ML13304A681
| ML13304A681 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/17/1980 |
| From: | Cardone A, Chandler L, Davis L, Reiter L, Rood H Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | FRIENDS OF THE EARTH |
| References | |
| ISSUANCES-OL, NUDOCS 8010210286 | |
| Download: ML13304A681 (46) | |
Text
UIITED STATES OF AMIERICA NUCLEAR REGULATORY COMiISSIO N BEFORE THE ATO!*IC SAFETY AND LICENSING BOARD ir the atter of SOUTHER:, CLIFOR'IA EDISON COMPAY,
)
Docket Nos.
50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2 and 3)
NRC STAFF ANSWERS TO INTERROGATORIES BY FRIENDS OF THE EARTH In accordance with the provisions of 10 C.F.R. § 2.740b, the following art the NRC Staff answers to interrogatories propounded by Intervenors Friends of the Earth et al.
(FOE)
(Intervenors) on September 4, 1980.
Although not wholly in conformance with the procedural provisions of 10 C.F.R.
§2.720(h)(2)(ii), the interrogatories.are answered voluntarily by the Staff in the interest of assuring the development of an adequate record in this proceeding and in the spirit of the Licensing Board's wishes that discovery proceed without delay. Tr. 201, 235-37.
NRC STAFF ANS4ERS
- 1.
FOE Interrogatory:
Is it possible that the Cristianitos fault has other subparallel branches that have not yet been mapped?
8010210 286
-2 "RC Staff Answ.er:
Yes, it is possible that the Cristianitos fault has other subparallel branches that have not yet been discovered and are therefore unmapped.
However, in view of the considerable mapping and related exploratory work that has been done regarding the Cristianitos fault, whatever faulting that may remain unmapped would likely be minor, noncapable, and insignificant. In addition to the extensive mapping and related exploratory work documented in the
a).
Dr. Perry L. Ehlig of California State University in "Geologic Report on the Area Adjacent to the San Onofre Nuclear Generatin: Station, Northwestern San Diego County, CA."
b).
Jack C. West, consulting geologist in "Generalized Sub-surface Geolocical and Geophysical Study Capistrano Area, Orange County, CI."
c).
Paul Morton, et al., Geologist, California Division of Mines and Geolo-y in "Geology and Engineering Geologic Aspects of the San Juan Capistrano Quadrangle Orange County, California," 1974, CDMG Special Report 112.
d).
Donald L. Fife, Geologist, California Division of Mines and Geology, in "Geology of the South Half of the El Toro Quadrangle, Orange County, California," 1974, CDMG Special Report 110.
e).
Roy J. Shlemon, consultant, in "Late Quatenary rates of Deformation, Laguna Beach-San Onofre Beach, Orange and San Diego Counties, California,"
1978.
-3
- 2.
FOE Interrogatory:
What data do you have to disprove the hypothesis that the type A features observed in the site of excavation beneath Unit 2 are evidence of a branch of the Cristianitos fault?
1RC Staff Answer:
Tne type A features observed in the site of excavation beneath Unit 2 are not evidence of a branch of the Cristianitos fault because:
a).
The "A feature is a strike-slip fault and the Cristianitos is a dip-slip fault. These parallel features could not be a product of the sa-,e stress syste.
b).
The type A feature has not been observed to exist within approximately one-half mile distance fra-the Cristianitos fault.
c).
The evidence along the sea cliff shows normal faults associated with the Cristianitos fault rapidly diminishing in number toward the plant.
There are no faults within one-half mile of the plant site, as exposed in the sea cliff.
d).
The A features are distributed over an area more than a File frorm, and not contiguous to, the Cristianitos fault.
-4
- 3.
FOE Interrocatory:
What data do you have to disprove the hypothesis that the shear zone observed in the quarry and sea cliff approximately 1.7 miles northvest of the site are evidence of another branch of the Cristianitos fault?
NR Staff Answer:
The shear zones observed in the quarry and sea cliff approximately 1.7 iles NW of the site have the sare orientation and appear to be the same as the A features at the site, suggesting the same origin for all the off-site and onsite features.
(See response to interrogatory number 2).
- 4.
FE Interrocatory:
What evidence do you have to disprove the hypothesis that because the San Onofre Nuclear Generating Station is underlain by conjugate sets of fractures and shear joints, and because these features are more exposed by excavations, that the structures and ground surface may experience greater seismic shakin:
effects than when they were still buried?
NRC Staff Answer:
After extensive examination we and our-advisors the U. S. Geological Survey have concluded that the type A and type B features, which we believe are referred to in interrogatory no. 4 as "conjugate sets of fractures and shear joints," are not capable faults as defined in Appendix A to 10 CFR Part 100.
The basis for our conclusion is discussed in "Safety Evaluation of the Geolocic Features at the Site of the San Onofre Nuclear GeneratinD Station,
July 8, 1975, USNRC.
Since the conjugate set of A and B features are at least 120,000 years old and non-capable, the likelihood of these beinc affected by seismic shaking is negligible.
Furthermore, seismologists consider the presence of cracks to be a factor in causin: seis-ic wave attenuation.
A reduction of nomal stress across these cracks (a possible effect of the removal of overburden) would cause a decrease in the frictional shear stress.
The passage of seismic waves would then more likely be attenuated due to increased sliding friction across the
- 5. FOE Interrocatory:
Has any study been made of those fractures known as feature A, feature S, feature C and feature D which relates then to potential rupture due to seismic shaking?
If so, please aive a summary of the result of that study.
NrC Staff Answer:
To our knowledge no study has been made of the A, B, C and D features which relates them to potential rupture due to seismic shaking. The following discussion is taken from "Safety Evaluation of the Geologic Features at tke Site of the San Onofre Nuclear Generating Station," July 8, 1975, USRE:
"The applicant has developed a concise and acceptable history for the evolution of the Type A, B, and D features and the Type C feature can be related to these.
The applicants' history follo's:
'Therefore, the sequence of events is that during some stage after the formation and probably at least partial consolidation of the
-6 San Mateo material, a north-south component of horizontal stress began to increase. At the same time, an east-west component decreased.
These stress changes eventually resulted in the genera tion of the nearly vertical conjugate set of A and B features in the fonration at a depth of at least 300 feet below the upper surface existing at the time (Drawing 20A).
The lateral extension permitting the reduction in the east-west component eventually stopped when the shearing displacement reached the level currently observed.
Erosion of the upper surface proceeded, lowering the surface by about 200 feet, when the generally north-south compres sion continued, or was reactivated with some rotation towards a more northerly direction.
The consequence at this time was the development of the D shear feature (Drawing 205).
It is concluded that this shear was generated when the upper level of the San Mtateo was not much different fron its present elevation but before deposition of the overlying terrace gravels.
Since the terrace deposit is about 120,000 years old and has not been dis turbed by the A, B, C, or D features, the chance of displacement occurrin3 on any of these features is negligible.
- 6.
FOE Interrogatory:
What evidence do you have to disprove the hypothesis that an earthquake offshore from SONGS with its epicenter several km south of the reactors and south of the point at which the Cristianitos and its branches intersect with the Offshore Zone of Deformation could cause rupture propagation directed towards the branches of the Cristianitos Fault and could cause amplification of ground motions on the shoreline where the Cristianitos goes out to sea?
NPC Staff Answer:
Recent seismic reflection profiling performed by Nekton, Inc. (submitted to NRC in August 1980) show that the Cristianitos fault does not intersect or connect with the OZD in the shallow stratigraphic horizons.
What their
-7 spatial relationship is at depth is not known.
Since the onshore evidence show that the Cristianitos fault is non-capable, not having moved for at least 120,000 years, the chance of rupture propagation towards the branches of the fault is negligible.
- 7.
FOE Interrocatory:
Have you or your consultants ever requested the Applicants to analyze the ground motions that would result at the SONGS 2 & 3 site fron focusing effects (as described by Dr. Brune in Testimony on Ground Ilotions at the Diablo Canyon hearings) that could cause sympathetic ground motions on the Cristianitos fault or its branches during an offshore earthquake on the Off-shore Zone of Deformiation?
If the answer to the above question is yes, please submit the result of such analysis.
%11 Staff Answer:
W!e have not requested the applicants to perform such an analysis since there is no geologic evidence, at least within the past 120,000 years, that an earth quake on the OZD would cause sympathetic ground motions on the Cristianitos.
- 8.
FOE Interrogatory:
What evidence does the NRC Staff have to disprove the hypothesis that the Newport-Inglewood-Rose Canyon-San Miguel fault zone could generate an earth quake of TIS or larger because of its structural relationship to the San Andreas System and the transform Plate Boundary tectonics of the Gulf of California?
J!RC Staff Answer:
The assumption of a structural relationship between the Newport-Inglewood Rose Canyon-San Miguel fault zone and the San Andreas system or the transform plate boundary of the Gulf is without merit. There has been no demonstrated connection between these features and the available evidence indicates no connection. In addition, a connection between the Newport-Inglewood-Rose Canyon Zone and the San Miguel fault has not been demonstrated. The evidence against a Newport-Inglewood Rose Canyon-San Miguel fault zone having MS or larger earthquake includes:
(1) No known connection of active faults between San Diego and the Calabasas fault or between the eastern end of the San Miguel fault zone and transform faults of the Gulf of California rift system.
(2) Lack of evidence for continuity for this zone on Landsat and other imagery.
(3) Evidence for non-continuity as shown by regional geologic mappir (Gastil and others, 1973).
(4)
Lack of evidence for continuity of seismic activity in the historic seismicity.
(5)
Field evidence and historic earthquake activity indicates that low to moderate earthquakes are characteristic of the above-listed faults.
(6)
The main zones of high rate of fault slip are along the San Andreas fault system and along parts of the Agua Blanca to Coronado Banks and San Clemente fault zones.
-9
- 9.
FOE Interrogatory:
What evidence does the NRC Staff have to disprove the hypothesis that the Cristianitos Zone of Deformation and its branches are part of a seismic gap?
i"C Staff Answer:
The utilization of seismic gaps to predict the occurren-ce of earthquakes has had most successes when applied to active seismic belts along major plate boundaries.
For that reason the NRC Staff does not consider it to be aT applicable technique with reference to the Cristianitos fault which does not define a plate boundary and has not had movement on it in at least 120,000 yEa rs.
- 10.
FOE Interrogatory:
If either of the Off-Shore Zone of Deformation or the Cristianitos Fault were in a seismic gap, what do you estimate would be the recurrence interval for a Magnitude 6.8 earthquake?
NRC Staff Answer:
Seismic Gaps have been used to predict the location and size of impendinc large earthquakes along major plate boundaries.
No extensive use has been made of this phenomenon to predict recurrence intervals.
To do this would require knowledge of aseismic and seismic slip along a fault zone and a well documented earthquake history that includes recurrence of large earthquakes in the same location.
The 0ZD is not a major plate boundary, there have been no historical records of iagnitude 6.8 earthquakes and there is insuffi cient information to differentiate between seismic and aseismic slip.
For
'110 10 these reasons, we do not believe it is possible at this tine to make any useful estimate of the recurrence time of magnitude 6.8 earthquake on the 0ZD using seismic gaps.
- 11.
FQE Interrogatory:
What research have you analyzed on the basement rocks beneath the depth of 10,000 feet on the Off-Shore Zone of Deformation to detemine if there is one continuous fault at that depth?
NRC Staff Answer:
We have reviewed the geologic literature and the deeper sensin: seis-ic reflection profiles for data on basement rocks below the 10,00 fo ot dept-.
along the Off-Snore Zone of Deformation.
Several of the specific reports researched are:
- 1.
Yerkes, R., et al., 1965, "Geology of the Los Angeles Basin, California,"
U.S. Geological Survey Prof. Paper 420-A.
- 2. Harding, T. P.,
- 1973, "Newport-Inglewood Trend, California -
An Exa7pIe of Wrenching Style of Deformation," AAPG Bull., V. 57, No. 1, p.97-116.
- 3.
- Yeats, R.S., 1973, "Newport-Inglewood Fault Zone, Los Angeles Basin, California," AAPG Bull., V. 57, No. 1, p. 117-136.
- 4. Barrows, A.G., 1974, "A Review of the Geology and Earthquake History of the Newport-Inglewood Structural Zone, Southern California," CD-G Special Report 114.
- 12.
FOE Interrogatory:
Have you considered the possibility of thrust faulting on the Off-Shore Zone of Deformation?
NRC Staff Answer:
- Yes, the possibility of thrust faulting on the Off-Shore Zone of Deformation has been considered in view of the existence of en echelon thrust faulting at the Rosecrans oil field, located along the Newport-Inglewood portion of the OZD (Harding, T. P. 1973).
Secondary faults associated with some of the folds have minor thrust faults, but the theory of wrench faults and the regional geologic relationships are inconsistent with deeper, basement faults of the Off-Shore Zone of Deformation orientation having a low angle thrust type mechanism.
- 13.
FOE Interrocatory:
What peak ground acceleration at SONGS would you predict fron the naximur possible EQ due to thrust faulting on the Offshore Zone of Deformation?
NRC Staff Answer:
In light of our response to interrogatory #12 with regard to the geologic reasonability of thrust faulting occurring on the OZD, we have not estimated ground motion on the OZD due to thrust faulting.
- 14.
FOE Interrogatory:
Would you consider thrust faulting unusual or typical of active wrench tectonic systems with conjugate faulting?
NRC Staff Answer:
Thrust faulting is not unusual in folds in the zone of shallow plastic deformation and has been recognized and described for active wrench tectonic systems with conjugate faulting.
12
- 15.
FOE Interrogatory:
Do you agree that microseismicity can indicate the presence of active faults?
If you disagree please state the basis for your disagreement.
1URC Staff Answer:
ficroseismicity may or may not indicate the presence of active faults.
It becomes a strong evidence for active faulting when the microearthquakes define a plane or planes consistent with the derived focal nechanisms, geological observations and historical seismicity.
- 16.
FOE Interrogatory:
Do you agree that accumulated stress on major faults can he transferrei to secondary faults or to en echelon strands or to branches?
NRC Staff Answer:
Yes, we agree that accumulated stress on major faults can be transferreJ with a variety of mechanisms, such as direct branching, conjugate faults or other distributing fracture systems to secondary faults, to en echelon stands, or to branches.
- 17.
FOE Interrogatory:
How wide do you calculate the plate boundary system to be in Southern California?
!,RC Staff Answer:
The width of the plate tectonic boundary systen in Southern California has not been defined or calculated. Plate tectonic relations suggest that the boundary is not sharply defined and that a number of zones of differential movement exist with varying rates of activity.
13
- 18.
FOE Interrogatory:
Do you agree that in a wrench tectonic model there is rotation on the structural blocks?
if you do not agree, state the basis of your disagreement.
RIPC Staff Answer:
The operation of a wrench tectonic model may, dependent on the style and structural pattern, involve rotation of local tectonic blocks, particularly for certain branching fracture systems and combinations of brittle and plastic behavior (e.g. Garfunkel, 1974, Geol. Soc. Amer. Bull. v. 85, p.
1931-194-).
- 19.
F0E Interrogatory:
Do you agree that wrench tectonic systems are characterized by en echelon and subparallel faulting, and plastic deformations?
tNRC Staff Answer:
The conventional wrench tectonic models and examples do indicate many en echelon and subparallel faulting features, and plastic deformational struc tures; examples are cited in Moody and Hill (1956, GSA Bull., v. 67, p.
1207-1246) and Harding (1973).
- 20.
FOE Interrogatory:
Do you think that faulting at great depths on a plate boundary would neces sarily cause surface rupture?
14
'RC Staff Answer:
The presence of surface rupturing is dependent upon the nature and thickness of surface deposits, rate and amount of fault slip, earthquake magnitude and deptn of focus.
Instrumental data indicate that earthquakes in southern California are occurring at shallow depths. Faulting at shallow focus depths on active faults and plate boundaries normally cause surface ruptures for earthquake magnitudes of above about magnitude 6.
- 21.
FOE Interroqatory:
Do you have any data or evidence that would contradict the hypothesis that movement on a single continuous fault in the basement rocks of the Newport Inglewood-PRose Canyon Fault Zone would not necessarily cause surface faultin7 in the ductile sedimentary deposits near the surface?
If so, please provide us with such data and evidence.
NRC Staff Answer:
We have no evidence that would contradict the possibility that movement on a single continuous fault in the basement rocks of the Newport-Inglewood-Rose Canyon fault zone would not necessarily cause surface rupture in the ductile sedimentary deposits near the surface.
- 22.
FOE Interroqatory:
Do you have any evidence that there is not one continuous fault in the basement rocks along the Newport-Inglewood-Rose Canyon-San Miguel-Zone?
NRC Staff Answer:
Evidence that there is not one continuous fault in the basement rocks between the Rose Canyon fault and the San Miguel fault includes the follow.'ing:
15 (1) The geologic mapping of Gastil and others (1973) and the more recent reports of Gastil indicate that there is no continuous zone of active faulting in non-plastic surficial deposits. The main faulting south of Tijuana is a northeast set of faults that is not appropriate for continuity of this zone and does not appear to be of proper orientation for continuation of the Rose Canyon fault.
(2) LANDSAT imagery shows no evidence for a throughgoing structure.
(3) There is no evidence for continuity of seismic activity on the Vallecitos fault zone.
- 23.
FOE Interroga tory:
Do you agree with the statement, "little strong motion data is available at distances of less than 10 km from the rupture surfaces.
Hence, estimates of ground motion at San Onofre from a major earthquake along the hypothesized zone of deformation approximately eight km offshore from the site would have signficant uncertainty when based on empirical data"?
NRC Staff Answer:
It is our position that determination of ground motion in the near field is clearly a problematic task which requires use of all available information and seismological and engineering judgment. The applicants' methodology for estimat ing ground motion at San Onofre was based largely upon empirical extrapolation of the data set available as of June 1979.
This data set, limited to site condi tions and the magnitude range appropriate for San Onofre, was almost exclusively made up of records recorded at distances greater than 10 km.
In order to assess the validity of this approach, comparisons were made with theoretical studies conducted for SONGS 1 and the significant collection of near field data recorded during the October 1979 Imperial Valley earthquake. Based upon these comparisons we find the applicants' empirical estimate to be reasonable.
16
- 24.
F0E Interrogatory:
Do you believe that you have adequate data to predict future seismicity on the Off-Shore Zone of Deformation by analyzing historic records?
NRC Staff Answer:
It is presently beyond the state of the art to predict future seismicity with respect to the location, tining and size of individual earthquakes on the OZD. We can, however, determine appropriate levels of around motion to be considered in the design of SONGS 2 & 3. This is done taking into account historical seismicity, instrumental seismicity, geological data geophysical data, tectonic interpretations and strong motion estimates.
- 25.
FOE Interrogatory:
How far would you estimate to be the extent of ground strains and land deformations associated with the San Andreas Fault System?
NRC Staff Answer:
The Staff has not made such estimate. However, such estimate is not necessary because it is not within the state of the art to use this method for making specific decisions on siting of nuclear power plants nor is it required by the Commission's regulations.
- 26.
FOE Interrogatory:
Have you researched the report by Dr. Wayne Thatcher of the USGS entitled "Horizontal Crustal Deformation From Historic Geodetic Measurements in Southern California?"
NRC Staff Answer:
Although we are familiar with the report by Dr. Thatcher we have not "researched" it.
17
- 27.
FOE Interrogatory:
What evidence do you have to disprove the hypothesis that faults parallel to the San Andreas Fault, such as the San Jacinto, Elsinore and Newport-Inglewood, absorb stress fron the seismic motions on the plate boundary?
PC Staff Answer:
There is no evidence to disprove that faults parallel to the San Andreas fault, such as the San Jacinto, Elsinore, and Newport-Inglewood, absorb stress from the seismic motions on the plate boundary.
- 20.
FOE Interrogatory:
How deep would you estimate to be the hypocenter of a postulated earthquael on the Offshore Zone of Deformation?
NRC Staff Answer:
The hypocenter of a postulated earthquake on the OZD (6-1s'- 7) would be assumed to be approximately 10 to 15 km deep.
- 29.
FOE Interrogatory:
Explain your analysis of the relationships between the hypocenter, epicenter, surface ruptures, and peak ground accelerations in the San Fernando earthquake?
NRC Staff Answer:
We have not conducted a specific analysis of the San Fernando earthquake.
- 30. FOE Interrogatory:
Have you or your consultants predicted ground accelerations at SONGS 2 & 3 from an earthquake on the Offshore Zone of Deformation with a magnitude of M7. 0?
18 NRC Staff Answer:
Neither we nor our consultants have specifically predicted ground accelera tions at SONGS 2 & 3 from an earthquake on the OZD with a magnitude of N17.0.
It is the staff position, however, that the response spectra proposed by the applicants for an MS=7.0, using an empirical approach, is a reasonable estimate of ground motion at SONGS 2 & 3 from such an event.
- 31.
FOE Interrogatory:
Have you or your consultants predicted ground accelerations at SONGS 2 & 3 from an earthquake on the Offshore Zone of Deformation with a magnitude of t7. 0?
If so, what is said prediction?
NRC Staff Answer:
This interrogatory is a repetition of FOE interrogatory 30.
See answer to 30 above.
- 32.
FOE InterroGatory:
Have you or your consultants predicted ground accelerations at SONGS 2 & 3 from an earthquake on the Offshore Zone of Deformation with a magnitude of If so, what is said prediction?
NRC Staff Answer:
No, we have not made such a prediction.
19
- 33.
FOE Interrocatory:
Have you or your consultants predicted ground accelerations at SONGS 2 & 3 from an earthquake on the Offshore Zone of Deformation with a magnitude of 1S. 0?
If so, what is said prediction?
NRC Staff Answer:
No, we have not made such a prediction.
- 34.
FOE Interrogatory:
Have you or your consultants predicted ground accelerations at SONGS 2 & 3 from an earthquake on the Offshore Zone of Deformation with a magnitude greater than 8.0?
If so, what is said prediction?
NRC Staff Answer:
No, we have not made such a prediction.
- 35.
FOE Interrogatory:
Do you agree that it is possible that a rupture propagating on the Off-Shore Zone of Deformation could be oriented so as to focus energy at the SONGS 2 &
3 site?
NRC Staff Answer:
Yes, we agree that a rupture propagating on the OZD could be oriented so as to result in some degree of focusing of energy at SONGS 2 & 3. See also answer to 63 below.
20
- 36.
FOE, Interrogatory:
Do you have any plans to conduct a microearthquake survey of the Cristianitos Fault Zone?
If not, why not?
kRC Staff Answer:
No, we have no plans to conduct a microearthquake survey along the Cristianitos fault.
The SONGS 2 & 3 applicants conducted such a survey during 1975.
There were very few events recorded in the area of the Cristianitos fault.
Because of this fact and since the California Institute of Technology already maintains a netvork in southern California capable of detecting earthquakes in this area down to least magnitude 2.5, no additional microearthquake surveys are being considered.
- 37.
FOE Interrogatory:
Has the NRC Staff done a class 9 Accident Analysis for SONGS 1?
NRC Staff Answer:
The Connission's regulations provide that:
"Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the proceeding,"
that "discovery shall relate only to those matters in controversy which have been identified by the Commission or the presiding officer in the prehearing conference order" and that "information sought [must appear] reasonably calculated to lead to the discovery
21 of admissible evidence."
10 C.F.R. § 2.740. Pennsylvania Power and Light Company and Allegheny Electric Cooperative, Inc., (Susque hanna Steam Electric Station, Units 1 and 2), ALAB-613, 11 NRC (slip op dated September 23, 1980 at 6).
The instant interrogatory concerning a Class 9 accident analysis at SONGS 1 does not relate to any contention admitted by the Licensing Board in its January 27, 1978 Memorandum and Order. In addition, whether or not a Class 9 accident analysis was done for SONGS 1 is factually irrelevant to the issue of the licensing of SONGS 2 and 3 and thus discovery on this subject is not "reasonably calculated to lead to discovery of admissible evidence." Accordingly, the Staff objects to this interrogatory.
3C.
FOE Interrogatory:
Has the NRC done a site-specific class 9 Accident Analysis for SONGS 2 & 3?
NRC Staff Answer:
Again, the issue of a Class 9 accident analysis for SONGS 2 & 3 is not a discoverable issue since there has been no Class 9 contention admitted by the Licensing Board.
Accordingly, the Staff objects to this interrogatory.
However, for the general information of the parties, consideration of the environmental effects of a Class 9 accident for SONGS 2 & 3 is being included in the operating license FES in accordance with the Commission'S "Statement of Interim Policy on Class 9 Accidents", 45 Fed. Rea.
40101 (June. 13, 1980).
22
- 39.
FOE Interrogatory:
What evidence does the NRC Staff have to disprove the hypothesis that the "0ZD" and its branches are part of a seismic gap?
NRC Staff Answer:
The utilization of seismic gaps to predict the occurrence of earthquakes has had most successes when applied to active seismic belts along major plate boundaries. Application of this methodology to zones of moderate seismicity such as the OZD that are not major plate boundaries is questionable at best.
The assumption that the SONGS 2 & 3 units should be designed to withstand an earthquake as large or larger than that which has occurred anywhere on the OZD during the historical record (more than 200 years) would appear to lead to results as conservative as those resulting from a "seismic gap analysis,"
if indeed one could reasonably be made.
- 40. FOE Interrogatory:
Does the NRC Staff believe that an adequate data base existed in 1964 at the time the AEC issued the construction pernit for siting nuclear reactors at San Onofre to determine or predict the ground motions that could occur at the site?
NRC Staff Answer:
The NRC Staff believes that the Staff views on the adequacy of the data base existent at the time of the issuance of the SONGS 1 construction permit is irrelevant to the Intervenors' admitted contention which deals with the maximum vibratory ground motion which is assigned to the safe shutdown earthquake for SONGS 2 and 3 and therefore is not "reasonably calculated to lead to the discovery of admissible evidence" in accordance with the provi sions of Section 2.740.
Accordingly, the Staff objects to this interrogatory.
23
- 41.
FOE Interrogatory:
Does the NRC Staff believe that an adequate data base existed in 1973 when the AEC issued the construction permit for SONGS 2 & 3 to deterine or predict the ground motions that could occur at the site?
N RC Staff Answer:
The NRC Staff believes that its views on the adequacy of the,ground motion data base for the issuance of the SONGS 2 & 3 construction permits in 1973 are not relevant to Intervenors' admitted contention dealing with the adequacy of maximum vibratory ground motion assigned to the SSE for operating license permit issuance. As recognized by the Licensing Board in its August 6, 1980 1e:iorandum and Order on Prehearing Conference of July 17, 1980, at page 3, information about old geologic features at the construction permit stage is res judicata absent intervening new seismic theory or geological information.
As noted in the Licensing Board's January 27, 1978 Memorandum and Order at 2, the thrust of Intervenors' contention is toward new geological information.
For that reason, any Staff view on old geologic evidence at the CP stage, without more, is in admissible and not discoverable under Section 2.740.
Accordingly, the Staff objects to this interrogatory.
- 42.
FOE Interrogatory:
Does the NRC Staff agree with scientists that it was not until 1969 that the theory of plate tectonics was widely accepted as the most logical explanation of earthquakes that occur around the Pacific Ocean rim?
NRC Staff Answer:
The Staff does not believe that any answer as to its views on the state of plate tectonic theory as of 1969 is relevant to the Intervenors' presently
24 admitted contention for the reasons discussed above in the Staff answer to Interrogatory 41.
For this reason, evidence concerning the evolution of geologic theories prior to construction permit issuance would not be reason ably calculated to lead to the discovery of admissible evidence and for that reason is not discoverable under Section 2.740.
Accordingly, the Staff objects to this interrogatory.
- 43.
FOE Interrogatory:
What is the Richter Magnitude for the Design Earthquake which the Applicants established with the AEC Staff for Unit One during the Operating License Proceedings?
NRC Staff Answer:
The Staff objects to this question concerning the design basis earthquake associated with SONGS 1 because the seismic safety of that plant is neither "relevant to the subject matter involved in this proceeding" (which is the licensing of SONGS 2 and 3), nor is there an admitted contention concerning SONGS 1. Moreover, an answer to such question does not appear to be "reasonably calculated to lead to the discovery of admissible evidence" and therefore is not discoverable under the provisions of 10 C.F.R. § 2.740.
- 44.
FOE Interrogatory:
Did the NRC Staff provide a formal written notice to the AEC Staff, ASLE, or Commissioners, in the context of the Operating Licensing Proceedings for SONGS Unit One, that in October 1967, the Department of Interior published a report which would require the Bolsa Island reactor to be designed for a Safe Shutdown Earthquake of Magnitude 8.0 on the Newport-Inglewood Fault Zone? If the answer is yes, cite the precise reference where this notice was given.
25 NRC Staff Answer:
The NRC Staff objects to Intervenors' interrogatory 44 inasmuch as the notification or non-notification of the Staff, Licensing Board or Commission in the Operating Licensing proceedings for SONGS 1 is irrelevant to the operating license proceeding for SONGS 2 and 3 nor does the information sought appear to be "reasonable calculated to lead to the discovery of admissible evidence" in this proceeding as required by 10 C.F.R. § 2.740.
- 45.
FOE Interrogatory:
Did the NRC Staff ever provide a formal written notice to the AEC, ASLD, or Comm.issioners, in the context of either the Construction Permit or Operating License Proceedings for SONGS Units 2 and 3, that in October 1967 the Depart ment of Interior had published a report that stated that the Bolsa Island Reactor should be designed for a Safe Shutdown Earthquake of Richter Magnitude 8 on the Newport-Inglewood Fault Zone?
NRC Staff Answer:
The NRC Staff does not believe that any answer it would give as to the notification or non-notification of the AEC of events occurring prior to the SONGS 2 and 3 construction pemit proceeding is "reasonably calculated to lead to the discovery of admissible evidence" concerning new geologic data or scientific methodology in keeping with the Intervenors' admitted conter tion and the Licensing Board's prehearing Memoranda and Orders.
For that reason, this issue is not discoverable under Section 2.740.
Accordingly, the Staff objects to this interrogatory.
26
- 46.
FOE Interrogatory:
What Richter Magnitude have the NRC Staff predicted for the Safe Shutdown Earthquake for Units 2 and 3 during the Operating License Proceedings.
Cite the precise reference for this prediction.
NRC Staff Answer:
It is the Staff's preliminary position that the SSE at SONGS 2 & 3 should be based upon the occurrence of a 1S=7.0 earthquake on the OZD 8 km froi the site.
"Richter" Magnitude, as it is comnmonly applied, refers to Local Magnitude (ML) for magnitudes less than about 6.0 and Surface Wave Magnitude (WS) for magnitudes greater than about 6.0. However, the Staff's review of this matter is not yet completed. Upon completion, the results, and tne Staff's ultimate position on this matter will be published in its Safety Evaluation Report for this facility.
- 47.
FOE Interrogatory:
What Richter Magnitudes did the AEC Staff predict for the Safe Shutdown Earthquake for Units 2 and 3 during the Construction Permit Proceedings?
NRC Staff Answer:
For the construction permit licensing stage, the safe shutdown earthquake was characterized in terms of Modified ercalli Intensity (X).
Richter magnitude was not specified.
- 48. FOE Interrogatory:
Does the NRC Staff agree that the OZD near SONGS 2 and 3 is an active fault capable of causing strong ground motions at the reactor site?
27 NRC Staff Answer:
The term "active fault" is used in different way by different agencies and geologists.
The NRC utilizes the term "capable fault" as defined in Appen dix A to 10 CFR Part 100.
The Staff has assumed the 0ZD to be capable within the context of this definition and therefore capable of producing strong ground motion at the SONGS site.
- 49.
-FOE Interrogarory:
Does the NRC Staff agree that the OZD is structurally related to the Newport Inglewood Fault Zone?
NRC Staff Answer:
Yes, the Newport-Inglewood Fault Zone is considered by the Staff to be part of the OZD.
- 50.
FOE Interrogatory:
Does the NRC Staff agree that the Newport-Inglewood Fault Zone is an active fault which is capable of causing strong ground motions at the SONGS site?
NRC Staff Answer:
The Newport-Inglewood Fault Zone is considered to be part of the OZD and therefore the answer given to Interrogatory #48 applies to this interroga tory also.
- 51.
FOE Interrogatory:
When will the NRC Staff ask to initiate a research contract with a consultant to analyze the ground motions at the site of SONGS 2 and 3 that would result frnm a Magnitude 8.0 earthquake on the Newport-Inglewood Fault Zone?
28 NRC Staff Answer:
Any information as to when a research contract would or would not be ini tiated is irrelevant to Intervenors' admitted contention and in any event is not reasonably calculated to lead to the discovery of admissible evidence; it therefore is not discoverable under Section 2.740. Accordingly, the Staff objects to this interrogatory.
- 52.
FOE Interrogatory:
Does the NRC Staff agree that one of the applicants consultants, Woodward-Clvde, has recently published a report to the California Coastal Commission regarding the siting of a LNG facility at Camp Pendleton just south of SOuGS, which predicted that the facility would need to be designed for a Magnitude 7.2E earthquake on the Offshore Fault Zone?
NRC Staff Answer:
In a report entitled "Geotechnical Evaluation of Five Potential Mainland California LNG Import Terminal Sites" (April 28, 1978) published by one of the applicants' consultants (Woodvard/Clyde), estimates were made for "maximum credible" earthquakes affecting these sites.
One of the sites that was evaluated was Camp Pendleton just south of the SONGS site.
The "maximum credible earthquake" for the South Coast Offshore Zone of Deformation (part of the OZD) was estimated to be 7 1/4.
This magnitude was arrived at by a simple assumption that 1/2 of the assumed length of the OZD would rupture.
No analysis of earthquake potential beyond that was attempted. While such simple estimates may be useful in generalized comparative analyses of rela tive seismic hazard at different sites, it is entirely inadequate for nuclear power plant siting.
For that reason, the Staff's preliminary position
29 stated in response'to interrogatory #46 is based upon a much more extensive review of geologic and seismological information than was apparently conducted for the above-mentioned study.
- 53.
FOE Interrogatory:
When will the NRC Staff request the Applicants to initiate a research contract with a consultant to analyze the ground motions at the site of SONGS 2 and 3 that would result from a Magnitude 7.25 earthquake on the OZD?
NRC Staff Answer:
The extent to which the Staff has considered predicted ground accelerations of earthquakes up to and above magnitude 8.0 in the OZD are listed in the answers to interrogatories 30 to 34, supra.
The issue of when the Staff will require the Applicants to "initiate a research contract with a consul tant" is irrelevant to the Intervenors' admitted contention therefore is not discoverable under Section 2.740.
Accordingly, for the reasons discussed in the Staff's objection to interro2 atory 51, above, we object to this interrogatory.
- 54.
FOE Interrogatory:
Has the NRC Staff considered the possibility that the SONGS 2 and 3 facilities are not designed to withstand an earthquake on the OZD that is greater than a Magnitude of 6.5?
Cite a reference for such consideration.
30 NRC Staff Answer:
Answers as to Staff consideration of maximum vibratory ground motions associ ated with earthquakes of up to magnitude 8.0 and above are listed in answers 30 to 34, above. The question of whether the plant design will withstand the maximum vibratory ground motion assigned, a question of structural adequacy, is outside the scope of the Intervenors' contention and, moreover, does not appear to be "reasonably calculated to lead to the discovery of admissible evidence" in accordance with Section 2.740 and the Susquehanna case, supra, and, thus, is not discoverable.
Accordingly, the Staff objects to this interrogatory.
- 55.
FOE Interrogatory:
Does the NRC Staff agree that in the California Coastal Plan issued in December 1975, the California Coastal Commission stated that the California Coastal Zone is not a proper zone to site nuclear reactors because of the severe seismic risks and the proximity of population concentrations which would be exposed to radiation hazards following earthquake damages to a reactor?
NRC Staff Answer:
The NRC Staff has not reviewed the California Coastal Zone Commission Plans in the context of the San Onofre 2 and 3 seismic review.
- 56.
FOE Interrocatory:
If the Applicants had not yet begun construction of SONGS 2 and 3, would the NRC Staff approve of an application for a construction permit to construct more reactors at San Onofre, considering the seismic hazards at that site?
31 NRC Staff Answer:
Intervenors' interrogatory 56 concerning the hypothetical and speculative approval of an application for a construction permit to construct more reactors at San Onofre does not appear to be "reasonably calculated to lead to the discovery of admissible evidence" concerning their contention which deals with the assignement of the maximum vibratory ground notion for SONGS 2 and 3. It therefore is not discoverable under Section 2.740. Accordingly, the Staff objects to this interrogatory.
- 57.
F0E Interrogatory:
Given the Southern California tectonic setting, would the NRC Staff agree that there is a component of stress on the Cristianitos Fault?
NRC Staff Answer:
Given the southern California tectonic setting it would be reasonable to assume that there is a component of stress on the Cristianitos fault.
However, it is obvious that this stress has not been of sufficient magnitude to cause movement on the fault for at least 120,000 years.
- 58.
FOE Interrogatory:
What evidence does the NRC Staff have that personnel at SONGS 2 & 3, durinc future operations, could perform necessary emergency procedures during and following a severe earthquake, when their lives are being threatened by the circumstances?
NRC Staff Answer:
Intervenors' interrogatory concerning reactor operator performance during emergencies does not appear to be designed to elicit information "reasonably
32 calculated to lead to the discovery of admissible evidence" since its admitted emergency plan contention is clearly directed toward the asserted non compliance with Appendix E because of the jurisdictional diversity of local and overlapping emergency plans, and not with operator perfomance. For this reason, the matter is not discoverable under Section 2.740.
Accord ingly, the Staff objects to this interrogatory.
- 59.
FOE Interrogatory:
Have the NRC Staff analyzed the tidal wave effects on coastal structures for the earthquake which occurred in the offshore region along the Pacific Coast of Colombia on December 12, 1979?
If the answer is no, does the NRC Staff plan to initiate an analysis of that earthquake?
NRC Staff Answer:
This interrogatory concerning the effect of tidal waves on coastal structures does not appear to be reasonably related to Intervenors' contention which deals with the assignment of the maximum vibratory ground motion for SOCGS 2
& 3 and not with structural engineering.
For this reason, the question is not "reasonbly calculated to lead to the discovery of admissible evidence" and is therefore not discoverable under Section 2.740.
Accordingly, the Staff objects to this interrogatory.
- 60.
FOE Interrogatory:
Does the NRC Staff agree that personnel would be more likely to make mistakes in procedures during an earthquake scenario than under "normal accidental conditions?"
33 NRC Staff Answer:
This question, like question 58, deals with operator emergency actions, a subject which is unrelated to the Intervenors' admitted contention which deals with alleged non-compliance with Appendix E because of overlapping local emergency plans.
For this reason, the question is not "reasonably calculated to lead to the discovery of admissible evidence".
Moreover, it does not relate to a matter in controversy as noted in the Susquehanna case, supra. Accordingly, the Staff objects to this interrogatory.
- 61.
FOE Interrogatory:
What psychological studies can the NRC Staff cite that support their argu ments that operating personnel could respond effectively to Earthquake circumstances at SONGS 2 & 3, during a threat to their safety?
NRC Staff Answer:
Like interrogatories 58 and 60, Intervenors' interrogatory as to whether plant personnel could respond effectively during an earthquake is not con cerned with their seismic contention of whether the maximum vibratory ground motion has been assigned or with their emergency planning contention.
- Thus, it is not concerned with a "matter in controversy" under the Susquehanna case, suora, and does not otherwise appear to be "reasonably calculated to lead to the discovery of admissible evidence" under Section 2.740. Accord ingly, the Staff objects to this interrogatory.
- 62.
FOE Interrogatory:
Whdt peak and effective ground accelerations (g values) were the spent fuel rod pools at SONGS Unit 1 designed and built for?
34 NRC Staff Answer:
This interrogatory seeks to elicit information concerning the spent fuel pools at SONGS 1, a matter which is not in contention in this case.
Further nore, the question does not otherwise appear to be "reasonably calculated to lead to the discovery of admissible evidence" and therefore is not discover able under Section 2.740 and the Susquehanna case, supra. Accordingly, the Staff objects to this interrogatory.
- 63.
FOE Interrogatory:
Have the NRC Staff contracted with consultants to analyze the directivity and focusing effects observed in the seismic wave propagations and instru mental data in the records for each of the following earthquake:
- a. The Long Beach earthquake of 1933;
- b. The Santa Barbara earthquake of August 31, 1978;
- c. The Coyote Lake earthquake of August 6, 1979;
- d. The Imperial Valley earthquake of October 15, 1979; and,
- e. The Livermore Valley earthquake of January 24, 1980.
NRC Staff Answer:
The NRC Staff has not specifically contracted with consultants to analyze the directivity and focusing effects associated with the referenced earth quakes. Our consultants, however, are currently reviewing generalized studies of the 1933 Long Beach earthquake, the 1979 Coyote Lake earthquake and the 1979 Imperial Valley earthquake found in Supplements 2 and 3 of "Simulation of Earthquake Ground Motions for San Onofre Nuclear Generating Station Unit 1 (1980)" submitted to NRC by the licensee. In addition, the applicants for SONGS 2 and 3 have used an empirical approach to estimate ground motion that includes a significant number of records recorded under conditions of above-average focusing.
35
- 64.
FOE Interrogatory:
Does the NRC Staff agree that the Applicants for SONGS 2 & 3 have maintained at least through March 1980 (see Applicants Response of March, 1980 to Intervenor's Interrogatory #15, submitted on February 15, 1980) that (in their words) "the maximum earthquake magnitude that may be conservatively associated with OZD is 1.6-1/2..." which is quoted from Applicants' Response to NRC Staff Question 361.33?
NRC Staff Answer:
Yes.
The applicants' reponse of Miarch 1980 to Intervenor's Interrogatory
'16 has been their position at least through that date.
Recently (October 7, 1980) in a revised response to Question 361.54, the applicants' have clarifief this position with respect to earthquakes of magnitude 6 1/2 and larcer.
The response states - "Applicants consider MS=6 1/2 to be the most reasonable estimate of maximum magnitude for a postulated earthquake on the hypothesized OZD opposite the site.
At the same time, MS=7 is considered to be appropriate for purposes of assessing the conservatism of the present design basis and an extrapolation of the MS=6 1/2 spectrum to MS=7 has been performed accord ingly.
Further, Applicants consider an earthquake of MS=7 1/2 to be completely unrealistic either as an estimate of maximum magnitude or as a basis for assessing conservatism of the present design."
- 65.
FOE Interrogatory:
Does the NRC Staff agree that during the meeting with Applicants and their consultants at the USGS headquarters in Menlo Park, California, on September 12, 1979, that the Staff advised the Applicants to consider the ground motions at the SONGS site for earthquakes on the OZD with Magnitudes of 7, 7.5, 8.0, and 8.5, as noted in media accounts of that meeting?
36 NRC Staff Answer:
The NRC Staff did not meet with the applicants on September 12, 1979. A public meeting between the NRC Staff, the applicants, their consultants, the U. S. Geological Survey, and the California Division of Mines and Geology was held on September 13, 1979 in Menlo Park, California.
Staff attendees at that meeting do not recall advising the applicants to consider the ground motions at the SONGS site for earthquakes on the OZD with magnitudes of 7, 7.5, 8.0 and 8.5.
No request for such information is noted in the staff meeting summary, dated November 5, 1979, which contains an extensive list of questions and concerns discussed at the meeting.
Staff questions regarding San Onofre seismology were formally transmitted to the applicant by letter dated December 21, 1979.
Question number 361.54 of the enclosure to the December 21, 1979 letter requested that the applicants extrapolate the ground motion at the site for magnitude 7 and 7 1/2 on the OZD. This written request represents the Staff's considered judgment as to the range of magni tudes of interest, and in addition would supercede any comnents that might have been made by individual staff members during meetings such as that of September 13, 1979.
- 66.
FOE Interrogatory:
Why did the NRC shutdown the Vallecitos Nuclear Reactor (GETR)?
NRC Staff Answer:
Interrogatories 66 through 69 seek to elicit information concerning seismology and the Staff's seismic reviews at several different California sites.
Since the seismic issue in contention in this proceeding is whether "the
37 earthquake which could cause the maximum vibratory ground motion has not been assigned as the safe shutdown earthquake" at SONGS 2 and 3, the dis covery sought does not relate to a contention admitted to this proceeding and thus the answers to these interrogatories would be irrelevant to any matter in this proceeding.
Furthermore, these interrogatories go to matters which do not appear to be "reasonably calculated to lead to the discovery of admissible evidence" and therefore is not discoverable under Section 2.740.
Accordingly, the Staff objects to interrogatories 66-69.
- 67.
FOE Interrogatory:
Why did the NRC shutdown the Humboldt Bay Reactor?
NRC Staff Answer:
See answer 66 above.
- 68.
FOE Interrogatory:
Why had the NRC delayed operations at the Diablo Canyon Reactors from 1973 until the present?
NRC Staff Answer:
See answer 66 above.
- 69.
FOE Interrogatory:
Please compare the amounts and types of research on offshore geology and seismology done by the Applicants at Diablo Canyon, to that done by the Applicants for SONGS 2 & 3.
38 NRC Staff Answer:
See answer 66 above.
- 70.
FOE Interrogatory:
Describe in detail the SEP Seismic Review for SONGS One, including a list of what documents and reports or quarterly summaries have been published in that review.
Provide a copy of each of these.
NRC Staff Answer:
The Staff's seismic review of San Onofre Unit 1 is currently in progress.
At this time, the Staff has not published any final results of this review in a Safety Evaluation Report.
However, in support of the seismic reevalua tion of the San Onofre Nuclear Generating Station Unit 1 (SONGS 1) the licensee (Southern California Edison) has submitted a theoretical numerical study (Del Mar Technical Associates, 1978) aimed at estimating ground motion at the site from an earthquake caused by a rupture along the Offshore Zone of Deformation.
For this study, a kinematic source model was assumed. The procedure for modelling ground motion was as follows:
- 1. Fault slip is characterized in terms of fault type, rupture velocity, dynamic stress drop (slip velocity at the onset of rupture at each point on the fault), static stress drop (fault offset) and duration of slip at each point. Random processes are included to approximate irregularities in actual earthquake rupture.
- 2. Propagation characteristics (Green's functions) are calculated for the particular earth structure; that is, surface motions are computed for
39 several hundred point sources along the fault plane.
These earth response calculations include all wave types up to frequencies of 20 Hz.
- 3. Ground notion is calculated by convolving in time and space the fault slip characterization from Step 1 with the earth response functions fro-, Step 2. By specifying hypocentral location, rupture extent and site location, the difference source site configurations can be examined.
The model (particularly the slip function) was calibrated using the 1966 Parkfield Earthquake (MS=6.0, ML 5.8).
Prior to the October 1979 Imperial Valley Earthquake this was the most well recorded earthquake in the near field. In addition, the recordings from the 1940 Imperial Valley Earthquake (iL=6.5, M S=7.1) and the 1976 Brawley earthquake (MS=4.9) were modelled.
Utilizing subsurface knowledge of the SONGS site, P and S wave velocity, density, attenuation and layer thickness were computed. Green's functions were calculated to predict propagation characteristics from source depths, extending to 15 km, out to epicentral distances of 60 km. The ground motion modelling centered about the effects of a 40 km long rupture 8 km from the site. This is an approximate representation of M S=7.0 earthquake on the 0ZD. Sensitivity tests were calculated to test the effect of variations in site distances, fault length, fault location along the OZD (focusing) fault depth, hypocentral depth changes in dynamic and static stress drop, duration of slip, and changes in earth structure.
40 In response to the staff's and its consultants' (Dr. Keiiti Aki, M.I.T.;
Don L. Bernreuter, Lawrence Livermore Labs; Dr. Robert Herrmann, St. Louis University; and Dr. J. Enrique Luco, University of California-San Diego) review., a revised model and additional studies were submitted (Del-Mar Technical Associates 1979a).
The revisions in the model included:
- 1. Utilization of additional randomness.
- 2.
Revision of the three parameter slip function.
Additional studies were conducted with respect to:
- 1. The effect of grid spacing used in the numerical modelling procedure upon results.
- 2. The assumption of a two parameter slip function.
- 3. Sensitivity of the results to changes in earth structure and fault parameters.
In response to other concerns the Licensee submitted a study (Del Mar Technical Associates, 1979b) calculations and discussions relating to magnitude and moment estimates of the proposed numerical estimates of ground motion and estimated ground motion at distances greater than 20 km.
In addition to the above mentioned consultants, the Staff initiated a separate study carried out on the Illiac computer by Systems, Science and Software (Day 1979) to investigate slip functions.
Making use of the unique capabilities of the Illiac, numerical dynamic studies were carried out to test the sensi tivity of earthquake slip functions to fault geometry frictional strength and prestress configuration.
41 In response to the Staff's further questions regarding the ability of the model to fit data from additional earthquakes, a Del Mar Technical Associates study (1980a) was submitted showing a comparison between theoretically estimated and observed ground motion at selected stations which recorded motion from the 1933 Long Beach Earthquake and the 1971 San Fernando Earthquake.
Del-Mar Technical Associates report (1980b) primarily represents an extensive effort by the SONGS 1 licensee to compare theoretically estimated and observed ground motion at selected stations for the very well recorded October 1979 Imperial Valley Earthquake.
Additional model changes (mostly greater random ness) were introduced in Supplements II and III.
The Staff has not yet completed its final review of the SONGS 1 modelling study particularly Supplements II and III.
However, attached is a list of the submitted reports requested by Intervenors' interrogatory.
Even though they are not "published" as designated in the interrogatory, the list of reports is being furnished for the convenience of Intervenors.
The Staff is willing to make these documents available for inspection and copying at a mutually agreeable time and place.
References
- 1. Del Mar Technical Associates (1978).
Simulation of Earthquake Ground Motions for the San Onofre Nuclear Generating Station -- Unit 1, May 1978, Final Report.
- 2. Del Mar Technical Associates (1979a).
Simulation of Earthquake Ground Motions for San On6fre Nuclear Generating Station -- Unit 1, Supplement 1, July 1979.
42
- 3.
Del Mar Technical Associates (1979b) Earthquake Ground Motion Simula tions for San Onofre -- Unit 1 Response to Proposed Task 4, September 1979.
- 4.
Day, Si (1979) Three-Dimensional Finite Difference Simulation of Fault Dynanics -- Final Report sponsored by NASA Ames Research Center, December 1979.
- 5.
Del Mar Technical Associates (1980a) Simulation of Earthquake Ground Motion for San Onofre Nuclear Generating Station Unit 1, Supplement II, August 1980.
- 6.
Del ar Technical Associates (1980b) Simulation of Earthquake Ground Motions for San Onofre Unit 1 -- Supplement III, August 1980.
- 71.
FOE Interrogatory:
Does the NRC Geosciences Branch agree with the following statement made by NRC Staff Seismologist in a meeting with earthquake engineers and geophysi cists in San Diego County on February 14, 1978, as published with the title "The Needs of the NRC in the Field of Strong Motion Seismology":
"The most difficult problem we face today is estimating strong motion in the vicinity of the earthquake source, i.e., the near-field. No nuclear power plant is intentionally placed near a known earthquake source or "capable" fault but subsequent investigations have revealed new faults and resulted in reassessment of some old faults. The Humboldt Bay, Diablo Canyon, San Onofre, and Vallecitos sites in California are the prime examples. In order to-determine whether facilities at these sites are sufficiently safe as designed, need to be upgraded or need to be abandoned, requires an assessment of motion near earthquake sources where we have few measurements most of which are from small earthquakes.
NRC Staff Answer:
This statement is correct except for its description of NRC policy regarding siting nuclear power plants near known capable faults. There is no regulation or policy prohibiting such siting.
Indeed the extensive and lengthy investiga tions and review conducted for SONGS 2 & 3 is a result of the recognition of the fact that the Offshore Zone of Deformation is capable of generating earthquakes.
43
- 72.
FOE Interrogatory:
What evidence do you have to disprove the hypothesis that the San Miguel fault zone is structurally related to the Plate Boundary System or Transform Zone in the Gulf of California?
NRC Staff Answer:
The geologic mapping of Gastil and others (1973), and the recent report of Gastil and others (1979 "Earthquake and Other Perils, San Diego Region," GSLk Field Trip, November, 1979) suggests "strain may be widely distributed rather than concentrated on a narrow transpeninsular fault zone."
There is an apparent seismic activity gap between the San Miguel and San Pedro Matir fault (also the Agua Blanca appears to be inactive at its eastern end and no fault is known to connect to the Gulf of California rift zone with the peninsular faults).
(See response to Interrogatory #8)
I hereby certify that the information detailed above is true and accurate to the best of my personal knowledge Dr. Leon Reiter (Interrogatories 4, 7, 9, 10, 13, 15, 20, 23 24, 25, 26, 28, 29, 30, 31, 32, 33, 34, 35, 36, 39, 46, 47, 48, 50, 52, 55, 63, 64, 70, 71).
A. Thomas Cardone (Interrogatories 1, 2, 3, 4, 5, 6, 8, 11, 12, 14, 16, 17, 18, 19, 20, 21, 22, 27, 49, 57, 72).
44 Harry Rood (Interrogatory 65)
Sworn to before me this day of October, 1980 Notary Pu lic/
Ily Commission' Expires:
L
}- \\i L. Aw Davis Lawrence J. Chandler (Objections to Interrogatories 37, 38, 40, 41, 42, 43, 44, 45, 51, 53, 54, 56, 58, 59, 60, 61, 62, 66, 67, 68, 69)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,
)
)
50-362 OL (San Onofre Nuclear Generating Station, )
Units 2 and 3)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF ANSWERS TO INTERROGATORIES BY FRIENDS OF THE EARTH," in the above-captioned proceeding has been served on the 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 mail system, this 17th day of October, 1980:
Ivan W. Smith, Esq., Chairman*
David R. Pigott, Esc.
Atomic Safety and Licensing Board Samuel B. Casey, Esc.
U. S. Nuclear Regulatory Commission Chickering & Gregory Washington, DC 20555 Three Embarcadero Center Twenty-Third Floor Dr. Cadet H. Hand, Jr., Member San Francisco, CA 94111 Director, Bodega Marine Laboratory University of California Alan R. Watts, Esq.
P. 0. Box 247 Rourke & Woodruff Bodega Bay, CA 94923 10555 North Main Street Suite 1020 Dr. Emmeth A. Luebke, Member Santa Ana, CA 92701 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Richard J. Wharton, Esq.
Washington, DC 20555 Wharton and Pogalies 2667 Camino Del Rio South Janice E. Kerr, Esq.
Suite 106 J. Calvin Simpson, Esq.
San Diego, CA 92108 Lawrence Q. Garcia, Esq.
California Public Utilities Commission Mrs. Lyn Harris Hicks 5066 State Building GUARD San Francisco, CA 94102 3908 Calle Ariana San Clemente, CA 92672 Charles R. Kocher, General Counsel James A. Beoletto, Esq.
David W. Gilman Southern California Edison Company Robert G. Lacy 2244 Walnut Grove Avenue San Diego Gas & Electric Co.
Rosemead, CA 91770 P.O. Box 1831 San Diego, CA 92112
-2 Phyllis M. Gallagher, Esq.
Atomic Safety and Licensing Board 1695 West Crescent Avenue Panel*
Suite 222 U.S. Nuclear Regulatory Commission Anaheim, CA 92701 Washington, DC 20555 A. S. Carstens Secretary 2071 Caminito Circulo Norte U.S. Nuclear Regulatory Comission Mt. La Jolla, CA 92037 ATT:
Chief, Docketing & Service Branch Washington, D.C.
20555 Atomic Safety and Licensing Appeal Panel (5)*
U.S. Nuclear Regulatory Commission Washington, DC 20555