ML20204B735
| ML20204B735 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 03/17/1987 |
| From: | Locke R PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - HUMBOLDT BAY |
| References | |
| CON-#187-2888 OLA, NUDOCS 8703250138 | |
| Download: ML20204B735 (27) | |
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2 78f nuito conatwo. tune 00CHETED USNHC 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 17 MAR 23 All'A3 2
BEFORE THE ATOMIC SAFETY AND LICENSING ROARD,g, g ,, , ,.g .
3 60gE'iiN r. . '.t i . i..
iep p y
) Docket No. 50-133-N#
5 In the Matter of )
)
6 PACIFIC GAS AND ELECTRIC COMPANY ) (Decommission 1r.1)
)
7 (Humboldt Bay Nuclear Power )
Plant Unit 3) ) March 17, 1987 8 )
9 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S 10 RESPONSE TO THE SECOND SET OF {
INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS 11 12 INTERROGATORY NO. 122:
13 Does the licensee intend to install a cover over the spent pool?
14 ANSWER NO. 122:
15 Yes.
16 INTERROGATORY.NO. 123:
17 If your answer to the preceding interrogatory is in the affirmative, 18 please state:
19 (a) the intended date of installation:
20 (b) the thickness of the material that will make up the cover; 21 (c) a description of the material the cover will be made of; 22 (d) the name, address and phone number of the cover 23 manufacturer / fabricator.
24 ANSWER NO. 123:
25 Installation of the cover over the spent fuel storage pool was 26 t.ompleted in January 1987. In addition to serving as a contamination control 0703250130 070317 h PDH ADOCK OD000133 0 PDR i
r D
1 barrier, the cover also serves as a security barrier. As such, details of 2 design and fabrication are withheld from public disclosure in accordance with 3 10 CFR 73.21. 3 4 INTERROGATORY NO. 124: l 5 How many fuel rods are contained in the 390 spent fuel rod assemblies
'6 presently contained in the spent fuel pool?
7 ANSWER NO. 124: l 8 There are 15,184 spent fuel rods presently contained in the spent 9 fuel pool.
10 INTERROGATORY NO. 125:
11 Nhat is the gross weight of rach fuel rod in the spent fuel pool?
12 ANSWER NO.'125:
13 The average gross weight of each fuel rod in the spent fuel pool is 14 approximately 3 kilograms. This is calculated based on the average weight of 15 a typical assembly divided by the number of fuel rods in an assembly.
16 INTERROGATORY NO. 126:
17 Nhat is the total weight of the uranium fuel contained in each fuel 18 rod in the spent fuel pool?
19 ANSWER NO. 126:
20 The average total weight of uranium contained in each fuel rod is 21 1.858 kilograms.
22 INTERROGATORY NO. 127:
23 Please state the title, author and date of pubitcation of each 24 document, text or reference on which you relied to formulate your answer to 25 interrogatory No. 1267 26 ///
1 ANSWER NO. 127:
2 Two references are relied upon to formulate our answer to 3 Interrogatory No. 126. ,
4 1. DOE Form RN-859, " Nuclear Fuel Data Form," for Humboldt Bay Power 5 Plant Unit 3 December 31, 1986.
6 2. DOE /NRC Form 742C, " Physical Inventory Listing," for Humboldt Bay 7 Power Plant Unit 3, April 30, 1986.
8 INTERROGATORY NO. 128:
9 Nhat is the total weight of all of the uranium fuel contained in all 10 of the fuel rods that are stored in the spent fuel poo11 11 ANSWER NO. 128:
12 The total weight of uranium stored in the spent fuel pool is 13 28,212.402 kilograms.
i 14 INTERROGATORY..NO. 129:
15 Please state the title, author and date of publication of each 16 document, text or reference on which you relied to formulate your answer to 17 interrogatory No. 1287 18 ANSWER NO. 129:
! 19 See Answer No. 127.
20 INTERROGATORY NO. 130:
l j 21 What is the total weight of that part of the uranium fuel contained 22 in the spent fuel pool that is made up of uranium 2357 23 ANSRER NO. 130:
24 The total weight of uranium 235 contained in the spent fuel pool is 25 329.411 kilograms.
I i 26 ///
s P
1 INTERR0GATORY NO. 131:
2 Nhat is the total weight of that part of the uranium fuel in the 3 spent fuel pool that is made up of uranium 234?
4 ANSNER NO. 131:
5 The total weight of uranium 238 contained in the spent fuel pool is
'6 27,822.966 kilograms.
7 INTERROGATORY NO. 132:
8 What is the total weight of uranium fuel in the spent fuel pool that 9 is made up of plutonium 2397 10 ANSWER NO. 132:
11 The total weight of plutonium 239 contained in the spent fuel pool is 12 95.944 kilograms' .
13 INTERR0GATORY No 133:
14 What is the total weight of all other transuranic elements contained 15 in the spent fuel in the spent fuel pool?
16 lutSWER No.133:
17 The total weight of all transuranic elements except plutonium 239 18 contained in the spent fuel pool is 342.358 kilograms.
19 INTERROGATORY NO. 134:
20 Please set forth the name of the author, date and title of each 21 " writing" that you relied to answer questions 130, 131, 132, and 133?
22 AN1MER N0._134:
23 ,
see Answer No. 127.
24 INTERROGATORY NO. 135:
25 Has the NRC performed a periodic Systematic Assessment of Licensee 26 Performance (SALP) for the Humboldt Say Unit 3 in the last three years?
1 ANSNER NO. 135:
i 2 h.
3 INTERROGATORY NO. 136: ;
4 If your answer was in the affirmative, please state what the NRC's ;
5 Systematic Assessment of Licensee Performance concluded for each of the last 6 three years?
7 ANSNER NO. 136:
8 Not applicable. '
9 INTERR0GATORY NO. 137:
10 If your answer to question No. 135 was in the affirmative, please 11 state the name, address and phone number of the employee who has custody of 12 the Licensees' copy of the SALP?
, 13 ANSWER NO._137.:
l 14 Not applicable.
15 INTERROGATORY NO. 138:
r
, 16 In your answers to interrogatories 51, dated February 2, 1987, you 17 indicated that the Licensee had not determined the maximum eerthquake which ,
is may occur on nearby faults at the point closest to the facility. Does the 3
! 19 licensee presently have a study or studies underway to determine what the -
1
- 20 maximum credible earthquake on the Little Salmon, Suhne Point, Bay Entrance or 21 North Spit fault would be?
22 ANSNER NO. 138:
4 23 No.
24 INTERROGATORY _.NO._139:
25 If your answer is yes, to interrogatory No.138, please indicate the 26 name of the person or company that has responsibility for carrying out the i
D I study, their address and the date they expect to complete their work 2 assignment?
3 ANSWER N0. 139: ,
4 Not applicable.
5 INTERROGATORY NO. 140:
6 In your answer number 51 to interrogatories, dated February 2, 1987, 7 you state at the end of your answer that "In any event, when postulated 8 accidents and associated consequences were evaluated for SAFSTOR, no credit g was taken for the structural integrity of any structure whose function was to 10 prevent or mitigate the consequences of such accidents." Please explain what 11 structures "whose function was to prevent or mitigate the consequences of such 12 accidents" your answer refers, and identif3 their location?
13 ANSHER N0..140:
14 The structures referred to in the answer to Interrogatory No. 51, 15 dated February 2, 1987, included the spent fuel pool, the fuel handling 16 building, and the off-gas stack. It should be noted that the functions of the 17 structures referred to in the earlier answer were those functions previously la intended for the operating plant.
Ig INTERR0GATORY..NO _141:
20 Do you contend that the Environmental Report prepared by Itcensee 21 addressed the possibility of the spent fuel building collapsing during an 22 earthquake on to the fuel in the spent fuel pool?
23 ANSWER,E E :
24 Yes.
25 INTERROGATORYJ0_142:
26 If your answer to interrogatory No.141 is in the affirmative please O
I state where in the Environmental Report the licensee addressed this issue.
2 ANSWER No. 142:
3 The Environmental Report, Section 6.3, documents PGandE's evaluation 4 of the consequences of postulated accidents during SAFSTOR. The evaluations 5 performed by pGandt assumed, for radiological consequence analysis, that all 6 the spent fuel was damaged by an accident of unknown origin, and that the 7 entire gaseous fission product inventory was released. The resulting doses 8 would remain within regulatory limits. The consequences of the spent fuel 9 building (refueling building) collapsing during an earthquake on to the fuel 10 in the spent fuel pool are enveloped by the evaluations documented in 11 Section 6.3 of the Environmental Report, as supplemented in pGandt responses 12 to NRC questions, dated February 28, 1985 (HOL-85-005).
13 INTERROGATORY No. 143:
14 If your answer to interrogatory No. 141 is in the negative, please 15 state why this possibility was not addressed?
- 16 ANSWER No. 143:
17 Not appilcable.
13 INTERR0GATORY N0 _144:
Ig Is it the licensee's contention that the Licensee is precluded by 20 governmental regulation, Iaws or rules from removing the spent fuel to a 21 Federal Interim Storage (FIS) facility?
22 ANSHIA N0 _144:
23 ,
The requirements for spent fuel storage in a federal facility have 24 been defined in the Nuclear Maste Policy Act of 1982 and in applicable NRC 25 regulations (10 CFR 53). According to these requirements, a civilian nuclear 26 power reactor licensee can only remove spent fuel to a Federal Interim Storage I facility after it has demonstrated that other alternatives have been pursued 2 but cannot reasonably be provided by the licensee. PGandE's SAFSTOR proposal 3 for HBPP has been made in recognition of these requirements and the fact that 4 such an interim facility does not currently exist.
5 INTERROGAT0AY N0 m145:
'6 If your answer to interrogatory No.144 is in the affirmative, please 7 state each and every reason why the licensee feels that it is precluded from 8 removing the spent fuel to a Federal Interim Storage facility and provide the.
9 governmental regulation, rule or law on which the answer is based?
10 ANSMER..NO J :
11 See Answer No. 144.
12 , INTERROGATORY NO 146:
13 If the Licensee does not contend that it is barred by governmental 14 rules, regulations or laws from removing the fuel to an FIS, does the licensee 15 nevertheless contend that some other factor or impediment would make removal 16 of the fuel stored at the facility impracticalf 17 MSHER No. 146: ,
18 See Answer No. 144.
19 MIIHQGMORL80.147:
20 If your answer to the preceding interrogatory is in the affirmative, 21 please state each and every reason you contend removal of the spent fuel is 22 impractical.
23 MSHELNO.147:
24 See Answer No. 144, 25 HIEROGMQREN0.148:
26 Please state the date of each earthquake, its epicenter, the gravity I and ground acceleration of the earthquake as recorded by each of the strong 2 ground motion indicators located at the licensees' facility between 1971 and 3 the present.
4 ANSWER N0._148:
5 PGandE is compiling the historical data associated with the recorded 6 earthquakes. However, the compilation has not yet been completed. PGandE 7 will furnish the data once the compliation is complete.
8 INTERROGATORY N0..149:
3 please state how many fuel rods are only partially spent of the total 10 number of rods stored in the spent fuel pool?
11 ANSWER N0. 149:
12 pGandt i:ensiders all of the fuel currently stored in the spent fuel 13 pool at H8pp Unit 3 as spent fuel. Only 140 of the 390 fuel assemblies have 14 undergone reactor exposures less than that normally espected of a fuel 15 assembly, which is nominally the burnup associated with three cycles of 16 reactor operation. In particular, these 140 spent fuel assemblies, removed 17 from the reactor in 1984, have burnups ranging from 5,009 to 15,492 13 megawatt-days per metric ton of uranium. The other 250 spent fuel assemblies It have burnups ranging from 14,400 to 19,481 megawatt-days per metric ton of 20 uranium.
21 M f0RY-No. 1501 22 please provide a list of all abnormal incidents that have occurred 23 involving the spent fuel pool, which Ilst should include the date of the 24 occurrence, the person who reported the incident and the number or identifying 25 label of the report submitted to the NRC, which have occurred since the 26 beginning of operations at Unit 3 to the present.
9
1 ANSMER No. 150:
2 Incident 1: Spent fuel pool liner leakage following installation of the liner.
3 Date of Occurrence: Second half of 1963 (actual date leakage began is
, 4 unknown).
5 Reports: The incident was reported and status of repairs was discussed in the
'6 fo110 wing reports from PGandt to the NRC:
7 a. Report on the operation of Humboldt Bay Power Plant, Unit 3, 8 covering the period of February 16, 1963, thrcugh August 16, 9 1963.
10 b. Report on the operation of Humboldt Bay Power Plant, Unit 3, 11 covering the period of August 14, 1963, through February 12 15,1964.
13 c. Pacific Gas and Electric Company. Humboldt Bay Power Plant, 14 Unit 3. Annual Operations Summary Report, 1964.
15 Incident 2: Spent fuel pool Itner leakage.
16 Date of Occurrence: March 1966.
17 Reports: The incident was reported and status of investigations and revised le operating procedures were discussed in the following reports:
19 a. Report on the 6peration of Numboldt Bay Power Plant, t.'ntt 3, 20 covering the period of February 16,1966, through 21 August 15,1966.
22 b. Report on the operation of Humboldt Bay Power Plant Unit 3, 23 ,
covering the period of August 16,1966, through 24 February 15,1967.
25 c. Pacific Gas and Electric Company, Humboldt Say Power Plant, 26 Unlt 3 Annual Operations Summary Report. 1966.
I d. Report on the operation of Humboldt Bay Power Plant Unit 3, 2 covering the period of February 16, 1967, through 3 August 15,1967. ,
4 e. Report on the operation of Humboldt Bay Power Plant, Unit 3, 5 covering the period of August 16, 1967, through
- 6 February 15, 1968.
7 f. Pacific Gas and tiectric Company, Humboldt Bay Power Plant, 8 Unit 3. Annual Operations Summary Report, 1967.
9 Incident 3: Dropped shipping can containing spent fuel assembly.
10 Date of Occurrence: July 6, 1969.
11 Reports: The incident was reported to the NRC in the following report:
12 Pacific Gas and Electric Company, Humboldt Bay Power 13 Plant. Unit 3. Semi-Annual Operations Report No. 69-2, 14 July 1, 1969 through December 31, 1969. e 15 Incident 4: Damaged fuel assembly while moving it in the spent fuel pool.
16 Date of Occurrence June 4, 1975.
17 Reports: The incident was reported to the NRC by telephone on June 5, 1975 by 18 Messrs. M. A. Raymond and E. D. Weeks. Written notification was 19 made in a letter dated June 11, 1975 from Mr. Philip A. Crane, Jr.
20 Incident 5: Spent fuel pool liner gap level exceeded the control band.
21 Date of Occurrence: December 22, 19R6.
I 22 Report: The incident was reported to the NRC by Mr. J. D. Shlffer on 23 January 22,1987 in I.lcense Event Report 3-86-003-00.
t 24 IMIIMOMIDRY NO.151:
25 Please provide the name, title, phone number and address of the 26 custodian of the records who has custody of the records requested in (
r
, I
E 1 interrogatory No. 150?
2 ANSWER NO. 151!
3 The name of the custodian of records is Bradford R. Hayes. He is 4 located at Room 1496, 77 Beale Street, San Francisco. The phone number is 5 (415) 781-4211.
6 INTERR0GATORY NO. 152:
7 Assuming, for the purposes of this interrogatory, that more than 8 101 of the fuel in the spent fuel pool began to go critical after being 9 damaged in an earthquake, what emergency contingency plans does the Ilconsee 10 have to abort the fuel going critical and to contain the accident?
11 ANSWER _N0,_112:
12 In order to preclude criticality in the spent fuel storage pool 13 following an event which may result in movement or damage to the fuel 14 assemblies, each fuel assembly has been enclosed in a can fabricated from 15 neutron-absorbing material (Boral). The Boral cans serve as an integral part 16 of the NBPP fuel assemblies and ensure that the k-effective will be less than 17 0.95 for the worst credible rearrangement of fuel. Therefore, the assumed 13 accident stated in the interrogatory is not credible and, accordingly, PGandt 19 does not have any emergency contingency plans to address such a noncredible 20 accident.
21 Bluft0GMQlLLNom In 22 What is the pounds per square inch (PSI) containment rating of the 23 spent fuel building?
24 M1HERh0 IU!
25 The spent fuel (refueling) building is designed to withstand a l
26 pressure of seven inches of water app 11ed internally or externally. This I pressure is equivalent to approximately 0.25 pounds per square inch.
2 INTERR0GATORY N0. 154:
3 please state how high above the mean high tide line,of Humboldt Bay 4 the floor of the spent fuel storage pool is located?
5 AN5NER N0. 154:
8 The floor of the spent fuel storage pool is located 14 feet below 7 sean lower low water, which by definition is below the "mean high tide line" 4 referred to in the interrogatory.
9 INTERR0GATORY N0. 155:
10 please define what is meant by the phrase "uncanned fuel assembly"?
11 AN5NER b0. 155:
12 pGandt is presently unable to give a response to this interrogatory 13 since the source of the phrase used by the Intervenors here has not been 14 identified.
15 INTERROGATORY N0. 158:
le please state the title, author and date of publication of each report 17 the licensee believes supports its assertion that the fuel in spent fuel pool 18 would not be substantially degraded by heating if all the pool water in the 19 pool were lost?
j 20 MSEd No. 158:
21 NRC question 84 transattied by letter dated January 23,1985 l
22 concerned the consequences of loss of water in the spent fuel pool on the l
23 fuel. pGandt's response of February 28, 1985, concluding that the fuel
'24 cladding would remain intact, was based on NUREG/CR-0649, " Spent Fuel Heatup f
25 Following Loss of Water During Storage " March 1979, written by Sandla l
24 National Laboratory. Additionally, the NRC Staff filed a report with the ASLO l
l LA.
4 s
1 on November 19, 1981 which stated that Staff studies had concluded the HBPP 2 fuel has decayed sufficiently so that air cooling is adequate to preserve 3 cladding intregrity. .
4 INTERROGATORY NO. 157:
5 Please state the name, occupation, business address and provide a .
-6 narrative statement of the qualifications of each witness the licensee intends
] 7 to call as a witness at the evidentiary hearing that will be held in this 8 matter?
9 ANSWER NO. 157:
10 PGandE has not yet determined all the witnesses that it intends to 11 call in an evidentiary hearing in this matter. However, when all witnesses 12 have been identified, qualification statements will be made available. At this time, PGandE definitely intends to call Mr. R. T. Nelson as a witness.
13 14 The occupation and business address along with a narrative statement of his 15 qualifications are provided in Attachment 1.
16 INTERROGATORY NO. 158:
4 17 Please state the' occupation, company affiliation, if any, and provide
, 18 a narrative statement of the qualifications of Frank W. Brady?
19 ANSHER NO. 158:
20 The occupation,-company affiliation, and a narrative statement of the 21 qualifications of Frank H. Brady are provided in Attachment 2.
22 INTERROGATORY NO. 159:
23 Please stab the occupation, company affiliation, if any, and provide 24 a narrative statement of the qualifications of Lloyd S. Cluff?
25 ANSHER NO. 159:
26 ///
I The occupation, company affiliation, and a narrative statement of the 2 qualifications of Lloyd S. Cluff are provided in Attachment 3.
3 Respectfully submit'ted, 4 BRUCE NORTON c/ R. F. Locke 5
6 H0HARD V. GOLUB RICHARD F. LOCKE 7 Pacific Gas and Electric Company P. O. Box 7442 8 San Francisco, California 94120 (415) 781-4211 9
Attorneys for 10 Pacific and Electric Company 11 12 gy gr 30 R c at F'. Locke 13 j 14 DATED: March 17, 1987
< 15 16 17 18 19 20 21 22 23 ,
24 25 26
ATTACHMENT 1 PROFESSIONAL QUALIFICATIONS OF ROBERT TERRY NELSON My name is Robert Terry Nelson. I am Plant Manager of the Humboldt. Bay Power Plant (HBPP) and Project Manager for decommissioning of HBPP Unit 3.- I have.
~ worked at HBPP since 1977 in the positions of Training Coordinator, Senior Power Production Engineer, and Power Plant Engineer. I became Plant Manager in 1986.
I graduated from the University of Washington in 1970 with a Bachelor of Science degree in Electrical Engineering. Following graduation, I received a commission in the U. S. Navy and served in the Navy Nuclear Power Program until 1977. During that . time, I qualified as Engineering Officer of the Hatch on four different nuclear reactors and was qualified by the Director, Division of Naval Reactors to serve as Engineer Officer on a nuclear-powered ship. I currently hold a Nuclear Regulatory Commission Senior Reactor Operator License for HBPP Unit 3.
I have completed the course " Decommissioning and Decontamination of Nuclear Facilities" presented by Technical Seminars, Inc. In July, 1985, I presented a paper titled "SAFSTOR Decommissioning of the Humboldt Bay Power Plant Unit 3" at the International Nuclear Reactor Decommissioning Planning Conference, sponsored by the Nuclear Regulatory Commission Office of Nuclear Regulatory Research.
(
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ATTACHMENT 2 PROFESSIONAL QUALIFICATIONS OF FRANK N. BRADY My name is Frank H. Brady. I am Assistant Program Manager of the Diablo Canyon Long Term Seismic Program in Pacific Gas and Electric Company's Geosciences Department. I am responsible for geology, seismology, geophysics, ground motions, and seismic hazards analysis elements of the program.
My education includes a B.S. in Civil Engineering from the University of Santa Clara (1960), and an M.S. in Civil Engineering (Structural Option) from Stanford University (1961).
I am registered in California as a civil engineer and a structural engineer.
I am a member of the American Society of Civil Engineers and the American Concrete Institute. My professional committee activities have included:
- Member, ACI-ASME Joint Committee on Concrete Pressure Components for Nuclear Service, ACI-359, 1978-1986 e Co-Chairman, Subgroup on General Requirements,Section III, ASME Boiler and Pressure Vessel Code, 1978-1986
- Co-Chairman, Working Group on Duties and Responsibilities,Section III, ASME Boiler and Pressure Vessel Code, 1976-1978
- Membar Working Group on Quality Assurance and Stamping Section III, ASME Boiler and Pressure Vessel Code, 1972-1976
'My previous civil engineering responsibilities at PGandE have included:
- Installation of a new brick liner in a 450-ft. reinforced concrete chimney at Pittsburg Power Plant Unit 6
- Civil engineering aspects of seismic design review for Humboldt Bay Power Plant Unit 3, including geology, seismology, geophysics, ground motions, seismic analysis of plant structures and piping, and installation of seismic modifications
- Review and approval of fabricator's detail design of Diablo Canyon Power Plant (DCPP) Unit 1 containment structure liner and hex collar
- Preparation of civil engineering parts of DCPP Final Safety Analysis Report
- Establishment of DCPP onsite Quality Assurance Office
- Civil design of DCPP Unit I containment structure and preliminary design of auxiliary building and turbine building Before joining PGandE, I served for four years in the U.S. Navy Civil Engineer Corps, earning the rank of Lieutenant.
e
'- ATTACHMENT 3 PROFESSIONAL QUALIFICATIONS OF LLOYD S. CLUFF My name is Lloyd S. Cluff. I am manager of the Geosciences Departme.nt at Pacific Gas and Electric Company and Program Manager of the Diablo Canyon Long Term Seismic Program. From 1960 to 1985, when I joined PGandE, I worked at Hoodward-Clyde Consultants in San Francisco, progressing from Staff Geologist to Vice President, Principal, and Director.
I received a Bachelor of Science degree in Geology from the University of Utah in 1960. I am a Registered Geologist and Certified Engineering Geologist in California. My professional affiliations are as follows:
Association of Engineering Geologists, Board of Directors, 1966-1970; Vice President, 1967-1968; President, 1968-1969 Earthquake Engineering Research Institute, Board of Directors, 1976-1980 Geological Society of America International Association of Engineering Geologists, Vice President, 1970-1974 International Association of Engineering Geology Commission on Seismicity, '
Chairman, 1970-1976 Seismological Society of America, Board of Directors,1980-present; Vice
- President, 1981-1982; President, 1982-1983 Structural Engineers Association of Northern California Utah Geological Association l
As Director of Geosciences for Woodward-Clyde Consultants, I was responsible for technical and administrative functions related to geologic, seismic, geophysical, and earthquake engineering investigations and evaluations. Types of projects included siting and design studies for critical facilities such as dams, nuclear power plants, LNG terminals, lifelines, hospitals, emergency service centers, offshore platforms, harbor facilities, and industrial centers.
My research and experience include studies of the relationship of tectonics, seismic geology, and seismicity in many tectonic environments throughout the world. I have completed fault activity studies in New Zealand, Australia, Chile, Peru, Argentina, Ecuador, Bolivia, Colombia, Venezuela, Costa Rica, Nicaragua, Honduras, El Salvador, Guatemala, Mexico, Japan, Taiwan, India, Nepal, Pakistan, Iran, Afghanistan, Turkey, U.S.S.R., Israel, Jordan, Italy, Romania, Switzerland, Spain, and Portugal. I have served as an advisor to governments of many of these countries regarding earthquake and geologic hazards and the formulation of seismic safety guidelines and public policy, especially in the siting and design of critical facilities. In North America, I have completed extensive field studies evaluating seismicity, fault activity, and seismic hazards in Alaska, Canada Hawaii, and throughout the western U.S.
i
I have been an invited lecturer on seismic geology, seismicity, paleoseismicity, earthquake hazards, and engineering geology at the University of California, the California Institute of Technology,the University of Utah, Pennsylvania State University, Washington and Lee University, the University of Nevada, the University of Idaho, the University of Alaska, and the University of Washington. I have been an invited lecturer for the Structural Engineers Associations of California, Utah, Missouri, Ecuador, Venezuela, and Brazil; the Professional Engineers Association of Colombia; the U.S. Nuclear Regulatory Commission; the Nuclear Regulatory Commission of Portugal; the Nuclear Regulatory Commission of Italy; the International Atomic Energy Agency, Vienna; the United Nations (UNESCO), Paris; the Atomic Energy Commission of Chile; and the European Nuclear Energy Association.
I have made detailed postearthquake field studies of many destructive earthquakes throughout the world including Hebgen Lake, Montana, 1959; Alaska, 1964; Parkfield, California,1966; Caracas, Venezuela,1967; Dasht-E Bayaz, Iran, 1968; Santa Rosa, California, 1969; Peru, 1970; San Fernando, California,1971; Managua, Nicaragua,1972; Oroville, California,1975; Guatemala, 1976; Romania, 1977; Livermore, California, 1980; and Algeria, 1980.
I have authored or coauthored more than 60 technical papers on subjects relating to seismic geology, paleoseismicity, regional seismicity, earthquake hazards and risk, earthquake engineering, and seismic safety of critical facilities. These papers have been published in the proceedings and journals of national and international scientific and engineering associations and societies.
I received the Hogentagler Award from the American Society for Testing and Measurements in 1968. I was elected to the National Academy of Engineering in 1978. In 1979, I delivered the Woodward Lecture at Hoodward-Clyde Consultants. I am listed in Engineers of Distinction and Who's Who in Science.
At Hoodward-Clyde Consultants, I served as Project Director and Technical Director for a wide variety of interdisciplinary projects. Representative projectsincluded:
1970-1985 Geologic and seismic studies for governmental agencies in Venezuela regarding the siting of major dams, reservoirs, and related structures, including Yacambu, Uribante-Caparo, La Honda, La Vueltosa, and Borde Seco.
1970-1981 Geologic and seismic studies for Comitato Nazionale Per L'Energia Nucleare, and Ente Nazionale Per L'Energia Elettrica, Rome, Italy, regarding seismicity and geologic conditions at nuclear power plant sites in Italy. Such sites included Brasimone, Torrente Saccione, Gargano, Tarquinia, and Busalla.
1972-1985 Satsop Nuclear Power Plant, Hanford Nuclear Siting Studies, for the Washington Public Power Supply System. Geologic and seismologic investigations of the sites of proposed nuclear power plants were conducted for the State of Washington as part of the HPPSS licensing efforts for these sites.
2-
1972-1985 Geologic and seismic studies for Interconexion Electrica S. A.
regarding seismicity hazards in siting large dams, reservoirs, and related hydroelectric facilities throughout Colombia. Such projects included Ituango, Canafisto, Alto Sinu, Rio Negro, San Carlos, Penderisco, and Troneras.
1972-1974 Trans-Alaska Pipeline Siting Study for the Alyeska Pipeline Service Company. To identify geologic factors to be' considered in designing the pipeline, extensive studies were conducted to identify and delineate active faults crossed by the pipeline route. Design values for surface fault displacements were also developed.
1972-1974 Managua, Nicaragua, postearthquake studies for the Ministry of Planning. An earthquake hazards evaluation was performed to assist the people of Nicaragua in rebuilding Managua following its destruction by earthquake in 1972. The study resulted in a seismic microzonation of Managua.
1974-1977 Proposed Stanislaus Nuclear Power Plant site evaluation for the Pacific Gas and Electric Company. Extensive site and regional geologic studies, seismic geology studies, microearthquake studies, static foundation and earthquake engineering studies, and groundwater hydrology studies were conducted as part of PGandE's licensing effort for the proposed plant.
1976-1977 Proposed Auburn Dam seismic and geologic evaluations for the U.S. Bureau of Reclamation. Detailed fault and earthquake investigations contributed to assessing the earthquake potential at the proposed dam site, characterizing the earthquake ground motions, and evaluating the potential for reservoir-induced seismicity.
1977-1978 New Melones Dam studies for the U.S. Army Corps of Engineers.
Earthquake hazard evaluations for the site of the New Melones Dam on the Stanislaus River, California, evaluated faults as sources of future earthquake activity, the potential for surface faulting at the site, and the potential for reservoir-induced seismicity.
1977-1982 Humboldt Bay Nuclear Power Plant studies for the Pacific Gas and Electric Company. Geologic and seismic investigations for PGandE's existing Unit 3 were performed to answer specific issues raised by the Nuclear Regulatory Commission regarding the potential for surface faulting at the site, and the basis for defining the vibratory ground motions at the site.
1977-1982 Alaska Natural Gas Transportation System studies for Northwest Pipeline Company and Fluor Engineers and Constructors.
Potential seismic hazards along the pipeline corridor were assessed for their significance to the pipeline design.
1979-1982. San Onofre Nuclear Generating Station studies for the Southern California Edison Company. Geologic, seismologic, and earthquake engineering studies were performed to develop a seismic exposure analysis for Unit 1; and a reevaluation of ;
-earthquake-resistant design parameters.using a new l t
degree-of-fault activity approach was conducted for Units 2 l and 3. .
I have served as an advisor to many government agencies and as a member of professional panels and committees. These assignments included:
1966-1970 Advisor to Governor's Earthquake Council, State of Utah, and the Utah. Geological and Mineralogical Survey regarding earthquake and geologic hazards in Utah 1967-1972 Advisor to the President of Venezuela's Earthquake Safety Commission 1968-1973 Consulting Board of the San Francisco Bay Con:ervation and Development Commission, Earthquake Engineering Criteria Review Board !
1969 Santa Barbara Oil Spill Panel, Office of the President and Secretary of the Interior; a special panel of consultants
, assigned'to evaluate the 1969 Santa Barbara Channel oil well blow-out 1969-1970 Consultant, International Consulting Board of the International '
Atomic Energy Agency, Vienna, regarding the seismic review of nuclear power plants in Mexico t
1969-1985 Consultant, Commision Federal de Electricidad, Mexico, regarding the seismic review of hydroelectric projects and nuclear power plants in Mexico 1970-1972 Consultant, Atomic Energy Commission of Chile, regarding seismic review and siting of nuclear power plants in Chile 1970-1976 International Panel of Experts on Seismic Phenomena Associated with Large Reservoirs, UNESCO, Paris, France ,
1970-1974 California Governor's Earthquake Council 1970-1974 Advisory Group on Land-Use Planning, California Legislature's l Joint Committee on Seismic Safety 1971-1973 Advisor, U.S. Atomic Energy Commission, regarding seismic and geologic criteria in siting and design of nuclear power plants 4
4 1972-1980 Consultant, President's Office of Science and Technology Policy;_ earthquake hazards and risk evaluations for the San Francisco Bay Area, the Los Angeles Metropolitan Area, and the Salt Lake City Area 1972-present Earthquake Engineering Research Institute, Earthquake Risk Committee 1975-1978 Earthquake Advisory Panel, Secretary of the Interior and the U.S. Geological Survey, USGS Earthquake Programs 1975-1977 Task Committee on Seismic Hazards and State-Owned Structures, State of California 1975-1979 Newmark-Stever Panel, President's Office of Science and Technology Policy; development of a national program for earthquake prediction and hazard mitigation for the U.S.
Geological Survey, the National Science Foundation, and the Federal Emergency Management Agency 1976-1979 National Academy of Sciences, Seismology Committee 1978 International Workshop on Strong-Motion Earthquake Instrument
. Arrays, Honolulu, Hawaii, for the International Association for Earthquake Engineering, UNESCO, and ti.e National Science !
Foundation 1978-present Earthquake Hazards Mitigation Advisory Panel, National Science Foundation 1978-1980 Panel on Rock Mechanics Research Requirements, U.S. National Committee for Rock Mechanics, National Academy of Sciences 1979 UNESCO Panel on Earthquake Risk and Insurance, Cocoyoc, Mexico 1979 Joint U.S.-Japan Symposium, Tokyo, Japan, Earthquake Safety Through Urban Design 1979-1985 Consultant. Atomic Energy Commission of Portugal, regarding seismic review and siting of nuclear power plants in Portugal 1980-1981 Chairman, Seismic Review Panel, regarding the proposeo LNG '
facility at Pt. Conception, California, for the California i Public Utilities Commission 1981 National Science Foundation, National Program for Strong-Motion Earthquake Instrument Arrays, Santa Barbara, California 1981-present Geological Sciences Board, National Research Council of the National Acadeny of Sciences
- i. !.
1982 Consultant, International Atomic Energy Agency, Vienna, regarding seismic hazards and siting of nuclear power plants in Venezuela 1982 Chairman, USAID/NSF Seismic Review Panel Aswan High Dam, Egypt i
i
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE SECOND SET OF ,
INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS I have assisted in preparing the answers to Interrogatory Nos. 158 and 159. Said answers are true and correct to the best of my knowledge and belief.
FRANK H. BRADY- )
Subscribed and sworn to before me this 17th day ,
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- THERESE TOUVER of March 1987. *
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Th6rese Toliver, Notary Public in and for the City and County of San Francisco, State of Californic My Commission expires December 25, 1990.
1 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE SECOND SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS I have assisted in preparing the answers to Interrogatory Nos. 122 through 147 and 149 through 157. Said answers are true and correct to the best of my knowledge and belief.
1 R. T. NELSON (Original executed copy signed on March 13, 1987, will be provided as soon as it is available)
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 37 mR 23 N1:43 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gFFt g E '{5}t l,y
. BRANCH
) Docket No. 50-133 In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) (Decommissioning)
)
(Humboldt Bay Nuclear Power )
Plant Unit 3) )
)
CERTIFICATE OF SERVICE
, I hereby certify that on March 17, 1987, copies of the following document in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class: LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE SECOND SET OF INTERROGATORIES PROPOUNDED BY
, THE JOINT INTERVENORS..
Dr. Robert M. Lazo, Chairman . Mitzi A. Young, Esq.
Administrative Judge Office of the General Counsel
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Nashington, DC 20555 Hashington, DC 20555 l- Dr. James H. Carpenter Public Affairs Officer Administrative Judge Region V Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1450 Maria Lane Nashington, DC 20555 Halnut Creek, CA 94596 Dr. Peter A. Morris Gretchen Dumas, Esq.
Administrative Judge California Public Utilities Atomic Safety and Licensing Board Commission U.S. Nuclear Regulatory Commission 350 McAllister, Room 5243 Hashington, DC 20555 San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Scott L. Fleider, Esq.
Attn: Document Control Desk 517 Third Street, Suite 14 Washington, DC 20555 Eurek 95501
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. Ricifard F.' Co'cTe '
Pacific Gas and Electric Company i 77 Beale Street, 27th Floor l San Francisco, CA 94106 Dated at San Francisco, California, this 17th day of March 1987.
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