ML20215K142
| ML20215K142 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 06/16/1987 |
| From: | Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | JOINT INTERVENORS - HUMBOLDT BAY |
| References | |
| CON-#287-3798 OLA, NUDOCS 8706250228 | |
| Download: ML20215K142 (16) | |
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h8Q7N wmu CORRESPOMBES
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June 16,1987 m.
UNITED STATES OF AMERICA -
NUCLEAR PEGULATORY COMMISSION '87 ^JUN 17 95 :33 BEFORE THE ATOMIC SAFETY AND LICENSING BOAhh . ,: M r 9 p t. w, In the Matter of )
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PACIFIC GAS AND ELECTRIC )- Docket No. 50-133 OLA COMPANY )
) (Decommissioning)
(Humboldt Bay Power Plant )
Unit No. 3) )
E NRC STAFF RESPONSE TO JOINT INTERVENORS' FIRST SET OF INTERROGATORIES PROPOUNDED TO NRC STAFF On May 28, 1987 the Joint Intervenors II in this proceeding filed one interrogatory with the NRC Staff pursuant to 10 C.F.R. 2.740 (b). 2_/ The Staff hereby submits its response.
The Interrogatory states as follows:
Interrogatory No.1 1
For each Contention which has been admitted by the Licensing Board in the Prehearing Conference Order dated December 2, -
1986, in the above-captioned proceeding, list the following:
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1/ The intervenors in this proceeding are: the League of Women Voters of Humboldt County and Gaye M. Barr, Daniel E. Hauser, Barry f Kenne, Douglas H. Bosco, Wesley Chesbro, and the Redwood '
Alliance, admitted as consolidated intervenors by Prehearing Conference Order (Order) dated December 3,1986, at 21.
2/
By cover letter to Judge Lazo, intervenors also asked for a Board order pursuant to 10 C.F.R. 5 2.720(h)(2)(li) requiring Staff to respond to the interrogatory. Such an order is unnecessary as the Staff is voluntarily responding. By the same letter the intervenors asked for a 30 day extension of discovery. Staff has no objection to this request. Discovery began December 15, 1986 and closed June 8, .1987 (thirty days after issuance of Staff's Safety Evaluation Report and Final Environmental Statement). See Order at 21.
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, (a) The identity of each person expected to be called as a witness at the hearing:
(b) The subject matter on which the witness is expected to testify; (c) The substance of the witness's testimony; and, (d) The witness's professional or other qualifications to testify on the subject matter on which the witness will testify.
For each contention b he t Staff witness (es) and expected testimo'ny are provided in response to interrogatory 1, parts (a) - (c). The professional qualifications of the witnesses are attached to this response in answer to part (d).,'-
Contention 1 (a) Robert Samworth and Jerry Swift.
(b) R. Samworth: non-radiological impact of SAFSTOR on local environment.
J. Swift: Radiological impact of SAFSTOR on local environment.
(c) The proposed decommissioning (SAFSTOR) of the Humboldt Bay Power Plant Unit 3 (H B PP-3) will have no significant radiological or non-radiological impact on the local environment.
Contention 2 (a) Rex Wescott, Jerry Swift, Frank Witt (b) R. Wescott: hydrology J. Swift: radiological impact of spent fuel pool (SFP) leakage F. Witt: SFP liner gap level control system and technical specifications
-3/ Six contentions were admitted for iltigation. The admitted contentions were numbered 1, 2, 5, 6, 7, and 8. Order, at 21.
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.- (c) There is no significant environmental impact from HBPP-3 SFP leakage.
Contention 5 (a) Peter Erickson and Robert Samworth (b) Possible alternative spent fuel storage ]
(c) There is no significant environmental impact to the SAFSTOR at I
HBPP-3 and no alternative spent fuel storage is available which is obviously superior to the proposed SAFSTOR at H B PP-3.
Contention 6 (a) Jerry Swift, Rex Wescott, Millard Wohl (b) J. Swift: radiological consequences of damage to SFP from flood or tsunami 'and earthquake ee i W. Wescott: characteristics of tsunami and floods i l
M. Wohl: radiological consequences of SFP damage from fire end earthquake ,
(c) Releases from damaqe to H B PP-3 caused by earthquake and fire , tsunami, or flood would be less than 10 C.F.R. Part 100 ,
limits and would not require offsite protective action by EPA guidelines.
Contention 7 (a) Jerry Swift, Rex Wescott, Millard Wohl (b) J. Swift: radiological releases to Humboldt Bay from earthquake damage R. Wescott: hydrology >
M. Wohl: SFP cooling after loss of all water
, (c) The consequences of all SFP water leakage into Humboldt Day would cause less radiological releases than natural background The fuel rods can be cooled adequately by natural radiation.
convection .a case of the loss of all pool water.
Contention 8 l
(a) Millard Wohl (b) Consequences of damage to HDPP-3 SFP from severe earthquake (c) No significant consequences for the environment would result from earthquake damage to HDPP-3 SFP.
The Staff further responds that the names of witnesses hereby l provided could be changed due to circumstances affecting their availability for hearing. If such change occurs the Staff will provide this information as a supplemental response to Interrogatory No.1.
Respectfully submitted, Colleen P. Woodhead Counsel for NRC Staff Dated at Bethesda, Maryland this 16th day of June,1987 9
t 1 n
r UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PACIFIC GAS AND ELECTRIC ) Docket No. 50-133 OLA COMPANY )
) (Decommissioning)
(Humboldt . Bay Power Plant )
Unit No. 3) ) !
AFFIDAVIT OF PETER B. ERICKSON i
I, Peter B. Erickson am employed by the U.S. Nuclear Regulatory Commission in the Standardization and Non-power Reactor Project Directorate.
I have provided the Answers to Interrogatory No.1 propounded by the Joint i
Intervenors to NRC Staff and am duly authorized to do so. I attest that ]
said answers are true and correct to the best of my knowledge and belief. ) 1 1
Peter B. Erickson
. Subscribed and sworn to before me this/4iday of June,1987 Notary Public My Commission expires: 7/,/fC 1
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1 Professional Qualifications Frank J. Witt June 1, 1987 I received a Bachelor of Chemical Engineering from Polytechnic Institute of Brooklyn in 1953 and a Masters Degree in Chemical Engineering from Rensselier Polytechnic Institute in 1959. I have been involved in various nuclear prograns since 1956. Decommissioning experience dates back to 1976, when I worked on the reactor decontamination and decommissioning aspects of the Table S-3, Table of Uranium Fuel Cycle Environmental Data, in the 10 CFR 51 Environmental Rule. A heve been active in providing comments to NRC Research in the development of regulatory guides and rules or reactor !
decommissioning. I have prepared the draft Standard Review Plan fer !
decommissioning reactor facilities. For Humboldt Bay, Unit 3, I have co-authored and ed,ited the Environmental Statement and the Safety Evaluation Repnrt for it's decommissioning. I have also participated in safety reviews on spent fuel pools and applications for increasing the storage capacity of spent fuel pools.
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r Professional Qualifications Peter B. Erickson .*
June 10, 1987 I received a B.S. Degree in Electrical Engineering from Montana State College in 1956 and an M.S. Degree in Systems Management from the University of Southern California (Extension Courses) in 1973. I have been involved in various nuclear reactor programs since 1956. I have been employed in Idaho, Los Alamos, N.M., Nevada and Washington, D.C. (Bethesda, MD). For the past 15 years I have been assigned Project Manager duties with the AEC and the NRC for many licensed research and power reactor with an emphasis on those undergoing decommissioning. i I have acted as the NRC Project Manager in the decommissioning of Fermi 1, Saxton, the N.S. Savannah, the Plumbrook Test Reactor, the NC State Pool Reactor and a number of other research and test reactors. At the present time I am the NRC Project Manager for Humboldt Unit 3, Indian Point Unit 1, Fermi Unit 1, Peach Bottom Unit 1, Dresden Unit 1 and the Lacrosse Boiling Water Reactor. All of these facilities are involved in decommissioning. I provided major input into the development of Regulatory Guide 1.86 on reactor decommis-sioning (1973 and 1974). I continue to assist NRC Research in the development of guidance and regulations on reactor decommissioning.
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r PROFESSIONAL QUALIFICATIONS REX G. WESCOTT JUNE 9, 1987 Organization: U.S. Nuclear Regulatory Commission !
-Office of Special Projects l
Title:
Plant Systems Engineer Birthdate: September 23, 1948 i
Education: B.S. Physics-Clarkson University, Postdam, N.Y. 1970 {
M.S. Engineering Science-Clarkson University, 1974 I 27 graduate credit hours in advance fluid mechanics and coastal engineering-Polytechnic Institute of N..Y. 1975-1978 24 credit hours in Fire Protection Engineering-3niversity of Maryland, 1985-1987 Professional Registration: Registered?ProfessionalEngineerinStateofMaryland Experience:
1986-Present Hydraulic Engineer, Plant Systems Branch, Responsible for Fire Protection Engineering, Hydraulic Engineering, and other systems related analysis 1981-1986 Hydraulic Engineer, Environmental & Hydrologic Engineering Branch and Geotechnical and Hydrologic Engineering Branch -
responsible for review of licensee applications and preparation of evaluations in the area of surface water hydrology, groundwater hydrology and coastal engineering. Specific tasks included evaluation of plant flood protection requirements, emergency cooling water availability and UHS dependability, radionuclide transport in surface and ground waters and water related environmental issues. Member of NRC Dam Safety Advisory Group. .
1978-1981 Hydraulic Engineer, Office of Standards Development, NRC 1975-1978 Civil Engineer, Ebasco Services Inc. N.Y., N.Y. - Responsible for design of hydraulic structures, hydrologic analyses and reports.
1973-1975 Staff Engineer, Woodward-Clyde Consultants, Clifton, N.J., -
Responsible for design of hydraulic structures, hydrologic analyses and reports.
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Personal Qualifications Statement Robert B. Samworth, Ph.D.
June 9, 1987
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Robert B. Samworth is employed by the U.S. Nuclear Regulatory Commission as the Senior Project Manager for Washington Nuclear Project 2 in the Division of Reactor Projects III/IV/V and Special Projects, Office of Nuclear Reactor Regulation. Prior to April, 1987 he served as a Senior Reactor Systems Engineer in the Facilities Operations Branch, PWR-A Division, Office of Nuclear Reactor Regulation. From May, 1976 to October, 1985 he was the Leader of the Environmental Engineering Section, Environmental and Hydrologic Engineering Branch, Division of Engineering, Office of Nuclear Regulation. The Division of Engineering and its organizational units were abolished in the NRR reorganization of October 1985.
As the Leader et' the Environmental Engineering Section, major portions of environmental impact statements for construction and operation of nuclear power plants were prepared under his supervision. Included were essentially all sections on non-radiological impacts to aquatic and terrestrial resources.
Dr. Samworth was the senior staff expert on environmental engineering questions and is highly qualified for this responsibility through education and training. He holds a B.S. degree in Civil Engineering from the University of Delaware, an M.S. degree in Sanitary Engineering from the Johns Hopkins University, and the Ph.D. degree in Civil Engineering fro-Cornell University. **
Dr. Samworth joined the regulatory staff in October, 1972, as an environmental engineer during the period of the NRC's initial NEPA reviews )
of nuclear power plant license applications. He performed reviews related to j impacts of power plant operation on water quality and water use and provided 1 Environmental Impact Statement input for several projects prior to assuming -
the responsibilities of Section Leader. He participated in the development l of review procedures as set forth in the Environmental Standard Review Plans, revisions to Regulatory Guide 4.2, and revisions to NRC's regulations for environmental reviews found in 10 CFR Part 51.
Prior to joining NRC he was the Chief of the Grants, Research, and Statist 9cs Branch with the Department of Environmental Services of the Government of the District of Col umbi a. There he was responsible f or evaluating new technology for achieving department objectives in water !
supply, wastewater collection and treatment, and solid waste collection and l disposal. He served as liason between laboratory scientists and design engineers in the design of the treatment processes employed at the District's new wastewater treatment plant.
Before that he was employed as a Public Health Engineer with the Tennessee Valley Authority where he conducted research concerning environmental problems associated with power production at steam- and hydro-electric generation facilities.
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Jerry J Swift PROFESSIONAL QUALIFICATIONS 1 am employed by the Radiation Protection Branch, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. The title of.my position is Health Physicist. Most of my work concerns radiological impacts of nuclear power plant operations.
From 1985 to 1987, I was employed in the Reliability and Risk Assessment Branch of the U.S. Nuclear Regulatory Commission, as a Reliability and Risk Analyst. Much of my work during this period concerned the January 4, 1986 accidental release of. uranium hexafluoride in Oklahoma and the April 26, 1986 accident at the Soviet Chernobyl plant. l From 1984 to 1985, I was employed in the Radiological Assessment Branch of the U.S. Nuclear Regulatory Commission, primarily in evaluation of environmental radiological impacts of nuclear power plant operations.
From 1982 to 1984, I was employed i$ the Clinch River Breeder Reactor Program Office of the U.S. Nuclear Regulatory Commission, primarily evaluating potential accident sequences which could lead to radiological consequences.
From 1980 to 1982, I worked at the U.S. Department of Energy on the environ-mental and safety aspects of a variety of nuclear technologies, including fusion devices, accelerators, transportation, waste management, and sewage irradiation.
l From 1972 to 1980, I was employed in the Office of Radiation Programs of the U.S. Environmental Protection Agency, as a Nuclear Engineer and Environmental Engineer. During this period, I was involved in evaluating the potential radiation doses and radioactive contamination of the environment that might result from severe reactor accidents, with application to the development of Protection Action Guides. I was also. involved in the evaluation of normal operating releases from nuclear fuel cycle facilities in support of the ,
l development of 40 CFR 190, " Environmental Radiation Protection Standards for Nuclear Power Operations." I assisted in development work for standards and guidance by EPA on management of high level wastes and uranium mill tailings.
I aided EPA's participation in nuclear policy reviews by Presidents Ford and Carter. I managed EPA's lengthy review of the Reactor Safety Study, WASH-1400.
From 1970 to 1972, I held a position as Physicist in the Institut fur Reaktorsicherheit, (now the Gesellschaft fur Reaktorsicherheit mbH) in Cologne, Germany; in this position, I was primarily concerned with evaluating
the nature and quantities of radioactive materials that might be released in postulated nuclear reactor accidents, and the resulting radiation doses that might be experienced. I was also involved in evaluating siting conditions.
While a graduate student at the Catholic University of America, from 1966 to 1970, I held the position of Assistant University Radiological Safety Official, performing health physics functions throughout much of the University.
I received the degree of Geological Engineer from the Colorado School of Mines in 1955, a Master of Science degree in Nuclear Engineering from Iowa State University in 1965, and a Ph.D degree in Nuclear Engineering from the Catholic University of America, Washington, D.C. in 1971. I have current certification in Health Physics from the American Board of Health Physics.
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MILLARD L. WOHL PROFESSIONAL QUALIFICATIONS TECHNICAL SPECIFICATIONS BRANCH DIVISION OF OPEP.ATIONAL EVENTS ASSESSMENT I am presently employed as a Reactor Engineer in tha Technical Specifications Branch, Division of Operational Events Assessment.
Until November 24, 1985, I was employed as a Nuclear Engineer in the Accident Evaluation Branch, Division of Systems Integration, U.S. Nuclear Regulatory Commission, Washington, D.C. My duties in this position were to conduct site and accident analyses, Emergency Response Facility Appraisals, and various other safety-related studies for nuclear power, test, and research reactor facilities. This includes probabilistic risk assessment (PRA) analyses for power reactor environmental impact statements as well as evaluation of applicant / licensee PRA's.
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I attended Case Western Reserve University (formerly Case Institute of Technology) and received a B.S. degree in Physics in 1956. I received a M.S.
degree in Physics from Indiana University in 1958. I did additional graduate work as a special student in Nuclear Engineering Science at Columbia j University and in Nuclear Engineering at Case Western Reserve University from 1962 through 1964 I have had short courses in Reactor Safety, Emergency Preparedness, Probabilistic Risk Assessment, Human Reliability, and Procedures for Evaluating Technical Specifications.
f I was a teachfng assistant in Physics at Indiana University from 1956 - 1958.
I have taught physics, physiul science, mathematics, and statistics in the evening divisions of Baldwin-War . ice College, the Ohio State University and Cuyahoga Community College from 1956 - 1973.
In 1957, I participated in the Special Power Excursion Reactor Tests at the SPERT-II Facility, National Reactor Testing Station, Arco, Idaho.
In 1958, I joined the NASA Lewis Research Center staff in Cleveland, Ohio.
My initial duties involved the writing of Monte Carlo computer codes for the determination of radiation shielding requirements and propellant radiation heating for proposed nuclear-powered rocket designs. Other assignments involved methods development and shielding and nuclear safety analyses for numerous proposed mobile nuclear vehicle applications including the Multi-purpose Nuclear Airplane. I was co-author of a study on disposal of ;
radwaste in space, performed for the USAEC, Numerous other technical publications involved in the course of the NASA work, some presented at ANS meetings. Additionally, during the period of 1958 - 1973, I had substantial research contract management responsibilities.
In 1973, I joined the General Atomic Company in La Jolla, California, as a nuclear engineer. At General Atomic I performed a variety of nuclear safety-related analyses for the High Temperature Gas-Cooled Reactor (HTGR).
These included the analysis of Design Basis Depressurization Accidents (DBDA) and containment integrity studies, as well as computer code upgrading and modification.
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In 1975, I ,iofned the Accident Analysis Branch in the Division of Technical' l I
Review, U.S. Nuclear Regulatuy Commission. My responsibilities involved site characteristic studies and acc1 dent analyses. More recently, I have had I
expanded responsibilities, involving Design Basis and Severe Accident (pRA)
Analyses for staff Safety Evaluations and Environmental Impact Statements.
These analyses include reactor core and piping system radiological accident ,
analyses, steam generator repair accident analyses, core reload accident evaluations, spent fuel p' col re-rack accident evaluations, containment )
enclosure shielding analyses, and severe accident consequence and risk l
analyses. Additionally, I have participated in operating plant Emergency Response Facility (ERF) appraisal. Also, I have had substantial contract management and expert hearing witness responsibilities.
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Presently, I am involved in the upgrading of nucibar power plant Technical Specifications in the Technical Specification Brarch, Division of Operational Events Assessment.
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U3E UNITED STATES OF AMERICA 87 JUN 17 P5 :33 <
NUCLEAR REGULATORY COMMISSION
~
Orrn .
BEFORE THE ATOMIC SAFETY AND LICENSING BOAFEyQ[C In the Matter of )
)
PACIFIC GAS AND ELECTRIC ) Docket No. 50-133 OLA COMPANY )
) (Decommissioning)
(Humboldt Bay Power Plant )
Unit No. 3) )
CERTIFICATE OF SERVICE i hereby certify that copies of "NRC STAFF RESPONSE TO JOINT INTERVENORS' FIRST SET OF INTERROGATORIES PROPOUNDED TO NRC STAFF" in' the above-captioned proceeding have been served on the i following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mall system, this 16th day of June,1987: ,,
Dr. Robert M. Lazo, Chairman
- Dr. Peter A. Morris
- Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board !
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l Washington, DC 20555 Washington, DC 20555 l l
Dr. James H. Carpenter
- Scott L. Fleider, Esq. i Administrative Judge 517 Third Street, Suite 14 - !
Atomic Safety and Licensing Board Eureka, CA 95501 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Richard Locke Appeal Board
- Pacific Gas and Electric Company U.S. Nuclear Regulatory Commission Law Department Washington, DC 20555 P.O. Box 7442 San Francisco, CA 94120 !
Docketing & Service Section* Atomic Safety and Licensing Board
- I Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555
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Honorable Dan Hauser Ralph & Nona V,raus Assemblyman, 2nd District - 2479. Wrigley Road 1334 Fifth Street Eureka, CA 95501 Eureka, CA 95501 Honorable Doug Bosco Honorable Barry Keene U.S. Congressman Second Senate District 517 Seventh Street 533 "G" Street Eureka, CA. 95501 Eureka, CA 95501 Redwood Alliance Honorable Wesley Chesbro Post Office Box 293 . Supervisor, Third District Arcata, Ca 95521 Post Office Box 4661 _ . _ .
Arcata, CA 95521 4
Colleen P. Woodhead N-Counsel for NRC Staff