ML20205F627

Affidavit of Pw Niles Reporting Results of Calculations Performed on Postulated Hosgri Event Data

ML20205F627
Person / Time
Site:	Diablo Canyon
Issue date:	08/15/1986
From:	Niles P AFFILIATION NOT ASSIGNED
To:
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ML20205F611	List: ML20205F607 ML20205F627
References
NUDOCS 8608190273
Download: ML20205F627 (19)

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B. NILE 5 AFFIDAVIT OF MR. PHILIP W.

deooses and says Mr. Philio W. B. Niles. beino duly sworn as fo11ows1 a engineer. CAM 21507.

1) I am a registered professional California, and a Pacific Gas resident of San Luis Obispo County.

and Electric Company ratepayer. I received a Bachelor of Science of California in 1957, and a Master of decrew from the University d

the University of Nuclear Engineerino at Science decree in in the I have worked as a consulting engineer California in 1958. of state of California for 20 years in the thermal-fluids area the faculty of the Encineering. I have been on Mechantcal for 19 vaars, first in the Calif ornia Folvtochic State Univeristy Environmental Engineerina Department, and later in the Mechanical Road.

Department. I reside at 665 Carpenter Canyon Engineering Arroyo Grando, California 93420,

2) On August 10, 1906, I received from Dr. Richard Ferguson Dr. Forpuson avors a computer diskutte containing certain data.

accoloration t i ene is an exac't copy of seismic that this data Hosgri ovent" historios representing the so-called " postulated l t ic (FHE) which had been given to him by the Pacific Gas and E ec r seismic model Company. I understand that this data reprouants the soont fuoi to analv:0 the proposed modifications to the used pools at the Diablo Canyon nuclear power' plant.

J) The purpose of this atfidavit is to report the rosults of Usino standard calculations i havo performod upon the PHE data.

velocity and techniquos. I hava calculated the sna thema ti cal accoloration displacomunt time historios associated with the PHE data. The results are shown in Figures 1 and 2.

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my calculations, the disdiacements

4) Accordino to all practical associated with the PHE acceleration data are for by Dr.

previously made public to those purposes identical 1986, which I have affidavit of June 15.

Ferguson in his examined.

by others that the seismic am aware at claims

5) I accurately Dr. Ferguson and me do not displacements domputed by Canyon retlect the expected ground displacements at the Diablo earthquake. I am not a power plant during a large nuclear seismologist and theretore not competent to assess these claims.

However, any discrepancies which may exist must arise from errors from computational in the original data provided by PG&E and not errors.

LONCLUSION that the total

6) It is my professional opinion by o

displacements associated with the acceleration data provided PG&E are as follows: ,.

The total East-West displacement varies from approximately The total G.35 meters (-1.15 feet) to + 2.0 meters (6.6 teet).

-0.42 meter's -

North-South displacement varies form approximately (1.38 feet) to +0.37 meters (1.21 feet).

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Executed this /.( A day of August. 1986, at i'

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l f-I declare under penalty of perjury that the foregoing is l-l true and correct to the best of my knowledge.

Ft lip W.)b Niles

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SUBSCRIBED AND SWORN TO BENRE ME HIIS 15HI -

DAY OF AUGUST,1986, DIE UNDERSIGNED NOIARY - - - - - _ . . -

PUBLIC IN AND FOR HIE COUN1Y OF SAN UJIS Omcr4L saan, 7; K. Scuoawrwa OBISPO,}STATEOFCALIERNIA. Morm ruaue . uo m

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My *$y,y My comission expires: May 27, 1989 6

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Presentation of Qualificatons Philio Ms B Niles 665 Carpenter Canyon Road Arroyo Grande, CA 93420 805-4G9-9274 Home 805-481-3517 Home 805-546-2407 University EMPLOYMENT RECORD 1967-Present fProfessor of Mechanical Engineering,. California

,e Polytechnic State University, San Luis Obispo.

Formerly associated with the Environmental Engineering Dept.

1967 Rand Corporation. Santa Monica, CA.

1964-1966 Post Graduate Research Engineer, and Predoctoral Fellow (Ford Foundation). University of California, Los Angeles.

1958-1962, Senior Research Engineer, Rocketdyne Division of 1965 North American Rockwell Corporation,.Canoga Park, California.

EDUCATION B.S.,

Mech. Engr.., University of California, Behkeley, 1957.

M.S., Engr. Sci.. University of California. Berkeley, 1958.

Additional graduate study, University of California, Los Angeles, 1960-1967, consisting of 85 quarter units of work in fluid i mechanics and applied mathematics. 1

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~ PROFESSIONAL MEMBERSHIP .

International Solar Energy Society, and the American Section.

American Society of Heating, Ventilating and Air-Conditioning Engineers. 1 Northern California Solar Energy Association. <

California Faculty Association.. '

Society'of Building Scien'ce Educat' ors.

American Association for the Advancement of Science.

Licenced Mechanical Engineer in the State of California.

COURSES RECENTLY TAUGHT AT CAL POLY Heat Transfer Passive Solar Building Design Solar Engineering Thermodynamics Thermal System Design Heating and Ventilating Fluid Flow Solar Laboratory

. Refriceration

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PRINCIPAL PROFESSIONAL ACTIVITIES Winter Quarter 1984, 1985: U.S.A.I.D. Consultant. I worked in the Republic of Botswana (Africa) on the Botswana Renewable Energy Technology Project, funded by the Government of Botswana and the U.S. Agency for International Development. I gave workshops, aided Government architects on the design of specific low-energy buildings, and did research on appropriate construction for various generic building types.  !

I helped arrange for a Botswana to come to Cal Poly for the Sqring '85 quarter, to study subjects involving low-energy design, and Ahe environmental control of buildings.

1984: Under invitiation by the O.S. Department of Energy, I authored the section, Simulation Analysis, in the forthcoming M.I.T. Press volumes reviewing developments in solar energy over the last decade.

1983: Co-founder of Renewable Eneray Institute, Cal Poly State University, and currently serving as a member of the Board of Directors of the Institute.

1982: I did the thermal design and analysis for a solar greenhouse heating system done b'y Cal Poly under.a California Energy Commission contract. I also did the thermal design and analysis of a solar heated broader house under a USDA grant.

1981-1982: I served on the State of Califonia technical review

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committee:for the PassiveSo'lar/ Energy. Conservation.Home; Monitoring Project.

1980s Co-Principle Investiga' tor on the California Passive Solar Handbook Project for the California Energy Commission. As part of the project I developed the building simulation computer program CALPAS, which was subsequently used by the Energy Commission--to~ develop of the. current residential energy buildina standards. CALPAS is a certified compliance tool for l the Standards, and is used throughout the U.S. a's a building design tool.

L < I ~ taught extension courses' on. usi ng. the Handbook at.both U.C.

Berkeley and U.C.'Irvine.

1979-present Consultant to the Berkeley Solar Group Inc.,

building energy consultants and building analysis sof tware developers; develpers of CALPAS3, a commercial enhanced version of CALPAS.

t I have consulted on numerous small private and commercial projects, as well as with government laboratories.

1980: I headed a, team to perform the thermal analysis of the entries to the Passive Design Competition, sponsored by the k~

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California Office of Appropriate Technolgy. The results are published in the book Solar Gain.

1980s Invited to Chicaao as a consultant to review the D.O.E.

sponsored multi-university project. Teaching Passive Design in Architecture.

1979: Published first version of Direct-Gain Design Graphs, a frequency-domain based design tool thct has been published in a number of forms. I was invited to the Solar Energy Research Institute at Boulder in 1984 to participate in a discussion of frequency domain methods.

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-1978: Served on the Ad-Hoc Departmental Advisory Committee for the Energy Element of the Century Freeway Housing Relocation Project, Department of Housing and Urban Development, State of Californin.

1974-1979: I worked as principal thermal design engineer on the design engineer on the Lamanu::i and Pantaleo commercial solar raison dehydrator in Fresno.

1974: I was the principal thermal designer and test engineer on the Atascadero Skytherm House. I have been involved as a consultant in numerous similar houses nationwide.

1958-1962.1965: I worked both in the turbomachinery research department, and in the turbomachinery R and D department, at the Rocketdyne Division of North American Rockwell Corporation.

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Publication listLavailable on request.

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2 ATTACHMENT C Affidavit of R. Clyde Herrick NRC Staff Response to Request for a Stay by Sierra Club and Mothers for Peace In the Matter of Pacific Cas and Electric, Docket Nos 50-275 OLA and 50-323 OLA

' June 25, 1986

[page 6]

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? , J" 9.- Fuel Fool Displacements:

The Issue: "During the pHE, the spent fuel pools (and indeed the of up to three feet in the north-south direction and eight feet in the east-west direction."

Affidavit

Reference:

Paragraph 13.

Response

In Paragraph 13 of his Affidavit, Dr. Ferguson incorrec He d

thenorth-southdirectjanandeightfeetintheeast-westdire l nt without from double integratien of the time-history data to yield disp acemeTwo sources of. error r realizing the possible errors that may result.

explained in the following paragraphs.

The first and major source of errer is expected to result from a slight offset, or bias, acceleration value in the acceleration time-history data.

The acceleratien time history was generated from the specified earthquake spectrum by a modified version Procedures of of in the use thethecomputer program program require that a l SIMQKE, a and widely used method.

baseline correction be made to adjust the mean square of velocity, and the. peak accelerations predicted.

it is 'possible that a very -small offset acceleration was. introduced to the t

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history data which, upon double integration to y'ield displacement', l'ed to t very large earthouake displacement cited by Dr. Ferguson.

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A second, and possibly smaller, source of error may have resulted fr Ferguson's inteoration methods. -

defined as sets of acceleration valuesTheatamount incremental of po a true mathematical integration of the Theacceleration.

greatest error data set. e smoothing, or interpol'ation procedures that are used. data set would be realized from direct double sumation of the time-history without the use of a smoothing, or interpolation procedure.

However, these errors leading to the large displacement plotted by Dr. Fergus did not adversely affect the licensing analysis. i time-history was to input the earthquake excitation to the dynamic h ck analys s,

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used excitation in the fonn of acceleration to produc -

offset acceleration.

In confirmation of the above, an inspection of the displacement curves pro by Dr. Ferguson indicated that an extremely small constant l offset t acce l

would account for the large displacement and the basic trend of the disp aceme curve.

r-r ATTACHMENT D Respondents' Brief SLO Mothers for Peace, g al. vs NRC 9th Circuit Court of Appeals July 30, 1986 (pp 32, 33]

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earthquake, does not affect this unchallenged conclusion.

if all of petitioners' specific asserted " errors and omissions" their central premise has were valid, and they are not, proviously been rejected by the NRC.

Moreover, petitioners' more specific allegations of The Commission and its staff have, error are also erroneous.

either as part of the amendment analysis or as part of the ruling h of on petitioners' stay? application, reviewed and rejected eac Slip op. at 13-15. Amendment petitioners' technical assertions.

16, 22-24, 31-32 and SER at 11-13; Appendix A to Amendment SER at We do not revive all 43r and Herrick Affidavit at i 4 and 6-9.

of those technical discussions here except to note one -

illustrative example of the magnitude of the errors made by Petitioners' expert maintains that during the p3titioners. be maximum postulated earthquake for Diablo Canyon, the pools can in the o=pected to undergo displacements up to three feet north-south direction and eight feet in the east-west direction.

Ferguson Affidavit at'! 13. As the Commission observed in its d p July 22 Order, this assertion is based upon a faulty analysis an See Herrick Affidavit at 1 6.

is flatly wrong. Slip op. at 14.

Some idea of the magnitude of the error can be gleaned from the (Footnote Continued) Thus, petitioners' f capacity provided in the original license. concerns about a five-fold e no relevance to the matter now before the Court.

18 Indeed, Region 1 of the new racks contains Boraflex as an additional protection against criticality in the unlikely event that unborated water somehow enters the system.

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I the original Diablo Canyon seismic analysis, which concluded that h k maximum ground displacement at the site due to such an eart qua e Supplement 5 at C-14 through C-16, is eight _ inches. License SER, Supplemental Record Excerpts, C-20, and C-38 through C-34.

item 3.

- In rejecting petitioners' challenge to the no l the significant hazard consideration determination in this case, Commission spec'ifically found that the technical bases for their claim " rest on f aulty assumptions, errors, and All of these mistakes greatly overstate the oversimplifications.

Slip op.

possible consequences of an earthquake accident."

at 15. The place for a petitioner to present technical evidence The Court is to the expert agency, not to a reviewing Court. l i

need not and should not immerse itself in the detailed tech dispute that the petitioners are attempting to revive in their It is enough that the expert brief and attached materials.

claims and responded agency has reviewed the petitioners' In rationally with appropriate technical support and analyses.

justifiably this situatici[, the " court's deference to the agency Carstens v. NRC, 742 F.2d 1546, 1551 (D.C.

reaches its zenith."

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19 0ther technical assertions made by petitioners' expert d and in rejected by the Commission and theSee staff noteinclude those note 3, suora.

' the Commission's July 22 decision.

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ATTACHMENT E Af fidavit of S. Bhattacharya Respondent Intervenor's Brief SLO Mothers for Peace, et al. vs NRC 9th Circuit < hurt of Appeals July 30, 198i

[pp 2, 3]

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1 made available, but received no response. Consequently, the 2 lack of data was listed as a contention by the Sierra Club to 3 the Atomic Safety and Licensing Board. (This contention was 4 accepted by the ASLB panel after a pre-hearing conference in 5 May, 1986.)

6 3. Following a promise by PGEE to provide the seismic 7 data, an amicable meeting with several PG&E engineers was held 8 in San Francisco, and I subsequently received a computer 9 diskette containing acceleration data for the PHE. ,No seismic 10 data relating to velocities or displacements was provided to me 11 since these are easily obtained from acceleration data by 12 simple, straightforward mathematical procedures.

13 4. I performed these procedures and found that the seismic 14 data provided to me by PG&E " predicted" the maximum seismic l 15 displacement associated with the PHE to be approximately three 16 feet in the north-south direction and eight feet in the east-17 west direction. The public documents relating to the proposed 18 reracking contained no reference to seismic displacements 19 whatsoever [ Because the displacement information may be I

20 important to understanding the proposed raracking at Diablo I

21 Canyon, I reported the displacement results in my affidavit.  !

22 5. The NRC now claims that these values are incorrect, 23 citing other references claiming tha_t seismic displacements .

24 would be much smaller, and argues that I have made some-mistake.

} 25 (NRC, p. 32). PG&E's expert, on the other hand, admits that I 26 did base my calculations on the data supplied to me by PG&E, but i 2

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1 that the data "was not intended to represent any actual physical 2 situation...". (Bhattacharya affidavit, pp. 2-3) 3 6. I am a physicist, not a seismologist, and have never 4 made any claims regarding the accuracy or appropriateness of the 5 seismic model or the data given to me. I have assumed in good 6 faith that the data supplied was, in fact, the data used in the 7 analysis of the proposed spent fuel racks. No one has yet

8. claimed otherwise.

9 7. If the seismic data does not represent the postulated 10 Hosgri earthquake as PG&E now apparently claims, I fail to 11 understand why the data was used to analyze the response of the 12 spent fuel pc.ls. Standard scientific practice demands that any 13 model used for analysis represent the physical situation under 14 investigation. Nor do I understand why this data was provided 15 to me without some disclaimer that it failed to " represent any 16 actual physical situation", as PG&E now claims.

17 8. All my work to date has been based on the seismic data 18 provided to me by the PGEE. If this data is in any way known to g .,

l 19 be inaccurate, I would, of course, reassess my calculations 20 concerning the Diablo Canyon reracking proposal. I would assume

' 21 that all those who have used this data, including the designers 22 of the spent fuel racks and all those who have reviewed PG&E's 23 proposal;for the NRC,~ would do the same. .

24 9. By the same measure, I fail to understand how the NRC  !

25 reached its no significant hazards consideration determination

26 if it did not have seismic data which represents the actual l l

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1 1 physical situation of the postulated Hosgri event at Diablo 2 Canyon. If more realistic data is available, then I fail to 3 understand why I was given other data.

4 10. Surely my results cannot be incorrect simply because 5 they are based on the same data used by those who designed the 6 spent fuel system unless their results are also incorrect. In 7 either case, the responsibility for any errors resulting from

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8 faulty data rests with the people at PG&E who supplied this data 9 to me. I submit that the entire controversy constitutes ample 10 proof of the necessity for holding public hearings before 11 license amendments are issued, instead of after the fact.

12 Rack-Wall Collisions:

13 11. Mr. Bhattacharya of PG&E claims that the NRC 14 adequately investigated ' the danger of collisions of the racks 15 with the walls,of the spent fuel pools during the PHE. He cites 16 as evidence the NRC's Safety Evaluation Report, Appendix A, 17 Section 3.4.5. This citation consists of two brief paragraphs; 18 the first admits that fuel racks are expected to impact with the 19 walls duririg the PHE but assumes that these racks are empty. No

. 20 mention is made of collisions with loaded racks. The second 21 paragraph considers only shaking of the racks and ignores any i 22 possibility of sliding. I consider this an inadequate analysis 23 of a potentially severe problem. ,

24 12. Mr. Bhattacharya raises several' technical issues  !

25 related to the model used in my original affidavit to estimate 26 the forces which could be expected during a collision of a i- I 4  :

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' UNITED' STATES'0F AMERICA. f NUCLEAR REGULATORY COMMISSION DOLKETED USNB' ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  ;-

)

.g mG 18 N0:31  ;

i In the Matter of: ) Docket Nos. 50-275-OLA

) and50gppgto!.APQit[-

PACIFIC GAS AND ELECTRIC COMPANY ) 90CKETthG \ dt?

) ASLBP No. 86-523-63bbk" (Diablo Canyon Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF_ SERVICE I hereby certify thatpcopies of a REPORT ON EFFORTS TO RESOLVE SIERRA CLUB CONTENTION (I)(A) in the above-captioned prodeeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk by express delivery, this 15th day of August, 1986.

• B. Paul Cotter, Jr. , Chairman Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission 4350 East West Highway 4th Floor Bethesda, MD 20814

• Glenn O. Bright Administrative Judge Atomic Safety and Licensing Board Panel ,

U.S. Nuclear Regulatory Commission 4350 East West Highway 4th Floor Bethesda, MD 20814

• Dr. Jerry Harbour Administrative Judge .,

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commicsion 4350 East West Highway 4th Floor.

Bethesda, MD 20814 Ms. Nancy Culver 192 Luneta Street

. San Luis 0.bispo, CA. 93401 Bruce Norton,. Esquire Norton, Berry, French & Perkins, P.C.

P.O. Box.10569 Phoenix, AZ 85064 1

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• Mrs. Jacquelyn Wheeler ,

8' 2455 Leona ' Street San Luis Obispo, CA 93401 Philip A. Crane, Jr. , Esquire P.O. Box 7442 San Francisco, CA 94120 Laurie McDermott, Co-ordinator CODES 731 Pacific Street Suite #42 San Luis Obispo, CA 93401 Mr. Lee M. Gus tafson Pacific Gas and Elecqgic Company Suite 1100 1726 M Street NW Washington, DC 20036-4502 Docketing and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board Panel .

U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Henry J.'McGurren, Esquire Lawrence J. Chandler, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555.,

Richard F. Locke Pacific Gas and Electric Company 77 Beale Street -

San Francisco, CA 94106

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