ML20212N520
| ML20212N520 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 03/06/1987 |
| From: | Locke R PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - HUMBOLDT BAY |
| References | |
| CON-#187-2771 OLA, NUDOCS 8703130059 | |
| Download: ML20212N520 (14) | |
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00CNETED USNRC 1 UNITED STATES OF AMERICA - - -- '
NUCLEAR REGULATORY COMMISSION '87 MAR 11 N1!41 2
BEFORE THE ATOMIC SAFETY JND LICENSING BOARD.,.g ,. .,j f 3 00Cdt TiMi .*, F 6 au,
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4
) Docket No. 50-133 M 5 In the Matter of ) -
)
'6 PACIFIC GAS AND ELECTRIC COMPANY ) (Decommissioning)
)
7 (Humboldt Bay Nuclear Power )
Plant Unit 3) ) March 6, 1987 8 )
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S 10 FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE JOINT INTERVENORS 11 12 Pursuant to 10 CFR 2.740b and 10 CFR 2.741, Licensee PACIFIC GAS AND 13 ELECTRIC COMPANY hereby propounds the following interrogatories and request 14 for production of documents to the Joint Intervenors on their Contentions 1, 15 2, 5, 6, 7, and 8.
16 17 INSTRUCTIONS 18 19 1. All information is to be divulged which is in the possession of the 20 individual, association, or corporate party, their attorneys, consultants, i 21 investigators, agents, employees, witnesses or other representatives of the 22 named party.
23 2. Mhere you have incomplete information that precludes your fully 24 answering an interrogatory, give such information as you have and state what 5 25 information you do not have. If you are unable to give the information in the 26 form sought but have the information aggregated differently, give the i
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1 information in the form in which you have it and explain the reason for the 2 deviation.
3 3. When asked in the interrogatories below to identify or to give the 4 identity of a person, please give the following information about him or her:
5 (a) full name; 6 (b) present job title, employer, and telephone number.
7 4. When asked in the interrogatories below to identify or to give the 8 identity of a document or writing, please give the following information about 9 the document:
10 (a) its title, if any; 11 (b) its nature (e.g., letter, memorandum, chart, computer printout, 12 ledger, notes, etc.);
13 (c) the date, if any, stated on the document; 14 (d) the identity of each person who signed it; 15 (e) the identity of each person to whom it is addressed; 16 (f) the present location of the document.
17 5. Where an individual interrogatory calls for an answer which involves 18 more than one part, each part of the answer should be clearly set out so that 19 it is understandable.
20 6. These interrogatories are intended as continuing interrogatories, 21 requiring you to answer by supplemental answer, setting forth any irformation 22 within the scope of the interrogatories as may be acquired by you, your 23 agents, attorneys or representatives following ycur original answers up to the 24 time of hearing.
25 7. " Documents" include printed material, writings, calculations, 26 worksheets, handwritten notes, photographs, xerox reproductions, and audio or
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1 video recordings. " Writings" and " recordings" consist of letters, words, or j 2 numbers, or their equivalent, set down by handwriting, typewriting, printing, 3 photostating, photographing, magnetic impulse, mechanical or electronic 4 recording, or other form of data ccupilation, as defined in Rule 1001 of the 5 Federal Rules of Evidence, 28 U.S.C. '
'6 7 INTERROGATORIES 8
9 Contention 1 10 11 Interroaators No. 1. Define the term " local environment and biota" as 12 used in your contention.
13 Interroaatorv No. 2. State each and every fact upon which you base your 14 contention that there is little or no discussion of analysis of the impact on 15 the local environment and biota of the proposed SAFSTOR activities for the 16 Humboldt Bay Nuclear Pcwcr Plant (HBPP).
17 Interroaatory No. 3. State with specificity the type of analysis that 18 you contend would constitute adequate analysis of the impact on the local 19 environment and biota of the proposed activities.
20 Interroaatory No. 4. State your understanding of the current state of 21 the local environment and biota.
22 Interrogatory No. 5. What do you consider to be a potential significant 23 environmental impact.
24 Interrocatory No. 6. What potential significant environmental impacts do 25 you allege would occur on the coastal wetlands due to long-term storage of 26 nuclear materials at HBPP?
1 Interroaatory No. 7 Identify any regulations that support your 2 allegation that potential significant environmental impacts are required to be 3 documented in the Draft Environmental Statement (DES).
4 Interroaatory No. 8. Identify the provisions of the California Coastal 5 Act which you claim support your allegation that potential significant
'6 environmental impacts are required to be documented in the DES.
7 Interroaatory No. 9. Provide the basis for your statement that "Humboldt 8 Bay is the largest wetland and estuarine habitat in the California coastal 9 zone, containing approximately 23 percent of the coastal wetlands in 10 California."
11 Interroaatory No.10. Define the term "long-term storage of nuclear 12 materials" as used in your contention.
13 Interroaatory No. 11. What requirements do you claim are mandated by NEPA 14 or the California Coastal Act with respect to documentation of impacts of 15 long-term storage of nuclear materials at HBPP?
16 17 contention 2 18 19 Interroaatory No. 12. State each and every fact upon which you base your 20 contention that there is inadequate discussion and analysis of the storage of 21 spent fuel rods in the spent fuel pool at HBPP.
22 Interroaatory No. 13. Define the phrase " plagued by leakage," as used in 23 this contention. What do you contend constitutes such leakage? !
24 Interroaatory No. 14. State each and every fact upon which you base your 25 allegation that the HBPP spent fuel pool is plagued by leakage.
26 Interroaatory No. 15. State with specificity the type of analysis that
1 you contend would constitute adequate analysis of the storage of spent fuel 2 rods in a fuel pool which could be subject to leakage.
4 3 Interroaatory No.16. Would your contention remain if there were no pool 4 leakage?
5 Interroaatory No. 17. Upon what facts do you base your contention that 6 leakage from the pool could affect the safety of spent fuel storage at HBPP?
7 Interroaatory No.18. What do you allege are the effects of spent fuel 8 storage in a pool " plagued by leakage?"
9 Interrogatory No. 19. State each and every fact upon which you base your 10 contention that mechanical means of controlling pool leakage are subject to 11 malfunction.
12 Interroaatory No. 20. Specify the types of pump malfunction that you 13 believe could occur.
14 Interroaatory No. 21. What do you believe would be the consequence if a 15 pump were to malfunction?
16 Interrogatory No. 22. Define the term " increased contamination," as used 17 in your contention.
18 Interroaatory No. 23. State each and every fact upon which you base your 19 contention that the potential impacts of increased contamination have not been 20 discussed.
21 Interrogatory No. 24. What do you contend would be the sources of such an 22 alleged " increased contamination?" Identify the materials you allege would 23 cause this increase.
24 Interroaatory No. 25. Define the terms " elevated" and " trace" levels of 25 radionuclides as used in your contention. What levels of radionuclides do you 26 consider to be acceptable? State which regulations and requirements you 1
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1 contend regulate these levels.
2 Interroaatory No. 26. State each and every fact upon which you base your 3 contention that the Environmental Report (ER) indicates that there are 4 elevated and trace levels of certain radionuclides in the surface soils at the 5 plant site. '
6 Interroaatory No. 27. Provide any information you hava on what the amount 7 of background radioactivity is at the plant site?
8 Interroaatory No. 28. State each and every fact upon which you base your 9 contention that leakage of the pool continues to this day. Identify with 10 specificity the amount of leakage you believe continues to this day.
11 Interroaatory No. 29. Identify the specific locations in the ER where you 12 allege "there is some information" to indicate there are radianuclides in 13 surface soils at the plant site.
14 15 Contention 5 16 17 Interroaatory No. 30. State each and every fact upon which you base your 18 conclusion that spent fuel could be shipped to Hanford, Washington or Idaho 19 Falls, Idaho.
20 Interroaatory No. 31. State each and every fact that supports your 21 contention that it is possible to build an interim storage facility in a safer 22 and more appropriate place.
23 Interroaatory No. 32. What do you contend would constitute a safer and 24 more appropriate place for fuel storage?
25 Interroaatory No. 33. State each and every fact upon which you base your 26 assertion that viable alternatives such as shipping spent fuel to locations 1 other than Diablo Canyon have not been considered.
2 Interroaatory No. 34. What do you contend would constitute adequate 3 consideration of alternatives? What criteria do you contend should be applied 4 to evaluate alternatives? What do you contend the regulations require?
5 Ir.terroaatory No. 35. What alternatives other than SAFSTOR do you contend 6 should have been considered?
7 Interroaatory No. 36. State each and every fact that supports your 8 contention that the spent fuel at Humboldt is similar to the case with Three 9 Mile Island, and could be shipped to other locations.
10 Interroaatory No. 37. Describe the immediate dismantlement proposal as 11 stated in your contention.
12 Interroaatory NoJ. What is the basis for your statement that the 13 imediate dismantlement proposal is consistent with PGandE's present proposal 14 for decommissioning Diablo Canyon?
15 Interroaatory No. 39. What is the basis for your contention that the 16 immediate dismantlement proposal for decommissioning Diablo Canyon would also 17 be appropriate for decommissioning HBPP?
18 Interroaatory No. 40. If a federal respository for spent fuel were not in 19 place by 1998, do you agree that SAFSTOR should continue? When do you believe 20 a federal repository will be available?
21 Interrogatory No. 41. Do you agree SAFSTOR should be a viable alternative
- 22 at least until a federal repository is available?
23 Interroaatory No. 42. State why you contend that the license should be 24 discontinued at such time as a federal high-level waste repository is 25 available.
26 Interroaatory No. 43. State why you believe that the proposal that d
- 1 SAFSTOR continue for 30 years is inappropriate.
2 Interroaatory No. 44. If dismantlement were to take place as soon as a 3 high-level waste respository is available, what do you contend should be done i 4 with the spent fuel at that time?
i 5 Interroaatory No. 45. State your understanding of the Department of ,
6 Energy's contractual arrangements and terms for taking spent fuel from nuclear
! 7 power plants.
8 Interroaatory No. 46. State your understanding of the requirements of the ;
! 9 Nuclear Maste Policy Act on storage of spent fuel. i 10 9
, 11 Contention 6 l- 12 L ;
{ 13 Interroaatory No. 47. State each and every fact upoa which you base your 14 contention that the DES failed to address the impact of a major flood, i
- 15 tsunami, or fire at the plant alone, or in conjunction with a major earthquake. >
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16 Interroaatory No. 48. State each and every fact upon which you base your 17 contention that a 50 or 100 year flood coupled with high tides could possibly j 18 inundate the Humboldt plant, destroy fuel storage tanks, and cause unknown i
19 damage to the containment structures and associated buildings and equipment.
. 20 Interroaatory No. 49. Provide the assumptions and methodology used to i
j 21 support your allegation that a 50 or 100 year flood coupled with high tides 22 could possibly inundate the Humboldt plant, destroy fuel storage tanks, and 23 cause unknown damage to the containment struetures and associated buildings 24 and equipment.
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! 25 Interroaatory No. 50. State each and every fact upon which you base your 26 contention that a fire, particularly if caused by an earthquake, could cause 1 l ! i
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- 1 damage similar to that which you allege could be caused by a 50 or 100 year L
2 flood, coupled with high tides.
3 Interroaatory No. 51. Provide the assumptions and methodology used.to 4 support your allegation that a fire, particularly if caused by an earthquake, 5 could cause damage similar to that which you allege cocid be caused by a 50 or
'6 100 year flood, coupled with high tides.
7 Interroaatory No. 52. What is the basis for your statement that it was an j 8 " oversight" for the DES not to address the impacts as stated in your-9 contention?
! 10 Interroaatory No. 53. Identify any regulations that you contend require i 11 the DES to document any impacts as stated in your contention.
12 Interroaatory No. 54. Provide the basis for your statement that the 13 alleged oversight is significant.
l 14 Interroaatory No. 55. Define the term " destroy" as used in your -
i 15 contention (e.g., destroy fuel storage tank, destroyed a portion of Crescent
, 16 City).
17 Interroaatory No. 56. State the basis for your contention that a tsunami, j 18 which previously destroyed a portion of Crescent City, is relevant to a 19 determination of significant potential environmental impacts at the plant.
l i 20 Interroaatory No. 57. Define the term "cause unknown damage" as used in I
l 21 your contention. State each and every fact upon which you base your 1
l 22 contention that a flood with high tides could "cause unknown damage" to ,
23 containment structures.
f 24 Interroaatory No. 58. Identify any regulations which you contend require 25 impacts be addressed of floods, tsunamis, or fires in conjunction with a major i
26 earthquake.
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.1 Contention 7 2
3 Interroaatory No. 59. Define the ters " falling debris" as used in your
'4 contention.
5 Interroaatory No. 60. State each and every fact upon which you base your
'6 contention that the DES fails to address the impact on the fuel rods stored in 7 the . spent fuel " pond" if the storage pool were to be emptied of water by a 8 major earthquake and/or damaged by falling debris.
9_ Interroaatory No. 61. What do you contend would be the impact on the fuel 10 rods if, as you allege, the pool were to be emptied of water by a major 11 earthquake and/or damaged by falling debris? Identify the specific health 12 effects that you allege would result from this impact.
, 13 1pterroaatory No. 62. Define " fluctuate wildly" as ust.d in your 14 contention.
15 Interroaatorv No. 63. State each and every fact upon which you base your
! 16 contention that groundwater levels around the plant could fluctuate wildly 17 duting an earthquake.
18 Interroaatory No. 64. State each and every fact upon which you base your i 19 contention that leakage from the fuel pond would be transported out into the 20 bay by fluctuations in the water table due to earthquake-induced fluctuating l
l 21 groundwater levels.
l 22 Interroaatory No. 65. Describe the scenario by which you allege leakage 23 from the fuel pool wotId be transported into the bay during an earthquake.-f.<
24 Interroaatory W.,. 66. Identify any regulation which you contend requires' 25 the DES to address impacts on stored fuel if the pool were damaged or emptied l
26 of water. '
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1 Interroaatory No. 67. Provide the basis for your allegation that the pool 2 might be emptied of water if it were damaged.
3 'Interroaatory No. 68. State your understanding of the groundwater levels 4 at the plant site.
5 6 Contention 8 7
8 Interroaatory No. 69. State each and every fact upon which you base your .
9 contention that license conditions requiring seismic investigations and i 10 analyses should not be deleted irrespective of how the license is modified 11 with respect to decommissioning.
a 12 Interroaatory No. 70. Describe the type of seismic investigations and 13 analyses that you believe should be performed during decommissioning.
I 14 Interroaatory No. 71. Identify the specific health effects that you 15 allege would result from discontinuing any such seismic investigations and 16 analyses.
- 17 Interroaatory No. 72. Identify the specific safety effects that you i ,
{ 18 allege would result from discontinuing any such seismic investigations and 19 analyses.
l 20 Interroaatory No. 73. Define the term "an area of great and everchanging f 21 seismic activity," as used in your contention.
22 Interroaatory No. 74. State each and every fact upon which you base your 23 contention that additional seismic investigations and analyses should be
$ 24 performed for the SAFSTOR period.
~~
25 Interroaatory No. 75. Identify any regulation that you contend requires a f 26 seismic investigation and analysis program for a plant to be decommissioned.
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1 Interroaatory No. 76. For each answer to these interrogatories, and all 2 subparts thereto, identify each person who participated in the preparation of 3 your answers pursuant to 10 CFR 2.740b(b).
.4 Interroaatory No. 77. Provide the professional qualifications, if any, of 5 each such person identified. -
6 Interroaatory No. 78. Please identify each and every document which you 7 claim supports each fact set forth in your responses to the preceding 8 interrogatories and correlate each such document as specifically as possible 9 (page and paragraph number) with each specific response.
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1 REOUEST FOR PRODUCTION OF DOCUMENTS 2
3 Request No. 1. You are requested to produce each document identified in
- 4 your answers to the preceding interrogatories.
5 Reauest No. 2. You are requested to produce all documents you intend to
.6 use or rely upon in written testimony or oral argument.
.7 'Reauest No. 3. You are requested to produce all documents you intend to 8 have marked for identification at the hearing of this matter or which you will 9 attach to any written testimony.
10 You are requested to produce the above described documents at the office 11 of Pacific Gas and Electric Company, 77 Beale Street, Room 2711, 12 San Francisco, California 94106 on Monday, April 13, 1987 at 10:00 A.M. or at 13 some other mutually agreed upon time and location. Alternatively, you may 14 provide these documents with your answers to the above interrogatories.
15 16 Respectfully submitted, 17 BRUCE NORTON c/o R. F. Locke 18 19 H0HARD V. GOLUB RICHARD F. LOCKE 20 Pacific Gas and Electric Company !
P. O. Box 7442 21 San Francisco, California 94120 (415) 781-4211 22 Attorneys for 23 Pacifi as and Electric Company BY Y'R l 25 A1 chard F. Locke 26 DATED: March 6, 1987
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'NINc" UNITED STATES OF AMERICA A NUCLEAR REGULATORY COMMISSION g g jj gj gj BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CkEifNG kP l i 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 6,1987, 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 FIRST' SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO 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 Safety and Licensing Board U.S. Nuclear Regulatory Commission
! U.S. Nuclear Regulatory Commission 1450 Maria Lane Washington, DC 20555 Walnut 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. Fielder, Esq.
Attn: Document Control Desk 517 Third Street, Suite 14 Hashington, DC 20555 Eureka, CA 95501 i
]/ .
Rlchard F. Locke Pacific Gas and Electric Company 1 77 Beale Street, 27th Floor San Francisco, CA 94106 Dated at San Francisco, California, this 6th day of March 1987.
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