ML20210E556
| ML20210E556 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 02/02/1987 |
| From: | Locke R PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - HUMBOLDT BAY |
| References | |
| CON-#187-2468 OLA, NUDOCS 8702100320 | |
| Download: ML20210E556 (29) | |
Text
.- 2 Vhr taunomaaesemassa DOWETED U NRC
, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 87 FEB -9 All :06
$Y
) Docket No. 50-133-4 M In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) (Decommissioning)
) .
(Humboldt Bay Nuclear Power )
Plant Unit 3) ) February 2, 1987
)
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE FIRST SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS INTERROGATORY NO. 1:
Do you contend that the Little Salmon Fault is not a " capable fault"?
ANSHER N6. 1:
No.
INTERROGATORY NO. 2:
If your answer to the preceding interrogatory is in the affirmative, please state the information on which your contention is based.
ANSHER NO. 2:
Not applicable.
l INTERROGATORY NO. 3: ,
( If your answer to Interrogatory No. I was in the affirmative, please
( state the author's name, date, and title of each writing upon which you have l relied in arriving at your answer.
l ANSHER NO. 3:
t Not applicable.
h2 G
O
O e
INTERROGATORY NO. 4:
Do you contend that the Buhne Point Fault is not a " capable fault"?
ANSHER NO. 4:
No.
INTERROGATORY NO. 5:
If your answer to the preceding interrogatory is in the affirmative, please state the information on which your contention is based.
ANSHER NO. 5:
Not applicable.
INTERROGATORY NO. 6:
If your answer to Interrogatory No. 4 was in the affirmative, please state the author's name, date, and title of each writing upon which you have relied in arriving at your answer.
ANSHER NO. 6:
Not applicable.
INTERROGATORY NO. 7:
Do you contend that the Bay Entrance Fault is not a " capable fault"?
ANSWER NO. 7:
No.
INTERROGATORY NO. 8:
If your answer to the preceding interrogatory is in the affirmative, please state the information on which your contention is based.
ANSHER NO. 8:
Not applicable.
INTERROGATORY NO. 9:
If your answer to Interrogatory No. 7 was in the affirmative, please state the author's name, date, and title of each writing upon which you have relied in arriving at your answer to Interrogatory No. 7.
0
- a. ANSWER NO. 9:
Not applicable.
INTERROGATORY NO. 10:
Do you contend that the North Spit Fault is not a " capable fault"?
ANSHER NO.10:
No.
INTERROGATORY NO. 11:
If your answer to the preceding interrogatory is in the affirmative, please set forth the information on which your contention is based.
ANSHER NO. 11:
Not applicable.
INTERROGATORY NO. 12:
If your answer to Interrogatory No. 10 was in the affirmative, please state the author's name, date, and title of each writing upon which you have relied in arriving at your answer to Interrogatory No. 10.
ANSWER NO. 12:
Not applicable.
INTERROGATORY NO. 13:
i Do you contend that surface faulting is not a credible risk to the
" structural integrity" of the facility's spent fuel pool?
l ANSWER NO. 13:
l .
l Yes.
i INTERROGATORY NO. 14:
If your answer to Interrogatory No.13 is in the affirmative, please set forth the facts on which your contention is based.
~.
l
ANSHER NO. 14:
During the past two decades, there have been numerous studies of ever increasing detail on the geologic structure, seismicity, and earthquake potential in the Humboldt Bay Region. These studies have been conducted largely by PGandE consultants, the U.S. Geological Survey, and academic institutions. Final consensus and conclusions have not been reached, but several generalizations seem clear:
- Surface traces of capable or potentially capable faults near the HBPP do not extend through the plant site.
e Any surface displacement which might occur in the plant site area is most likely to occur along nearby faults; thus, no new plane of rupture is expected to develop.
- The probability that surface rupture will penetrate the plant
, foundation is negligible.
Capable or potentially capable faults near the HBPP include the Little Salmon Fault, Bay Entrance Fault, and Buhne Point Fault. The faults strike northwest and dip to the northeast. The surface trace of each fault passes within 2.5 km (1-1/2 miles) of the HBPP but in no case crosses the plant site. The subsurface trace of the Buhne Point Fault is nearest to the site, coming within 180 m (600 ft) of the plant foundation. Woodward-Clyde Consultants (1980) concluded that all subsequent displacement in the plant site area is most likely to occur along these faults, and that no new plane of rupture is expected to develop.
J l INTERROGATORY NO. 15:
If your answer to Interrogatory No.13 was in the affirmative, please i
state the author's name, date, and title of each writing upon which you have relied in arriving at your answer.
ANSWER NO. 15:
l j a. Pacific Gas and Electric Company (J. O. Schuyler) letter to NRC
- (H. R. Denton) dated July 30, 1984 Attachment 6, " Environmental l Report for the Decommissioning of Humboldt Bay Power Plant Unit No.
j 3 " prepared by B. S. Ausmus, L. A. Hofman, and P. A. Trinoskey, Decommissioning and Restoration Department, Advanced Technology Division, Bechtel National, Inc.
i l b. L.S. Cluff et. al., Woodward-Clyde Consultants, Evaluation of the l Potential for Resolvina the Geoloaic and Seismic Issues at the Humboldt Bay Power Plant Unit No. 3, October 1, 1980.
t
d INTERROGATORY NO. 16:
Please state what the largest " magnitude" earthquake is that the spent fuel pool building is designed to withstand without sustaining any struct' ural damage.
ANSHER NO. 16:
The spent fuel pool building, spent fuel pool and liner, and ventilation stack (off gas stack) were reviewed and shown capable of withstanding an operating basis earthquake (OBE) of 0.25 g ground acceleration and a safe shutdown earthquake (SSE) of 0.5 g acceleration during the seismic design review of 1974-1977. These criteria have not been associated with any particular earthquake magnitude or intensity.
INTERROGATORY NO. 17:
Please set forth the name of the author, the date and title of each j " writing" that you claim supports your answer to Interrogatory No. 16.
ANSHER NO. 17:
- a. Pacific Gas and Electric Company (J. O. Schuyler) letter to NRC (H. R. Denton), dated July 30, 1984, Attachment 3 "SAFSTOR Decommissioning Plan for the Humboldt Bay Power Plant, Unit No. 3."
- b. Pacific Gas and Electric Company, Final Hazards Summary Reoort:
Hn=holdt Bay Power Plant Unit No. 3, September 1, 1961.
- c. Bechtel Power Corporation, Summary Report of Seismic Desian Review, Humboldt Bay Power Plant - Unit 3, Revision 3. February 1977.
l INTERROGATORY NO. 18:
Please state what is the largest " magnitude" earthquake that the spent fuel pool and its stainless steel liner are designed to withstand and still maintain their structural integrity.
ANSHER NO. 18:
See Answer No. 16.
INTERROGATORY NO. 19:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 18.
ANSHER NO. 19: .
See Answer No. 17.
INTERROGATORY NO. 20:
Please state what is the largest " magnitude" earthquake that the off gas stack is designed to withstand without sustaining any structural damage.
ANSWER NO. 20:
See Answer No. 16.
INTERROGATORY NO. 21:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 20.
ANSHER NO. 21:
See Answer No. 17.
INTERROGATORY NO. 22:
Please state what the greatest " intensity" earthquake is that the spent fuel pool building is designed to withstand without sustaining any structural damage.
ANSWER NO. 22:
See Answer No. 16.
INTERROGATORY NO. 23:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 22.
- ANSHER NO. 23:
! See Answer No. 17.
INTERROGATORY NO. 24: -
Please state what is the greatest " intensity" earthquake that the spent fuel pool and its stainless steel liner are designed to withstand without sustaining any structural damage.
ANSHER NO. 24:
See Answer No. 16. ,
INTERROGATORY NO. 25:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 24.
ANSHER NO. 25:
See Answer No. 17.
INTERROGATORY NO. 26:
Please state what is the greatest " intensity" earthquake that the off gas stack was designed to withstand without sustaining any structural damage.
ANSHER NO. 26:
See Answer No. 16.
INTERROGATORY NO. 27:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 26.
ANSWER NO. 27:
See Answer No. 17.
I INTERROGATORY NO. 28:
Do you contend that surface faulting is not a credible risk to the
" structural integrity" of the facility's spent fuel pool building?
ANSWER NO. 28:
Yes.
INTERROGATORY NO. 29:
l If your answer to Interrogatory No. 28 is in the affirmative, please i set forth the facts on which your contention is based.
ANSHER NO. 29:
See Answer No. 14.
4 INTERROGATORY NO. 30: ~.
' Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 28.
'ANSHER NO. 30:
See Answer No. 15.
INTERROGATORY NO. 31:
Do you contend that surface faulting is not a credible risk to the
" structural integrity" of the facility's off gas stack?
ANSHER NO. 31:
Yes.
INTERROGATORY NO. 32:
If your answer to Interrogatory No. 31 is in the affirmative, please set forth the facts on which your contention is based.
ANSHER NO. 32:
See Answer No. 14.
INTERROGATORY NO. 33:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 31.
ANSWER NO. 33:
See Answer No. 15.
INTERROGATORY NO. 34:
Please state what you contend is the maximum earthquake magnitude that the Little Salmon Fault is capable of generating.
ANSWER NO. 34:
~
PGandE has not determined the max 1 mum earthquake magnitude that the Little Salmon Fault is capable of generating.
I INTERROGATORY NO. 35:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 34.
ANSHER NO. 35:
Not applicable.
- . INTERROGATORY NO. 36
1 Please state what you contend is the maximum earthquake magnitude that the Buhne Point Fault is capable of generating.
4 ANSWER NO. 36:
PGandE has not determined the maximum earthquake magnitude that the Buhne Point Fault is capable of generating.
INTERROGATORY NO. 37:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 36.
ANSHER NO. 37:
1 Not applicable.
INTERROGATORY NO. 38:
) Please state what you contend is the maximum earthquake magnitude that the Bay Entrance Fault is capable of generating.
ANSWER NO. 38:
i PGandE has not determined the maximum earthquake magnitude that the
- Bay Entrance Fault is capable of generating, i
INTERROGATORY NO. 39:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 38.
ANSWER NO. 39: ;
Not applicable.
INTERROGATORY NO. 40:
Please state what you contend is the maximus earthquake magnitude that the North Spit Fault is capable of generating.
ANSHER NO. 40:
PGandE has not determined the maximum earthquake magnitude that the North Spit Fault is capable of generating. ,
_g_
INTERROGATORY NO. 41:
t Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 40.
ANSHER NO. 41:
Not applicable.
INTERROGATORY NO. 42:
Please state what you contend is the maximum intensity earthquake that the Little Salmon Fault is capable of generating.
ANSHER NO. 42:
- PGandE has not determined the maximum intensity earthquake that the Little Salmon Fault is capable of generating.
i INTERROGATORY NO. 43:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 42.
ANSHER NO. 43:
Not applicable.
INTERROGATORY NO. 44:
Please state what you contend is the maximum intensity earthquake that the Buhne Point Fault is capable of generating.
i l
ANSHER NO. 44:
PGandE has not determined the maximum intensity earthquake that the Buhne Point Fault is capable of generating.
INTERROGATORY NO. 45:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 44.
ANSHER NO. 45:
Not applicable.
4
. INTERROGATORY NO. 46:
Please state what you contend is the maximum intensity earthquake that the Bay Entrance Fault is capable of generating.
ANSHER NO. 46:
PGandE has not determined the maximum intensity earthquake that the Bay Entrance Fault is capable of generating.
INTERROGATORY NO. 47:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 46.
ANSWER NO. 47:
Not applicable.
INTERROGATORY NO. 48:
Please state what you contend is the maximum intensity earthquake that the North Spit Fault is capable of generating.
ANSHER NO. 48:
PGandE has not determined the maximum intensity earthquake that the North Spit Fault is capable of generating.
INTERROGATORY NO. 49:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 48.
ANSHER NO. 49:
Not applicable.
~
INTERROGATORY NO. 50:
Is it your contention that the structural integrity of the spent fuel pool building would not be compromised if the maximum intensity earthquake postulated for the Little Salmon Fault occurred on that fault at the point closest to the facility?
ANSWER NO. 50:
See Answer No. 51.
i
. - - . . ~. - - . ._ _ _.
i INTERROGATORY NO. 51:
Please set forth the facts on which you base your answer to Interrogatory No. 50.
ANSWER NO. 51:
As noted in earlier answers, PGandE has not determined the maximum earthquake which may occur on nearby faults at the point closest to the facility. Therefore, PGandE cannot respond either in the affirmative or in
- the negative to Interrogatory No. 50. However, the facility was designed to withstand an acceleration level of 0.5 g. If an earthquake were postulated to occur with a peak acceleration of 0.5 g, associated with a certain maximum magnitude and intensity, then PGandE does contend that the integrity of the structure would not be compromised by that maximum earthquake. Moreover,
, sufficient safety margins exist in seismic design so that the structural integrity would not necessarily be compromised even if the maximum earthquake were postulated to occur at levels greater than 0.5 g. Failure of a structure designed for an acceleration of 0.5 g would, therefore, occur at levels in excess of the design basis acceleration (see, e.g., " Equipment Response at the
, El Centro Steam Plant During the October 15, 1979 Imperial Valley Earthquake,"
by R. C. Murray, et al, NUREG/CR-1665, October 1980). In any event, when postulated accidents and associated consequences were evaluated for SAFSTOR, no credit was taken for the structural integrity of any structure whose
, function was to prevent or mitigate the consequences of such accidents.
l INTERROGATORY NO. 52:
4 Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 50.
ANSHER NO. 52:
Not applicable.
INTERROGATORY NO. 53:
Is it your contention that the structural integrity of the spent fuel j pool and its liner would not be compromised if the maximum intensity earthquake postulated for the Little Salmo.n Fault occurred on that fault at "
the point closest to the facility?
ANSWER NO. 53:
l See Answer No. 51.
i INTERROGATORY NO. 54:
Please set forth the facts on which you base your answer to i Interrogatory No. 53.
1
._....-_1.,__,____-.m.- , _ _ . _ , , , , _ . . _ , _,.. . . , _ - __-, _. _ _ _ _ .
. ANSWER NO. 54:
See Answer No. 51.
INTERROGATORY NO. 55:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 53.
ANSWER NO. 55:
Not applicable.
INTERROGATORY NO. 56:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum intensity earthquake postulated for the Little Salmon Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 56:
See Answer No. 51.
INTERROGATORY NO. 57:
Please set forth the facts on which you base your answer to Interrogatory No. 56.
ANSWER NO. 57:
- See Answcr No. 51.
INTERROGATORY NO. 58:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 56.
ANSWER NO. 58:
Not applicable.
INTERROGATORY NO. 59:
Is it your contention that the structural integrity of the spent fuel pool building would not be compromised if the maximum magnitude earthquake postulated for the Little Salmon Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 59:
See Answer No. 51.
INTERROGATORY NO. 60:
Please set forth the facts on which you base your answer to Interrogatory No. 59.
ANSHER NO. 60:
See Answer No. 51.
INTERROGATORY NO. 61:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 59.
ANSHER NO. 61:
Not applicable.
INTERROGATORY NO. 62:
Is it your contention that the structural integrity of the spent fuel pool and its liner would not be compromised' if the maximum magnitude earthquake postulated for the Little Salmon Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 62:
See Answer No. 51.
INTERROGATORY NO. 63:
r Please set forth the facts on which you base your answer to Interrogatory No. 62. .
ANSHER NO. 63:
See Answer No. 51.
INTERROGATORY NO. 64:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. '62.
~
ANSWER NO. 64:
Not applicable.
INTERROGATORY NO. 65:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum magnitude earthquake postulated for the Little Salmon Fault occurred on that fault at the point closest to the facility?
ANSWER NO. 65:
See Answer No. 51.
INTERROGATORY NO. 66:
Please set forth the facts on which you base your answer to Interrogatory No. 65. l ANSWER NO. 66:
See Answer No. 51. ,
)
INTERROGATORY NO. 67:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 65.
ANSWER NO. 67:
- Not applicable.
INTERROGATORY NO. 68:
Is it your contention that the structural integrity of the spent fuel j pool building would not be compromised if the maximum intensity earthquake postulated for the Buhne Point Fault occurred on that fault at the point closest to the facility?
i ANSWER NO. 68:
See Answer No. 51.
INTERROGATORY NO. 69:
Pleasesetforththefactsonwhichyoubaseyouranswerho Interrogatory No. 68.
ANSHER NO. 69:
See Answer No. 51.
INTERROGATORY NO. 70:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 68.
ANSWER NO. 70:
Not applicable.
INTERROGATORY NO. 71:
Is it your contention that the structural integrity of the spent fuel pool and its liner would not be compromised if the maximum intensity earthquake postulated for the Buhne Point Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 71:
See Answer No. 51.
INTERROGATORY NO. 72:
Please set forth the facts on which you base your answer to Interrogatory No. 71.
ANSHER NO. 72:
See Answer No. 51.
INTERROGATORY NO. 73:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 71.
ANSWER NO. 73:
Not applicable.
INTERROGATORY NO. 74:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum intensity earthquake ~. postulated for the Buhne Point Fault occurred on that fault at the point closest to the facility?
4 ANSMER NO. 74:
See Answer No. 51.
, INTERROGATORY NO. 75:
Please set forth the facts on which you base your answer to j Interrogatory No. 74.
ANSHER NO. 75:
See Answer No. 51.
INTERROGATORY NO. 76:
- Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 74.
l ANSHER NQ. 76:
Not applicable.
i INTERROGATORY NO. 77:
Is it your contention that the structural integrity of the spent fuel pool building would not be compromised if the maximum magnitude earthquake postulated for the Buhne Point Fault occurred on that fault at the point closest to the facility?
1 ANSWER NO. 77:
See Answer No. 51.
INTERROGATORY NO. 78:
Please set forth the facts on which you base your answer to l Interrogatory No. 77. .
ANSWER NO. 78:
See Answer No. 51.
INTERROGATORY NO. 79:
Please set forth the name of the author, the date and tit 1.e of each
" writing" that you claim supports your answer to Interrogatory No. 77.
_. _._ _ ._ __ ~. __ , _ _ _ _ _ . _ _ . . . _ _ _ _ _ __ _ . _ _ _ _ _ _ _ _ _ _ _ _
. ANSHER NO. 79:
Not applicable.
INTERROGATORY NO. 80:
Is it your contention that the structural integrity of the spent fuel pool and its liner would not be compromised if the maximum magnitude earthquake postulated for the Buhne Point Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 80:
See Answer No. 51.
INTERROGATORY NO. 81:
Please set forth the facts on which you base your answer to Interrogatory No. 80.
ANSHER NO. 81:
See Answer No. 51.
INTERROGATORY NO. 82: ,.
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 80.
l ANSHER NO. 82:
Not applicable.
INTERROGATORY NO. 83:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum magnitude earthquake postulated for the Buhne Point Fault occurred on that. fault at the point closest to the facility?
ANSHER NO. 83:
See Answer No. 51.
INTERROGATORY NO. 84:
Please set forth the facts on which you base your answer o Interrogatory No. 83.
ANSHER NO. 84:
See Answer No. 51.
INTERROGATORY NO. 85:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory Nc. 83.
ANSHER NO. 85:
1 Not applicable.
INTERROGATORY NO. 86:
i Is it your contention that the structural integrity of the spent fuel pool building would not be compromised if the maximum intensity earthquake j'
postulated for the Bay Entrance Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 86:
See Answer No. 51.
INTERROGATORY NO. 87:
l Please set forth the facts on which you base your answer to .
- Interrogatory No. 86.
! ANSHER NO. 87:
l See Answer No. 51.
l INTERROGATORY NO. 88:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 86.
i ANSHER NO. 88:
i l Not applicable, i
INTERROGATORY NO. 89:
l Is it your contention that the structural integrity of the spent fuel pool and its liner would not be compromised if the maximum intensity earthquake postulated for the Bay Entrance Fault occurred on that fault at the point closest to the facility?
i i
f
4 ANSWER NO. 89:
See Answer No. 51.
INTERROGATORY NO. 90:
Please set forth the facts on which you base your answer to Interrogatory No. 89.
ANSHER NO. 90:
See Answer No. 51.
INTERROGATORY NO. 91:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 89.
ANSWER NO. 91:
Not applicable.
INTERROGATORY NO. 92:
, Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum intensity earthquake postulated i
for the Bay Entrance Fault occurred on that fault at the point closest to the facility?
ANSWER NO. 92:
l See Answer No. 51.
INTERROGATORY NO. 93:
Please set forth the facts on which you base your answer to Interrogatory No. 92.
ANSWER NO. 93:
See Answer No. 51.
l INTERROGATORY NO. 94:
1 Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 92.
l
ANSHER NO. 94:
Not applicable.
INTERROGATORY NO. 95:
1 Is it your contention that the structural integrity of the spent fuel pool building would not be compromised if the maximum magnitude earthquake postulated for the Bay Entrance Fault occurred on that fault at the point closest to the facility?
8KSHER NO. 95:
See Answer No. 51.
INTERROGATORY NO. 96:
1 Please set forth the facts on which you base your answer to Interrogatory No. 95. ,
1 ANSWER NO. 96:
See Answer No. 51.
INTERROGATORY NO. 97:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 95.
ANSHER NO. 97:
Not applicable.
l INTERROGATORY NO. 98:
l Is it your contention' that the structural integrity of the spent fuel I pool and its liner would not be compromised if the maximum magnitude earthquake postulated for the Bay Entrance Fault occurred on that fault at the point closest to the facility? j -
ANSHER NO. 98:
See Answer No. 51.
IhTERROGATORY NO. 99:
Please set forth the facts on which you base your answer to Interrogatory No. 98.
ANSHER NO. 99:
See Answer No. 51.
INTERROGATORY NO. 100:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 98.
ANSHER NO. 100: ;
Not applicable. '
INTERROGATORY NO. 101:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum magnitude earthquake postulated for the Bay Entrance Fault occurred or, that fault at the point closest to the facility?
ANSHER NO. 101:
See Answer No. 51.
INTERROGATORY NO. 102:
Please set forth the facts on which you base your answer to Interrogatory No. 101.
ANSHER NO. 102:
See Answer No. 51.
INTERROGATORY NO. 103:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 101.
ANSHER NO. 100:
Not applicable.
l l INTERROGATORY NO. 104:
Is it your contention that the structural integrity of the spent fuel i pool building would not be compromised if the maximum intensity earthquake postulated for the North Spit Fault occurred on that fault at the point closest to the facility?
j
ANSHER NO.104:
See Answer No. 51.
INTERROGATORY NO. 105:
Please set forth the facts on which you base your answer to Interrogatory No. 104.
ANSHER NO. 105:
See Answer No. 51.
i INTERROGATORY NO.106:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 104.
ANSWER NO. 106:
Not applicable.
INTERROGATORY NO. 107:
Is it your contention that the structural integrity of the spent fuel
- pool and its I; 1er would not be compromised if the maximum intensity
- earthquake post lated for the North Spit Fault occurred on that fault at the I point closest to the facility?
ANSWER NO. 107:
l See Answer No. 51.
1 INTERROGATORY NO. 108:
Please set forth the facts on which you base your answer to Interrogatory No. 107. .
1 ANSWER NO. 108:
See Answer No. 51.
I i INTERROGATORY NO. 109:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No."107.
l l
ANSHER NO. 109:
Not applicable.
INTERROGATORY NO. 110:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum intensity earthquake postulated for the North Spit Fault occurred on that fault at the point closest to the facility?
ANSWER NO. 110:
See Answer No. 51.
INTERROGATORY NO. 111: ,
Please set forth the facts on which you base your answer to Interrogatory No. 110.
ANSHER NO _lll:
See Answer No. 51.
INTERROGATORY NO. 112:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 110.
- ANSWER NO. 112
Not applicable.
INTERROGATORY NO. 113:
Is it your contention that the structural integrity of the spent fuel pool building would not be compromised if the maximum magnitude earthquake postulated for the North Spit Fault occurred on that fault at the point closest to the facility? -
ANSHER NO. 113:
See Answer No. 51.
l INTERROGATORY NO. 114:
Please set forth the facts on which you base your answer to Interrogatory No. 113. ,
l i
l l
L
a ANSWER NO. 114:
See Answer No. 51.
INTERROGATORY NO. 115:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 113.
ANSWER NO.115:
Not applicable.
INTERROGATORY NO. 116:
Is it your contention that the structural integrity of the spent fuel pool and its liner would not be compromised if the maximum magnitude earthquake postulated for the North Spit Fault occurred on that fault at the point closest to the facility?
$NSWER NO.116:
See Answer No. 51.
r INTERROGATORY NO. 117:
Please set forth the facts on which you base your answer to Interrogatory No. 116.
ANSWER NO. 117:
See Answer No. 51.
l INTERROGATORY NO. 118:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No.116.
ANSWER NO. 118:
Not applicable.
INTERROGATORY NO. 119:
Is it your contention that the structural integrity of the off gas stack would not be compromised if the maximum magnitude earthquake postulated for the North Spit Fault occurred on that fault at the point closest to the facility?
ANSHER NO. 119:
See Answer No. 51.
INTERROGATORY NO. 120:
Please set forth the facts on which you base your answer to Interrogatory No. 119.
ANSHER NO. 120:
See Answer No. 51.
INTERROGATORY NO. 121:
Please set forth the name of the author, the date and title of each
" writing" that you claim supports your answer to Interrogatory No. 119.
ANSHER NO. 121:
Not applicable.
Respectfully submitted.
BRUCE NORTON c/o P. A. Crana H0HARD V. GOLUB PHILIP A. CRANE, JR.
RICHARD F. LOCKE Pacific Gas and Electric Company P. O. Box 7442
! San Francisco, California 94120 l (415) 781-4211 Attorneys for Pacific Gas and Electric Company BY Richard F. Locke DATED: February 2, 1987
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE FIRST SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS I have assisted in preparing the answers to Interrogatory Nos. I through 121. Said answers are true and correct to the best of my knowledge and belief.
u .
FRANK H. BRADY l Subscribed and sworn to _.. __. __. ..,____
OFFICIAL SEAL i before me this 28th day l ,er$63}c!@@&, ,
< CTY AND CC(;4Ty of SAN FRANDSCO' of January 1987.
f*" t "'! '" l f;f, y.J '
Therese Toliver, Notary Public in and for the City and County -
of San Francisco, State of California My Commission expires December 25, 1990.
t
- LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE FIRST SET OF INTERROGATORIES PRODOUNDED BY THE JOINT INTERVENORS I have assisted in preparing the answers to Interrogatory Nos. 1 through 121. Said answers are true and correct to the best of my knowledge and belief.
~ ~
L'RD 'S. CLUFF' Subscribed and sworn to f -
^ ^ ^ ^ ^ ^ ^THERESE TOUVERoiriFli^sm^
before me this 28th day cIEaY$uTJS,,
a, c- c % u. , ;l
~~~~~~
of January 1987. ~~~~'
1 n
ddd / na'u Therese Toliver, Notary Public in and for the City and County s of San Francisco, State of California
! My Commission expires December 25, 1990.
f
[
e
. DCthE1U UNITED STATES OF AMERICA uiNM NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 87 FEB -9 All :06 0Ff L. A DOCM.! N e_ .i M.l
) Docket No. 50-133 BF>hC" 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 February 2,1987, 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 FIRST 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 Dr. James H. Carpenter Public Affairs Officer Administrative Judge Region V Atomic St.fety 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 Washington, DC 20555 , San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Scott L. Fielder, Esq.
Attn: Document Control Desk 517 Third Street, Suite 14 Mashington, DC 20555 Eureka, CA 95501 l .
Richard F. Locke .
Pacific Gas and Electric Company 77 Beale Street, 27th Floor San Francisco, CA 94106 Dated at San Francisco, California, this 2nd day of February 1987.
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