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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20211N0401999-09-0303 September 1999 Exemption from 10CFR50.44(d) & (E) to Remove Hydrogen Control Requirements from SONGS Units 2 & 3 Design Basis. Exemption Also Allows Licensee to Modify Emergency Operating Instructions to Remove Operator Action Requirements ML20206G6481999-04-27027 April 1999 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR for San Onofre Nuclear Generating Station,Units 2 & 3 ML13319B1321999-02-25025 February 1999 Transcript of 990225 Plant Unit 1 Decommissioning Meeting in San Clemente,Ca.Pp 1-84 ML20198Q8481998-01-15015 January 1998 Comment Opposing PRM 50-63A by Pg Crane Amending Petition for Rulemaking Re Use of Potassium Iode ML20198P7461998-01-11011 January 1998 Comment on Petition for Rulemaking PRM 50-63A Re Aftermath of Nuclear Meltdown at San Onofre NPP & Possibility of Nuclear Emergency Caused by Navy Proposed Mixed Waste Facility & Plans to Homeport Nuclear Carriers in San Diego ML20203F7541997-09-30030 September 1997 Transcript of 970930 Predecisional Enforcement Conference of Util in Arlington,Tx ML20210T0401997-08-29029 August 1997 Order Approving Application Re Corporate Restructuring of Enova Corp,Parent of San Diego Gas & Electric Co,By Establishment of Holding Company W/Pacific Enterprises ML20138K0721997-05-0202 May 1997 Comment Opposing Proposed Rule 10CFR73 Re Physical Protection of Plants & Matls ML20149H5221997-04-25025 April 1997 Amended Emergency Petition Re Degradation of Steam Generator Internal Tube Supports (Egg Crates),Based on 970417 Rept. Plant Will Not Be Able to Completely Withstand Major Seismic Event ML20091R5651995-08-31031 August 1995 Comment on Review of Revised NRC SALP Program.Recommends That SALP Assessment Process Either Be Abandoned or Justified as within Authority of NRC Through Appropriate Rulemaking ML20058E3351993-11-19019 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Categories of Personnel Listed in 10CFR50.120 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20046A9191993-07-19019 July 1993 Comment on Proposed Rules 10CFR170 & 171 Re NRC Fee Policy. Opposes Rule ML20045F8901993-07-0202 July 1993 Exemption from Requirements of 10CFR50.54 to Allow Approvals Provided for Therein to Be Granted by Certified Fuel Handler ML13312A6931993-05-21021 May 1993 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-206/93-14 & 50-206/93-06 ML20044D3551993-05-13013 May 1993 Comment on Draft Insp Procedure 38703, Commercial Grade Procurement Insp. Believes Appropriate Application of NRC Endorsed Stds to Critical Characteristics Remains Responsibility of Licensee Re Engineering Judgement ML20035A3521993-03-18018 March 1993 San Diego Gas & Electric Company Nuclear Facilities Qualified California Public Utilities Commission Decommissioning Master Trust Agreement for San Onofre Nuclear Generating Stations ML20035A3481993-03-18018 March 1993 San Diego Gas & Electric Company Nuclear Facilities Non-Qualified California Public Utilities Commission Decommissioning Master Trust Agreement for San Onofre Nuclear Generating Station ML13309A3601992-11-20020 November 1992 Exemption from Requirements of 10CFR50.54(o) & 10CFR50, App J Re Containment Leakrate Testing ML20087E1841991-12-31031 December 1991 Exemption Granted to Allow Duration of Next Requalification Cycle to Exceed 24-month Period Prescribed in Regulation ML20073M4081991-05-0707 May 1991 Exemption from Conducting Third Type a Test in 10 Yr Svc Period During Unit Shutdown for 10 Yr ISI ML20056B3671990-08-0909 August 1990 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements. Exemption Allows Handling & Storage of Irradiated or Unirradiated Fuel Assemblies at Station W/O Having Two Criticality Monitoring Sys ML20055F0001990-06-20020 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Operator Licenses. Proposed Rule Unnecessary & Can Only Adversely Impact Safe Operation of Nuclear Power Facilities by Negatively Affecting Morale of Licensed Operators ML13309A0881990-01-0202 January 1990 Order Confirming Licensee Commitments on full-term OL Open Items Re Installation of Reactor Vessel Level Indication Sys During Cycle 12 Refueling Outage Instead of Cycle 11 ML13316B4151989-07-13013 July 1989 Exemption from Technical Requirements of Section III.G.3 of App R to 10CFR50 Re Installation of Fixed Fire Suppression Sys in Pipe Tunnel ML20247L3791989-05-25025 May 1989 Transcript of 890525 Hearing in San Diego,Ca.Pp 150-278. Supporting Info Encl.Witnesses:A Keltz,A Talley,W Flynn, E Cone,N Hunemuller,J Zwolinski ML13316B3611989-05-10010 May 1989 Order Requiring Full Compliance W/Generic Ltr 82-28, Inadequate Core Cooling Instrumentation Sys, Including Addition of Reactor Water Level Monitor ML20245J6161989-04-25025 April 1989 Notice of Withdrawal of 840307 Application for Amends to Licenses NPF-10 & NPF-15,revising Tech Specs to Reflect Changes in Util Organizational Structure & to Incorporate New NRC Reporting Requirements ML13316B2731989-01-25025 January 1989 Exemption from 10CFR50,App J Requirements Re Containment Air Lock Testing ML20195G9881988-11-12012 November 1988 Requests 90-day Extension in Order to Submit Public Comment on 10CFR26 Re Fitness for Duty Program ML20195H1611988-11-12012 November 1988 Requests 90-day Extension of Public Comment Period for Proposed Rule 10CFR26 Re Fitness for Duty Issue for Nuclear Power Plant Workers ML20195H3221988-11-12012 November 1988 Requests 90-day Extension to Submit Comment on Proposed Rule 10CFR26 Re Fitness for Duty Issue ML20195H1751988-11-12012 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Unannounced Random Tests for Drug Use Should Not Be Part of Program ML20206D7531988-11-0808 November 1988 Requests Extension of Comment Period for 10CFR26 Re Random Drug Test Issue for Nuclear Power Plants.Period Provided Inadequate as Fr Notice Just Received ML20205D5691988-10-21021 October 1988 Memorandum.* Board Confirms Listed Schedule for Completing Case as Discussed W/Parties During 881018 Prehearing Conference.Served on 881024 ML20205D7301988-10-18018 October 1988 Transcript of 881018 Prehearing Conference in San Diego,Ca. Pp 1-62 ML20204F0291988-10-0606 October 1988 Comment on Proposed Rule 10CFR26 Re Drugs in Nuclear Workplaces ML20155D0011988-10-0303 October 1988 Exemption from 10CFR50.54(w)(5)(i) Requirements Re Onsite Property Damage Insurance Until Rulemaking Finalized But No Later than 890401 ML20155A1541988-10-0303 October 1988 Exemption from Requirements of 10CFR50.54(w)(5)(i) Re Onsite Property Damage Insurance Pending Completion of Rulemaking But No Later than 890401 ML20154D9891988-05-0909 May 1988 Order (Resolving Remanded Medical Svcs Issue).* Adequate Measures to Protect Public in Event of Radiological Emergency Taken.Served on 880510 ML20151P3771988-03-22022 March 1988 Stipulation & Proposed Order Re Remand of Medical Svcs Issue.* Stipulates That Parties Involved Reviewed Relevant Documentation Re Licensee Compliance w/10CFR50.47(b)(12) Including Licensee 870629 Submittal.W/Declaration of Svc ML13331B0091988-02-0808 February 1988 Requests Partial Exemption from Requirements of 10CFR171.15. Surcharge Levied in Addition to 10CFR171 License Fees Should Not Exceed Listed Amount ML20237B1861987-12-11011 December 1987 Transcript of 871211 Telcon in Bethesda,Md.Pp 19-24 ML20235R5441987-10-0101 October 1987 Notice of Appearance.* Certificate of Svc Encl ML20238F1691987-09-10010 September 1987 Notice of Withdrawal.* All Mail & Svc Lists Should Be Amended to Delete Author Name After 870921.W/Certificate of Svc ML20216J8751987-06-29029 June 1987 Licensee Submittal Re Emergency Medical Svcs (10CFR50.47(b)(12)).* Completed Arrangements for Offsite Emergency Medical Svcs,Including Annual Conduct of Emergency Drills Since 1981,discussed ML20206T1731987-04-20020 April 1987 Notice of Reconstitution of Aslb.* Sj Wolfe,Chairman & Ch Hand & Eb Johnson,Members.Served on 870421 ML20205R3881987-04-0101 April 1987 Notice of Appearance.* Ck Oconnell Will Appear on Behalf of Southern California Edison Co,San Diego Gas & Electric Co & Cities of Riverside & Anaheim,Ca ML20205R3571987-04-0101 April 1987 Applicant Status Rept on Implementation of Emergency Medical Procedures.* Applicant Close to Completing Emergency Medical Svcs Arrangements & Will Make Ordered Filing at Earliest Possible Time.Declaration of Svc of Mail Encl 1999-09-03
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20035A3481993-03-18018 March 1993 San Diego Gas & Electric Company Nuclear Facilities Non-Qualified California Public Utilities Commission Decommissioning Master Trust Agreement for San Onofre Nuclear Generating Station ML20035A3521993-03-18018 March 1993 San Diego Gas & Electric Company Nuclear Facilities Qualified California Public Utilities Commission Decommissioning Master Trust Agreement for San Onofre Nuclear Generating Stations ML20245J6161989-04-25025 April 1989 Notice of Withdrawal of 840307 Application for Amends to Licenses NPF-10 & NPF-15,revising Tech Specs to Reflect Changes in Util Organizational Structure & to Incorporate New NRC Reporting Requirements ML20205D5691988-10-21021 October 1988 Memorandum.* Board Confirms Listed Schedule for Completing Case as Discussed W/Parties During 881018 Prehearing Conference.Served on 881024 ML20235R5441987-10-0101 October 1987 Notice of Appearance.* Certificate of Svc Encl ML20238F1691987-09-10010 September 1987 Notice of Withdrawal.* All Mail & Svc Lists Should Be Amended to Delete Author Name After 870921.W/Certificate of Svc ML20216J8751987-06-29029 June 1987 Licensee Submittal Re Emergency Medical Svcs (10CFR50.47(b)(12)).* Completed Arrangements for Offsite Emergency Medical Svcs,Including Annual Conduct of Emergency Drills Since 1981,discussed ML20206T1731987-04-20020 April 1987 Notice of Reconstitution of Aslb.* Sj Wolfe,Chairman & Ch Hand & Eb Johnson,Members.Served on 870421 ML20205R3571987-04-0101 April 1987 Applicant Status Rept on Implementation of Emergency Medical Procedures.* Applicant Close to Completing Emergency Medical Svcs Arrangements & Will Make Ordered Filing at Earliest Possible Time.Declaration of Svc of Mail Encl ML20205R3881987-04-0101 April 1987 Notice of Appearance.* Ck Oconnell Will Appear on Behalf of Southern California Edison Co,San Diego Gas & Electric Co & Cities of Riverside & Anaheim,Ca ML20214C7741986-11-18018 November 1986 Notice of ASLBP Constitution.Jl Kelley,Chairman & Ch Hand & Eb Johnson,Members.Served on 861120 ML20100K3471985-04-0909 April 1985 Response to 850403 Order Re 850329 Motion.As Result of Guard Vs NRC Decision Remanding Case to Nrc,Motion Properly Addresses Full Commission.Proof of Svc Encl ML20126G8961984-10-0303 October 1984 Memorandum Discussing NRC Authority to Permit Immediate Restart.Order Issued in Aug 1982 Directing Unit Shutdown Pending Improvement of Seismic Safety Protections Does Not Constitute License Amend.Order within NRC Jurisdiction ML20205D8191984-05-0202 May 1984 Interim Decision,Concluding That Util Achieved Understanding with NRC Re Scope & Methods of Making Mods Required by NRC for Initial Restart of Facility Cost Effective ML20076C7741983-08-18018 August 1983 Comments Supporting ASLB 830812 Memorandum & Order Re Offsite Medical Svcs.Declaration of Svc by Mail Encl ML20079R1591983-06-17017 June 1983 Reply to Intervenor 830606 Briefs on Status of Medical Svcs Issue.Further Hearings Unjustified Since Commission Already Ruled on Adequacy of Onsite Medical Svcs.Declaration of Svc Encl ML20071P8761983-06-0606 June 1983 Comments Re Offsite Medical Svcs,Objections to Applicant Motion to Augment Record & Request for Hearing & Proposed Licensing Condition.Adequate Arrangements for Medical Svcs Not Met.Further Hearings Required ML20023D1131983-05-16016 May 1983 Position Re Commission 830405 Memorandum & Order CLI-83-10 on Offsite Medical Svcs.Util Provided Necessary Level of Medical Svcs for General Public.Declaration of Svc Encl ML20063P8761982-10-13013 October 1982 Position on ASLB Request for Commission Direction on Whether to Proceed to Hearings.Further Hearings on Medical Svcs Issue Should Be Deferred Pending Commission Determination & Issuance of Guidance.Declaration of Svc Encl ML20027C4031982-10-13013 October 1982 Brief Re Required Medical Svcs for General Public in Response to Commission Order CLI-82-27.Agrees W/Aslb Re Definition of Contaminated Injured Individuals Per 10CFR50.47(b)(12).Certificate of Svc Encl ML20063P8941982-10-13013 October 1982 Brief Re Certified Questions on Definition & Implementation of 10CFR50.47(b)(12) Re Medical Svcs.Applicant Interprets 10CFR50.47(b)(12) as Applying to Individuals Who Are Contaminated & Traumatically Injured.W/Declaration of Svc ML20063M3201982-09-0303 September 1982 Response to ASLB 820806 Memorandum & Order Re Further Proceedings on Adequacy of Offsite Planning for Medical Svc. Declaration of Svc Encl ML20063M3141982-09-0303 September 1982 Response to ASLB 820806 Request to Address Questions Re Necessity for Further Hearings on Issue of Medical Arrangements for General Public in Offsite Emergency Plans. Certificate of Svc Encl ML20055B9751982-08-0606 August 1982 Confirmation of Emergency Preparedness Items,Transmitting DB Matthews Affidavit Certifying That Siren Sys Performs in Accordance W/Tech Specs.Issue of Ingestion Pathway Emergency Planning Zone to Be Addressed Later ML20053E9961982-06-0707 June 1982 Comments on Adequacy of Existing Public Notification Sys in San Clemente,Ca Per ASLB 820514 Order.Addition of NOAA Type or Cablevision Override Sys Is Redundant & Unnecessary.No Items Raised by San Clemente Deserve ASLB Involvement ML20053E0431982-06-0101 June 1982 Notice of Appeal of ASLB 820514 Initial Decision ML20053A5451982-05-21021 May 1982 Comments on Immediate Effectiveness of ASLB 820514 Initial Decision.Decision Should Not Be Given Immediate Effectiveness.Noted Deficiencies Should Be Corrected. Certificate of Svc Encl ML20053A4281982-05-21021 May 1982 Comments Supporting ASLB 820514 Initial Decision Authorizing Full Power Operation.Certificate of Svc Encl ML20052G8171982-05-13013 May 1982 Advises That Applicants Consider ASLB 820316 Order to Provide 5 Days Notice of Achieving Criticality to Be Moot & Will Not Be Providing Such Notice.Certificate of Svc Encl ML20050C0161982-04-0202 April 1982 Response to Aslab 820316 Order to Inform of Criticality 5 Business Days in Advance.Criticality Will Be Achieved in mid-May.To Commence Low Power Testing,Initial Decision on Emergency Preparedness Issues Needed.W/Declaration of Svc ML20039D7091982-01-0404 January 1982 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20039B7581981-12-21021 December 1981 Response to ASLB 811210 Order,Commenting on Earthquake Swarm.Applicants Repts Should Not Be Included in Record. Repts Being Reviewed to Determine If Cause Exists to Reopen Record.Proof of Svc Encl ML20039B5351981-12-15015 December 1981 Comments on Earthquake Swarm Per ASLB 811210 Order.Applicant Rept Is Part of ASLB Record.Repts of NRC & Intervenors Should Also Be Included in Record If Applicant Rept Included.Certificate of Svc Encl ML20011A7851981-10-29029 October 1981 Corrected Certificate of Svc Certifying NRC Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision Permitting Fuel Loading & Low Power Testing at Unit 2 & Proposed Transcript Corrections,On 811029 ML20031G1211981-10-13013 October 1981 Supplemental Certificate of Svc of Exhibits Admitted Into Evidence on Emergency Planning Contentions ML20005B9481981-08-28028 August 1981 Notice of Change of Address of co-counsel CE Mcclung. Certificate of Svc Encl.Related Correspondence ML20010D1851981-08-17017 August 1981 Second Set of Direct Testimony & Accompanying Exhibits on Emergency Planning Contentions.W/O Encl.Declaration of Svc Encl.Related Correspondence ML20030B8821981-08-17017 August 1981 Notice of Appearance in Proceeding ML20010D1661981-08-17017 August 1981 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20030B8571981-08-12012 August 1981 Forwards Jr Sears Testimony on Guard Emergency Planning Contentions 1.2.E,2.I,2.J & 2.K ML20010B4151981-08-10010 August 1981 Forwards NRC 810806 Testimony on Guard Contentions 2.A,2.B, 2.C,2.D,2.F,2.G & 2.H Re Emergency Preparedness ML20030B9131981-08-0505 August 1981 Submits Concerns for Establishment of Temporary & Permanent QA Program for Normal Form Type B Radioactive Matls ML20009H2181981-08-0505 August 1981 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20105D0811981-08-0404 August 1981 Comments W/Respect to ASLB 810729 Order Raising Issue Concerning Earthquakes & Emergency Planning.Not Necessary to Consider Unlikely Earthquakes in Excess of Sse.Affidavit of B Grimes Encl ML20030C3821981-07-29029 July 1981 Rept on Limited Appearance of DW Phifer & Alleged Geologic Features,Camp Pendleton,Ca,Jul 29,1981. Aperture Cards Are Available in PDR ML13303A2101981-07-23023 July 1981 Order of Presentation of NRC Witnesses.Witnesses on Contention 1 Will Be Made Available at Same Time as Witnesses on Contention 4.Certificate of Svc Encl ML20105D2901981-06-22022 June 1981 NRC Views Re Questions Posed by ASLB on Emergency Planning. Effects of Moderate Earthquake Should Be Considered in Offsite & Onsite Planning.Affidavit of Bk Grimes Encl ML20005A5101981-06-19019 June 1981 Notice of Appearance in Proceeding.Proof of Svc Encl ML20005A5031981-06-19019 June 1981 Notice of Appearance in Proceeding.Proof of Svc Encl ML20005A4631981-06-19019 June 1981 Notice of Appearance in Proceeding.Proof of Svc Encl 1993-03-18
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DCtMETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'A1 DEC 21 N0:46 ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES'
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~ T r.E' James L. Kelley, Chairman 2L:'
Elizabeth B. Johnson Cadet H. Hand, Jr.
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In the Matter of
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Docket Nos. 50-361-OL
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50-362-OL SOUTHERN CALIFORNIA EDISON
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COMPANY, _ET _AL.
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(San Onofre Nuclear Generating
)
December 15, 1981 9
g Station, Units 2 and 3)
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l Dec COMMENTS BY INTERVENORS ON EARTHQUAKS SWARM 4
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SUBMITTED PURSUANT TO BOARD ORDER hhd.
DATED DECEMBER 10, 1981 9\\
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The Atomic Safety and Licensing Board (hereinafter referreM'F as "ASLB") by telephone conference and Board Order dated December 10, 1981, issued a call to the parties to submit additional comments and information regarding a swarm of earthquakes occurring near the
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San Onofre site on November 6 - 9, 1981.
By way of preface to these comments it must be pointed out that Intervanors Bill Carstens, F.O.E.,
GUARD, and their attorneys of record have not, as of the morning of December 15, 1931, received a copy of the Applicants' reports dated November 18 and November 30, 1981, concerning the swarm of earthquakes.
The Board in its order states that by memorandum dated December 6, 1981, the Staff transmitted such documents "to the Board and parties".
While not disputing that such documents may have been sent on such a date, I,
Richard J. Wharton, Attorney for Intervenors, p503
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Carstens et al. have not received such documents nor, to my knowledge, have any other Intervenors as of 10 a.m. on December 15, 1981.
Intervenors, Cartsens et al. have received the Staff report dated December 11, 1981, sent by cover letter by Lawrence Chandler.
Attorney for Carstens et al. is leaving on December 16, 1981, for a long ago scheduled family'Christraas in Florida.
Intervenors F.O.E.
et al. is submitting these comments without the benefit of review of the report of Applicants.
Intervenors. Carstens et al. submits the following comments as required by the Board in their order of December 10, 1981.
1.
THE BOARD INVITED THE INTERVENORS AND STAFF "iO COMMENT ON THE TECHNICAL SIGNT.FICANCE OF THE EARTHQUAKE SWARM AND THE MERITS OF THE APPLICANT'S REPORTS.
Intrervenors, Carstens et al. have commitments from Dr. Brune and others at Scripps Institute of Oceanography to prepare an inde-pendent review of the events and using sophisticated scientific methods to locate the epicenters.
This is being done as a public service by Scripps and none of the participants, (who will be named in the report) are being compensated in any way.
This report will be sent by Dr. Brune and others directly to the Nuclear Regulatory Commission'and the parties.
Intervehars will receive the report in the same manner and time as the parties, and do not know the contents of such report as of this writing and have agreed not to review or influence the report before it is sent to this board and the parties.
As of this writing Intervenors do not have a copy of the Appli-eent's report.
I will be requesting that the Applicant send a copy directly to Scripps Institute of Oceanography in care of Dr. James Brune.
If that report is received in sufficient time, an evaluation -
of the merits of the Applicant's report will be submitted.
2.(a)
SHOULD THE 7.PPLICANT'S REPORT BE INCLUDED IN THE RECORD ON SEISMIC ISSUES?
i It is presumed by Intervenors that the November 18, 1981 Board notification of the seismic events of November 6 - 9, 1981, are part of the record.
The Applicant's report is in response to the Board notification.
As a result of the Board notification and the Appli-cant's response, this hearing board has requested further comments from all of the parties.
It is Intervenors position that the fundamental requirements of due process require that if Applicant's response to the Board notification is included in the record, then the reports of the Staff and the Intervenors must be included in the record.
Intervenors submit that the cccurrance of 20 seismic events on the CZD is relevant new evidence which must be considered by this board and that all of the evidence from all of the parties must be considered and made part of the record.
The record in the hearing ref]scts that it was assumed by the Applicants and the Staff that the recently discovered CZD was not a " capable fault" under Nuclear Regulatory Commission regulations.
This board must determine whether the CZD is in fact a capable fault and more specifically whether it experienced movement at or near the ground surface at least once within the past 35,000 years, or has a structural relationship to a capable fault.
(See 10 C.F.R.
Part 100, Appendix A III).
The Staff report on the recent earthquakes concludes that "the earth-quakes occurred in an area where the OZD and the projected CZD are near each other (1.5 km apart as depicted by Greene and Kennedy, Geologic Structure Maps - San Onofre Offshore, SONGS 2 and 3 SER.
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Appendix F)".
. The Staff report locates the events at the projected merging of the CZD and OZD.
This is one of the areas in which there was a DATA VOID and about which more information is required.
The board should admit all new relevant evidence about.this recent seismic activity in-cluding the Applicant's report, the Staff report and the Intervenors' report so that the record may be complete.
2.(b)
WHICH OF YOUR PROPOSED, FINDINGS NOW PENDING BEFORE THE BOARD WOULD BE AFFECTED BY REOPENING THE RECORD FOR THIS AND POS3IBLY OTHER INFORMATION ABOUT THE EARTHQUAKE SWARM?
The following proposed findings of Intervenors would be affected by reopening the record:
1.
Finding 150 The Nuclear Regulatory Commission Staff SER p. 2-46 states...,
"The age of most recent faulting along the CZD is unknwon."
This new evidence would establish the most recent faulting along the CZD at 4 weeks ago!
2.
Finding 151 "The seismic reflection data reviewed show that a fairly continuous fault zona extends south to southeastward offshore from San Onofre to within 1 kilometer of the OZD, where a projected connection is possible."
This new evidence indicates earthquakes at the projected connection of the CZD and the OZD.
It is proof of existence and activity of the CZD in that area previously referred to as a data void.
It also indicates that movement on the OZD is accompanied by movement on the CZD. l
3.
Finding 152 states that the locacion of the connection of the OZD and CZD is approximately 16 kilometers southeast of the site.
This is the approximate location of the events occurring on November 6 - 9, 1981, and indicates that the movement was on the CZD.
4.
Finding 154 "Mr. Cardone also agrees that it is possible that the C2D may be a branch of the OZD (tr. p. 6495, line 14, p. 6496 line 9).
The fact that recent earthquakes occurred on either the CZD or OZD at their projected point of connection indi-cates that the CZD is in fact a branch of the OZD.
5.
Finding 160 All of this finding is affected but most importantly the request of Kennedy and Davis to the NRC that:
"We feel that it is important that the Applicant assess the nature of this structural relationship and the possibi-lity that the Cristianitos Fault and its presumed of f-shore extencion may' represent a secondary fault in a wrench system including the OZD. "
6.
Finding 161 states that NRC Staff witness, Thomas.Cardone tastified that the NRC has not requested any research of the Applicants since the NRC received the
- eene and Kennedy report and the Davis and Kennedy letter.
This new evidence clearly shows that such assessment as requested by Davis and Kennedy is necessary and the possibility that the CZD is a secondary fault in a wrench system must be investigated instead of merely assuming that l
the CZD is inactive and of no consequence.
This new evidence clearly indicates that the CZD is a branch of the OZD, and may be part of a wrench tectonic system.
7.
Finding 162 concludes that the NRC has not requested the Applicant or U.S.G.S.
to perform any research regarding whether movement on the OZD could be accompanied by move-ment on the CZD.
This new evidence indicates that movement on the OZD could be accompanied by movement on the CZD.
8.
Finding 163 Y
NRC witness Cardone sums up the Applicant and Staff's entire case on the CZD by stating:
"Movament on the CZD for at least 120,000 years has not been accompanied by movement on the CZD.
Therefore, we conclude the CZD is noncapable."
4 This new evidence indicates that movement on the OZD has been accompanied by movement on the CZD as recently as 4 weeks ago.
9.
Findings 164, 165, 166, 167, 168, 169 and 170 all refer to the age dating techniques used by Applicant in determining the age of the last movement on the CZD.
All methods used by Applicant and Staff are speculative and untested and i
not based ~on observed data.
Evidence of the recent movement on the CZD is the best evidence that the fault is capable under 10 C.F.R.
Part 100.
The hearings should be reopened with the assumption that the CZD is capable and structurally related to the OZD and that raovement on the OZD could be reasonably expected to
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be accompanied by movement on the CZD with the knowledge hhat the OZD ;1as been mapped to within 4 kilometers of the l
plant.
Further investigations should be made of the C D in the area presently marked as DATA VOIDS on the map of Greene and Kennedy to determine exactly how far onshore they ex-tend and whether the CZD is structurlly related to the ABCD features.
10.
Findings 172, 173, 174, 175, 176, 177, and.178 all point out that the ABCD features (faults) are all structurally related to the Cristianitos Zone of Deformation as is the Cristianitos fault (see finding 160, 159, 156 and 138).
Since the Applicant and Staff have assumed that the CZD is inactive they have totally ignored the relationship between all of these faults.
Since all of these faults are close to or directly under-neath the plants, the Applicants and Staff have failed to meet the requirements of 10 C.F.R. Part 100, Appendix A Section J which requires detailed investigation to detsr-mine the need to design for surface faulting (See Conclusion of Law D2) 11.
Conclusion of Law D The new evidence supports the entirety of conclusion of Law D in that the Applicants have failed to conduct investiga-tions required by 10 C.F.R. Part 100 Appendix A, Sections II, III(j), IV(a) and (B), V(b) and VI(b) in that they have failed to determine the structural and tectonic relation-ships between the Cristianitos Zone of Deformation and the -
Offshore. Zone of Deformation.
The new evidence belies 1
the Applicants and the NRC Staff's expedient.and simplistic conclusion that the CZD is noncapable, thereby precluding any further investigation.
The record clearly shows that i
no further investigation of the structural and tectonic, significance of the CZD was performed after its discovery in August 1980.
It is significant that the discovery and report on the CZD was the only truly independent report prepared for the NRC Staff in these proceedings.
It is also sicnificant that its recommendations were ignored and that its significance was quickly explained away by the Applicants and Staff by simply stating that the CZD was noncapable and not worthy of further consideration.
This new physical evidence cannot be ignored nor can the obvious be continually explained away.
This new evidence necessitates that further investigations be performed to meet the requirements of 10 C.F.R., Part 100, and that the hearings be reopened to determine whether these requirements have been met.
2.(c)
DOES THE EARTHQUAKE SWARM CONSTITUTE GOOD CAUSE TO REOPEN THE RECORD FOR FURTHER HEARINGS?
According to the NRC Staff report,the earthquakes occurred in an area where the OZD and the projected CZD are near each other (1.5 km apart as depicted by Greene and Kennedy).
This is the location of the DATA VOIDS on the Greene and Kennedy map and the area 4
where Greene and Kennedy postulate that the CZD merges with or truncates the OZD.
_g_
a l
The record shows that this is a critical area about which little is known.
The ramifications of movement in this area are significant.
If the earthquakes were on the CZD it would by definition mean that the CZD is a capable fault within the meaning of 10 C.F.R. Part 100 Appendix A and that this fault has been mapped to within 4 kilometers of the plant and may very well extend under the plant itself as evidenced by the A and B features.
This raises the question of the possibility of surface faulting underneath the plant which under 10 C.F.R.
Part 100 Appendix A V 2b must be fully investigated.
Surface faulting under the plant is the most hazardous seismic risk possible since no structure can be built to withstand surface faulting.
Hearings are required to fully adjudicate and determine this most serious issue.
If the movement was on both the OZD and the CZD as indicated by the Staff report, such movement would establish the CZD as a capable fault under 10 C.F.R. Part 100 Appendix A Section II g3 in that it demonstrates a structural relationship such that movement on one fault could be reasonably expected to be accompanied by covement oa tite other.
It is difficult to perceive how the NP.C Staff can conclude that the swarm of earthquakes occurred in the vicinity of the OZD and the CZD where these two zones are very close to each other and from this conclusion state that this new information which indicates recent movement on the CZD does not cause the Staff to reconsider their position regarding the capability of the CZD.
Since there is no explanation for this quantum leap in logic, the hearing should be reopened so that Intervenors may cross-examine the authors of this report as to the scientific basis for their
conclusion.
The basis for their conclusion cannot be determined from the report.
As of this. Writing Intervenors have not had an opportunity to review the Applicant's report.
Therefore Intervenors cannot comment on the need to cross-examine on that report.
However, since the issue of the capability of the CZD is of such importance in this case it would appear incumbent upon the board that any evidence received regarding movement on this fault 4
be subject te full cross-examination so that the opinions of the authors and the methods used may be fully evaluated.
I Respectfully submitted, bM I T) l$$l
},,
RICHARD J.
W RTON Attorney for ntervenors j
Carstens et al.
I i
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cco<m. r.
us, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO I
DEC 21. ymS4 BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD UCQDiNG g
. C..
ERANCH In the Matter of
)
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SOUTHERN CALIFORNIA EDISON COMPANY,
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Docket Nos. 50-361-OL
--ET AL.
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50-362-OL
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(San Onofre Nuclear Generating Station,)
Units 2 and 3)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " COMMENTS BY INTERVENORS ON EARTHQUAKE SWARM SUBMITTED PURSUANT TO BOARD ORDER DATED DECEMBER 10, 1981" in the above-captioned proceeding have 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 15th day of December 1981:
Kelley, Esq., Chairman David R. Pigott, Esq.
Administrative Judge Samuel B.
Casey, Esq.
Atomic Safety and Licensing Board John A. Mendez, Esq.
U.S. Nuclear Regulatory Commission Edward B. Rogin, Esq.
Washingotn, D.C.
20555 Of Orrick, Herrington &
Sutcliffe Dr. Cadet H. Hand, Jr.,
A Professional Corporation Administrative Judge 600 Montgomery Street c/o Bodega Marine Laboratory San Francisco, CA 94111 University of California P.O. Box 247 Alan R. Watts, Esq.
Bodega Bay, CA 94923 Daniel K. Spradlin, Esq.
Rourke & Woodruff Mrs. Elizabeth B.
- Johnson, 10555 North Main Street Administrative Judge Suite 1020 Oak Ridge National Laboratory Santa Ana, CA 92701 P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Richard J. Wharton, Esq.
University of San Diego Janice E. Kerr,' Esq.
School of Law J. Calvin Simpson, Esq.
Alcala Park Lawrence Q. Garcia, Esq.
San Diego, CA 92110 California Public Utilities Commission 5066 State Building Mrs. Lyn Harris Hicks San Francisco, CA 94102 GUARD 3908 Calle Ariana San Clemente, CA 92672 4
O Charlee R.
Kocher, Esq.
A.
S. Carstens James Beoletto, Esq.
2071 Caminito Circula Norte Southern California Edison Co.
Mt. La Jolla, CA 92037 2244 Walnut Grove Avenue Rosemead, CA 91770
- Atomic Safety & Licensing Board Panel David 'd. Gilman U.S. Nuclear Regulatory Commission Robert G. Lacy Washington, D.C.
20555 San Diego Gas & Electric Co.
P.O. Box 1831
- Atomic Safety and Licensing San Diego, CA 92112 Appeal Board Panel U.S. Nuclear Regulatory Commission Phyllis M. Gallagher, Esq.
Washington, D.C.
20555 1695 West Crescent Avenue Suite 222
- Secretary Anaheim, CA 92701 U.S.
Nuclear Regulatory Commission ATTN:
Chief, Docketing & Service Charles E. McClung, Jr.,
Esq.
Branch Fleming, Anderson, McClung Washington, D.C.
20555
& Finch 24012 Calle de la Plata Lawrence Chandler, Esq.
Suite 330 Deputy Assistant Chief Hearing Laguna Hills, CA 92653 Counsel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Richard J. Wna ton Attorney for I tervenors I