ML20003C355
| ML20003C355 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/18/1981 |
| From: | Raynard Wharton FRIENDS OF THE EARTH, WHARTON & POGALIES |
| To: | SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML13302B923 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8102270815 | |
| Download: ML20003C355 (24) | |
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-- . r UNITED STATES OF AMERICA NUCLEAR REGULATCRY CCMJ1ISSICN SEFOC" "" ATCMIC SAFE'"Y AND LICENSD G 3 CARD In the Matter of )
SCUMERN CALIFCRNIA EDISCN CCMPANY, 2 Docket Nos. 50-361 CL ET AL. #
50 -362 CL
)
(San Onofre Nuclear Generating Station, )
Units 2 and 3) )
DITERVENOR , FCE E'" AL FIF5 SET INTERRCGATCRIES TO SCU"?iE?li CALIFCRNIA EOISCN Intervenors Friends of the Earth, et al, requests that the Southern California Edison Ccepany answer under cath, pursuant to 10 C.F.R. 2.7406, the folicwing interrogatories within 14 days of service thereof. In answering these interrogatories, you are required to furnish such infor=ation as is available to you, including information in the possession of your atter-neys and investigators for your attorneys.
INSTRUCTIONS AND DEFINITICNS For purposes of these Interrogatcries and your respenses thereto, the folicwing definitions and instructions shall apply:
l (a) The term " Applicants" "You" or "Your" refers l jointly to Southern California Edison Ccmpany and the San Diego Gas & Electric Company.
, (b) The term " person" means any natural person and any 1
private or public entity of any nature, including without
! limitation, corporations, firms, partnerships, sole proprietorships, associations, groups, organizations, trusts and estates.
81e2 270 Sl 5 .
(c) The term " document" means:
(1) The original, or (2) If the original is not in your custody or under your control, then a ecpy thereof.
(d) As used herein, unless the context otherwise requires, the singular number includes the plural and the plural includes the singular; the masculine gender includes the feminine, and the feminine includes the =asculine.
(e) When you are requested to " identify" any document, you shall include in your response a description sufficient to satisfy the " reasonable particularity" requirement found in Title 10, Part 2, Section 2.741(c) of the code of Federal Regulations, including without limitation the folicwing information with respect thereto:
(1) The nature of the document; (2) Its.date; (3) The names of its addressor (s) and addressee (s), if any; l
(4) The name(s) of the persen(s) who prepared it; (5) The name(s) and address (es) of the present I custodian (s) of the original and any copies thereof; and l (6) A summary of its contents.
In lieu of providing the information specified in Paragraph (e),
Items (1)-(6), you may attach. to your responses to these Interrogatories a true ecpy of such document, identifying the Interrogatory to which it is responsive and stating in your answer only such of the information specified in Paragraph (e),
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Items (1)-(6) as does not clearly appear en the face of such document.
If you claim a document is privileged or attorneys' work product, describe the same generally and state all facts
- upon which you base the claim of privilege or the claim such document constitutes attorneys' work product.
(f) When you are requested to
- identify" any persen, you shall set fcrth the full name and last kncwn business address, and employer of such person you are asked to identify.
(g) The term " expert" refers to a persen who by virtue of his knowledge, skill, experience, training or education has acquired a scientific, technical or specialized kncwledge which can assist the Nuclear Regulatory Commission Licensing Scard in underscanding the evidence or deternining a fact, opinion, or scientific theory relevant to an issue in this proceeding.
(h) When you are requested to " identify" an " expert" as that latter term is defined in Paragraph (g) above, you shall set forth the full name and last known business address, academic affiliations, and present employer of each such " expert" you are asked to identify.
(i) In answering these Interrogatories, you shall furnish all information available to you, your respective agents, employees, investigators, representatives and attorneys, and at merely such information as is known from personal knowledgm (j) The term " SONGS 2 and 3" refers to the San Onofre Nuclear Generating Station, Units 2 and 3.
(k) The term "SCE" refers to the Southern California Edison Company.
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( 1) The term "NRC" refers to the United States Nuclear Regulatory Cc= mission.
(m) The term "FSAR" refers to the " Final Safety Analysis Report, San Onofre Nuclear Generating Station, Units 2 and 3," which intervex=s believe is currently available to the public in the Public Documents Room of the Mission viejo Public Library.
(n) Where the Interrogatories ask whether Applicants have
" analyzed" a document or subject, Intervenors define " analyze" to be where Applicants have reviewed the document or subject in the context of SONGS 2 and 3 and have submitted a written report of that review.
(o) Offshore Zone of Ceformation ("CZD") as used in this proceeding is a hypothesized zone of deformation which as defined by the United States Geological Survey-("USGS") consists of the Newport Inglewood Zone of Cefor=ation, the South Coast Offshore Zone of Deformation and the Rose Canyon Fault Zone.
INTERROGATORIES INTERRCGATCRY NO. 1 Define the follcwing terms:
(a) structurally related (b) wrench fault (c) wrench fault system (d) wrench fault tectonics (e) active tectonic system (f) branch or splay (g) seismic gap 4
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(h) en echelon (i) plate boundary INTERRCGATORY NO. 2.
For each of the terms listed in Interrogatory No. 1.
(a) Identify each and every document. written authority or communication upon which you rely in defining each term; (b) Identify each and every person. expert or otherwise, upon whom you rely in defining each term; and (c) Identify any writings, opinions, or testimony of the person (s) you have listed in Interregatory 2(b) upon which you rely in defining each term.
INTERROGATORY NO. 3.
Do yua contend that the cristian1tos Fault does not extend southward for a distance greater than 6000 feet offshore from its coastal expression? If so, (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention. or on whose ,
writings, opinions, or testimony you base this contention; and (d) . Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
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(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Su==arize the factual and theoretical basis, as well as any other grounds, for each cpinion to which the witness is expected to testify.
INTERROGATCRY NO. 4.
What do you contend is the' minimum age of last displacement on the Cristianitos Fault?
(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions. or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify.
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INTERRCGATORY NO. 5 Do you contend that the Cristianitos Fault is not a
" capable fault" If so, (a) State each and every fact upon which you base this contention; (b) Identify each and every document or ccmmunicatien upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, epinions, or testimony you base this contention; and (d) Identify each and every person. expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the follcwing information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each cpinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.
INTERRCGATORY NO. 6.
Do you contend that the OZD is the controlling geologic structure for seismic design of SCNGS 2 and 3? If so:
(a) State each and every fact upon which you base this contention:
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(b) Identify each and every document or cc==unication upon which you base this contention; (c) Identify each and every persen with kncwledge of the factual basis or bases for this contention, or on whose writings, opinions or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each epinion to which the witness is expected to testify.
INTERROGATCRY NO. 7.
What do you contend is the maximum magnitude earthcuake that could occur on the OZD?
(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this contention, or on whose writings, opinions. or testimony you base this contention; and (d) Identify each and every person. expert or otherwise. whom you expect to call as a witness at the hearing 8
before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis.
as well as any other grounds, for each opinion to which the witness is expected to testify.
INTERRCGATORY NO. 8.
What do you contend is the maximum magnitude earthcuake that could occur on the geologic structural relationship between theOZDandtheCristianitosboneofDeformation?
(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this centention, or on whose writings, opinions, or testimony you base this contention; and (d) Identify each and every person expert or otherwise, whom you expect to call as a witness at the hearing L
before the Atomic Safety and Licensing Board in support of this contention and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; l
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(ii) Su=marize the factual and theoretical basis as well as any other grounds, for each opinion to which the witness is expected to testify.
INTERRCGATORY NO. 9.
What do you contend is the minimum age of last displacement on the South Coast Offshore Zone of reformation portion of the OZD? :
(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the -
following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify; and (e) . Identify _each and every event upon which you base this contention 10 M t*
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INTERROGATORY NO. 10.
What do you contend is the minimum age of last displacement on the Newport Inglewood Zone of Ceformation portion of the OZD7 (a) State each and every fact upon which you base this contentii.n; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings. opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise whom you expect to call as a witness at the hearing before the Atemic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the follcwing information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis.
as well as any other grounds- for each opinion to which the
! witness is expected to testify; and (e) Identify each and every event upon which you base this contention.
INTERROGATORY NO. 11.
What do you contend is the minimum age of last displacement on the Rose Canyon Fault Zone portion of the OZD?
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(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings. opinions- or testimony you base this contention; and (d) Identify each and every persen expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention. and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis.
as well as any other grounds, for each opinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.
INTERROGATORY NO. 12.
Is it your contention that the postulated zone of deformation which extends frem the coastal exposure of the Cristianitos Fault toward the OZD dies out before reaching the CZD? If so (a) State each and every fact upon which you base your contention; 12
(b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this contention or on whose writings. opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify.
INTFRRCGATORY NO. 13.
Do you contend that there is not a structural relation-ship between the Cristianitos Fault and the CZD? If so.
(a) State each and every fact upon which you base this contention; i (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention. or on whose writings. opinions, or testimony you base this contention; and (d) Identify each and every person expert or 13
otherwise. whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing scard in support of this contention, and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify.
(e) Identify each and every event upon which you base this contention.
INTERROGATORY NO. 14.
Do you contend that the CZD does not extend south of the Rose Canyon Fault Zone? If so (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this contention or on whose r
! writings. opinions. or testimcny you base this contention; and (d) Identify each and every person. expert or otherwise. whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
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(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis.
as well as any other grounds for each opinion to which the witness is expected to testify, INTERRCGATORY NO. 15.
Do you contend that there is no structural relationship between the Rose Canyon Fault Zone and the Vallecitos Fault in Baja, California? If so.
(a) State each and every fact upon which you base this contention; (b) Identify each and every document or cc=munication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention- or on whose writings- opinions. or testimony you base this contention; and (d) Identify each and every person. expert or otherwise. whom you expect to call as a witnes: at the hearing before the Atomic Safety and Licensing Board in support of this contention. and as to each potential witness so identified provide the following information:
i (i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds. for each opinion to which the witness.is expected to testify.
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INTERRCGATORY NO. 16.
Do you contend that there is not a structural relationship between the Rose Canyon Fault Zone and the San Miguel Fault in Baja, California? If so, (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings opinions, or testimony you base this contention; and (d) Identify each and every person expert or otherwise. whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention and as *.o each potential witness so identified provide the fol'1owing information:
(i) State the substance of the facts and cpinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as weU. as any other grounds. for each opinion to which the witness is expected to testify.
INTERROGATORY NO. 17.
Do you contend that there is not a relationship between the OZD and the San Andreas. If so (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication 16
upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis er bases for this centention or on whose writings epinions or testimony you base this contention; and (d) Identify each and every person expert or i
otherwise whcm you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and cpinions to which you expect the witness to testifyr (ii) Summarize the factual and theoretical basis, as well as any other grounds. for each opinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.
INTERROGATORY NO. 18.
Do you contend that .67 g is the proper design acceleration value for SONGS 2 and 37 INTERROGATORY NO. 19.
If your answer to Interrogatory No. 18 is Yes.
(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of 17 L
the factual basis or bases for this contention. or on whose writings opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention and as to each potential. witness so identified provide the folicwing information:
(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Su=marize the factual and theoretical basis, as well as any other grounds for each opinion to which the witness is expected to testify. .
INTERRCGATORY NO. 20.
Do you contend that there is no possibility of ground displacement within the plant site? If so (a) State each and every fact upon which you base this contention; l
(b) Identify each and every document or communication upon which you base this contention; 1
l (c) Identify each and every person with knowledge of 1
1 the factual basis or bases for this contention, or on whose writings opinions, or testimony you base this contention; and l (d) Identify each and every person expert or otherwise whom you expect to call as a witness at the hearing j
before the Atomic Safety and Licensing Board in support of this contention and as to each potential witness so identified provide the folicwing information:
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l (i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Su==arize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.
INTERRCGATORY NO. 21.
Have you contracted with or contacted any consultants to analyze any aspect of the Imperial valley earthcuake of October 15 1979? If so.
(a) Identify each and every consultant who has conducted such analysis on your behalf; (b) Identify each and every document. writing or acommunication arising out of the analysis performed by your consultants on the Imperial Valley earthcuake which you expect to use at the hearing on the seismic contention before the Acomic Safety and Licensing Board; (c) Summarize the substance of the findings and/or conclusions of your consultants which they have derived from their analysis of the Imperial valley earthcuake (1) with respect to SONGS 2 and 3 (2) with respect to any other nuclear power plant site in california; and (d) Summarize the factual and theoretical bases as well as any other grounds .upon which your consultants base their 19
l findings and/or conclusions on the Imperial valley earthcuake (1) with respect to SONGS 2 and 3 (2) with respect to any other nuclear pcwer plant site in California.
INTERRCGATORY NO. 22.
Do you contend that the Cristianitos Fault is only about 32 kilometers (20 miles) in length? If so (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contentiont (c) Identify each and every person with knowledge of the factual basis or basea for this contention or on whose writings opinions, or testimony you base this contention; and (d) Identify each and every person. expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this i
contention. and as to each potential witness so identified provide the following information:
(i) State the substance of the facts and opinions to which you expect the witness to testifyr (ii) Summarize the factual and theoretical basis, as well as any other grounds for each opinion to which the witness is expected to testify.
INTERRCGATORY NO 23.
Do you agree that the OZD is located 7 kilometers 20
offshore as described by Dr. Gary Greene and Dr Michael Kennedy in their report to the NRC in August 19807 If you do not agree state the basis for your disagreement including all documents on which you rely and identify all expert witnesses on whom you rely and the substance of their expected testimony.
IN'ITRRCGATCRY NO 24.
Do you contend that the Cristianitos zone of Ceformation's structural relationship with the CZD is not the controlling geologic structure for the seismic design of SCNGS 2 and 3? If so (a) State each and every fact upon which you base this contentign; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this centention, or on whose writings. opinions - or uestimony you base this contention; and (d) Identify each and every person expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified l aprovide the following information:
1 (i) State the substance of the facts and opinions i
to which you expect the witness to testify; l
(ii) Summarize the factual and theoretical basis as well as any other grounds for each opinien to which the witness is expected to testify.
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Dated: February 17, 1981 By /s/ \ ,
, 0l sw R1Caafwa J. Wharrn of Attorney for Inpervenors F.O.E. IT AL.
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CERTIF;CATE OF SERVICE 19 I hereby certify,that en the 34th day of February, 1991, a copy of the foregoing INTERVENCR, FOE ET AL. FIF SET INTERRCGATCRIES TO SOUTHERN CALIFORNIA EDISCN, Attorney RICHARD J. WHARTCN, was served upon each of the folicwing by depositing in the United States = ail, first-class, postage prepaid, addressed as follcws:
Ivan W. Smith, Esq., Chairman Atomic Safety and Licensing Scard U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Cadet H. Hand, Jr., Member Director, Sodega Marine Laboratory University of California P. O. Box 247 Sodega Bay, California 92923 Dr. E=meth A. Luebke Atomic Safety and Licensing Scard Panel U. S. Nuclear Regulatory Ccmmission Washington, D. C. 20555 Iawrenca J. Chandler, Esq.
Office of the Executive Legal Director U. S. Nuclear Regulatory Ccmmission Washington, D. C. 20555 Janice E. Kerr, Esq.
J. Calvin Simpson, Esq.
Lawrence Q. Garcia, Esq.
California Public Utilities Ccmmission 5066 State Building San Francisco, California 94102 David W. Gilman Robert G. Lacy San Diego Gas & Electric Ccmpany P. O. Box 1831 San Diego, California 92112 l
l James H. Drake, Vice President Southern California Edisen Company P. O. Box 800 l 2244 Walnut Greve Avenue Rosemead, California 92770 23
John R. Sury, General Counsel Charles R. Kccher, Esq.
James A. Beoletto, Esq.
Southern California Edison Company P. O. Ecx 800 2244 Walnut Grove Avenue Rosemead, California 91770 Alan R. Watts, Esq.
Rourke & Woodruff California First National Bank Building 1055 North Main Street, Suite 1020 Santa Ana, California 92701 Ms. Lynn Harris Hicks GUARD 3908 Calle Ariana San Clemente, California 92672 Mr. Lloyd von Haden 2089 Foothill Drive Vista, California 92083 Atomic Safety and Licensing Scard Panel U. S. Nuclear Regulatory Cc= mission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U. S. Regulatory Commission Washington, D. C. 20555 David R. Pigott, Esq.
Chickering and Gregory Counsel for San Diego Gas and Electric Company and Southern California Edison Ccmpany Three Embarcadero Center, 23rd Ficor San Francisco, California 94112 and 2501 M Street N.W.
Suite 560 Washington, D. C. 20037 Phyllis M. Gallagher, Esq.
1695 West Crescent Avenue Suite 222 Anaheim, California 92801 b
DATED: February p , 1981
/s/ ) ,f RICHARD J. WFy TON, Attorney for Intervencrs FRIENDS CF THI EARTH, ET AL.
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