact,that they are redoing the 23 calculation to a CN of 96; do you see that?
24 A.
Yes.
25 Q.
Which is a much more conservative CN number,
56 1
correct?
l l
2 A.
Yes.
It's approaching 100 which is no loss.
3 Q.
Which is much more conservative than your 4
infiltration rate of 1.5, then, correct?
5 A.
Yes.
1 6
Q.
And they calculate a PMF of 85000 cfs using f '
7 that?
8 A.
That's what tne comment on the front of this 9
is so I assume that's it.
10 Q.
You haven't had a chance to review it, but you 11 assume that's what it shows, right?
12 A.
Yes.
13 Q.
And 85,000 is greater than what you calculated 14 of 64,000?
15 A.
Yes, it is.
16' Q.
I would like to show you your Second Amended 17 Responses to Interrogatories.
These are already on the 18 record so I won't mark this.
These are responses 19 concerning Utah N which you were responsible for, again, 20 correct?
21 A.
Yes, they are.
22 Q.
If you look on page 7, please, Interrogatory 2 23 says, " Identify and fully explain each respect in which 24 the State claims that the facilities designed is no:
25 adequate to protect access to the site against adverse i
57 L
1 consequences for potential flooding as cultivated by the 2
State."
3 And the response says, "In PFSF cross-sections 4
described in down view of the access road, PFSF appears 5-to assume that a vertical berm is in place to prevent 6
the PMF flood discharge from spreading west on the 7
access road and possibly flooding the site.
There is 8
not enough information shown to describe the geometry of 9
the berm an'd how the access road gets past the berm."
10 That's what we discussed previously, right?
11 A.
Yeah.
That's what I raised a minute ago.
4 12 Q.
And if the berm were constructed to protect 13 the site from 85000 cfs flood, then that would protect 14 it from your 64000 cfs flood, right?
15 A.
Yes.
16' Q.
And you go on to say that-- it refers to the i
17 fact that "the access road may be flooded or washed out 18 preventing necessary operations, personnel or emergency 19 services to provide access to the site."
20 What would be the adverse consequences of the 21 access road being flooded out in that sense, to the 22 health and safety of the public, do you know?
23 A.
Well, like it says here, it would just prevent 24 someone accessing the sit.e if you needed to.
25 Q.
That would be the only thing?
j
1 58 1
A.
That's all I know, i
l 2
Q.
Do you know what consequences that would 3
result in if they weren't able to access the site if 4
scmebody was stranded on the site?
5 A.
I wouldn't expect them to be too great.
I 6
mean, that's--
7 Q.
Okay.
8 A.
Unless something was going on out there that 9
you needed to take care of in an enargency.
10 Q.
And also, it's possible to rent a helicopter 11 or something like that too, correct?
12 A.
I suspect so.
This is a big flood so maybe 13 it's raining real hard.
14 Q.
Talking about the PMF and 100-year flood.
15 With respect to generally structures and buildings, l
16 they're usually designed to protect against the 100-year 17 flood as opposed to a PMF flood; isn't that correct?
18 A.
When you say buildings, I'm not sure we could 19 say buildings, but in some cases they are.
I mean, I
(
20 was trying to think.
Like FEMA will require flood 1
21 insurance if you're in a 100-year flood plain.
22 Q.
Right.
And there are special restrictions if 23 you're within the 100-year ficod plain, yes?
24 A.
If you're within a 100-year flood plain, yes.
25 Q.
And that's where FEMA tries to discourage l
EXCERPTS FROM STATE OF UTAH'S SECOND AMENDED RESPONSES AND SUPPLEMENTAL RESPONSES TO APPLICANT'S FIRST SET OF FORMAL DISCOVERY REQUESTS t
W
E UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of:
)
Docket No. 72-22-ISFSI
)
PRIVATE FUEL STORAGE, LLC
)
ASLBP No. 97 732-02-ISFSI
{
(Independent Spent Fuel
)
Storage Installation)
)
May 12,1999 STATE OF UTAH'S SECOND AMENDED RESPONSES AND SUPPLEMENTAL RESPON3ES TO APPLICANT'S FIRST SET OF FORMAL DISCOVERY REQUESTS The State of Utah amends and supplements its April 14,1999 and April 29, 1999 response to the Applicant's First Set of Formal Discovery Requests (" Applicant's Discovery Requests"). This response supplements the State's responses to General Interrogatories Nos. 3 and 4, and Document Requests for Utah Contention K (Inadequate Consideration of Credible Accidents) and Utah Contention M (Probable Maximum Flood); and amends Request for Admissions Nos.14,15, and 16 for Utah K; Request for Admissions Nos.1 and 4 and Interrogatories 1-6 for Utah M; and corrects pages 37 and 53 in the State's April 14,1999 Response to Applicant's Discovery Requests.
I.
STATE'S SUPPLEMENTAL RESPONSES TO GENERAL INTERROGATORIES GENERAL INTERROGATORY NO.1.
State the name, business address, and job title of each person who was consulted and/or who supplied
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were originally scheduled to be completed by mid 1999. However, it is almost mid.
i 1999 and no space plan flights have occurred to date.
B.
Amended Responses to Requests for Admissions for Utah Contention M Probable Maximum Flood
._ REQUEST FOR~ ADMISSION NO.1 - UTAH M.
Do you admit that -
the 270 square mile drainage area used to calculate flooding in PFS's response to RAI
_ Question 2-3 is an appropriate drainage area for calculating the potential for flooding at the PFS ISFSI?
STATE'S AMENDED RESPONSE TO REQUEST FOR ADMISSION NO.
1 UTAH M:
The State admits that the 270 square mile drainage area is an appropriate drainage area for calculating the potential for flooding at the PFS ISFSI.
REQUEST FOR ADMISSION NO. 4 - UTAH M..
Do you admit that the lowest elevation of the PFS site as identified in the PFS Environmen.al Report at 2.5-3 and Response to RA1 Question 2-3 at 3 is 4460 ft.?
SIATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION NO.
4 - UTAH M:
Admit in part and deny in part. Admit that the PFS Environmental Report at 2.5 3 and Response to RAI Question 2-3 at 3 identify an " approximate" ISFSI site
. elevation low of 4460 feet. Deny that 4460 feet is the lowest elevation at the PFS site.
Other RAI responses by the Applicant use different lowest site elevation figures for the ISFSI site. See e.g., Enclosure to Commitment Resolution Information, PFS Response to RAI 2 3 (second round), Flooding Analysis, at 1 ("[t]he lowest corner of the PFSF site (elevation 4462 ft)"), submitted by PFS to NRC under cover letter dated March 25, 5
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1 1999. Further, the State does not have access to the ISFSI site and, thus, has not conducted a ground survey to verify PFS's claim that 4460 ft. is in fact the lowest elevation at the PFS site. In addition, the ER and the RAI responses do not contain l
l the basis for PFS's estimation that the lowest elevation at the PFS site is 4460 ft.
l C.
Amended Responses to Interrogatories - Utah Contention M l
INTERROGATORY NO.1 - UTAH M. Identify and fully explain each respect in which the State claims that PFS failed "to accurately estimate the Probable l
Maximum Flood (PMF) as required by 10 CFR $ 72.98" or the 100 Year Flood for the PFS ISFSI, taking into account PFS's response to RAI Question 2-3 as supplemented.
STATE'S AMENDED RESPONSE TO INTERROGATORY NO.1 -
UTAH M:
The State has reviewed PFS's responses to RAI Question 2-3, as last supplemented on March 25,1999, and has now re-calculated the Probable Maximum 8
Flood based on the following parameters and a computer program developed by the State based on Soil Conservation Service (now called Natural Resources Conservation Service) methods to generate a storm hydrograph, including peak flow rate. The inputs into this program include drainage area: 270 square miles area (see Admission No. I above); time of concentration (T) (based on the Army Corps of Engineers formula): 8.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; infiltration rate (curve number): 0.15 inch per hour (State's
' PFS's Interrogatory asks that the State take into account PFS's response to RAI Question 2 3 as supplemented. Since PES's supplementation of this RAI question was sent to NRC under cover letter dated March 25,1999, it is inappropriate for PFS to complain that the State has had the supplemented answer "since mid February." See Applicant's Motion to Compel dated April 22,1999 at 7.
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original parameter based on the soil and vegetation in the drainage area). The storm L
hydrograph generated a peak flow rate of 64,500 cfs. After the State generated the
. storm hydrograph, it used the Corps of Engineers HEC-RAS program and the cross sections describing the geometry of the flood channel from PFS recent calculations: (p,
- 17) to compute the probable maximum flood elevation at and near the PFS site.
INTERROGATORY NO. 2 - UTAH M. Identify and fully explain each respect in which the State claims that the facility's design does not adequately protect j
the access road or the site against adverse consequences from potential flooding as calculated by the State.
STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 2 -
)
UTAH M:
In PFS's cross sections describing the geometry of the access road, PFS appears to assume that a vertical berm is in place to prevent the PMF f'lood discharge from spreading west along the access road and possibly flooding the site. There is not 3
enough information shown to describe the geometry of the berm and how the access road gets past the berm. It appears that without this berm or with aninadequate berm the PFS site would be flooded by water backed up by the access road during the PMF 2 Zeng, V N. an 1 Liang, G.H.C. (Stone oc Webster Engineering Corp.), March 22,1999, PFSFFlood Analysis unh Larger Drainage Basin, Calculation No.
0599602G(B) 12, Rev.1, submitted by PFS to NRC under cover letter dated March 25, 1999, from John L. Donnell to Mark Delligatti, NRC.
3 See e.g., Figure 1, Hydraulic Model at Access Road Crossing (p. 6), Zeng, V.N.
and Liang, G.H.C. (Stone oc Webster Engineering Corp.), March 10,1999, PFSEFlood A nalysis with Proposed A ccess Road and Rail Road, Calculation No. 0599602G(B)-17, Rev. O, submitted by PFS to NRC under cover letter dated March 25,1999, from John L. Donnell to Mark Delligatti, NRC.
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l-flood. Additionally, the access road may be flooded or washed out, preventing necessary operations, personnel or emergency service providers access to the site.
Hence the Applicant would not be able to cope with emergencies as required by 10 CFR 72.24(k).
INTERROGATORY NO. 3 - UTAH M. Identify and fully explain each respect in which the State claims that the access road may be adversely impacted by potential flooding as calculated by the State and any resulting adverse safety consequences to the PFS ISFSI.
STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 3 -
' UTAH M:
See State's amended response to Interrogatory 2 - Utah M. Additionally, the State's present calculation shows that flooding would be approximately 3.5 feet deep j
where it crosses the access road. As stated in Response to Interrogatory No. 2, this would result in preventing necessary operations, personnel or emergency service providers access to the site.
INTERROGATORY NO. 4 - UTAH M. Identify and fully explain each respect in which the State claims that " consequences important to safety may occur because of flooding or an inadequate berm construction and location," based on potential flooding as calculated by the State.
STATE'S AMENDED RESP 7NSE TO INTERROGATORY NO. 4 -
UTAH M:
See State's amended response to Interrogatory 2 - Utah M.
INTERROGATORY NO. 5 - UTAH M. Identify and fully explain each other respect in which the State claims that the PFS ISFSI site may be adversely impacted by potential flooding as calculated by the State and the resulting adverse safety 8
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STATE'S AMENDED RESPO3SE TO INTERROGATORY NO. 5 -
UTAH M:
See State's amended response to Interrogatory 2 - Utah M.
INTERROGATORY NO. 6 - UTAH M. If the State continues to claim an adverse impact from potential flooding as calculated by the State on the " operation, maintenance of the ISFSI," the " washing out" of the access road, the " translation motion of the storage pad and building foundations," and the " transport (of] onsite chemical and radiological contaminants to offsite soils and ground and surface waters,"
identify and fully explain the scientific, technical, engineering and/or other bases on which the State bases these claims and any other claims of adverse impact and/or safety consequences identified in response to interrogatories 3 through 5 above.
STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 6 -
UTAH M:
See State's amended response to Interrogatory 2. Utah M. Furthermore, until the State can accurately ascertain the lowest elevation at the ISFSI site, it cannot fully respond to this interrogatory.
IV.
CORRECTIONS TO STATE'S RESPONSES DATED APRIL 14,1999, TO UTAH CONTENTIONS K AND N.
A.
State's Correction to Contention K, Response to Interrogatory No. 2:
Correction to page 37, fourth line of the response: Change the word " confine" to " confound."
B.
State's Correction to Contention N, Response to Request for Admission No.1:
Correction to the propeny description on page 53,1 ( b), which has three 9
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,.4 references, instead of two, to "the SE 1/4 of" and should read as follows: "within the N1/2 of the SE1/4 of the SE1/4 of Section 12, Township T1S, Range R8W."
DATED this 12* day of May,1999.
Respectfully s
- itted, STATE OFf H '
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Denise ' Cyan'cellor, ssistant AtWtGe W Fred G Nhlson, Assistant Attorney General Dime Curran, Special Assistant Attorney General Connie Nakahara, Special Assistant Attorney General Daniel G. Moquin, Assistant Attorney General Attorneys for State of Utah Utah Attorney General's Office 160 East 300 South,5th Floor, P.O. Box 140873 Salt Lake City, UT 84114 0873 Telephone: (801) 366-0286, Fax: (801) 366 0292 i
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