ML20212F855
| ML20212F855 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 02/26/1987 |
| From: | Fielder S FIELDER, S.L., JOINT INTERVENORS - HUMBOLDT BAY |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| CON-#187-2681 86-536-07-LA, 86-536-7-LA, OLA, NUDOCS 8703050188 | |
| Download: ML20212F855 (13) | |
Text
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W M CORRE#PONDc,rygg oo
f,[a kY 1
SCOTT L.
FIELDER Attorney at Law 2
517 Third Street, suite 14 Eureka, California 95501 gg um -4 P2 53 3
Telephone:
(707) 444-3031 4
Attorney for the Joint Intervenors yff f~
Douglas H.
Bosco, Wesley Chesbro, 5
Daniel E. Hauser, Barry Keene, The Redwood Alliance, Ralph Krause, 6
Nona Krause, Gaye H.
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
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(Decommissioning) 12
)
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ASLBP No. 86-536-07 LA 13
)
In The Matter Of
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JOINT INTERVENORS SECOND SET OF 14 Pacific Gas and Electric
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INTERROGATORIES PROPOUNDED TO Company (Humboldt Bay
)
THE LICENSEE PACIFIC GAS AND 15 Power Plant, Unit No. 3)
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ELECTRIC COMPANY 16 17 1.
PRODOUNDING " ARTY:
The Joint Intervenors LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY, 18 DANIEL E.
HAUSER, BARRV KEENE, DOUGLAS H. BOSCO, WESLEY CHESBRO, 19 RFDMOnD ALLIANCE, RALDH KRAUSE, NONA KRAUSE and GAYE M. BARR 20 2.
SET NUMBER:
TWO 21 3.
RESPONDING PARTY:
The Licensee, PACIFIC GAS AND 22 ELECTRIC COMDANY 23 YOU ARE HEREBY REOUESTED to answer under oath the follow-24 ing interrogatories within fourteen (14) days from the time ser-25 vice is made upon you, in accordance with 10 Code of Federal 26 Regulations section 2.740(b).
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B703050188 870226 28
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PDR ADOCK 05000133 O
- )503 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 knowledge 5 of all other persons of whom inquiry may reasonably be made and 6
the contents of your books and records, and those available to you 7
for examination.
Your answers to these interrogatories should be 8
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 information 11 requested, please state in detail:
12 (a)
Your answer to the fullest extent nossible; 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 fully.
17 When an interrogatory asks you to identify a writing, you 18 may in lieu of answering that interrogatory, attach a copy of that 19 writing with a statement in answer to the interrogatory that such 20 copy is attached and such copy is a true copy of the original of 21 the writing.
If you refuse to voluntarily attach a copy of that 22 writing, then identify each such writing in detail so that it may 23 be produced by you in response to a Notice To Produce or other 24 discovery devices.
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1 II 2
DEFINITIONS 3
When used in these interrogatiories and for purposes 4
thereof:
5 (a)
Licensee means and refers to Pacific Gas and Elec-6 tric Company, its agents, employees, servants, representatives and 7
any one acting on its behalf or at its recuest.
8 (b)
Facility means and refers to the Humboldt Bay Power 0
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 rod assem-12 blies at the Humboldt Bay Power Plant, Unit No.
3.
13 (d)
Writing means handwriting, typewriting, printing, 14 photostating, photographing, and every other means of recording 15 upon any tangible thing any form of communication or representatior 16 including letters, words, pictures, sounds, or symbols, or com-17 bination thereof.
18 (e)
Earthquake magnitude:
Magnitude of an earthquake 10 is a measure of the size of an earthquake and is related to the 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 24 the earth's surface at a particular location.
Intensity means the 25 numerical value on the Modified Mercalli Scale.
26 (g)
Fault:
A fault is a tectonic structure along which 27 a differential slippage of the adjacent earth materials has occur-28 red parallel to the fracture plane.
It is distinct from other [
I types of ground disruptions such as landslides, fissures and crater:
2 (h)
Surface faulting:
Surface faulting is differential 3 ground displacement at or near the surface caused directly by 4
fault movement and is distinct from nontectonic types of ground 5
disruptions, such as landslides, fissures and craters.
6 (i)
Capable fault:
A capable fault ic a fault which has 7
exhibited one or more of the following characteristics:
8 1.
Movement at or near the ground surface at least once 9
within the past 35,000 years or movement of a recurring 10 nature within the past 500,000 years; 11 2.
Macro-seismicity instrumentally determined with records 12 of sufficient precision to demonstrate a direct relation-13 ship with the fault; 14 3.
A structural relationship to a capable fault according 15 to characteristics 1. or 2. of this paragraph such that 16 movement on one could be reasonably expected to be accom-17 panied by movement on the other; 18 (j)
FIS:
Refers to the concept of the Federal Interim 19 Storage facility; 20 (k)
NRC:
Refers to the Nuclear Regulatory Commission; 2I (1)
Fuel Weight:
Means and refers to the weight of the l
22 fuel in pounds.
23 Interrogatory No. 122 24 Does the licensee intend to install a cover over the spent 25 poo17 20 Interrogatory No. 123 l
27 If your answer to the preceding interrogatory is in the 28 affirmative, please state:
1 l
1 (a) the intended date of installation; 2
(b) the thickness of the material that will make up the 3
cover; 4
(c) a description of the material the cover will be made 5
of; 6
(d) the name, address and phone number of the cover manu-7 facturer/ fabricator.
8 Interrogatory No. 124 9
How many fuel rods are contained in the 390 spent fuel rod 10 assemblies presently contained in.the spent fuel pool?
11 Interrogatory No. 125 12 What is the gross weight of each fuel rod in the spent 13 fuel pool?
14 Interrgoatory No. 126 15 What is the total weight of the uranium fuel contained in 16 each fuel rod in the spent fuel pool?
17 Interrogatory No. 127 18 Please state the title, author and date of publication of 19 each document, text or reference on which you relied to formulate 20 your answer to interrogatory No. 126?
l 21 Interrogatory No. 128 22 What is the total weight of all of the uranium fuel con-l 23 tained in all of the fuel rods that are stored in the spent fuel 24 pool?
25 Interrogatory No. 129 26 Please state the title, author and date of publication of 27 each document, text or reference on which you relied to formulate 28 you answer to interrogatory No. 1287 1
Interrogatory No. 130 2
What is the total weight of that part of the uranium fuel 3
contained in the spent fuel pool that is made up of uranium 235?
4 Interrogatory No. 131 5
What is the total weight of that part of the uranium fuel 6
in the spent fuel pool that is made up of uranium 238?
7 Interrogatory No. 132
'8 What is the total weight of uranium fuel in the spent fuel 9
pool that is made up of plutonium 239?
10 Interrogatory No. 133 11 What is the total weight of all other transuranic elements 12 contained in the spent fuel in the spent fuel pool?
13 Interrogatory No. 134 14 Please set forth the name of the author, date and title of 15 each " writing" that you relied to answer questions 130, 131, 132, 16 and 133?
17 Interrogatory No. 135 18 Has the NRC performed a periodic Systematic Assessment of 19 Licensee Performance (SALP) for the Humboldt Bay Unit 3 in the 20 last three years?
21 Interrogatory No. 136 22 If your answer was in the affirmative, please state what 23 the NRC's Systematic Assessment of Licensee Performance concluded 24 for each of the last three years?
25 Interrogatory No. 137 26 If your answer to question No. 135 was in the affirmative, 27 please state the name, address and phone number of the employee 28 who has custody of the Licensees' copy of the SALP? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
1 Interrogatory No. 138 2
In your answers to interrogatories 51, dated February 2, 3
1987, you indicated that the Licensee had not determined the maxi-4 mum earthquake which may occur on nearby faults at the point 5
closest to the facility.
Does the licensee presently have a study 6 or studies underway to determine what the maximum credible earth-7 quake on the Little Salmon, Buhne Point, Bay Entrance or North SP t fault would be?
i 8
9 Interrogatory No. 139 10 If your answer is yes, to interrogatory No. 138, please 11 indicate the name of the person or company that has responsibility 12 for carrying out the study, their address and the date they expect 13 to complete their work assignment?
14 Interrogatory No. 140 15 In your answer number 51 to interrogatories, dated Feb-16 ruary 2, 1987, you state at the end of your answer that "In any 17 event, when postulated accidents and associated consequences were 18 evaluated for SAFESTOR, no credit was taken for the structural 19 integrity of any structure whose function was to prevent or miti-20 gate the consequences of such accidents".
Please explain what 21 structures "whose function was to orevent or mitigate the conse-22 quences of such accidents" your answer refers, and identify their 23 location?
24 Interrogatory No. 141 25 Do you contend that the Environmental Report prepared by 26 licensee addressed the possibility of the Spent Fuel Building 27 collapsing during an earthquake on to the fuel in the Spent Fuel 28 Pool? __
1 Interrogatory No. 142' 2
If your. answer to interrogatory No. 141 is in'the affirma-3 tive please state where in the Environmental Report the licensee 4
addressed this issue.
5 Interrogatory No. 143 6
If your answer to interrogatory No. 141 is in the negative, 7
please state why this possibility was not addressed?
8 Interrogatory No. 144 9
Is it the licensee's contention that the Licensee is pre-10 cluded by governmental regulation, laws or rules from removing the 11 spent fue,1 to a Federal Interim Storage (FIS) facility?
12 Interrogatory No. 145 13 If your answer to interrogatory No. 144 is in the affirma-14 tive, please state each and every reason why the licensee feels 15 that it is precluded from removing the spent fuel to a Federal 16 Interim Storage facility and provide the governmental regulation, l
17 rule or law on which the answer is based?
l 18 Interrogatory No. 146 I
l 19 If the Licensee does not contend that it is barred by 20 governmental rules, regulations or laws from removing the fuel to 21 an FIS, does the licensee nevertheless contend that some other 22 factor or impediment would make removal of the fuel stored at the 1
23 facility impractical?
l 24 Interrogatory No. 147 25 If your answer to the preceeding interrogatory is in the 26 affirmative, please state each and every reason you contend 27 removal of the spent fuel is impractical.
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1 Interrogatory No. 148 2
Please state the date of each earthquake, its epicenter, 3
the gravity and ground acceleration of the earthquake as recorded 4
by each of the strong ground motion indicators located at the 5
licensees facility between 1971 and the present.
6 Interrogatory No. 149 7
Please state how many fuel rods are only partially spent ~of 8
the total number of rods stored in the spent fuel pool?
9 Interrogatory No. 150 10 Please provide a list of all abnormal incidents that have 11 occurred involving the spent fuel pool, which list should include 12 the date of the occurrence, the person who reported the incident 13 and the number or identifying label of the report submitted to 14 the NRC, which have occurred since the beginning of operations at 15 Unit 3 to the present?
16 Interrogatory No. 151 17 please provide the name, title, phone number and address of 18 the custodian of the records who has custody of the records request 19 ed in interrogatory No. 150?
20 Interrogatory No. 152 21 Assuming, for the purposes of this interrogatory, that 22 more than 10% of the fuel in the spent fuel pool began to go criti-23 cal af ter being damaged in an earthquake, what emergency contin-24 gency plans does the licensee have to abort the fuel going critical 25 and to contain the accident?
20 Interrogatory No. 153 27 What is the pounds per square inch (PSI) containment rating 28 of the spent fuel building? >
1 Interrogatory No. 154 2
Please state how high above the mean high tide line of 3 Humboldt Bay the floor of the spent fuel storage pool is located?
4 Interrogatory No. 155 5
Please define what is meant by the phrase "uncanned fuel 6
assembly"?
7 Interrogatory No. 156 8
Please state the title, author and date of publication of 9
each report the licensee be'l es supports it's assertion that the 10 fuel in spent fuel pool would ot.be substantially degraded by 11 heating if all the pool water in the pool were lost?
12 Interrogatory No. 157 13 Please state the name, occupation, business address and 14 provide a narrative statement of the qualifications of each wit-15 ness the licensee intends to call as a witness at the evidentiary 16 hearing that will be held in this matter?
17 Interrogatory no. 158 18 Please state the occupation, company affiliation, if any, 19 and provide a narrative statement of the qualifications of Frank 20
- w. Brady?
2I Interrogatory No. 159 22 Please state the occupation, company affiliation, if any, 23 and provide a narrative statement of the qualifications of Lloyd 24 S. Cluff?
/f((87 25 Dated:
~
26
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27 SCOTT L. FIELDER 28 Attorney For The Joint Intervenor3 PROOF OF SERVICE mcrETED w r; I am a resident of the County of Humboldt; I am over the age of eighteen years and not a party to the withigy agog;ifo;qd psyy Suite 14, Eureka, Cal
- fHia, business address is 517 - 3rd Street, 95501.
a.e r
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, I served the withins On February 26, 1987 Joint Intervenors Second Set of Tni prrman+ nripe pennrumAna To The Licensee Pacific Gas And Electric Comoany on the interested parties in said action By placing a true copy thereof enclosed in a sealed en-( X) velope with postage thereon fully prepaid, in the United States mail at Eureka, California, addressed as listed below.
(
)
By personally delivering a true c6py thereof to the persons listed below.
I declare under penalty of perjury that the foregoing is true and correct.
Executed at Eureka, California, on Februarv 2 fi. 1497 Ys-&
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'KAiBERLY MANGES co' See Attachment 3
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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 Richard F. Locke Pacific Gas and Electric Company Post Office Box 7442 San Francisco, California 94120 Mr. Bruce.NOrton c/o Richard F. Locke Pacific Gas and Electric Company Post Office Box 7442 San Francisco,-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 Robert M. Lazo, Esq.
Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James H. Carpenter, Member Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C.
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ATTACHMENT'(con't)
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 Honorable Wesley Chesbro Supervisor, Third District Post Office Box 4661 Arcata, California 95521 Redwood Alliance Post Office Box 293 Arcata, California 95521
_ _ _ _ _ _.