|
---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20215K1421987-06-16016 June 1987 NRC Staff Response to Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20214P2791987-05-28028 May 1987 Joint Intervenors Third Set of Interrogatories Propounded to Pg&E.* Util Requested to Answer Under Oath to Listed Interrogatories within 14 Days.Proof of Svc Encl.Related Correspondence ML20235M2411987-05-28028 May 1987 Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* NRC Requested to Answer Under Oath Following Interrogatories within 14 Days.W/Proof of Svc.Related Correspondence ML20214N3801987-05-20020 May 1987 Answers to Licensee First Set of Interrogatories Re Facility Decommissioning.Proof of Svc Encl.Related Correspondence ML20213G1081987-05-0505 May 1987 PG&E Supplemental Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Forwards Attachment 2 in Response to Info Requested Re Interrogatory 148.W/ Certificate of Svc.Related Correspondence ML20215K9371987-05-0101 May 1987 Joint Intervenors Response to First Set of Interrogatories Propounded by NRC Staff.* List of Witnesses Will Be Provided When Settled Upon.Proof of Svc Encl.Related Correspondence ML20215K9221987-04-24024 April 1987 NRC Staff First Set of Interrogatories to Joint Intervenors.* First Set of Interrogatories Re Decommissioning of Facility.Certificate of Svc Encl. Related Correspondence ML20204B7351987-03-17017 March 1987 Licensee PG&E Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Cover Will Be Installed Over Spent Fuel.Related Documentation & Certificate of Svc Encl.Related Correspondence ML20212N5201987-03-0606 March 1987 Licensee PG&E First Set of Interrogatories & Request for Production of Documents to Joint Intervenors.* Certificate of Svc Encl.Related Correspondence ML20212F8551987-02-26026 February 1987 Joint Intervenors Second Set of Interrogatories Propounded to Licensee Pg&E.* Proof of Svc Encl.Related Correspondence ML20210E5561987-02-0202 February 1987 Licensee PG&E Response to First Set of Interrogatories Propounded by Joint Intervenors.* Certificate of Svc Encl. Related Correspondence ML20207Q0181987-01-13013 January 1987 Joint Intervenors First Set of Interrogatories Propounded to Licensee Pg&E.* First Set of Interrogatories Cover Spent Fuel Pool,Earthquake Magnitude & Fault in Support of Plant Decommissioning 1987-06-16
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company ML20246M2251989-08-22022 August 1989 Exemption from Requirement of 10CFR50.54(w) Re Reduction to Required Min Amount of Primary Property Damage Insurance ML20246M1531989-08-11011 August 1989 Exemption from Requirements of 10CFR50.54(w) Re 890609 Request for Reduction in Required Min Amount of Primary Property Damage Insurance ML20235T3311989-02-23023 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. NRC Failed to Demonstrate That There Is Industry Maint Problem & Therefore Lacks Justification for Rule ML20206K6081988-11-18018 November 1988 Temporary Exemption from 10CFR50.54(w)(5)(i) Re Increase in Amount of Onsite Property Damage Insurance Required by Power Reactor Licensees & Insurance That Prioritize Insurance Proceeds for Stabilization & Decontamination After Accident ML20149F0871988-02-0909 February 1988 Order (Dismissing Contentions & Terminating Proceeding).* Licensee Motion to Dismiss Contentions & Terminate Proceeding Granted.Nrr Authorized to Make Appropriate Findings & Conclusion Contained in Ser.Served on 880209 ML20237L6881987-08-26026 August 1987 NRC Staff Response to Licensee Motion to Dismiss Contentions & Terminate Proceeding.* Board Granting of Licensee Motion to Dismiss Contentions,Terminate Proceedings & End Jurisdiction Over Amend Requested.W/Certificate of Svc ML20236N9541987-08-0707 August 1987 Motion to Dismiss Contentions & Terminate Proceeding.* Parties Agreed to Withdrawal of All Contentions Per Encl Stipulation.Dismissal of All Contentions,Issuance of License Amend & Termination of Proceeding Requested ML20236N9881987-07-23023 July 1987 Stipulation for Withdrawal of Contentions.* Parties Request That Contentions Be Withdrawn Based on Terms of Encl 870608 Mou.W/Certificate of Svc ML20215K1421987-06-16016 June 1987 NRC Staff Response to Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20235M2411987-05-28028 May 1987 Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* NRC Requested to Answer Under Oath Following Interrogatories within 14 Days.W/Proof of Svc.Related Correspondence ML20214P2791987-05-28028 May 1987 Joint Intervenors Third Set of Interrogatories Propounded to Pg&E.* Util Requested to Answer Under Oath to Listed Interrogatories within 14 Days.Proof of Svc Encl.Related Correspondence ML20214N3801987-05-20020 May 1987 Answers to Licensee First Set of Interrogatories Re Facility Decommissioning.Proof of Svc Encl.Related Correspondence ML20213G1081987-05-0505 May 1987 PG&E Supplemental Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Forwards Attachment 2 in Response to Info Requested Re Interrogatory 148.W/ Certificate of Svc.Related Correspondence ML20215K9371987-05-0101 May 1987 Joint Intervenors Response to First Set of Interrogatories Propounded by NRC Staff.* List of Witnesses Will Be Provided When Settled Upon.Proof of Svc Encl.Related Correspondence ML20215K9221987-04-24024 April 1987 NRC Staff First Set of Interrogatories to Joint Intervenors.* First Set of Interrogatories Re Decommissioning of Facility.Certificate of Svc Encl. Related Correspondence ML20206T5221987-04-17017 April 1987 Notice of Appearance.* Author Enters Appearance in Proceeding.W/Certificate of Svc ML20204B7351987-03-17017 March 1987 Licensee PG&E Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Cover Will Be Installed Over Spent Fuel.Related Documentation & Certificate of Svc Encl.Related Correspondence ML20212N5201987-03-0606 March 1987 Licensee PG&E First Set of Interrogatories & Request for Production of Documents to Joint Intervenors.* Certificate of Svc Encl.Related Correspondence ML20212F8551987-02-26026 February 1987 Joint Intervenors Second Set of Interrogatories Propounded to Licensee Pg&E.* Proof of Svc Encl.Related Correspondence ML20212C9951987-02-23023 February 1987 Notice of Author Withdrawal from Proceeding.Name Should Be Deleted from All Svc & Distribution Lists.W/Certificate of Svc ML20210E5561987-02-0202 February 1987 Licensee PG&E Response to First Set of Interrogatories Propounded by Joint Intervenors.* Certificate of Svc Encl. Related Correspondence ML20207Q0181987-01-13013 January 1987 Joint Intervenors First Set of Interrogatories Propounded to Licensee Pg&E.* First Set of Interrogatories Cover Spent Fuel Pool,Earthquake Magnitude & Fault in Support of Plant Decommissioning ML20214Q4921986-12-0303 December 1986 Order Consolidating Joint Intervenors,Admitting Contentions 1,2,5,6,7 & 8 for Adjudication,Rejecting Contentions 3 & 4 & Setting Period for Discovery from 861215 Until 30 Days After Issuance of Staff SER & Fes.Served on 861204 ML20211G5791986-10-27027 October 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20197B2461986-10-21021 October 1986 Transcript of 861021 Prehearing Conference in Eureka,Ca. Pp 1-141.Supporting Documentation Encl ML20211C0361986-10-14014 October 1986 Answer to Amended Petition to Intervene of Redwood Alliance, DG Bosco,W Chesbro,De Hauser & B Keene & ASLB Notice That Prehearing Conference Would Be Held in Eureka,Ca on 861021-22.Certificate of Svc Encl ML20203P0471986-10-10010 October 1986 Response Advising That Petitioners Adequately Demonstrated Standing to Intervene,Proffered at Least One Admissible Contention & Should Be Admitted as Parties to Proceeding. Certificate of Svc Encl ML20215D6931986-10-0909 October 1986 Response Opposing League of Women Voters late-filed Request for Hearing & Petition for Leave to Intervene Re Amend to Decommission Facility.Petitioners Fail to Satisfy five-factor Test for Late Intervention.W/Certificate of Svc ML20215C4691986-10-0606 October 1986 Answer to Petition to Intervene in License Amend Proceedings of League of Women Voters of Humboldt County & Gm Barr. Certificate of Svc Encl ML20210T1251986-10-0303 October 1986 Response to Petition to Intervene in License Amend Proceedings,Request for Hearing & Further Relief.Proposed Contentions 2,5,6 & 7 Should Be Admitted as Changed & Contentions 1,3,4 & 8 Rejected.Certificate of Svc Encl ML20214T6061986-09-26026 September 1986 Amended Petition of Redwood Alliance for Leave to Intervene & Request for Hearing.Proof of Svc Encl ML20214T6261986-09-19019 September 1986 Petition of League of Women Voters of Humboldt County to Join Petition to Intervene in License Amend Proceedings, Request for Hearing & Request for Further Relief.W/ Certificate of Svc ML20214P8141986-09-17017 September 1986 Supplemental Petition of Dh Bosco,W Chesbro,De Hauser, B Keene & Redwood Alliance for Leave to Intervene & Request for Hearing.Proof of Svc Encl ML20209G1511986-09-0909 September 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20212N1871986-08-26026 August 1986 Notice of 861021 Prehearing Conference in Eureka,Ca to Permit Identification of Key Issues in Proceeding,Consider Petition for Leave to Intervene & Establish Schedule for Completing Hearings.Served on 860827 ML20203L8811986-08-26026 August 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20212M7561986-08-22022 August 1986 Response to Redwood Alliance,W Chesbro,Dh Basco,B Keene & DE Hauser 860802 Joint Petition for Leave to Intervene & Request for Hearing.Addl Info Requested Re Standing & Interest of Parties Except DE Hauser.W/Certificate of Svc ML20203L2301986-08-18018 August 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20203L2321986-08-18018 August 1986 Answer to Petitions to Intervene & Request for Hearing. Redwood Alliance,Dh Bosco & B Keene Petitions Should Be Denied,Per 10CFR2.714 Requirements.De Hauser & W Chesbro Petitions Acceptable.Certificate of Svc Encl ML20203K1751986-08-0101 August 1986 Petition of W Chesbro,Sl Fielder,D Hauser,D Bosco,B Keene & Redwood Alliance for Leave to Intervene & Request for Hearing.W/Proof of Svc ML20204F9281986-07-30030 July 1986 Testimony of Rt Nelson & Le Vincent Before Subcommittee on Investigations & Oversight & Subcommittee on Energy Research & Production on 860730 Re Alternative Methods for Decommissioning Plant ML20137F1041986-01-14014 January 1986 Order Granting Licensee 801231 Motion to Withdraw Application to Permit Resumption of Power Operation & Granting NRC 851011 Motion Seeking Order Dismissing Proceeding.Proceeding Terminated.Served on 860115 ML20133Q3071985-10-28028 October 1985 Response to NRC 851011 Motion to Terminate Proceeding.Motion Should Be Granted.Certificate of Svc Encl ML20133H1501985-10-11011 October 1985 Motion to Terminate Proceeding Re Withdrawal of Application for License Amend.Submission of Decommissioning Plan Renders Amend Application & Any Issue Concerning Contested Application Moot.Certificate of Svc Encl ML20125C9721984-09-10010 September 1984 Transcript of ACRS Subcommittees on Humboldt Bay Project & Reactor Radiological Effects 840910 Meeting in Eureka,Ca Re Review of Util Decommissioning Plan.Pp 1-144 ML20055B5711982-07-21021 July 1982 Order Extending Time Until 820820 for Commission to Act to Review Director'S Decision DD-82-7 ML20054M8201982-07-0707 July 1982 Decision Denying R Guenther Request to Decommission Facility ML20054M9761982-06-29029 June 1982 Exemption from Requirement for Obtaining Property Damage Insurance 1996-10-18
[Table view] |
Text
_ _.
So mAwqmmew
, 00CKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '87 MAY 12 A11 :11 0FF:Li :- ': . /. E /
00CK!.iim.<. F'c 1
) Docket No. 50-133 4 6& W E "
In the Matter of -
)
)
PACIFIC GAS AND ELECTRIC COMPANY ) (Decommissioning)
)
(Humboldt Bay Nuclear Power )
Plant Unit 3) ) May 5, 1987
)
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS On March 17, 1987, PGandE filed its Response to the Second Set of Interrogatories Propounded by the Joint Intervenors (" Response"). In Answer to Interrogatory No. 148 of the Response, PGandE stated that compilation of recorded earthquake data had not been completed, and that the data will be furnished once the compilation is complete. PGandE has now completed the compilation of data necessary to respond to Interrogatory No. 148, and the data is furnished below.
Additionally, in the March 17 filing, PGandE furnished an unsigned and unexecuted copy of a sworn statement by R. T. Nelson in support of the Response. The executed signed statement is provided as Attachment 1.
INTERROGATORY NO. 148:
Please state the date of each earthquake, its epicenter, the gravity and ground acceleration of the earthquake as recorded by each of the strong ground motion indicators located at the licensee's facility between 1971 and the present.
8705180125 B70505 PDR ADOCK 05000133 G PDR Prepared for Attorneys in Preparation for Hearings - NOT DISCOVERABLE 4 OJ
- ' ~. .
ANSWER NO. 148 The information requested is provided in Attachment 2.
Respectfully submitted, BRUCE NORTON c/o R. F. Locke HOWARD V. GOLUB RICHARD F. LOCKE Pacific Gas and Electric Company P. O. Box 7442 San Francisco, California 94120 (415) 781-4211 Attorneys for Pacific Gas 'nd Electric Company f l' BY i i' '
Richa'id F. Lo'cke DATED: May 5, 1987 l
l l
l l Prepared for Attorneys in Preparation for Hearings - NOT DISCOVERABLE l
k ATTACHMENT I
. LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE SECOND SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS I have assisted in preparing the answers to Interrogatory Numbers 122 through 147, and 149 through 157. Said answers are true and correct to the best of my knowledge and belief.
IN WITNESS WHEREOF party has executed these presents this 13 % day of M 1987.
ROBERT T. NELSON Subscribed and sworn to a:a yey wmgese, before me this 13th day j}eean-nwe+++e MARCIA J. CONGDON }
of March 1987. I kI[lj NOTARY PU3LIC -f
, s, . , j G***MT CC JNTY, CALIFORMA ,e, n, e m .. . , ..w, . .n. n. n e 9 '
e ,.'
M"=s **: g < a g:+, m nyp.944peap,.g.,,*
D G Mar]iaJ. 'onddn,NothPublic in and for e State of California My Commission expires January 27, 1989 i
+
., .- __ , . . . _ , , _ , , _.. . _ , , _ . , . . _ . - , . . . . _ . _ ___._._.y __ , . - _
I ATTACHMENT 2 1
Humboldt Bay Power Plant, Unit 3 Recorded Earthquakes Acceleration (a)
Date Haanitude Location Component Location No. 1 1 Location No. 22 Location No. 33
, 03/12/73 4.3R 34 miles SE N-S 0.032 0.022 0.01 from plant site E-H 0.053 0.026 0.01 il 1 V Not Available4 Not Available4 Not Available4
! 06/07/75 5.5R 15 miles SSH N-S 0.26 0.20 0.12 i
from plant site E-H 0.35 0.25 0.16 V 0.07 0.13 0.10
].
02/03/79 4.75R 85 miles SE from N-S 0.15 0.056 0.05 l 0.08 0.05-
- plant site E-H 0.11 l V 0.06 0.04 0.035
! 11/08/80 7.OR Offshore N-S Not Available5 0 Not Available5 45 miles HNH E-H Not Available5 0.365 Not Available5 l from plant site V Not Available5 0 Not Available5 08/24/83 5.6R 20 miles SH N-S Not Ava11able6 0.0375 Not Available6
! of Eureka E-H Not Available6 0.0225 Not Available6 V Not Ava11able6 0.01 Not Available6 i
l
! 1. Floor slab of storage building 280' south of reactor caisson.
I 2. Refueling Building, elevation +12.
! 3. Reactor Caisson, elevation -66.
l 4. Information was not processed because recorded horizontal accelerations were not considered significant.
- 5. Time history recorder did not function properly. Values at location No. 2 are from Engdahl Peak Shock Recorder.
- 6. Data were not processed because recorded accelerations at Location No. 2 were not considered significant.
i I
ATTACHMENT 2 (Cont'd)
Humboldt Bay Power Plant, Unit 3 Recorded Earthquakes Acceleration (a)
Date Maanitude _ Location Component Location No. 1 1 Location No. 22 Location No. 33 09/20/84 3.7R 3.7 km SH N-S 0.037 0.022 Not Available7 from plant site E-H 0.039 0.027 Not Available7 V 0.04 0.026 Not Available7 11/21/86 5.1R 48 km SW N-S 0.078 0.120 0.116 from plant site E-H 0.046 0.097 0.103 V 0.3448 0.054 0.029 a
1 i
i
- 7. Sensor was out of service for repairs.
- 8. Record was judged to be influenced by nearby storage racks.
1 i
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THE SECOND SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS I have assisted in preparing the answer to Interrogatory No.148. .Said answer is true and correct to the best of my knowledge and belief.
FRANK H. BRADY (Executed copy will be provided as soon as it is available.)
l l
Prepared for Attorneys in Preparation for Hearings - NOT DISCOVERABLE
UNITED STATES OF AMERICA N NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAg MAY 12 All :11 h0ckrdi:;IMMib[.
) Docket No. 50-133 BRANCH 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 May 5,1987, 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 SUPPLEMENTAL RESPONSE TO THE SECOND SET OF INTERROGATORIES PROPOUNDED BY THE JOINT INTERVENORS.
Dr. Robert M. Lazo, Chairman Mitzi A. Young, Esq.
Administrative Judge Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, 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 l Hashington, DC 20555 Halnut Creek, CA 94596
! Dr. Peter A. Morris Gretchen Dumas, Esq.
( Administrative Judge California Public Utilities Atomic Safety and Licensing Board
~
Commission U.S. Nuclear Regulatory Commission 350 McAllister, Room 5243 Hashington, DC 20555 San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Scott L. Fielder, Esq.
Attn: Document Control Desk 517 Third Street, Suite 14 Hashington, DC 20555 Eureka, CA 95501
.k b ;
/ 7 Ri"ctfard F.' l'ocke' Pacific Gas and Electric Company 77 Beale Street, 27th Floor San Francisco, CA 94106 Dated at San Francisco, California, this 5th day of May 1987.
Prepared for Attorneys in Preparation for Hearings - NOT DISCOVERABLE
-_ __.