ML20207Q018
| ML20207Q018 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 01/13/1987 |
| From: | Fielder S FIELDER, S.L., JOINT INTERVENORS - HUMBOLDT BAY |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| CON-#187-2228 86-536-07-LA, 86-536-7-LA, OLA, NUDOCS 8701210068 | |
| Download: ML20207Q018 (68) | |
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1 SCOTT L. FIELDER JOCKE!ED Attorney at Law UMPL 2 517 Third Street, Suite 14 Eureka, California 95501 3 Telephone: (707) 444-3031 '87 JAN 20 A8 :43 4 Attorney for the Joint Intervenors Ct... t >
Douglas H. Bosco, Wesley Chesbro, DOCE '.
5 Daniel E. Hauser, Barry Keene, '"*
The Redwood Alliance, Ralph Krause, 6 Nona Krause, Gaye M. Barr and the League Of Women Voters Of Humboldt 7 County 8 UNITED STATES OF AMERICA 9 NUCLEAR REGULATORY COMMISSION 10 11 ) Docket No. 50-133-OLA
) (Decommissioning) 12 )
) ASLBP No. 86-536-07 LA 13 )
In The Matter Of ) JOINT INTERVENORS FIRST SET OF 14 Pacific Gas and Electric ) INTERROGATORIES PROPOUNDED TO Company (Humboldt Bay ) THE LICENSEE PACIFIC GAS AND 15 Power Plant, Unit No. 3) ) ELECTRIC COMPANY 16 17 1. PROPOUNDING PARTY: The Joint Intervenors GAYE M. BARR, LEAGUE OF WOMEN VOTERS OF HUMBOLDT 18 COUNTY, DANIEL E. HAUSER, BARRY KEENE, DOUGLAS H. BOSCO, WESLEY 19 CHESBRO and the REDWOOD ALLIANCE 20 2. SET NUMBER: One 21 3. RESPONDING PARTY: The Licensee, PACIFIC GAS AND ELECTRIC COMPANY 22 l
l 23 YOU ARE HEREBY REQUESTED to answer under oath the fol-24 lowing interrogatories within fourteen (14) days from the time 25 service in made upon you, in accordance with 10 Code of Federal 26 Regulations section 2.740(b).
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P t a 1 I 2 GENERAL PROVISIONS 3 The interrogatories ask not only for your own knowledge 4 and the contents of your books and records but also the know-5 ledge of all other persons of whom inquiry may reasonably be 6 made and the contents of your books and records, and those 7 available to you for examination. Your answers to these inter-8 rogatories should be based on all of the aforementioned sources.
9 If, following your exercise of due diligence to answer 10 any interrogatory, you are still unable to provide the informa-11 tion requested, please state in detail:
12 (a) Your answer to the fullest extent possible; 13 (b) Why you are unable to answer more fully; 14 (c) What efforts you have made to answer fully; 15 (d) The anticipated date of your completion of such 16 investigation and discovery necessary to answer 17 fully.
18 When an interrogatory asks you to identify a writing, 19 you'may, in lieu of answering that interrogatory, attach a copy 20 of that writing with a statement in answer to the interrogatory 21 that such copy is attached and such copy is a true copy of the 22 original of the writing. If you refuse to voluntarily attach 23 a copy of that writing, then identify each such writing in de-24 tail so that it may be produced by you in response to a Notice 25 To Produce or other discovery devices.
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P 19 f 1 II 2 DEFINITIONS 3 When used in these interrogatories and for purposes 4 thereof:
5 (a) Licensee means and refers to Pacific Gas and Elec-6 tric company, its agents, employees, servants, representatives 7 and anyone acting on its behalf or at its request.
.8 (b) . Facility means and refers to the Humboldt Bay 9 Power Plant, Unit No. 3.
10 (c) Spent fuel pool means and refers to the pool in 11 which the-Licensee presently stores the 390 spent fuel rods.at 12 the Humboldt Bay Power Plant, Unit No. 3.
13 (d) writing means handwriting, typewriting, printing, i
14 photostating, photographing, and-every other means of recording 15 upon any tangible thing any form of communication or represent-16 ation, including letters, words, pictures, sounds, or symbols, 17 or combinations thereof.
ll8 (e) Earthquake magnitude: Magnitude of an earthquake 19 is a measure of'the size of an. earthquake and is related to the l
20 energy released in the form of seismic waves. " Magnitude" means 21 , the numerical value on a Richter scale.
22 (f) Intensity: The intensity of an earthquake is a 23 measure of its effects on man, on man-built structures, and on L . 24 the earth's surface at a particular location. Intensity means o
i 25 the numerical value on the Modified Mercalli Scale.
l j 26 (g) Fault: A fault is a tectonic structure along
! 27 which a differential slippage of the adjacent earth materials 28 has occurred parallel to the fracture plane. It is distinct l
a
I from other types of ground disruptions such as landslides, fis-2 sures and craters.
3 (h) Surface faulting: Surface faulting is differential 4 ground displacement at or near the surface caused directly by 5 fault movement and is distinct from nontectonic types of ground 6 disruptions, such as landslides, fissures and craters.
7 (i) capable fault: A capable fault is a fault which 8 has exhibited one or more of the following characteristics:
0 1. Movement at or near the ground surface at least 10 once within the past 35,000 years or movement of a re-Il curring nature within the past 500,000 years; 12 2. Macro-seismicity instrumentally determined with 13 records of sufficient precision to demonstrate a direct 14 relationship with the fault; 15 3. A structural relationship to a capable fault 16 according to characteristics 1. or 2. of this paragraph 17 such that movement on one could be reasonably expected 18 to be accompanied by movement on the other.
10 (j) Structural Integrity compromised: means that the 20 man made structure loses its rigidity, strength and ability to 21 bear loads and collapses either in whole or part.
22 (k) "You" or "your" means and refers to the licensee, 23 its agents, its employees, its servants, its representatives 24 and anyone acting on its behalf or at its request.
25 NOTE: IF YOU ARE UNSURE AS TO THE INTENT OR MEANING OF 26 ANY CF THE FOREGOING GENERAL PROVISIONS OR DEFINITIONS, YOU ARE 27 HEREBY REQUESTED TO HAVE YOUR ATTORNEYS CONTACT THE ATTORNEY OF 28 //
O e 1 RECORD FOR THE JOINT INTERVENORS WHO HEREBY OFFER TO PROVIDE 2 ANY NEEDED ASSISTANCE NECESSARY FOR YOU TO UNDERSTAND THE INTENT 3 AND MEANING OF ANY OF THE FOREGOING.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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1 INTERROGATORY NO. 1:
2 Do you contend that the Little Salmon Fault is not a 3 " capable fault"?
4 ANSWER NO. 1:
5 6
7 8 :
9 10 11 12 13 14 INTERROGATORY NO. 2 15 If your answer to the preceding interrogatory is in 16 the affirmative, please state the information on which your 17 contention is based.
18 ANSWER NO. 2:
19 20 21 22 23 24 25 26 27 l 28 i
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1 INTERROGATORY NO. 3:
2 If your answer to Interrogatory No. 1 was in the affirm-3 ative, please state the author's name, date, and title of each 4 writing upon which you have relied in arriving at your answer.
5 ANSWER NO. 3:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 4:
16 Do you contend that the Buhne Point Fault is not a 17 " capable fault"?
18 ANSWER NO. 4: .
19 20 21 22 23 24 25 26 27 28 l
1 INTERROGATORY NO. 5:
2 If your answer to the preceding interrogatory is in the 3 affirmative, please state the information on which your conten-4 tion is based.
5 ANSWER NO. 5:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 6:
16 If your answer to Interrogatory No. 4 was in the affirm-17 ative, please state the author's name, date, and title of each 18 writing upon which you have relied in arriving at your answer.
19 ANSWER NO. 6:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 7:
2 Do you contend that the Bay Entrance Fault is not a 3 " capable fault"?
4 ANSWER NO. 7:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 3:
16 If your answer to the preceding interrogatory is in the 17 affirmative, please state the information on which your conten-18 tion is based.
19 ANSWER NO. 8:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 9:
2 If your answer to Interrogatory No. 7 was in the affirm-3 ative, please state the author's name, date, and title of each 4 writing upon which you have relied in arriving at your answer to 5 Interrogatory No. 7.
6 ANSWER NO. 9:
7 8
9 10 11 12 13 14 15 16 INTERROGATORY NO. 10:
17 Do you contend that the North Spit Fault is not a 18 " capable fault"?
19 ANSWER NO. 10:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 11:
2 If your answer to the preceding interrogatory is in the 3 affirmative, please set forth the information on which your con-4 tention is based.
5 ANSWER NO. 11:
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8 9
10 11 .
12 13 14 15 INTERROGATORY NO. 12:
16 If your answer to Interrogatory No. 10 was in the af-17 firmative, please state the author's name, date, and title of 18 each writing upon which you have relied in arriving at your 19 answer to Interrogatory No. 10.
20 ANSWER NO. 12:
21 22 23 24 25 26 27 28 l
1 INTERROGATORY NO. 13:
2 Do you contend that surface faulting is not a credible 3 risk to the " structural integrity" of the facility's spent. fuel 4 pool?
5 ANSWER NO. 13:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 14:
16 If your answer to Interrogatory No. 13 is in the affirm-17 ative, please set forth the facts on which your contention is 18 based.
19 ANSWER NO. 14:
20 21 22
'23 24
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1 INTERROGATORY NO. 15:
2 If your answer to Interrogatory No. 13 was in the af-3 firmative, please state the author's name, date, and title of 4 each writing upon which you have relied in arriving at your 5 answer.
6 ANSWER NO. 15:
7 8
9 10 11 12 13 14 INTERROGATORY NO. 16:
15 Please state what the largest " magnitude" earthquake is 16 that the spent fuel pool building is designed to withstand with-17 out sustaining any structrual damage.
18 ANSWER NO. 16:
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1 INTERROGATORY NO. 17:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 16.
5 ANSWER NO. 17:
6 7
8 9
10 11 12 13 14 INTERROGATORY NO. 18:
15 Please state what is the largest " magnitude" earthquake 16 that the spent fuel pool and its stainless steel liner are de-17 signed to withstand and still maintain their structural integ-18 rity.
19 ANSWER NO. 18:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 19:
1 2 Please set forth the name-of the author, the date and '
3 title of each " writing" that you claim supports your answer 4 to Interrogatory No. 18. !
I ANSWER NO. 19:
5 6
7 8
9 10 11 12 13 14 INTERROGATORY NO. 20:
15 Please state what is the largest " magnitude" earthquake 16 that the off gas stack is designed to withstand without sustain-17 ing any structural damage.
18 ANSWER NO. 20:
, 19 20 21 22 23 24 25 26 27 28
1 INTERROGATORY NO. 21:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to L4 Interrogatory No. 20.
5 ANSWER NO. 21:
6 7
8 9
10 11 12 13 4
14 15 INTERROGATORY NO. 22:
16 Please state what the greatest " intensity" earthquake 17 is that the spent fuel pool building is designed to withstand
! 18 without sustaining any structural damage.
19 ANSWER NO. 22:
20 21 22 23 24 25 26 27 l
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I 1 INTERROGATORY NO. 23:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 22.
5 ANSWER NO. 23:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 24:
16 Please state what is the greatest " intensity" earthquake 17 that the spent fuel pool and its stainless steel liner are de-18 signed to withstand without sustaining any structural damage.
19 ANSWER NO. 24:
20 21 22 23 24 25 26 27 28
1 INTERROGATORY NO. 25:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer 4 to Interrogatory No. 24.
5 ANSWER NO. 25:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 26:
16 Please state what is the greatest " intensity" earth-17 quake that the off gas stack was designed to withstand with-18 out sustaining structural damage.
19 ANSWER NO. 26:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 27:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 26.
5 ANSWER NO. 27:
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10 11 12 13 14 15 INTERROGATORY NO. 28:
16 Do you contend that surface faulting is not a credible 17 risk to the " structural integrity" of the facility's spent fuel 18 pool building?
19 ANSWER NO. 28:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 29:
2 If your answer to Interrogatory No. 28 is in the affirm-3 ative, please set forth the facts on which your contention is 4 based.
5 ANSNER NO. 29:
6 7
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10 11 12 13 14 15 INTERROGATORY NO. 30:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 28.
19 ANSWER NO. 30:
20 21 22 23 24 25 20 27 28 1 INTERROGATORY NO. 31:
2 Do you contend that surface faulting is not a credible 3 risk to the " structural integrity" of the facility's off gas 4 stack?
5 ANSWER NO. 31:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 32:
16 If your answer to Interrogatory No. 31 is in the affirm-17 ative, please set forth the facts on which your contention is 18 based.
19 ANSWER NO 32:
20 21 22 23 24 25 26 27 28
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1 INTERROGATORY NO. 33:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 31.
5 ANSWER NO. 33:
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10 11 12 13 14 15 INTERROGATORY NO. 34:
16 Please state what you contend is the maximum earthquake 17 magnitude that the Little Salmon Fault is capable of generating.
18 ANSWER NO. 34:
19 20 21 22 23 24 25 26 27 28 l
1 INTERROGATORY NO. 35:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 34.
5 ANSWER NO. 35:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 36:
16 Please state what you contend is the maximum earthquake 17 magnitude that the Buhne Point Fault is capable of generating.
18 ANSWER NO. 36:
19 i 20 21 22 23 24 s
25 26 27 28 1 INTERROGATORY NO. 37:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer 4 to Interrogatory No. 36.
5 ANSWER NO. 37:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 38:
16 Please state what you contend is the maximum earthquake 17 magnitude that the Bay Entrance Fault is capable of generating.
18 ANSWER NO. 38:
19 20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 39:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 38.
5 ANSWER NO. 39:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY No. 40:
16 Please state what you contend is the maximum earthquake 17 magnitude that the North Spit Fault is capable of generating.
18 ANSWER NO. 40:
19 20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 41:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No.140.
5 ANSWER NO. 41:
6 7
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, 9 10 11 12 13 14 15 INTERROGATORY NO. 42:
16 Please state what you contend is the maximum intensity 17 eart2 quake that the Little Salmon Fault is capable of generating.
18 ANSWER NO. 42:
19 20 21 22 23 24 25 26 27 28 l
1 INTERROGATORY NO. 43:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 42.
5 ANSWER NO. 43:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 44:
16 Please state what you contend is the maximum intensity 17 earthquake that the Buhne Point fault is capable of generating.
18 ANSWER NO. 44:
19 20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 45:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 44.
5 ANSWER NO. 45:
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8 9
10 11 12 13 14 15 INTERROGATORY NO. 46:
16 Please state what you contend is the maximum intensity 17 earthquake that the Bay Entrance Fault is capable of generating.
18 ANSWER NO. 46:
19 j
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 47:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 46.
5 ANSWER NO. 47:
6 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 48:
16 Please state what you contend is the maximum intensity 17 earthquake that the North 3 pit Fault is capable of generating.
18 ANSWER NO. 48:
19 20 21 22 23 24 25 26 27 28 P
1 INTERROGATORY NO. 49:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 48.
5 ANSWER NO. 49:
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8 9
10 11 12 13 14 15 INTERROGATORY NO. 50:
16 Is it your contention that the structural integrity of 17 the spent fuel pool building would not be compromised if the 18 maximum intensity earthquake postulated for the Little Salmon 19 Fault occurred on that fault at the point closest to the 20 facility?
21 ANSWER NO. 50:
22 23 24 25 26 27 28 1 INTERROGATORY NO. 51:
2 Please set forth the facts on which you base your answer 3 to Interrogatory No. 50.
4 ANSWER NO. 51:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 52:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 50.
19 ANSWER NO. 52:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 53:
2 Is it your contention that the structural integrity of 3 the spent fuel pool and its liner would not be compromised if 4 the maximum intensity earthquake postulated for the Little 5 Salmon Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 53:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO.54:
18 Please set forth the facts on which you base your answer 19 to Interrogatory No. 53.
20 ANSWER NO. 54:
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1 INTERROGATORY NO. 55:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 53.
5 ANSWER NO. 55:-
6 7
8 9
10 11 12 13 INTERROGATORY NO. 56:
14 Is it your contention that the structural integrity 15 of the off gas stack would not be compromised if the maximum 16 . intensity earthquake postulated for the Little Salmon Fault 17 occurred on that fault at the point closest to the facility?
18 ANSWER NO. 56:
19 20 21 22 23 24 25 26 27 28 o o 1 INTERROGATORY NO. 57:
2 Please stat forth the facts on which you base your answer 3 to Interrogatory No. 56.
4 ANSWER NO. 57:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 58:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 I..terrogatory No. 56.
19 ANSWER NO. 58:
20 21 22 23 21 25 26 27 28 1 INTERROGATORY NO. 59:
2 Is it your contention that the structural integrity of 3 the spent fuel pool building would not be compromised if the 4 maximum magnitude earthquake postulated for the Little Salmon 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 59:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 60:
18 Please set forth the facts on which you base your answer 19 to Interrogatory No. 59.
20 ANSWER NO. 60:
21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 61:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 59.
5 ANSWER NO. 61:
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8 9
10 11 12 13 14 INTERROGATORY NO. 62:
15 Is it your contention that the structural integrity of 16 the spent fuel pool and its liner would not be compromised if 17 the maximum magnitude earthquake postulated for the Little 18 Salmon Fault occurred on that fault at the point closest to the 19 facility?
20 ANSWER NO. 62:
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1 INTERROGATORY NO. 63:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 62.
4 AWSWER NO. 63:
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10 11 12 13 14 15 INTERROGATORY NO. 64:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 62.
19 ANSWER NO. 64:
20 21 22 23 24 25 26 27 28 i
1 INTERROGATORY NO. 65:
2 Is it your contention that the structural integrity of 3 the off. gas stack would not be compromised ~if the maximum mag-4 nitude earthquake postulated for the Little Salmon Fault occur-5 red on that fault at the point closest to the facility?
6 ANSWER NO. 65:
7 8
9 10 11 12 13 14 15 16 17 INTERROGATORY NO. 66:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory No. 65.
20 ANSWER NO. 66:
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1 INTERROGATORY NO. 67:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 65.
5 ANSWER NO. 67:
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10 11 12 13 INTERROGATORY NO. 68:
14 Is it your contention that the structural integrity of 15 the spent fuel pool building would not be compromised if the 16 maximum intensity earthquake postulated for the Buhne Point 17 Fault occurred on that fault at the point closest to the 18 facility?
19 ANSWER NO. ,68:
20 21 22 23 24 25 26 27 28 a 0 1 INTERROGATORY NO. 69:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 68.
4 ANSWER NO. 69:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 70:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 68.
19 ANSWER NO. 70:
20 21 22 23 24 25 26 27 28 a 0 1 INTERROGATORY NO. 71:
2 Is it your contention that the structural integrity of 3 the spent fuel pool and its liner would not be compromised if 4 the maximum intensity earthquake postulated for the Buhne Point 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 71:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 72:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory No. 71.
20 ANSWER NO. 72:
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1 INTERROGATORY NO. 73:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 71.
5 ANSWER NO. 73:
6 7
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10 11 12 13 INTERROGATORY NO. 74:
14 Is it your contention that the structural integrity of 15 the off gas stack would not be compromised if the maximum in-16 tensity earthquake postulated for the Buhne Point Fault occur-17 red on that fault at the point closest to the facility?
18 ANSWER NO. 74:
19 20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 75:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 74.
'4 ANSWER NO. 75:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 76:
16 niease set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 74.
19 ANSWER NO. 76:
20 21 22 23 24 25 26 27 28 o .
1 INTERROGATORY NO. 77:
2 Is it your contention that the structural integrity of 3 the spent fuel pool building would not be compromised if the 4 maximum magnitude earthquake postulated for the Buhne Point 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 77:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 78:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory No. 77.
20 ANSWER NO. 78:
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1 INTERROGATORY NO. 79:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 77.
5 ANSWER NO. 79:
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10 11 12 13 INTERROGATORY NO. 80:
14 Is it your contention that the structural integrity of 15 the spent fuel pool and its liner would not be compromised if 16 the maximum magnitude earthquake postulated for the Buhne Point 17 Fault occurred on that fault at the point closest to the 18 facility?
19 ANSWER NO. 80:
20 21 22 23 24 25 26 27 28
- o o 1 ' INTERROGATORY NO. 81:
2 Please set forth the facts on which you base your ans-3 .wer to Interrogatory No. 80.
4 ' ANSWER NO. 81:
5 6
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9 10 11 12 13 14 15 INTERROGATORY NO. 82:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 80.
19 ANSWER NO. 82:
20 21 22 23 24 25 26 27 28
1 INTERROGATORY NO. 83:
2 Is it your contention that the structural integrity of 3 the off gas stack would not be compromised if the maximum mag-4 nitude earthquake postulated for the Buhne Point Fault occurred 5 on that fault at the point closest to the facility?
6 ANSWER NO. 83:
7 8
9 10 11 12 13 14 15 16 17 INTERROGATORY NO. 84:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory No. 83.
20 ANSWER NO. 84:
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1 INTERROGATORY NO. 85:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 83.
5 ANSWER NO. 85:
6 7
8 9
10 11 12 13 INTERROGATORY NO. 86:
14 Is it your contention that the structural integrity of 15 the spent fuel pool building would not be compromised if the 16 maximum intensity earthquake postulated for the Bay Entrance 17 Fault occurred on that fault at the point closest to the 18 facility?
19 ANSWER NO. 86:
20 21 22 23 24 25 26 27 28
-1 INTERROGATORY NO. 87:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory.No. 86.
4 ANSWER NO. 87:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 88:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 86.
19 ANSWER NO. 88:
20 21 22 23 24 25 26 27 28 I
1 INTERROGATORY NO. 89:
2 Is it your contention that the structural integrity of 3 the spent fuel pool and its liner would not be compromised if 4 the maximum intensity earthquake postulated for the Bay Entrance 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 89:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 90:
18 Please set forth the facts on which you base your ans-10 wer to Interrogatory No. 89.
20 ANSWER NO. 90:
21 22 23 24 25 26 27 28
. o 1 INTERROGATORY NO. 91:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer 4 to Interrogatory No. 89.
5 ANSWER NO. 91:
6 7
8 9
10 11 12 13 INTERROGATORY NO. 92:
14 Is it your contention that the structural integrity of 15 the off gas stack would not be compromised if the maximum in-16 tensity earthquake postulated for the Bay Entrance Fault occur-17 red on that fault at the point closest to the facility?
18 ANSWER NO. 92:
10 20 21 22 23 24 25 2(i 27 28 1 INTERROGATORY NO. 93:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 92.
4 ANSWER NO. 93:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 94:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 92.
19 ANSWER NO. 94:
20 21 22 23 24 25 26 27 28 l
1 INTERROGATORY NO. 95:
2 Is it your contention that the structural integrity of 3 the spent fuel pool building would not be compromised if the 4 maximum magnitude earthquake postulated for the Bay Entrance 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 95:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 96:
18 Please set forth the facts on which you base your ans-10 wer to Interrogatory No. 95.
20 ANSWER NO. 96:
21 22 23 24 25 26 27 28
. . I 1 INTERROGATORY NO. 97:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 95.
5 ANSWER NO. 97:
6 7
8 9
10 11 12 13 INTERROGATORY NO. 98:
14 Is it your contention that the structural integrity of 15 the spent fuel pool and its liner would not be compromised if 16 the maximum magnitude earthquake postulated for the Bay Entrance 17 Fault occurred on that fault at the point closest to the 18 facility?
19 ANSWER MO. 98:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 99:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 98.
4 ANSWER NO. 99:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 100:
16 Please set forth the name of the author, the date and '
17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 98.
10 ANSWER NO. 100:
20 21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 101:
2 Is it your contention that the structural integrity of 3 the off gas stack would not be compromised if the maximum mag-4 nitude earthquake postulated for the Bay Entrance Fault occurred 5 on that fault at the point closest to the facility?
6 ANSWER NO. 101:
7 8
9 10 11 12 13 14 15 16 17 INTERROGATORY NO. 102:
18 Please set forth the facta on which you base your ans-19 wer to Interrogatory No. 101.
20 ANSWER NO. 102:
21 22 23 24 25 26 27 28
1 INTERROGATORY NO. 103:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 101.
5 ANSWER NO. 103:
6 7
8 9
10 11 12 13 INTERROGATORY NO. 104:
14 Is it your contention that the structural integrity of 15 the spent fuel pool building would not be compromised if the 16 maximum intensity earthquake postulated for the North Spit 17 Fault occurred on that fault at the point closest to the 18 facility?
19 ANSWER NO. 104:
20 21 22 23 24 25 26 27 28 O O 1 INTERROGATORY NO. 105:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 104.
4 ANSWER NO. 105:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 106:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 104.
10 ANSWER NO. 106:
20 21 22 23 24 25 26 27 28
. o 1 INTERROGATORY NO. 107:
2 Is it your contention that the structural integrity of 3 the spent fuel pool and its liner would not be compromised if 4 the maximum intensity earthquake postulated for the North Spit 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 107:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 108:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory no. 107.
20 ANSWER NO. 108:
21 22 23 24 25 26 27 28 I
1 INTERROGATORY NO. 109:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 107, 5 ANSWER NO. 109:
6 7
8 9
10 11 12 13 INTERROGATORY NO. 110:
14 Is it your contention that the structural integrity of 15 the off gas stack would not be compromised if the maximum in-16 tensity earth quake postulated for the North Spit Fault occurred 17 on that fault at the point closest to the facility?
18 ANSWER NO. 110:
19 20 21 22 23 24 25 26 27 28 e O 1 ' INTERROGATORY NO. 111:
2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 110.
4 ANSWER NO. 111:
5 6
7 8
9 10 11 12 13 14 15 INTERROGATORY NO. 112,:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 110.
19 ANSWER NO. 112:
20 21 22 23 24 25 26 27 28 e 0 1 INTERROGATORY NO. 113:
2 Is it your contention that the structural integrity of 3 the spent fuel pool building would not be compromised if the 4 maximum magnitude earthquake postulated for the North Spit 5 Fault occurred on that fault at the point closest to the 6 facility?
7 ANSWER NO. 113:
8 9
10 11 12 13 14 15 16 17 INTERROGATORY NO. 114:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory No. 113.
20 ANSWER NO. 114:
21 22 23 24 25 26 27 28 1 INTERROGATORY NO. 115:
2 Please set forth the name of the author, the date and 3 . title of each " writing" that you claim supports your answer to 4 Interrogatory No. 113.
5 ANSWER NO. 115:
6 7
8 9
10 11 12 13 INTERROGATORY NO.-116:
14 Is it your contention that the structural integrity of 15 the spent fuel pool and its liner would not be compromised if 16 the maximum magnitude earthquake postulated for the North Spit 17 Fault occurred on that fault at the point closest to the 18 facility?
19 ANSWER NO. 116:
20 21 22 23 24 25 26 27 28 e .
1 INTERROGATORY NO. 117:
l 2 Please set forth the facts on which you base your ans-3 wer to Interrogatory No. 116.
4 ANSWER NO. 117: ,
I 5 l 1
6 ,
d 7
8 9
10 11 12 13 14 15 INTERROGATORY NO. 118:
16 Please set forth the name of the author, the date and 17 title of each " writing" that you claim supports your answer to 18 Interrogatory No. 116.
19 ANSWER NO. 118:
20 21 22 23
-24 25 26 27 28
e . .
1 INTERROGATORY NO. 119:
2 Is it your contention that the structural integrity of 3 the off gas stack would not be compromised if the maximum mag-4 nitude earthquake postulated for the-North Spit Fault occurred 5 on that fault at the point closest to the facility?
6 ANSWER NO. 119:
7 8
9 10 11 12 13 14 15 16 17 INTERROGATORY NO. 120:
18 Please set forth the facts on which you base your ans-19 wer to Interrogatory No. 119.
20 ANSWER NO. 120:
21 22 l 23 24 25 26 l 27 l
l 28 l
a r0 y 1 INTERROGATORY NO. 121:
2 Please set forth the name of the author, the date and 3 title of each " writing" that you claim supports your answer to 4 Interrogatory No. 119.
5 ANSWER NO. 121:
6 7
8 9
10 11 12 13 C
15 Dated: [ [1 -
16 A SCOTT L. FIELDER k 17 Attorney for the Joint Intervenors 18 19 20 21 22 23 24 25 26 27 28 l
e e. o PROOF OF SERVICE DCCKETEP Uc N::c age ofI am a resident eighteen of and years the County of Humboldt; not a party to the withTnIgpm,pv9g WEtiBn, gha qf3 4aae- *
' '8 e'---' " - - - ' - -
' ' 4 # ^ ed -
b"U0E 4
I0 WEu~caTybs 6f.]lc.Yide[sN%{S[E 3 B i' Ui .
On GM Mv V b; l$9 *
, I served the withine i
JOINT INTERVENORS FIRST SET OF INTERROGATORIES PROPOUNDED TO,THE LICENSEE PACIFIC GAS AND. ELECTRIC COMPANY -
on the interested parties in said action (X) By placing a true copy thereof enclosed in a sealed en-velope with postage thereon fully prepaid, in the United States mail at Eureka, California, addressed as listed below.
( ) By perso7L.1y delivering a true copy thereof to the persons listed below.
I declare under penalty of perjury that the foregoing is true and correct.
Executed at I .;, California, on 4W%aYj ) .
t ( '( '
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f \ '
See Attachment l
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i l
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[
e o. o ATTACHMENT United States Nuclear Regulatory Commission Public Document Room 1717 "H" Street NW Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 l l
Richard F. Locke l
. Phillip A. Crane, Jr.
Pacific Gas and Electric Company Post Office Box 7442 San Francisco, California 94120 Mr. Bruce Norton C/O Phillip A. Crane, Jr.
Pacific Gas and Electric Company Post Office Box 7442 San Francis'co, California 94120
- Mitzi Young, Esq.
. Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Secretary United States Nuclear Regulatory Commission Washington, D.C. 20555 i
. Robert 21. Lazo, Esq.
Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C. 20555 L
r i a. . .
ATTACHMENT (con't)
Dr. James H. Carpenter, Member Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Peter A. Morris, Member Atomic. Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C. 20555 Ralph and Nona Krause 2479 Wrigley Road Eureka, California 95501 Honorable Dan Hauser Assemblyman, 2nd District
'1334 Fifth Street Eureka, California -95501 Honorable Barry Keene Second Senate, District 533 "G" Street Eureka, California 95501 Honorable Doug Bosco U.S. Congressman 517 Seventh Street Eureka, California 95501 3 Honorable Wesley Chesbro Supervisor, Third District Post Office Box 4667.
Arcata, California 95521 Redwood Alliance Post Office Box 293 Arcata, California 95521 i