ML20214Q378
| ML20214Q378 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/16/1986 |
| From: | Norton B PACIFIC GAS & ELECTRIC CO. |
| To: | Sierra Club |
| Shared Package | |
| ML20214Q354 | List: |
| References | |
| OLA, NUDOCS 8609240335 | |
| Download: ML20214Q378 (15) | |
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1 UNITED STATES OF AMERICA s
NUCLEAR REGULATORY COMMISSI 3(( c!
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BEFORE THE ATOMIC SAFETY AND LICENSI 3
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Docket Nos. 50-275 5
In the Matter of
)
.50-323
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6 PACIFIC GAS AND ELECTRIC COMPANY )
(Reracking of Spent Fuel Pools)
)
7 (Diablo Canyon Nuclear Power
)
Plant Units 1 and 2)
)
8
)
9 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S 10 FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SIERRA CLUB 11 12 Pursuant to 10 CFR 2.740b, Licensee PACIFIC GAS AND ELECTRIC COMPANY 13 hereby propounds the following interrogatories and document requests to Sierra 14 Club on its Contentions I and II.
15 INSTRUCTIONS 16 1.
All information is to be divulged which is in the possession of 17 the individual, association, or corporate party, their attorneys, consultants, 18 investigators, agents, employees, witnesses or other representatives of the 19 named party.
l 20 2.
Where you have incomplete information that precludes your fully 21 answering an interrogatory, give such information as you have and state what 22 information you do not have.
If you are unable to give the information in the 23 form sought but have the information aggregated differently, give the 24 information in the form in which you have it and explain the reason for the 25 deviation.
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1 3.
When asked in the interrogatories below to identify or to give 2
the identity of a person, please give the following information about him or 3
her:
4 (a) full name; 5
(b) present job title, employer, and telephone number.
6 4.
When asked in the interrogatories below to identify or to give I
7 the identity of a document or writing, please give the following information 8
about the document:
9 (a) its title, if any; 10 (b) its nature (e.g., letter, memorandum, chart, computer-11 printout, ledger, notes, etc.);
12 (c) the date, if any, stated on the document; 13 (d) the identity of each person who signed it; 14 (e) the identity of each person to whom it is addressed:
15 (f) the present location of the document.
16 5.
Where an individual interrogatory calls for an answer which 17 involves more than one part, each part of the answer should be clearly set out 18 so that it is understandable.
19 6.
These interrogatories are intended as continuing interrogatories, 20 requiring you to answer by supplemental answer, setting forth any information
-21 within the scope of the interrogatories as may be acquired by you, your 22 agents, attorneys or representatives following your original answers up to the 23 time of hearing.
24 7.
" Documents" include printed material, writings, calculations, 25 worksheets, handwritten notes, photographs, xerox reproductions, and audio or 26 video recordings.
"Hritings" and " recordings" consist of letters, words, or
t i
numbers, or their equivalent, set down by handwriting, typewriting, printing, 2
photostating, photographing, magnetic impulse, mechanical or electronic 3
recording, or other form of data compilation, as defined in Rule 1001 of the 4
Federal Rules of Evidence, la U.S.C.
5 INTERROGATORIES 6
1.
State each and every fact upon which you base your contention 7
that the expected velocity and displacement of the spent fuel pools as a 8
function of time in three dimensions during the postulated Hosgri earthquake 9
(PHE) are necessary to be included in the reports for independent verification,
10 of the claims made in the reports regarding the consistency of the proposed 11 reracking with the protection of the public health and safety, and the 12 environment.
13 2.
State each and every fact upon which you base your contention 14 that the expected maximum velocity and displacement of the racks obtained from 15 the computer modeling of rack behavior during the PHE are necessary to be 16 included in the reports for independent verification of the claims made in the 17 reports regarding consistency of the proposed reracking with the protection of 18 the public health and safety, and the environment.
19 3.
State each and every fact upon which you base your contention i
20 that the resonant behavior of the spent fuel assemblies in the racks in 21 response to the PHE and the consequences of such behavior should have been 22 considered in the reports to permit independent verification of claims made in 23 the reports regarding consistency of the proposed reracking with the public 24 health and safety, and the environment, and with federal law.
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1 4.
State each and every fact upon which you base your contention 2
that the use of anchors, braces, or other structural members to prevent rack 3
motion and subsequent damage during the PHE should have been considered in the 4
reports to permit independent verification of claims made in the reports 5
regarding consistency of the proposed reracking with the public health and 6
safety, and the environment, and with federal law.
7 5.
State each and every fact upon which you base your contention 8
that the use of "boraflex" neutron absorbing material for all spent fuel racks 9
should have been considered in the reports.
10 6.
State each and every fact upon which you base your contention 11 that alternative on-site storage facilities, including:
12 (1) construction of new or additional storage facilities and/or; 13 (ii) acquisition of modular or mobile spent nuclear fuel storage 14 equipment, including spent nuclear fuel storage casks; 15 should have been considered in the reports.
16 7.
What would constitute adequate consideration of alternatives?
17 8.
Two alterritive on-site storage facilities are identified in 18 your Contention I(B)7. What other alternatives should have been considered, 19 if any?
20 9.
What federal or state regulations require consideration of 21 alternatives in a spent fuel pool reracking?
22
- 10. State each and every fact upon which you base your contention 23 that during the PHE, collisions between the racks and the pool walls are 24 expected to occur resulting in impact forces on the racks significantly larger 25 than those estimated in the reports.
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1
- 11. State each and every fact upon which you base your contention 2
that during the PHE, collisions between the racks and the pool walls are 3
expected to occur resulting in impact forces on the racks significantly larger 4
than those expected to damage the racks.
5
- 12. State each and every fact upon which you base your contention 6
that during the PHE, collisions between the racks and the pool walls are 7
expected to occur resulting in significant permanent deformation and other 8
damage to the racks and pool walls.
9
- 13. State each and every fact upon.which you base your contention 10 that during the PHE, collisions between the racks and the pool walls are 11 expected to occur resulting in reduction of the spacing between fuel 12 assemblies.
13
- 14. State each and every fact upon which you base your contention 14 that during the PHE, collisions between the racks and the pool walls are 15 expected to occur resulting in increase in the nuclear criticality coefficient 16 k(eff) above 0.95.
17
- 15. State each and every fact upon which you base your contention 18 that during the PHE, collisions between the racks and the pool wall.s are 19 expected to occur resulting in release of large quantities of heat and 20 radiation.
21
- 16. State each and every fact upon which you base your contention 22 that during the PHE, collisions between the racks and the pool walls are 23 expected to occur resulting in radioactive contamination of the nuclear power 24 plant and its employees above the levels permitted by federal regulations.
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- 17. State each and every fact upon which you base your contention 2
that during the PHE, collisions between the racks and the pool walls are 3
expected to occur resulting in radioactive contamination of the environment in 4
the vicinity of the nuclear power plant above the levels permitted by federal 5
regulations.
6
- 18. State each and every fact upon which you base your contention 7
that during the PHE, collisions between the racks and the pool walls are 8
expected to occur resulting in radioactive contamination of humans and other 9
living things in the vicinity of the nuclear power plant above the levels 10 permitted by federal regulations.
11
- 19. State each and every fact upon which you base your contention 12 that during the PHE, collisions between groups of racks with each other and/or 13 with the pool walls are expected to occur resulting in impact forces on the 14 racks significantly larger than those estimated in the reports.
15
- 20. State each and every fact upon which you base your contention 16 that during the PHE, collisions between groups of racks with each other and/or 17 with the pool walls are expected to occur resulting in impact forces on the 18 racks significantly larger than those expected to damage the reports.
1 l
19
- 21. State each and every fact upon which you base your contention 20 that during the PHE, collisions between groups of racks with each other and/or 21 with the pool walls are expected to occur resulting in significant permanent l
22 deformation and other damage to the racks and pool walls.
23
- 22. State each and every fact upon which you base your contention 24 that during the PHE, collisions between groups of racks with each other and/or i
25 with the pool walls are expected to occur resulting in reduction of the 26 spacings between fuel assemblies.
W M
4 1
23.
State each and every fact upon which you base your contention 2
that during the PHE, collisions between groups of racks with each other and/or 3
with the pool walls are expected to occur resulting in increase in the nuclear 4
criticality coefficient k(eff) above 0.95.
5
- 24. State each an:1'every fact upon which you base your contention 6
that during the PHE, collisions between groups of racks with each other and/or 7
with the pool walls are expected to occur resulting in release of large 8
quantities of heat and radiation.
9
- 25. State each and every fact upon which you base your contention j
10 that during the PHE, collisions between groups of racks with each other and/or 11 with the pool walls are expected to occur resulting in radioactive 12 contamination of.the nuclear power plant and its employees above the levels 13 permitted by federal regulations.
14
- 26. State each and every fact upon which you base your contention 15 that during the PHE, collisions between groups of racks with each other and/or 16 with the pool walls are expected to occur resulting in radioactive 17 contamination of the environment in the vicinity of the nuclear power plant 18 above the levels permitted by federal regulations.
19
- 27. State each and every fact upon which you base your contention 20 that during the PHE, collisions between groups of racks with each other and/or j
21 with the pool walls are expected to occur resulting in radioactive 22 contamination of humans and other living things in the vicinity of the nuclear 23 power plant above the levels permitted by federal regulations.
-24
- 28. State each and every fact upon which you base your allegation 25 that the NRC has not assessed the impact of the potential for collision of one 26 rack with another rack.
(Ferguson Aff., 6/15/86 at 5.)
l l _-. -
1
- 29. State each and every fact upon which you base your allegation 2
that forces as large as 600,000 pounds would be generated from rack-rack 3
collisions.
(Ferguson Aff., 6/15/86 at 9.)
4 30.
State each and every fact upon which you base your allegation 5
that Dr. Ferguson's calculations, which allow for potential movement of all 6
surrounding racks and assume no cushioning effect of water, are more realistic 7
than the calculations performed by PGandE.
(Ferguson Aff., 6/15/86 at 9.)
8
- 31. State each and every fact upon which you base your allegation 9
that the force on a rack could be as large as 1,000,000 pounds or greater when 10 a rack collides with a wall.
(Ferguson Aff., 6/15/86 at 7.)
11 32.
State why you believe a one-dimensional analytical model is 12 adequate to predict realistic response of the rack modules under seismic 13 loading conditions.
24 33.
Provide the method, assumptions, dynamic model, and results of 15 your analysis which shows that the fuel racks, located inches from the walls 16 of the pool, would collide with these walls as a result of seismic motion of 17 the magnitude postulated to occur at Diablo Canyon. (Ferguson Aff., 6/15/86 18 at 6.)
19
- 34. Define what is meant by " resonant behavior of the spent fuel 20 assemblies."
21 35.
Please set forth what you believe to be the appropriate 22 coefficients of friction for analysis of rack response.
23 36.
Is it your belief or position that there is a standard 24 engineering practice for the proposed reracking? Provide the basis for the 25 response.
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- 37. State each and every fact upon which you base your statement 2
that the proposed retrofit-involves unique seismic considerations.
3
- 38. State.each and every fact upon which you base your allegation 4
that the resulting hazard to the public health and safety and to the 5
environment is a problem unique to the proposed reracking at Diablo Canyon.
6 (Ferguson Aff., 6/15/86 at 8.)
7
- 39. State each and every fact upon which you base your allegation 8
that use of freestanding racks of much greater density has a significant 9
impact on the safety of the spent fuel storage pools.
10
- 40. State each and every fact upon which you base your allegation 11 that the NRC has overemphasized the cushioning effect of water in collisions 12 involving fuel racks.
(Ferguson Aff., 6/15/86 at 6) l 13
- 41. State what you believe to be the appropriate method of 14 accounting for the cushioning effects of water in collisions involving fuel 15 racks.
16
- 42. Define the " cushioning effects" of water.
17
- 43. Is it your belief or position that potential collisions between 18 racks may damage the racks, leading to criticality? Provide the basis for the 19 response.
20
- 44. State each and every fact upon which you base your allegation 21 that during seismic activity, two or more racks could slide together as a 22 unit.
(Ferguson Aff., 6/15/86 at 7.)
23
- 45. Is it your belief or position that the higher density racks will 24 not preclude criticality due to the closer spacing? Provide the basis for the 25 response.
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1 46.
State each and every fact upon which you base your statement 2
that the proposed reracking would significantly reduce the margin of safety 3
for the spent fuel storage system and pose a risk to the public health and 4
safety and protection of the environment.
(Ferguson Aff., 6/15/86 at 2) 5
- 47. State each and every fact upon which you base your statement
'6 that PGandE has increased considerably the potential for serious consequences 7
if collisions do occur.
(Ferguson Aff., 6/15/86 at 5) 8 48.
Provide the basis for using constant velocity, constant 9
acceleration, and a value of zero for the coefficient of friction between the 10 rack and the liner in the calculation of the force on a spent fuel rack 11 colliding with a wall. (Ferguson Aff., 6/15/86, Appendix A.)
12
- 49. State each and every fact that supports your estimate that 13 sliding racks during the PHE will attain speeds ten times those used by 14 PGandE.
(Ferguson Aff., 8/4/86 at 6.)
15 50.
State each and every fact that supports your claim that fluid 16 forces would not be expected to reduce impact forces to the values used by 17 PGandE.
(Ferguson Aff., 8/4/86 at 7.)
18 51.
State each and every fact that supports your claim that PGandE ll 19 extrapolated results "of the cited reference" beyond its demonstrated 20 validity.
(Ferguson Aff., 8/4/86 at 8.)
21
- 52. State each and every fact that supports your allegation that 22 PGandE's extrapolation procedure is not in keeping with standard scientific 23 practice.
Identify the scientific practice which you reference.
(Ferguson 24 Aff., 8/4/86 at 8.)
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- 53. Provide a description of the dynamic model and detailed 2
calculations to support your results that forces on loaded racks sliding 3
during the PHE are expected to be large enough to damage the racks.
(Ferguson 4
Aff., 8/4/86 at 5.)
5
- 54. State each and every fact that supports your allegation that 6
PGandE's extrapolation procedure is the reason why the impact forces estimated 7
by PGandE are too small. Define what you mean by " scientifically dubious" W
O' extrapolation procedure.
(Ferguson Aff., 8/4/86 at 8.)
9
- 55. For each answer to these interrogatories, and all subparts 10 thereto, identify each person who participated in the preparation of your 11 answers pursuant to 10 CFR 2.740b(b).
12
- 56. Provide the professional qualifications, if any, of each such 13 person identified.
14
- 57. Please identify each and every document which you claim supports 15 each fact set forth in your responses to the preceding interrogatories and 16 correlate each such document as 'specifically as possible (page and paragraph 17 number) with each specific response.
18 19 RE00EST FOR PRODUCTION OF DOCUMENTS 20 1.
Pursuant to 10 CFR 2.241, you are requested to produce each l
21 document identified in your answers to the preceding interrogator 13s.
22 2.
You are requested to produce all documents you intend to use or 23 rely upon in written testimony or oral argument.
l 24 3.
You are requested to provide all documents you intend to have 25 marked for identification at the hearing of this matter or which you will l
26 attach to any testimony.
l t l
4.
The documents should be produced on October 22, 1986 at 10:30 a.m. at 1
the 31st floor conference room, 77 Beale Street, San Francisco.
2 3
Respectfully submitted, 4
BRUCE NORTON 5
c/o P. A. Crane 6
ROBERT OHLBACH 7
PHILIP A. CRANE, JR.
RICHARD F. LOCKE 8
Pacific Gas and Electric Company P. O. Box 7442 9
San Francisco, California 94120
- 15) 781-42H 10 Attorneys for 11 Pacific Gas and Electric Company 12 By
_"*D 14 Bruce Norton 15 16 DATED:
September 16, 1986 17 18 19 20 21 22 23 24 25 26
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SEP 191986* :g 1
UNITED STATES OF AMERICA %
tocmnic s NUCLEAR REGULATORY COMMISSIO g SEggByfica BEFORE THE ATOMIC SAFETY AND LICENSIN Ann-3
~/'6I 4
)
Docket Nos. 50-275 In the Matter of
)
50-323 5
)
PACIFIC GAS AND ELECTRIC COMPANY )
(Reracking of Spent Fuel Pools) 6
)
(Diablo Canyon Nuclear Power
)
7 Plant Units 1 and 2)
)
)
8 9
NOTICE OF CHANGE OF ADDRESS 10 Henceforth, please send all correspondence, whether regular mail, 11 express mail, or courier, to Bruce Norton at the following address:
12 13 Bruce Norton 14 clo P. A. Crane 15 Pacific Gas and Electric Company 16 77 Beale Street, 31st Floor 17 San Francisco, CA 94106 18 19 The telephone number where Mr. Norton can be reached during business 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> is (415) 768-4462.
21 23 24 Bruce Norton 25 26 Dated at San Francisco, California, this 16th day of September,1986.
mLAic CUnstruwnr n A DOLKETED UNC 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
Docket Nos. h5i$d Sf(c[
4 In the Matter of
)
50-323 RANCH
)
5 PACIFIC GAS AND ELECTRIC COMPANY )
(Reracking of Spent Fuel Pools) 4
)
6 (Diablo Canyon Nuclear Power
)
Plant Units 1 and'2)
)
7
)
4 8
CERTIFICATE OF SERVICE 9
I hereby certify that on September 16, 1986, copies of the following documents in the above-captioned proceeding have been served on the following 10 by deposit in the United States mail, first class, or as indicated by an asterisk through delivery by courier: 1) Licensee Pacific Gas and Electric 11 Company's First Set of Interrogatories and Request for Production of Documents to the San Luis Obispo Mothers for Peace; 2) Licensee Pacific Gas and Electric 12 Company's First Set of Interrorgatories and Request for Production of Documents to the Consumers Organized for Defense of Environmental Safety; and 13
- 3) Licensee Pacific Gas and Electric Company's First Set of Interrogatories
~
and Request for Production of Documents to the Sierra Club:
14 B. Paul Cotter, Jr., Chairman Docketing and Service Branch 15 Administrative Judge Office of the Secretary l
Atomic Safety and Licensing US Nuclear Regulatory Commission 16 Board Panel Washington DC 20555 US Nuclear Regulatory Commission 17
.4350 East West. Highway 4th Floor Bethesda MD 20814 18 Glenn O. Bright Lawrence Chandler, Esq.
19 Administrative Judge Henry J. McGurren. Esq.
Atomic Safety and Licensing Office of Executive Legal Director
~
20 Board Panel US Nuclear Regulatory Commission US Nuclear Regulatory Commission Maryland National Bank Building i
21 4350 East West Highway 4th Floor Room 9604 i
Bethesda MD 20814 7735 Old Georgetown Road 22 Bethesda MD 20814 23 Dr. Jerry Harbour Lewis Shollenberger Administrative Judge Regional Counsel 24 Atomic Safety and Licensing-US Nuclear Regulatory Commission l
Board Panel Region V 25 US Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 4350 East West Highway 4th Floor Halnut Creek CA 94596 26 Bethesda MD 20814 l
__m.,.
4 1
Diablo Canyon Service List 2
3 Atomic Safety and Licensing Dian M. Grueneich 4
Board Panel Grueneich & Lowry US Nuclear Regulatory Commission 345 Franklin Street 5
Hashington DC 20555 San Francisco CA 94102 l
6 Atomic Safety and Licensing Jacquelyn Wheeler Appeal Board Panel 2455 Leona Street t
7 US Nuclear Regulatory Commission San Luis Obispo CA 93401 Hashington DC 20555 8
Laurie McDermott, Coordinator Mr. Lee M. Gustafson C.O.D.E.S.
9 Pacific Gas and Electric Company 731 Pacific Street Suite #42 1726 M Street NH Suite 1100 San Luis Obispo CA 93401 10 Hashington DC 20036-4502 Managing Editor 11 Janice E. Kerr, Esq.
San Luis Obisno County Public Utilities Commission
. Telearam-Tribune 12 5246 State Building 1321 Johnson Avenue 350 McAllister Street San Luis Obispo CA 93406 13 San Francisco CA 94102 Richard E. Blankenburg 14 Nancy Culver Co-publisher 192 Luneta Street Wayne A. Soroyan, News Reporter 15 San Luis Obispo CA 93401 South County Publishing Company P. O. Box 460 16 Arroyo Grande CA 93420 17 Dr. Richard Ferguson Vice-Chairman l
18 Sierra Club l
Rocky Canyon Star Route l
19 Creston CA 93432 1
h 21 Bruce Norton c/o P; A. Crane 22 Pacific Gas and Electric Company 77 Beale Street, 31st Floor 23 San Francisco, CA 94106 24 Dated at San Francisco, California, this 16th day of September,1986.
25 26 O
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