ML20114E988
| ML20114E988 | |
| Person / Time | |
|---|---|
| Site: | Bodega Bay |
| Issue date: | 03/29/1962 |
| From: | Mccool W US ATOMIC ENERGY COMMISSION (AEC) |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML093631134 | List:
|
| References | |
| NUDOCS 9210120331 | |
| Download: ML20114E988 (67) | |
Text
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Sdlf in UNCLASSIFIED AEq-R %62 O).
March 29, 1952 COPY Nv.
\\
ATOMIC ENERGY ColetISSION
SUMMARY
OF HEARIMO MORE CALIFORNIA PUBLIC UTILITIES COi4115SION ON PACIF10 GAS AND EIECTRIC APPLICATIGTT5R CERTIFIC ATION OF EODEGA BAY NUCLEAR PO'#E!i PLANT Ncte by the Secretarf The Director of ReEulation has requested that the attached su:::marv of the hearing before the California Public Utilities Commission on Pacific Gas and Electric Company I.pplication for certification of Ibdega Bay Nuclear Power Plant be circulated h
for the information of the Con::nission.
W. B. McCool Secretary DISTRIRfTION COP' UO.
Secretary 1
Com.insioners 2 - 6,61 Dir. of Regulation 7
General Manager 8-9 Deputy Dir, of Regulation 10 9
Deputy Gen. Per, 11 Asst. Gen. Mgr.
12 Asst. GM-Plans & Prod.
13 Asst. Gen. Mgr. R&D 14 Asst. Gen. Mgr. Adm.
15 General Counsel 16 - 20 Compliance 21 - 27 Con 6r. Liaison 28 C-Ind Participation 29 Cp Public Information 30 - 31 r
Insp'c etion
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/
Licensing & Regulation 33 - 34
[A/
V Operational Safety 35 Operations Analysis 36 Radiation Standards 3
Reactor Development 33 750 Manager, Naval Reactors 51 San Francisco Oprns.
52 D. C. Ortice 53 - 55 Secretariat 56 - 60 J
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UNITED STATES ATOMIC ENERGY ColctISSION-g.
i furch 10, 1962 i
Joseph Fouchard, Division of Public TO q
Information, Headquarters i
i FROM
- Rodney L. Southwick, Assistant to the
!!anager for Pu'olic Information, SAN SUEJECT : SUTC4ARY OF HEARIN3 BEFORE CALIFORNIA PUC ON PG AND E APPLICATION FOR CERTIFICATION OF DODEGA BAY-NUCLEAR POWER PLANT i
j SYM20L : III:RLS i;
On March 7, 8 and 9, 1962, hearings were conducted by 4
Examiner Leonard S. Patterson of the-California Public Utilities Com".tission, on the application of Pacific Gas and Electric Co. for l
a certificate to build a 325 MW nuclear power plant at Bodega Bay, California. The plant would be financed by PG and d, with General l
Electric furnishing a boiling water reactor, at an estimated cost j
of $61,000,000 exclusive of transmission costs ($64,185,000 in-cluding transmission and step-up).
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As shown in " Estimated Cost of Power from Bodega Bay Plant",
PG and E figures its cost of power at the plant, at 90 percent i
l capacity, at 5.5 mi:.le/kwh and the average delivered cost at 6.2 mills /kwh. Other figures are listed for other capacity levels.
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The applic ation was supported by the Sonoma County Labor and i
Industrial Board; Sonoma County Industrial Development Board;
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Sonoma County Harbor Commission; Sonoma County Planning Commission; Sonoma County Zoning Commission; Sonoma County Board of Super-d
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visors; and Sonoma County Central Iabor Council. In addition l
Alexander Grendon, Coordinator of Atomic Energy Development and j
. Radiation Protection,' appeared in favor of the application.
)
However, a representative of the California Fish and Game
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Department (Harold Eissell) requested that as part of the certification the Public Utilities Commission (PUC) include a i
i list of conditions relating to marine studies and controls. This j
was opposed by-PG and E, although it was agreed that the Depart-ment's requirements would be met including a two year pre-operational marine study -in the Bodega Head area.
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Such a study, probably under Dr. Ernest Salo of Humboldt State College, would.be used to show whether slight amounts-of radioactivity in discharged water would have a significant effect 1
i-on the biota, and would serve as a base for'the operational period, i
The two-year period was requested to take into consideration any j-changes in cycles and to allow for changes caused by fallout.
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Opponents of the application were an attorney representing Mrs. Rose--Gaffney who owns 64 acres of land sought by PG and E in a condemnation proceeding; Harold Gilliam, San Francisco author
.and newsman; Ned Chapin, Menlo Park, an electronics engineer; and i
Peter William Eubanks, a youngster and part time student in San Francisco School of-Fine Arts.
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Chapin, however, limited hiu criticism to the proposed transmission lines which would cross frc? D°a Head to the mainland cdvocating that such lines be pi:ced underground, the cost of which was estimated by PG and E at $5,000,000.
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PG and E witnesses stated during the proceedings that four nuclear power units ultimately were planned at Bodega Head, but no decisions had been made as to the type of reactors to be used at this time. Actually the plans designs and siting for various, fa0ilities including transmission lines appeared to be approxima.
tions and preliminary.
Access to Bodega Head was the subject of considerable discussion. Although presently the land is privately owned by FG and E, Mrs. Gaffney and others, there is no access to the public. In addition the head is located on steep palisades ranging up to 200 feet high of sheer perpendicular rock. Currents and tidal action around the head are extremely strong and make boating and swimming at the base impossible.
Bodega Head is located just west of the San Andreas fault zone, but P0 and E witnesces testified that the granitic nature l
of the head and construction of earthquake resistant structures would prevent any shock damage. The reactor itself, as presently planned, would be underground on the east, or bayside, of Bodega Head. The water discharge area is on the west or oceanside.
Water discharge from the plant for one unit would be at the rate of 250,000 gallons per minute. For four units this would be 1,000,000 gallons per minute, it was testified.
PROCEEDINGS The hearing was opened by the PG and E attorney (Morrissey) with a review of the available power sources in the north San Francisco Eay Area. Those counties considered immediate service area include Sonona and Marin, and parts of Napa an; Mendocim, all north of the Bay Area.
Morriscey sunmarized PG and E's interest in nuclear energy since 1951 in participation with other utility companies and reacter manufacturers, noting the PUC approved the Vallecitos Boiling Vater Reactor in 1957; Humboldt Eay 60 FM reactor in 195); and PG and E participation in the Dresden 180 Mw plant.
l Operation at Eodega Bay of the 325 MW unit being considered at the hearing is scheduled for 1956. The 5.5 mill rate, he explained, was based on a second core to be installed after three and a half years operation of the first core (which really means Eodega Bay would have power at that estimated rate possibly in 1970). The average power cost at plant in August 1950 for the PG and E system was about 8 mills /kwh.
At this point PUC staff counsel (Bricca) stated persons appearing at the hearirs would be given opportunity to express their views and that concern of staff counsel was with public safety and the economic feasibility of the reactor plant. He added that PG and Eis presentation had been sketchy, but Morrissey objected saying the company was just beginning its presentation.
An acsistant State Attorney-General (Ralph Scott) then stated that the concern of the State Fish and Game Department <
I UNOLASSIFIED f'
i over access to fisheries, the harbor of refuge at Dodega Bay, and proposed leasing of certain tidelands by PG and E from Sonoma County.
(Purpose of leasing is for PG and E to construct an access road from the mainland around the inside of the Head to the plant site and for transmission lines over Doran Beach to the mainland. Efforts are being made to obtain Corps of Engineers approval for this. PG and E would build.
the road and give it to the County for maintenance. In return PG and E would get easements for the lines.)
Scott summarized his testimony by saying the State wished to rule on the si::e of screening for the water intal:e (previously done at another PGE plant); and to have PGE arrange acces.3 to various areas on the Company property on Bodega Head; assess the mixing characteristics of ocean water for the outfall; curvey marine ecology; and conduct a collection of marine organism for a two-year period prior to opera'. ions.
7 J. Dean Ucrthington, Chief Civil Engineer for PGE was the first witness. He said application to AEC for a construction permit would be made next July or August, and said PGE expected to purchase by condemnation a 64-acre tract (owned by Mrs. Gaffney) north of present PGE holdings. He indicated the tract was necessary to comply with proposed AEC site criteria.
Selection of Dodega Head was based on studies made since 1952 to establish power generating sites in the north Bay Area to meet increasing residential and industrial demands for electric energy.
He described the proposed plant as having 1,008 M.T thermal capacity and said although they counted on 325 ad electric output, he was hopeful the plant could produce about 350 Kd on the basis of General Electric estimates. He noted the site was suitable for four units.
Consultations on the a'arthquakes stresses and patterns in the area and on suitable conutruction was discussed with Don Tocher, University of California seismologist; Dr. William Ouaide; and Dr.
George W. Hauser, Cal Tech structural engineer.
o Test borings have been made and criteria established for plant con::truction. The foundation would be in solid granite and the proximity of the San Andreas fault ::ene was not considered hazardous.
Power frca bodega would be transmitted 32 miles to Ignacio substation on the mainland. Total plant cost was estimated as of May, 1961, at $64,153,000.
It was conceded that the cost of materials, labor and design changes and improvements might increase the total. Fuel costs, however, were considered by Worthington as likely to be stable or possibly cheaper in the future.
In explaing the " equilibrium core" listed by PGE in the exhibits bearing on costs, Worthington testified this really rueant the cecond core. He stated the first core was not typical of succeeding cores which would have lower enrichment and that the second would be more typical of cores used later. He testified 90 percent of capacity was expected. He explained "use charges" were those charged by the AEC for fuel and stated that $9.50 per gram of Pu for buy-back was listed because the AEC-guaranteed price of $30/ gram expires in 1953.
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UNCLASSIFIED f-from the reactor, Worthington claimed reactors were relatively in describing the factor of 90 percent of capacity expected simple compared with complex conventional systems. Worthington stated conventional fuel costs were based on. oil at $2 35/ barrel.
He forecast a further decrease in costs for nuclear plants both for capital costs and fuel costs and, conceding that capital costs would also be reduced for conventional plants, he asserted that fossil fuels were 111:ely to go up, offsetting the capital cost improvement and that the advantage would be increasingly in~
favor of nuclear plants in the future.
At this point public witnesses were permitted to testify, many of them representing county, public and private organizations in support of the application. Howe"er, S. Lennart Cedarborg, attorney for Mrs. Gaffney (landowner at Bodega) voiced opposition on the grounds the plant would ruin the scenic value of Bodega Head, would endanger the community and deflate real estate values, lower the water level for yachting and boating, and that plant and transmission lines would be unsightly. He suggested use of an alternate site in NAPA County (exact location not given).
I Worthington, resuming the stand, in reply to questions said the intake for water would be on tidalands and M'at permission had been requested to build intake facilities. At
'es,- Worthington said, would be permitted on the planned road ao far at the
" boundary area", but AEC will have something to say about this.
But, Worthington said, he did not expect AEC to block such access.
The main powerplant area would be closed to the public as are conventional plants.
I It was noted here that PGE would be guided
= 20 standards to be published later, it would be Company polics co open lands i
adjacent to plants (as done in the mountain country) after operating experience, and provided restrictions permitted such i
opening. It was indicated that PGE would be willing to cooperate J
in making access to some areas of the Head svailable.
Worthington, replying to questions, said a monitoring program was planned of fish and wildlife as well as the ocean and a study j
of marine ecology and ocean currents would be made, h
There was a censiderable amount of discussion on interties 1
with Southern Cal Edison and the proposed Canadian pool and the Northwest intertie which do not bear directly on the nuclear plant.
l In addition to furnishing north Bay Areas, during off-peak periods. Bodega Bay would be used to feed the PGE systems, 3
Worthin5 ton said, Earthquake and seismic effects were discussed in detail.
Briefly, Worthington smted that PGE provides a 20 percent factar 1
in construction for conventional power plants, but for Bodega Bay expected to have a 33 percent factor for the main buildings
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related to the plant except for the reactor itself which would be allowed a 50 percent factor. The site is one mile from the l
San Andreas fault zone. Tocher and Quaide are preparing geological and seismic reports on the site. Worthington stated that even at 15 miles from the fault zone, effects would be caly slightly less than those to be expected at the present site.
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4 UNCLASSIFED in Willard H. Nutting, Senior Mechanical Engineer for PGE, j -.
described the operation of a. nuclear reactor.and listed the.
boiling water reactors operating, building or-planned.- In his 3
description of the detailed components he noted that the reactor vessel was designed with an inside diameter of 181 inches, height i
i of 51 feet, 6 inches, and thici: ness of 7 inches. Total weight -
336 tons. He estimated fuel replacement shut-down time at 7 to j
10 days. He said the pressure suppression containment for. Bodega would be similar to Humboldt Bay. He answered detailed questions 4
i about the types of waste, their handling and the types of radio
- nuclides involved. All AEC regulations would be complied with, j
he said, i
In su e.ary, hign level uastes would move with used fuel elements to processing plants; solid wastes to be handled by A*.C-licensed disposal firms; liquids to be retained, demineralized and concentrated for disposal in compliance with AEC and North Coast Pollution Control Board regulations; gases to be discharged j-to the stack under control wJ th offsite monitoring.-
He noted, personnel would be trained and operators licensed j.
by the AEC. So far 31 PGE operators have been licensed by AEC l
Vallecitos, he said, le emphach:ed that nothing " novel or untried" would be placed i
in the Bodega plant. Sampling operations nuld be emntinued after operations begin in compliance with AEC, State Healv.: and Pollution Centrol Board requirements. He described AEC licensing require-ments and review.
3 Dr. Ernest Salo, Humboldt State College, Associate Professor l-of Fisheries, and graduate of the Unive.rsity of U1shington who worked under Seymour and Donaldson at the Radiation Biology Lab, and in the Department of Oceanography at Washington, testified no significant effects could be. expected from wattr discharged into the sea. He has made preliminary current surveys and taken j
some samples from the area, but thorough studies are expected two years prior to an operating date, t
2 -
He estimated that water discharged would total 150 curies of natural radioactivity annually while contaminants added by the i
plant would total 50 curies a year. of the radionuclides carried j
by the water 69 percent would be composed of magnesium-55 with extremely short half-life.
There is no indication he said of any area 'in the-ocean receiving one one-thousandth or even one ten-thousandth of maxi-f zum permissable levels from the 250,000 gallon / minute-discharge.-
Thermal effects would cause no changes of biological j
significance, Salo said, estimating that three-tenths to four-t, tenths of one degree would be the rise caused by the outfal'., and j
- that natural = temperature fluctuations are much greater in the-area.
t.
j On cross-exam, Salo said there would be no significant-3 deleterious effects on fish, shellfish or organisms and no population effects or deaths to any organisms as a result of the outfall. He had not made any calculations for a possible 1,000,000-
- gallon / minute discharge,'if four units were emplaced at Dodega.
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UNC LISSLc 1ED j
He referred to studies on the Columbia River and by the I -
United Kingdom in giving results of previous experienet with the discharge of water from reactor 1.
Vorthington, under cross-exam, s' J POE now owns 160 acres at Bodega for which it paid about $60 03.
Worthinston also stated that he erpected a plant coat of 5.7 mills /kwh from the first core. ' Asked about future nuclear reactors at Bodega, Worthington said if built today they-would use the came type, but expect future improvementa which may make the proposed reactors very different in design from the unit proposed for construction.
He said that' insurance of $60,000,000 would be taken out for property damage; $60,000,000 for liability and that AEC indemnity went up to $500,000,00^.
There were no specific records for earthquakes at Bodega, Worthington said, but 1906 was the moet severe.
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proposed in the application, but that "this is not firm".
He conceded PCE was considering a different design from that l
l Nutting, in reply to staff questions on quake effects, said J
there was not a specific scram for earthquakes. The site he said meets the proposed AEC site criteria regulation. During questions on health-and safety, Nutting said POS had modified some of its studies being conducted at Humboldt Bay to include suggestions from the State Health Department and wouldLalso provide that department opportunity for review of Bodega Bay plans.
Grendon, State Atomic Energy Coordinator, testified for the plant and noted that as a result of studies made by his office it is expected that nuclear fuels will become cheaper while fossil fuels in future decades will increase in price and ultimately -
become short in supply.
He made an interesting observation to the effect that i
" Federal law attempts to clarify that -reactor operations are in l(:,
the federal domain". However, he insisted that California was interested in and responsible for the environment, and that l\\~
State law requires adequate monitoring subject to the State Health-l Department,_ He said he expected to continue to look out for i
public health and safety, that a multiplicity of agencies - State, 1
local and federal - were concerned with safety. He referred to i-establishment of an advisory committee two years ago.which found '
preoperational monitoring nectosary for two years prior to reactor operation to establich base lines to determine any effects of the operation.
E At this point Eubanks (part-time art student) asked whether l-the plutonium returned to AEC would be "used for bombe?" This i
was objected to by PGE counsel.
witnesses if desired by recipients of this memo.) given by POE (I have additional notes on details of costo i
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UNITED STATES GOVERNMENT Memorandum To Files DATE: August 15, 1962 l' ROM R. S. Boyd/ R. H. Wilcox y
[
Research & Power Reactor Safety Branch SUBJLCT: BODEGA BAY ATOKIC PARK, UNIT NO. 1 An ACRS Subcoastittee meeting was held at H Street on July 31, 1962, to dia: usa Pacific Gas & Electric Company's Bodega Bay reactor. It is anticip.ted that an application for a construction permit will be filed ia September.
The following people were in attendance; ACRS AFC iTrr F PG&E H. Kouts (Ch.)
J. Newell C. Whelchel L. Silverman R. Boyd F. Mant K. Osborn R. Wilcox W. Nutting R. Stratton R. Waterfield R. Lemon-(GE)
A C. Williams J. VanderBoven (WB)
D. McDaniel (GE)
Y J. G' sham G. Hadlock. (OGC) h19 The overall schedule for the Bodega plant, as outlined by PG&E, is O
the following:
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m L (1) August 15, 1962
- Issuance of Permit by State of California e (&
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(2)
September 1, 1962 - Site : reparation and Meteorology Program l
(3) March 1, 1963
- Excavation begins 3
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(4) June 1, 1963
- First concrete pouring
[}i (5)
November 1, 1965 - Initial criticality g
2 (6) May 1, 1966
- Full power operation s
J M'
As the schedule implies, PG&E will require a construction permit be-0.( % j T construction permit, with a Hazards Summary Report, on September 4, fore June 1,1963.
It is their plan to file an application for a J
1962. A schedule tendered by Mr. Whelchel contemplated an October ACRS meeting, a November hearing, and issuance of a Construction
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Permit by January 15, 1963. During discussion of the proposed sched-ule we indicated that it was somewhat unrealistic, and that indeed
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more time was available before the construction permit was needed.
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It appears that a hearing as late as March, 1963, would not incon-s jV 4
vience PG&E.
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I Files August 15, 1962-The proposed Bodega reactor will be a 325 Mw(e),1060 psig, forced circulation boiling water reactor with internal steam separation -
and vapor suppression containment.
The details of the meeting, presented below, are intended to provide the Staff and the ACRS with a cursory description of the site and i
the plant.
I (1)
PGkE will provide its own architect-engineering services (this was not the case with Humboldt Bay). GE-APED will i
provide the nuclear steam supply system, turbine-generator, and will act as nuclear consultacts.
(2) The plant location, about 50 miles North of San Francisco, is at Campbell Cove on Bodega Head.- The nearest conmuunity, Bodega Bay, has a population of about 350.
PG&E now owns.
j-j all of the land, about 225 acres, that they think necessary for the site..The University of California is planning.a i
marine biology station on 400 acres north of the site, and j
the State is considering a state park north of the station.
(3) The land use is mostly involved with sports and commercial fishing. There are no residences within-1.5 miles of the i
site. There is 2700 ft exclusion distance to the North and 1300 f t SE to Durand Beach. The town of-Bodega Bay is es-l sentially 2 miles due East of the site. There are 500 people within 'a 5 mile radius, 2100 people within a 10 mile 4
i radius, and 115,000 people within a 25 mile radius.
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(4) Meteorology for the site is sketchy. However, PG6E is planning a program, designed to obtain temperature and wind data starting in September. These plans call for a 252 ft mast with transducers at 7, 50. and 252 feet.
(5) The geology of the alte 'was explained with the remark that t
Bodega Head is an " island of granite".
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(6)
Seismology will probably be one of the major site problems.
The San Andreas Fault runs through.the area with the western boundary estimated to be about 1500 f t Ear >. of the site, i
PG&E has utilized consultants on this matter and presumably
-l considerable information on seismic effects will be included l
I in the hazards report.
(7) Oceanographic tests involving dyes and current drifts have.
been conducted at the site and will be continued.
In gen-eral the pre-operational monitoring program for Bodega is l
proposed to be similar to that conducted at Humboldt Bay.
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Files August 15, 1962 4
(8)
Plant layout vill involve grading from 90 ft MSL down to 25 ft MSL. The pressure,, suppression system will be in-bedded in 20-30 f t of ro3k.- The stack height has not yet i
been determined. There is no rail' spur on the head; trans-l portation of equipment is expected to be by barge.
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(9). Fuel handling for Bodega will be underwater at all times.
The fuel elements will be 10 f t long.
4 (10)
Comaents on the nuclear steam supply system are the following:
I thermal power - 1008 Hw(t) a.
b.
vessel designer - Combustion Eng.
i length 51.5 ft; 15 ft.I.D.
material: 302 plate - Section VIII of code i
thickness: 6 1/2" at core; clad 7/32" - 30455 6.6.
18 avt (above 1 mev neutrons) - 2.5 x 10 c.
steam flow - 4 x 106 lb/hr d.
recirculation flow - 43.5 x 10+6 lb/hr e.
internals - centrifugal stesa separators, ia-core j
monitors, core spray and poison system f.
fuel - 2.7% enrichment, 127 inches activs length, UO2 Pellets, 11 mil SS clad, Zr channels, 7 x 7 j
matrix,147" diameter core with 592 assemblies 3
g.
rod drives and blades - GE drives,.1 blade per four fuel assemblies, total 145; B C blades; poison cur-4 l
tains in initial core (1% Boron Steel); no peripheral i
- rods, b.
Exposure: 15,000 Mwd /T.
No critical experiments planned.
2 1.
Power density, 33 Kw/1; avg. flux.103,000 Btu /(hr)(f t );
heat transfer area, 33,000 sq. ft.; Burnout ratio at overpower,1.5 (overpower level not set); total void l-fraction, 30%) exit quality, 9.5; moderator to fuel ratio, 2.7 i
- j. reactivity balance - 281; blades,18%; curtains,131; shutdown margin, 31 F
k.
It is planned that this may some day be a 4 reactor site.
PG&E hopes'to get 350.Mw(e) out of the turbine on the
- 1 plant ultimately. Present considerations are, however, that this be a one reactor site.
2 i
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Maximum credible accident: with 28"~ pipes, a 6.4 ft area rupture. - 38 psig in dry well, tentative design:
50 psig; 29 psig in suppression pool; design, 35_psig (11) The Suppression Pool design has been based on Moss Landing tests subsequent to the Humboldt Bay tests. Additional tests are proposed to prove feasibility of the omaission of baffle plates in the pool by testing with and without baf fles.
Files-
- ' August 15, 1962-I (12)- The - accident analyses -asicompared. to those for Humboldt Bay are;
' Cask drop accident - none-(no cask)
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b.
fuel handling - none (no cask).
control rod drop out.- the rods.are worth-less than c.
the Humboldt' Bay rods d.
The fuel loading accident is considered to-form the basis for containment refueling building design.
There would be expected to be some (0.57.)- nobe[f gas release.
The reactor-is designed such that loss ~of all pumping _
e.
power would not result in fuel damage'.
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BAY AREA CHAPTER Northern California Association To Preserve Bodega Head and Harbor Berkeley 4, Coilfornia 2731 Durant Avenue ADVi$oR5 May 6, 196)
Ansel Adores oovid ero..r The Public Utilities Commission Harold GiHioni State.of California J Gu$'' "
California-State Building Woloon f. Heald San IranCisco 2, California Joel Hedgpeth Re:
Application No. 43808 F.onci Herrmg
-Interim Decision No. 64537
- o.. ty,,,
winiom Penn Mott,Jr.
gear girs Thomas Porkmson Transmitted herewith are fifteen (15) copies of Kenneth Rearoth this Association's Memorandum of Action on Late Filed 1.tr4 eevnoids Exhibit 48 and Related Evidence, ' this date, concerning D {d ff*"3* ",,,
Pacific Gas and Electric Company's application for a certificate of public convenience and necessity for tne proposed Bodega Bay Atomic Park.
Copies of this document' have-.been delivered today-by messenger to Applicant and by. U.S. mail to other i interestea parties as listed in the table of Initial Distribution on page 49 of-the Memorandum.
1Be are. confident that the diligence manifest in this Memorandum, the issues of due process ~ which it raises, and the extraordinary nature of the circum-stances with which it deals will not go unattended by the Commission.
Respectfully submitted.
s/ David E. Pesonen DAVID E. PESONEN Executive' Secretary f
Purpose:
To work for pres *rvation of the scenst and historic headlands of Bodego Boy and to msvre the ecological infogrity of the surroundmg marine environment.
A California Non profit Corporation l
f
-.. - =..
~
a MEMORANDUM OF ACTION CONCERNING i
LATE FILED EXHIBIT NO. 48 AND RELATED EVIDENCE l
4 l
Contents l
P,, asp, i
1 I.
INTRODUCTION e
4 4
1 i
Petitioner's Standing
+
I APPLICANT'S LATE FILED EXHIBIT 48
~
1 II.
Dental of Opportunity to Cross-Examine 1
1 DISTANCE BETWEEN THE PROPOSF"> FACILITY i
j-II'..
8 AND THE SAN ANDREAS FAULT 1
8 Exhibit 48 1
9 i
}-
Applicant's Testimony 13 f
Additional Sources POTENTIAL SEISMIC ACTIVITY AT PROPOSED j
IV,
15
/
REACTOR SITE 18 Quality of Foundations for Proposed Facility 32 Anticipated Seismic Shock at Bodega Bay I
Discrepancies Between Exhibit 48 and-Preliminary 38 Hazards Analysis Submitted to' the AEC i
43 V.
ARGU MENT t
46 VI.
PRAYER FOR RELIEF -
i i-h o1 3
1 1
l
. - _.. - ~,. _. _ _,.. _
t b
j j
s j
4 List of Appendices 4
i Annotated Oblique Aerial Photographs (2), Bodega Head.
l-A 1
Map, Geology of Bodega Head, William Quaide, CPUC. Ex. 48, Sec. 8.
j B
]
Site Plan, Equipment Locatloc. Section; CPUC Ex; 2A,B.
C 5
Vertical Aerial Photo, Bodega Head, Proposed Reactor Excavation; D
7 March 63.
E Map, Topography, Bedrock,-Dwg,- 423179-2, CPUC Ex. 48, Sec.11.
i Scheme VI, Bodega Bay Power Plant, Dwg, SK8098-7-A; CPUC Ex. 48, 1
F 5
Sec. 8.
Scheme VII, Bodega Bay Power Plant, Unnumbered; CPUC Ex. 48, f
G Sec. 11.
i H.
G.W. Housner: Fig.1, Plot Plan; Fig. 3, Section_ Thn2 Reactor; t
I Fig. 4, Section Thru Reactor: CPUC Ex. 48, Sec.12.
3 I
' Dames & Moore: Section Looking Northeast; Section Looking North-
)
west: CPUC Ex. 48, Sec.15, Ackerman, A.J. ; " Atomic Power, A Failure in Engineering Responsi-i-
l J
bility," American Engineer, Jan
'63.
i i
Pesonen, D.T., " A Visit to the Atomic Park," reprinted from the l
K
[
S_ebastopol Times, Copyright, 1962.
i
.I'
?
i e
11 l
l i
.c.
..,,.._,-..,mm..4,s_,...,,,M.,.__,_...m.c,,,
....,.,,,,,,_......r,_,_,,._,.
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i 2
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE
}
OF CALITORNIA j
In the matter of the application of
)
j PACIFIC GAS AND ELECTRIC COMPANY )
i for a certificate of public convenience )-
Appl: cation No. 43808 and necessity to construct, install,
)
i operate and maintain Unit No.1, a
)
Interim Decision No. 64537 l
nuclear power unit, at its Bodega Bay
)
j Atomic Park.
-)
(El ectric) -
)
MEMORANDUM OF ACTION CONCERNING l
LATE FILED EXHIBIT NO. 48 AND RELATED EVIDENCE I
i 1
INTRODUCTION Petitioner's Standino i
The Northern California fisociation to Preserve Bodega Head and Harbor i
(he einafter referred to as the Association) is a non-profit corporation organized i
j under the laws of the State of Calitornia. It descends directly f.om the unincor-l porated association.of identical title, which is a party to the proceedings of Ap-f plication No. 43808 before the Californio Dublic Utilities Commission and applAes i
here to the Commission as a party to the proceedings.
I II l
APPLICANT'S LATE FILED EXHIBIT NO. 48 f
Denial of Opportunity to Cross-Examine j
The Association wishes to draw the Commission's attention to certain dis-I-
crepancies between Applicant's testimony ard evidence submitted by Applicant in Late filed Exhibit 48. No opportunity was afforded during the proceedings to con-front Applicant with the discrepancies hereinafter set forth. These discrepancies strongly suggest that Applicant has attempted to deceive the Commission and that the testimony of Applicant's witnesses as it relates to the substance of Exhibit 48-the San Andreas fault and related senmic conditions-1; impeachable.
.. m
. ~.
Since we were not afforded the exercise of cross-examining Applicant i:
with respect to the subject matter discussed here:n, this memorandum stands partially in lieu of cross-examination, Subject of the Exhibit 48-ThiCommission ordered the submission of Exhibit 48 because of the in-terest which developed during the proceedings concerning poss'ble hazards to the i
public stemming from the proximity of the' proposed nuclear facility at Bodega Bay to the San Andreas Fault, The Exhibit contains 24 Sections,-dealir.g generally with three areas of interest: (1) the location of the San Andreas Fault,'and related seismic and geo-logic conditions at Bodega Head, (2) the nature of the foundations for the proposed facility, and (3) the structural design of the' proposed facility in light of the >eism:c, geologic, and foundation data. -These areas of-interest are woven throughout Ex-hibit 48.
For each of the above-listed areas of interest a different consultant was retained by Applicant. The principal consultant on seismic conditions was Dr. D. Tocher of the University of California at Berkeley, assisted by Dr. William Quaide of Claremont, a geologist. The firm of Dames and Moore of San Francisco was retained to consult on the foundations. Dr.. George Housner of the California Institute of Technology was Applicant's principal consultant on structural design-of the facility itself.
Applicant Was Afforded an Early Opportunity to Submit Seismic Data, Applicant was afforded ample opportunity to _ submit a significant portion of the material contained in Late Filed Exhibit 48 before the close of the proceedings.
1The proposed reactor will be cf an unusually large olze and will contain rnochiv R hiilinn mie4ae # od4~ ~4.-
<< -+ - - - - ' - - - -
___ J
l 4
However, a verbal exchange between Applicant's Chief Counsel John -Morrissey, Applicant's Civil Engineering Witness J. Dean Wortnington, and the Commission's -
Staff Counsel William Bricca, early in the proceedings (Tr. 37-38,_7 Mar 62) sug-gests that Applichnt was reluctant to submit the subject evidence, When asked if the reports of Applicant's consultants were to be put in evidence, Counsel Morrissey replied: "Well, we didn't intend to put any of them in. They are quite lengthy, they are quite' voluminous. Certainly they are available for-tne Commission staff to look at and to study. Indeed, if we can get extra cepies, we will ive you an extra g
copy...."
The record shows that Staff Counsel Bricca then engaged in an exchange of remarks with Applicant's counsel Morrissey concerning the nature of expert evidence regarding the San Ardreas Fault. He argued that without documentation and without the direct testimony of Applicant's corsultants, the assmances given by Mr. -Worth-ington constituted hearsay. But this line of inquiry was interrupted by a recess in the proceedings. The matter of Applicant'c putting related documents in evidence was not again raised until the closing minutes of the preceedings, three months
'later.
Applicant's testimony regarding seismic effects on the proposed facility was said to be based partly on the expert report by Dr. Tocher. This repo-t, dated 14 September 1960, contained a map prepared-by Willia:: Quaide anc' bearing a trace of the western limit of the San Andreas Fault Zone, running through'the harbor entrance just east of Campbell Cove. (Appendix B of th;s memorandum.) Exhibit 48 -
.shows that this report and map were the only survey of t.e. location of the San Andreas-Fault on which Applicant relied,- after deciding to place tne facility at Campbell Cove
- on Bodega Head.
)
The stimulus for the Commission to require sube.ission of Exhibit 48 was
4 a map on file with the California Bureau of-Mines (Exhibit 39), prepared by F. A.-
Johnson in 1934 and indicating the trace of a secondary fault running directly-.
through Bodega Head in a northwesterly d.rection just west of the reactor site (see Appendix A). This trace is not shown on Qualde's map: but the text of Dr.
Tocher's report (Ex. 48,' Sec. 8, p.12) contains a pertinent conclusien, No. 4, as follows:
"The quartz-diorite is strongly jointed and is fa.:lted on old minor f aults. However, there have been no movements on these f aults m the past few thousand years. Lack of recent movement strongly implies, but does not guarantee, that there will be no movements-tnroughout the life-expectancy of a power plantht' Campbell Cove on Bodega Head]
j The record shows that the ambiguity in the proceedings which resulted from submission of Exhibit 39 might have been resolved if Applicant had presented this conclusion of Dr. Tocher's report. In fact, Dr. Tocher himself, as we later discovered, was present in the room at the time this ambiguity was being discussed.
Nevertheless, it was necessary to summarily call to the stand a geologist from the Bureau of Mines (James Koenig), wno was also present in the audience, to be examined on the significance of ExE it_39. From the tone of the record (Tr.
1348-1360),-it is clear-that Applicant preferred the-ambiguity which remained after Mr. Koenig's testimony to the greater certainty which would _have come from testi-
' mony by Dr. Tocher.
Instead, the so-called " Johnson's" fault shown on Exnibit 39, was dis-cussed in correspondence between Mr. Worthington and Dr. Tocher, after the proceedings had been concluded. On.16 June --19 62, Dr.: Tocher wrote as follows
~
to Mr. Worthington (Ex. 48, Sec. 22):
"From his remarks,2 I infer tnat Johnson regarded the fault;which he did show on his map-as the most well-defined of the many f aults and shear zones that can be observed in the quartz-diorite of Bodev Head, bt.. attached no greater significance to it than that,"
Finally, the remarks of Witness Worthington and of Counsel Morrissey at the time Exhibit 48 was ordered submitted clearly reflect a reluctance to ex-pose to the Commission's attention the true location of the San Andreas Fault, the quality of the foundations, or the plant design. The following excerpts from the Transcript reasonably support this al.egation (Tr. 1402-1413):
Worthing ton:
...Now, location of fault lines may have been of interest to Mr. Johnson but I am pretty certain that Dr. Quaide's interest in this matter was much greater since his assignment was specifically to go on to Bodega Head and find if there were any zones of active f aulting.
"He. spent several days on the Head and reported that he had found none... "
Hollis (PUC Staff Engineer): "Your company holds the responsibility to review the geological strength of the foundations for this plant, does it not? "
Worthington: "It certainly does...The work of Doctors Tocher and Quaide has been correlated with that of Dr. Housner.. The prox-mity of the San Andreas Fault has been a major consideration in these designs... "
Hollis: "And these designs are also related to the Atomic Energy-Commission site criteria and your future representations before 2?ohnson, F. A. (deceased), Thesis, Ph.D., University of California, Berkeley,19 34, "Petaluma Region," in California Division of-Mines, Bulletin 118, Apr. 19 4 3.
The following remarks occur on pages 24-25 of Johnson's thesis:
i "The diorite, where excellently exposed in sea cliffs, is deeply weath-ered, and badly crushed, sheared, and faulted. A zone of gouge, an inch o'r two thick, is associated with many of the faults, but generally the amount of move-ment where determinable has been slight. One well defined high-angle fault on the west side of the ridge has a strike of N 25 W, the general strike of the gneis-sold banding. Dikes can be traced but a few feet before evidence of repeated shearing, crushing, and faulting can be observed. Considering the proximity of the massif [ Bodega Head)to the San Andreas Rift, which separates the diorite from the Franciscan Group occurring to the east on the mainland, the abundant-evidence of movement which has affected the rock mass becomes tenable."
2
i 1
+
F
. 6-i
. the AEC in connection with your construct:on and later-permits :
to be received from them, if granted?"
Worthington: "That is correct.."
Hollis: "Accordingly, for the Commission staff's information may there be filed, Mr. Examiner, a late filed exhibit presented-for the Com-i mission's information as a matter of comp'eteness of-the record 'a full geological report reflecting the company's position with respect to the proximity of the earthquake faults and their effect on plant design including the reports of Doctors C; aide and Dr. Housner and Dr. Tocher if such reports exist or can be made? a Morrissey: "Well, M:. Worthington, are these reports understandable in and of themselves ?"
Worthington: "The reports are of a-technical nature, of such a ncture that I don't'believe it would be helpful to the Commission at all.
"Further, the reports have been worked upon through the medi-4 um of correspondence between consultai.ts, between the Pacific Gas and Electric Company and the corisultants.
"In order to follow through ard have any significance at all in the understanding of these reports would be a tremendous job.
"It is one'which we have followed ve y closely and we thorough-ly understand. A good _ deal of the action tnat has been taken has i
been in the form of oral conversations wit: Dr. Housner and others, "I don't believe it would be helpful. "
Morrissey:
"Mr. Examiner, I call your attention to the fact that we have been' spending now some six or seven days. ' A good bit of it_was re-~
lated to this very subject and we have presented evidence on this subject which is sufficient to sustain our action _ which we are going-forward with. "
(Mr. Bricca supports the position of M Hollis and reaffirms the staff's-h o
position, stated on Tr. - 38, that "it wos not be appropriate to rely _ on the hearsay evidence" presented by Applicant and that "the Commission itself would be the best judge" of the evidence.]-
Examiner Patterson- "Well, this is certainly a very important part of this proceeding. Apparently the applicant is_ w:lling to-stand upon the record that they have made with respect tc the - "
l
- Morris sey: "That's correct. "
Examiner Patterson:
"--San Andreas Fault. But, the staff, I gather that is the position that additional information will be helpful'to the Com-mission in evaluating this. "
l' L
~7-
)
4 "And for completenes s of the record.... "
i Hollis:
b Bricca: "In the absence of receiving it,-we w:uld'have to urge that this part of-the burden of proof the applicent tas-not met... "
Morrissey:
"Could the summary: be prepared, Mr. Worthington ?"
1 Worthington: "Yes, a summary could be prepared. There would be a-L tremendous amount of work in doing so, but we can do it... "
3 Morrissey: "Well, Mr. Examiner, could l res;ectfully ask an amend-4 ment to what you have just ordered, to the effect that we will pro-i vide the. summary, and we will have aval.able at our offices the documents. "
4 l
Berry (Counsel for tne Sierra Club):
"Mr. Exa.iner, I must strenuously -
object to this suggestion. Tae more and core that Counsel makes it apparent that he does not want to have inese original records made completely available to the public, :1e more I become suspici-ous that there is something in those docu.ents which is fairly im-
+
j portant... "
{
Ext
' r Patterson: "... Now,.when might that be made available... "
i Wonnington:
...It might take a week or so t: compile.this, Mr. Exam-iner."
i The exhibit which was the subject of this excr.ange in the proceedings i
was ordered late filed and numbered Fxhibit 48. It is t e principal material on which this memorandum is based. In order for Exhibit 43 to be complete,T Appli-cant found it necessary, as the exhibit shows, to cond;;t additional correspond-ence with Us consultants after the close of the proceeings, which is. included in the exhibit. 'The summary mentioned above ts a1five-pa;c document, dated 6 July 1962, and attached as Section 1 of. Exhibit 48. The aut.or of the summary is Mr. Worthington. The Exhibit was filed on 9 July 1962,. Just over a month after the close of hearings on Application No. 43808. The text of the Commission's Interim Opinion No. 64537 suggests that the Commissic.< relied ' exclusively on Applicant's~ testimony in hearings and summary of Exhib:t 48 and reglected a close examination of-the substance of the exhibit itself in assessing earthquake hazards
-.---..-.-..a-
at the Bodega Bay Atomic Park.
I III DISTANCE BETWEEN THE PROPOSED FACILITY AND THE SAN ANDREAS TAULT Exhibiti _
48 In this discussion it will be understood that, in reference to the distance -
between the proposed facility at Bodega Head and the San Andreas Fault, distances i
are measured between the centerline of the reactor and a line of the westera edge of the San Andreas Fault, as shown on the map prepared by William Quaide (Ex. 48, Sec. 8). Regarding the significance of this line on Qualde's map Tocher reported as follows (Ex. 48, Sec. 8, p. 7):
" Western Marcin o_f the San Andreas Fault Zone--The San Artireas' fault f
in this area is not a single dislocation but a zone of dislocations a mile and one half wide. The rocks in the fault zone can not be observed, for they are crushed and broken so.that they are easily eroded. The position of the zone.is marked by a belt of low relief, covered here by sand dunes and recent marine deposits. The West-ern margin of the fault zone is indicated on the geologic map
[Qualde's map] as a straight line separating granitic exposures of the southwest from the dune-covered low relief area to the northwest.
The western margin may not be as _ exactly straigat as indicated, but -
evidence for a more detailed location is lack _ing. Very straight trends, moreover, are characteristic features of large strike-slip faults such as the San Andreas. "
This map shows the " Western Limit of the San Andreas Tault Zone" run-ning just east of Campbell Cove. But since this map does not show the plant'lo-cation, it has been difficult to establish on one map the :ocation of both the fault and the nuclear reactor so as to scale the distance between-them.
A number of maps are included in Exhibit 48, but they vary in such a l
way that it is impossible to accurately plot both of these features-the' f ault and the reactor-simultaneously. The scales vary, the grid orientationc vary, bench-marks are placed on some maps and deleted from others, and so forth. It should
s also be noted that several drawings in Exhibit 48 have been improperly indexed.
For example, where a certain. drawing is indexed as Change' 1, Change 2 or an unnumbered drawing is actually included in the Exhibit. Thus the entire docu-ment is singularly confusing. Nevertheless,'from maps we have prepared and trom aerial photographs (Appendix D) :f the excavatiott now in progress at the reactor site, it has been possible to plot the proposed reactor location within a very few feet of its precise location in relation to the western edge of the fault.
By our measurements, tne distance between the proposed nuclear. reactor and the western trace of the San Andreas Fault is very close to 1000 feet.
- Acolicant's Testimony The Commission's attention is drawn, therefore, to Interim Opinion No.
64537 (p. 19) which states that '.he San Andreas alt bone 9according to the
~
record is more than one-fourth mile east of tne L.oposed reactor site." (Empna-sis added.) In addition, the Commission's Interim Order takes particular and specific note of the Atomic Energy Commission reactor site criteria (Exhibit 23),
- Sec. 100.10(c)(1): To facility should be located closer than one-fourth mile from the surface location of a known active earthquake fault.-"
One-fourth mile equals 1320 feet, wnich is 320 more than thel distance between the proposed Bodega Bay nuclear reactor and the San Andreas Fault Zone, according to the best evidence in the record.
The Commission's attention is ' drawn to the fact that Exhibit 48 and other evidence, show that Applicant had full knowledge of the true distance'between the reactor and the fault at the time of J.he hearings on Application No. 43800.
Yet Applicant led the Commission and the public to believe that the distance was greater then one-quarter mile. The distance is significant because
10 l
4 I
it is one of the' few verifiable, ron-discretionary criteria of the Atomic Energy _
Comraission's reactor siting requirements. That Aopl:: ant submitted Exhibit 23L to the Commission is evidence that.he. attached some :mportance to the AEC criteria: submission was rot an idle act.
Nevertheless we have the testimony in the record which led the Com-mission to note that the distance is greater than one. fourth mile.
Witness Wortnington (Tr.169) testified that the San Andreas Fault is-
"approximately a mile" from the reactor vessel. When cross-examined by staff engineer Holl:s on the location of the fault Mr. Worthington referred ex-tensively to a f airly imprecise line visible on th'e aer:al photograph in Exhibit-1, although the reture of the examination clearly reflects tMt Quaide's map was the kind of data being sought (Tr. 378-380). Witnes s Nutting,..under direct examination by Applicant's counsel Morrissey compounded the error (Tr. '520).
Questioned, "Does the proposed cite of Bodega Head satisfy the requirements c
of the AEC regulation, in your opinion?," he replied, "Yes, it _does. "
It should be noted that between the time of t e testimony by Witness Worthington cited above (Tr.169, 8 Mar 62) and the testimony by Witness Nut-
- ing cited above (Tr. 520, 21-May 62) the AEC reactor site criterion respecting earthquake hazards was changed.
Exhibit 23 was filed during testimony by Witness Nuttir.9
.It had be '
come effective on 12 May 62 (27 FR 3509,-12 Apr 62) inirty days after publica-tion in the Federal Recister and nine days pricr to_ Mr. Nutting's-testimony (Tr.
518). At the time of Worthington's testimony, therefere, the language em-
~
ployed-(10 CFR 100.10(b)(1).
Notice of Proposed Guides, 26 FR -1224,-.11 Feb.
- 61) was that "No facility should be located closer than 1/4 t,o 1/2 mile from
the surface location of a known active earthquake fault." (Emphasis added.) The reason for the change, occording to personal correspondence with AEC Director of Regulation, Harold L. Price, was "to avoid the ambiguity. "3 It should be nnted that in the statement of Witness Nutting (Tr. 520) cited above, the context dealt with the exclusion area around the reactor re-quired by the AEC, in relation to Doran Park, the curvea sandspit which defines the southern boundary of Bodega Harbor (see Appendix A). But later, under cross-examination, Witness Nutting stated that the facility would be at least one-quar-ter mile from the fault (Tr.1232).
Cor espondence included in Exhibit 48 reflects that Applicant's princi-pal consultant on the design of the proposed facility, Dr. George Housner, suf-fered under a misapprehension as to the distance from the facility to the San Andreas Fault. Exhibit 48 shows no evidence that Applicant attempted to correct this error.
Presumably Dr. Housner was in possession of the Tocner and Qualde report of 14 September 1960. Perhaps, however, the map prepared by Quaide and showirg the fault to run just east of the plant site was mislaid. The record 3Pertinent in this regard, the Commission may find interest in the fol-lowing exchange during hearings beft te the Joint Committee on Atomic Energy, 88th Congress,1st Sess., pursuant to Sec. "202" of the Atomic Energy Act of 19 54: Feb. 20-21,19 63, page 162.
Representative Westland:
...I think PG&E announced their Bodega Bay project about a year ago last August or September (1961] Land yet it is still in the mill. Is that not a long time ?... "
Director Price: "They had their problem first with the California Utilities Com-rm: sion. They just finished up with that late last year. They only
' their application for a license from the [ Atomic Energy] Commis--
^ dt the end of this -past December. - So they have just within the past 2 months brought the case to the Commission for a construction pe rmit. I don't anticipate that anything in our licensing process will delay their planned start of construction. "
__1--.-s.
4 12-j
-I gives no bas.s for resolving the questions which arise c:ncerr.:ng this distance
{
in correspondence b_ tween Applicant and Dr. Housner.
For example, three morths af ter receipt of-the Dcher and Qualde repon, Mr. Worthington wrote to Dr. Housner (Ex. 48, Sec. 11, on 8 December 1960; emong the enclosures to this correspondence was a facsunile cf page 28 from the October 1960 Monthly News Bulletin of tne Atomic Indus: rial T: rum (a trade ass -
{
r clation). This facsimile reproduced certain unofficial reactor site criteria, in-l cluding " Item 4" as follows:
i "The reactor site must be located at least one-alf m:le from ';ny l
known earthquake fault; for reactors located in setive earthquake regions, appropriate design and consideration ust be included. "
(Emphasis added.)
i Mr. Worthington's 8 December 1960 letter to Cr. Housner contains sev-eral questione concerning the design of the proposed Bo:iega f acility, one of which would appear to be unnecessary in light of Quaide's map: "Will the site t
qualify under item 4 of the enclosed copy of the AEC site criteria?" There is l
l no explanation in Exhibit 48 of why this question was asked of Dr, Housner, l.
I since at deals not with structural design of the reactor but with' verifiable seismic l
l facts for which Applicant had retained Tocher arid Quaide.
Nevertheless, Dr. Hc 3ner replied to Mr. Won.ington's question in a -
letter of 3 January 19610. 4 8, Sec. 13). Without refe ring te a precise one-balf male dista...e, mentioned in " Item 4" of the reactor site cr:teria, Dr. Housner -
{
t stated that a facility design to withstand carthquakes is possible at this site.
But in the introducticn to ;411 report, " Earthquake Hazards and Earthquake Resis-tant Design, -Bodega Bay Power Plant Site," dated ITnuar/1961, forwarded to.Mr.
Worthington shortly after the 3 January.19 61. letter menti:ned above,_ Dr. Housner states (Ex. 48, Sec.12):- The proposed location of the plant :s shown in Fig.1 n
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4 I
i j -
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j (PG6E Scheme Vil).
Appendix H of tnis memorandum. This site is clos'.e to the L
i l
San Andreas Tault Zone which passes a mile or so to the east." (Emphasis added.)
l 4
l And in tne body of the report (p. 5), Dr. Housner confirms this error, noting that -
1 l
"The proposed site is only about a mile or so from the fault... " (Emphasis added.)
1
)
Not only does Exhibit 48 show what must be described as a casual at-l j
tention to the location of the San Andreas Eault at Bodega Bay but a close reading l
of the Exhibit leads to the strong impression that Applicant was prepared to build i
l.
a nuclear power plant at Bodega Head regardless of any adverse seismic consider-ations, contrary,to AEC reactor site criteria, and contrary to grave reservations j
reflected in the reports of Applicant's own consultants. This impression is borne a
J out by consideration of potential celsmic activity at the reactor site itself and the f
l-quality of the foundations for the reactor in particular, and the facility in general.
J.ocation d the San Andreas Pault Confirmed by Additional Sources The Commission's Interim Order No. 64537 grants a certificate of pub-l 1
lic convenience and necessity to Applicant,- subject to certain conditions. One t
of these conditions (1 (c)(1), page 25),- is "that proper authority has been se-t i
i cured from the Atomic Energy Commission to construct the nuclear energy plant... "
l Ir. pursuit of satisfying this condition, Applicant filed with the AEC an
[
application for a Class 104b (cnnstruction) license on 28 December 1962-(AEC 1
_ Docket No. 50-205). The material r_ elating to hazards is included as Exhibit C, j
" Preliminary Hazards Analysis," to the application.
b On 26 February 1963 the AEC Division of Licensing and Regulation sub-mitted to Applicant a series of questions raised by the staff of that division after j
study of Exhibit C to the Class 104b application.
On 4 March 1963, Applicant's president N.R. Sutherland certified 1-
I i
e t
14 lenendment No. I to AEC Docket No. 50-205, consisting of " answers to questions l
raised by the Division of Licensing ard Regulation and ettached to the [AEJ Com-mission's letter dated February 26, 1963."
We wish to draw the Public Utilities Commission's attention to item 43 l
of the abovc mentioned Amendment No. I to AEC Docket No. 50-205 as evidence i
1 that Applicant was informed of the actual (1000 feet) distance between the pro-posed Bodega reactor and the western limit of the San Andreas Tault Zone at the time he testified to the contrary before the Commission. As the Commission wil!
note, Applicant refers the. Atomic Energy Commission to the map of 14 September
[
1960 prepared by William Qualde, for authority in stating this distance. Item 4 3
[
j is reproduced below in full for the Commission's convenience:
l
- 43. [EC query]
]
"How 'ar from the nea.est earthquake fault or branch fault-is the reactor to be located? How far from the San Andreas fault is the reactor to be located ?"
hpplicant's reply]
"The geologic and seismologic characteristics of Bodega Head j
have been carefully Investigated by the Company's consultants, I
Mr. William Quaide, geologist, and Mr. Don Tocher, consult-ing seismologist of University of California at Berkeley. In addition, extensive soll borings were conducted to determine i
soil and rock conditions on Bodega Head and to determine wheth -
j er or rot rock faulting exists in thel selected power plant site.
-It is the conclusion of the Company's consultants and verified j.
by the borings that no active faulting exists on-Bodega Head
{
and particularly under the power plant site. The geoloolc map in Appendix IV which was prepared M M,r. William Qualde h-i dicates the western margin of the San Andreas fault zone.
L The distance from this' western margin to tne reactor is approx 1-i:
mately 1000 f eet. The f ault zone at this point is estimated E
to be about a mile and a half-wide. Since there' arc no active branch f aults on Bodega' Head the western edge of the San Andreas f ault is therefore the closest known active fault line to the plant site. " (Emphasis added.)
i l
The significance of this-reply by Applicant to the AEC, insofar as the--
present memorandum is concerned,-is that it confirms our earlier allegation that
- -.. - -.. - - -. - - - -. - - -... ~. - - -.. -...
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t l.
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Applicant possessed knowledge that the reactor would be less v.an one-quarter i
I i
mile from the San Ardreas Tault at the time that he test:f ted before the Ccmmission that it was more than one-quarter mile distant._ It was inis misleading testimony f
I j
which led the Commission to err, by finding incorrectly that the San Andreas Fault is "more than one-fourth male east of the proposed reactor s)te. "
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IV 4
POTENTIAL SEISMIC ACTIVITY AT THE PROPOSED REACTCR SITE-i Campbell Cove, as shown on the maps in the Appendices to this memor-andum, is a gentle indentation on the eastern face of tne headland, near its southern extremity. Both the surface and substrate topography-of _the headland show that Campbell Cove lies at the point where a " sediment f:!'.ed valley" or i
l_
saddle, trending east-we st across the headland, plunges below sea level, The possibility that this valley rnay be controlled by secondary faulting on the headland had prompted Applicart's first consultant on seismology and geology, Mr. Clark McHuron, consulting engineering geologist, to recommend the outline of three general creas on the headland where a power plant might be safely built and to exclude Campbell Cove as a possible site (Ex. 48, Sec. 4, Drawing titled " Bodega Head").
This "sedimert filled valley" is mentioned several timos in Dr. Tocher's t
report of 14 September 1960 (Ex. 48, Sec. 8). On page 8, in tne body of the r
411.should be noted that, at first, McHuron ' ound a s:te near Horse-f shoe Cove, further north and on the seaward side of the Bodega Head, to be satisfactory for a power plant. This site exactly straddles the western limit of the San Andreas Fault as traced on Qualde's map of 14 September 1960.
(Ex. 48,_ Sec. 2, Drawing 6172-A, " Proposed General Layout, Seneme No.1,-
Power Plant 'N' ")
The site 'of proposed Power Plant "N" is practically identical to the planned location of the Uriversity of California's Bodega Marine Laboratory.
. -. _. - _ -. -. _ _. - -- -- _ _~
16-i i
report: "There is no evidence indicating that the location of the east trending J
sediment filled valley at Campbell Cove is controlled by a laroJ ault. The power f
~
plant and tunnel sites there do rot aopear to straddle large faults. " (Emphasis added.) And on page 6: " Although ihr gudence it nqi conclusive, at is succe.m tive that.tne valley trend is rot controlled by faulting " (Emphasis added.)
Although great strides have beenmade in techniques for designing earth-quake-resistant structures since the San Trancisco earthquake of April 18; 1906, and the El Centro earthquake of 1940, it is still not feasible to design a sinicture wh!.:n can withstand shearing-action directly at the site itself. For this reason, when Dr. Housner replied (EY.. 48, scc. 7, 30 June 60) to the letter of Applicant's 1
chief civil engineer, Mr. Worthington (Ex. 4 8, Sec. 6, 24 June' 60), accepting his election as Applicant's consultant on structural design, he also sent a letter to Dr. Tocher, asking four questions dealing with possible earth movement at the proposed reactor site (Er. 48, Sec, 7).
Of considerable interest to the Commission is the following statement in Dr. Housner's letter of 30 June 1960 to Mr. Worthington:
"As regards gross ground movement produced by f aulting, I would say that if there appeared even a small likelihood of this happen-ing, then the site should not bg used. The investigation of Dr.
Tocher and--Dr. Quald (sic) should be aimed at assessing.the like-lihood of faulting occurring o,n p_r near the~ site. " '(Ex. 48, Sec.
7,.
emphasis added.)
Two and one half months later, Tocner and Qualde, in reply-to question No I from Dr. Housner ("What is the likelihood of active faulting occurring on
![
or near the-site ?") reported as follows (Ex. 48, Sec. 8, p. 9):
i "Within the probable lifetime'of a large power plant (on the order of a l
century) there is a strong likelihood that active mcvement will occur l
in the San Andreas fault zone near the site on Bodega Head...
l-
"There is no evidence indicating that the location of the east trending report:
i sediment filled valley at Campbell Cove is controlled by a laroe fault.
The power plant and tunnel sites there do rot appear to straddle large faults. "
(Emphasis t
added. ) And on page 6:
"Although the evidence Ls nol conclusive, it is sugges-s ti,ye that,the valley trend is rot controlled by f aulting. " (Emphasis added.)
1.
Although great strides have beenmade in techn:4ues for designing earth-4 1:
i quake-resistant structures since the San Trancisco earthquake of April 4
18, 1906, l
and the El Centro earthquake of 1940, it is still not feas:ble to design a structure 1
j which can withstand shearing action directly at the site ;tself.
For this reason, j-when Dr. Housner replied (Ex. 48, -Sec. 7, 30 June 60) to the letter of Applicant's chief civil engineer, Mr. Worthington (Ex. 48, Sec. 6, 24 June 60), accepting i
I his election as Applicant's consultant on structural design, he also sent a letter l
to Dr. Tocher, asking four questions d ?aling with possible earth movement at the l
proposed reactor site (Ex. 48, Sec. 7).
I j
Of considerable interest to the Commission _is_ the following statement j
in Dr. Housner's letter of 30 June 1960 to Mr. Worthington:
j.
"As regards gross ground movement produced by faulting, I would-say that if there appeared even a_ small likelihood of this happen-
[.
. Ang, then the site should not be used. The investigation of Dr.
Tocher and Dr. Quaid (sic] should be aimed at assessing the like -
11 hood of f aulting occurring on or near the site " (EX. 4 8, Sec. 7, emphasis added.)
i Two and one half months later, Tocher and Qualde,-In reply to question :
l-No.1 from Dr Housner ("What is the likelihood of active faulting occurring on
~
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or near tne site ?") reported as follows. (Ex. 48, Sec. 8, p. 9):
"Within the probable lifetime of a large power plant (on the order of a -
I' century) there is a strono likelihood that active movement will occur
~
in the San Andreas fault zone near the site on Bodega Head....
No evidenen was found in the geologic examination to indicate the existence of a large f au'lt beneath the plant or tunnel sites.
Chances of disruption of the sites 1y, breakace alonc,
arce 2
fault are therefore small. " (Emphasis added.)
To be quite certain on this point, Dr. Housner also asked Dr. Tocher:
"What is the likelihood of ground movements occurring at the site during an earth-quake because of fissuring or fracturirg of the rock ?" (Ex. 48, Sec. - 7). And Toch-er and Quaide's report answers (Ex. 48, Sec. 8, p. 9):
"Probably quite small.... Complete absence of fracturing in the quartz-diorite cannot le predicted with certainty, however. "
(Emphasis added.)
Turther, as noted on page 4 of this memorandum, Tocher and Quaide's Conclusion No. 4 (Ex. 48, Sec. 8, p. 12) states that:
" Lac *: of recent movements St Campbell Cove] strongly imp.es, but does g d guarantee, thaT"there will be no movements through-out the life-expectancy of a power plant. " (Emphasis added.)
The uther two questio ns of Tocher posed by Dr. Housner dealt with-(1) the likelihood of landsliding at the site and (2) the expected intensity of earthquake activity _ at the site as compared with a "similar she 15 miles or more" from the fault. Both of these questions will be discussed later in this memoran-dum.
- As for the magnitude of potential earth movement near the site,~ we have Applicant's own testimony under direct examination, which would appear to be based'on Tocher and Quaide's report (Tr. 534):
Morris sey: "Approximately= how much movement or displace nent was there in the 1906 quake of the San Andreas fault in thi area, if you know ? "
Worthington:- "I haven't found any records of the amount of displace-ment at Bodega proper. However, the displacement at the Head of Tomales Bay {ee Appendix] was about 16 feet, and I would
. judge _ from studying the records both north and south of Bodega
that the displacement was somewnere between 10 and 16 feet, more likely the latter. "
It'is clear from the above discussion that Toc er and Quaide's analysis of the site could not assure against gross ground movement at the proposed re-actor site. There is no evidence of large faults at the site-but there may be smaller faults:.the likelihood of ground movement at the site is "probably quite small:" the evidtnce "does not guarantee" that there w;11 be no movements at the. site:" but there is a " strong likelihood" of active movement "near the site."
Exhibit 48 shows that at the time of Tocher and Qualde's report, Dr.
Tocher possessed a carbon copy of Dr. Housner's letter of 30 June 1960 to Mr. -
Worthington, in which Dr. Housner was quite emphatic in stating that "even a small likelihood" of gross ground movement at the site would dictate that the site be abandoned.
Altogether, it is reasonable to infer that Tocher.and Qualde.were telling Applicant as delicately as possible that Campbell Cove is an unsuitable site for a reactor from a -seismological point of view. This alone should have discouraged.
Applicant from proceeding with his plans; nevertheless.the plans went forward with vigor.
' Quality of Toundations for Proposed Facility.
The Commission's Interim. Opinion No. 64537 discussed several of the features which Applicant testified made the Bodega Bay site desirable for a nucle-ar power plant. "Some of the desirable features which.e enumerated as existing at the proposed site," observed the' Commission's opinion (p. 4) "are...a_ solid =
v granitic type of rock providing a2 excellent foundation, : solation from population centers.... " and so forth. (Emphasis added.)
..J
The Commission's attention is drawn to the ev.dence discussed below in Exnibit 4B that there is no solid granitic type of rock at Campbell Cove and that the foundations for the proposed facility are of an extremely inferior quality.
Iratially Applicant may have been justified in t.e assumption of solid rock for the foundations at Campbell Cove. Quaide's now f am111ar map bears a note referring to the northern shore of Campbell Cove: " Quartz-diorite exposed to 5 feet above sea level." This would suggest rock at suitable elevations for founding the reactor structure.
However, it should be noted that the term " quartz-diorite" does not necessarily mean t' rock:" it refers to the mineral-chemical composition of the-material, which may vary from nearly clay to hard rock. At Campbell Cove, as Exhibit 48 shows, the quartz-diorite is closer to being clay.
The reason for this highly decomposed condition in the rock of Bodega Head is best explained in a paragraph from Tocher and Qaaide's report of 14 September 1960 (Ex. 48, Sec. 8, p. 5):
"The quartz-diorite at Bodega Head is extensively fractured, sneared, and jointed, as are all the other granstic rocks _ lying west of the San Andreas fault system. The rock is not penetratively sheared but is cut by innumerable discrete shear surfaces with brec-j cla (broken rock) and mylonite (milled rock) zones ranging from a feather edge to a foot thick,...Many cases were observed, however, where large dikes were cut off by laults. and not observed again on the other side of the fault, indicating movements of tens of feet or -
more. The intensity of the faulting and jointing in the rock is so great that the formerly, massive rock is now broken into a mosaic of blocks with averace dimensions of approximately one foot. "
(Emphasis added.)
As mentioned earlier in this memorandum, the reactor site at Campbell.
Cove lies where an east-west trending " sediment filled valley" plunges below-sea level in an easterly direction. According to Tocher and Qualde's report, the -
entire headland was submerged.at some time in the past and sediment was
deposited over the rock; subsequently the headland was uplifted. The deposits have accumulated in the sediment filled east-west trending valley at Campbell Cove, therefore, and have masked the very prominent valley which would-be vist-ble if the deposits were not present. The situation at Campbell Cove may be ccm-pared to a flour-scoop buried near the surf ace in a flour-bin.
Applicant retained the firm of Dames and Moore of San Trancisco to con-sult on the location and quality of the foundation material at Campbell Cove. Tneir first seismic survey, dated 25 January 1960 (Ex. 48, Sec. 5) was made available to Tocher and Qualde an'd to Dr. Housner.
This Dames and Moore report contained the results of I boring and 7 -
seismic sections in the vicinity of._ Campbell Cove. The bedrock contours hy-pothesized from these tests were drawn on Drawing No. 423179; but according
~
1 to Applicant's addendum to Section 6 of Exhibit 48, the original tracing of this drawing is not available. In place of it,- Drawing No - 423179-2, dated 22 Maren 60 (Appendix E), which may differ from the original (the record affords no 'oppor-tunity to verify any possible difference), has been substituted'(Ex. 48,' Sec.11).
A traced f acsimile of the Campbell Cove portion of this drawing is included -as Appendix E of this memorandum.
When Mr. Worthington, Applicant's chief civil engineer, wrote _ to Dr.
Housner on 24 June 1960_(Ex. 48, Sec. 6), he included eight enclosures, of which three concern us.here. The first was a map of the bedrock contours, Draw-
.ing 42 3179 mentioned above; the other two were Drawings 55319 and SK8038-7-A, the latter showing a proposed plar.t layout,' Scheme VI (Appendix T). Drawing l
55319 is a detailed topographic map, later used as a base map'for an alternative i
to Scheme VI and is labelled Scheme VII (unnumbered and undated). (Ex. 4 8, Sec.11. )
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j.
I' 4
The importance of these drawings will appear in a merent.
)
The second report by Dames and Moore, 2 December 1960 (Ex. 48, Sec.
i 10, p. 2), states that "for a nuclear plant the most advantageous rock elevaticn is about ten feet below plant grade. " This report, tit:ed " Preliminary Soils In-i vestigation and Seismic Survey," contained the results of further borings in the
)
j vicinity of Campbell Cove which showed " bedrock" te be not only severely frac-i This Dames-j tured and jointed but to lie at unexpectedly _ great depris as well.
- and Moore report also commented on the earlier seism:0 survey, as follows:
i "SUBSURTACE CONDITIONS:
i 4
The seismic refraction survey conductec in Phase-I of this in---
l l
vestigation showed bedrock to be considerah:y shallower than the l
test borings disclosed in Phase II.- The discrepancy in bedrock ele-j vations is due_ to the difficulties in' interpret;ng seismic velocity j
data for a four-phase system where the deptr. to rock rapidly in-creases or decreases along the seismic line. An indicated inter-i mediate velocity layer above the granitic rock has further compli-l cated the' interpretation of the seismic data. This uncommon occurr--
i ence results in a situation termed the " case f the. missing layer. "
l In other words, the velocity of this layer is n:t found on the veloci-j_
ty section, and depth calculations are too sr.silow, as generally j
the case here. The one test boring drilled ir. Phase I to correlate j
the seismic work had indicated excellent agreement between in-j; terpreted and actual c'apths to rock. It is obvious now that.more test borinris should have been drilled g correlate with the seismic data in the areas of the steeply sloping rock." (Emphasis added.)
{
Nevertheless, the preliminary designs for the facility, prepared by Dr.
Housner and included with his report of January 1961 Ex. 48, Sec.12), show p
the " bedrock" at roughly ten to twenty feet below plan: grade. Dr. _Housner's Figure 1 (plot plan), and figures 3 and 4 (sections thr: ugh ~ the reactor) are in-i cluded as Appendix H of this memorandum.
The proposed facility consists of several components, two of which are
[
of particular. interest to this discussion-the reactor bu;1 ding and the turbine-gen-erator.- In plan view, these two components of the fac;lity look roughly like a c
w.
+we-
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F"'-'
F*-
wooden gavel, with the reactor building representing the. head of the gavel and the turbine-generator building representing the handle.
Immediately after receipt of the second Dames and Moore report, on 8 December 1960, Mr. Worthington wrote to Dr. Housner,' forwarding the report and also enclosing "two prints of an unnumbered drawing entitled Scheme 7, Bodega Bay Power Plant" (Appendix G) (Ex. 48, Sec.11). He also enclosed a-copy of a letter to G.L. Coltrin of Applicant's engineering department, from Dr.
Tocher, dated 11 November 1960, in which Dr. Tocher referred to the plant lay-out shown in Drawing SK8098-7-A (Scheme VI) and asked: "Sometime I would be interested to see how you have-rearranged the plant layout to avoid the problems presented by the bedrock's being deeper than originally anticipated." (Ex. 48 Sec. 9).
From the evidence available in Exhibit 48 it is difficult to sort out pre-cisely what happened at this point in the history of the interactions among Ap-plicant and his consultants. But Drawing SK8098-7-A, Scheme VI, shows the plant layout with the turbine-generator extending in a southerly direction from the reactor building, where the so-called bedrock lies deepest. The fact that the turbine-generator would rot be founded on bedrock apparently prompted the question by Dr. Tocher noted above, regarding rearrangement of the plant layout.
Scheme VI is approximately the layot t submitted to the Commission on 9 March 1962' by Mr. Worthington as " Site Plan," Exhibit 2-A (Appendix C).
However, the act of sending two prints of the unnumbered c'rawing, labelled Scheme VII, to Dr. Housner on 8 December 1960, apparently prompted Dr. Housner to infer that this was to be the final plant layout. This layout is used in Dr. Housner's Figure.1 in his final report of January 1961-the turbine-
generator, the handle, extends in a westerly direction from the reactor building, along the contour of bedrock on the flank of the sedimer.t filled valley. It is approximately 90 degrees out of line with the actual layout submitted to the Com-mission as final.
It would have been reasonable for Dr. Housner to make such an inference since he received two copies of the higher-number Scheme VII six months after naving receivsd the copy of Scheme VI. Whereas Scheme VI is similar to the lay-out submitted to the Commission in Exhibit 2, Dr. Housner proceeded to design a facility in accordance with the abandoned Scheme VII. Exhibit 48 shows no active effort by Applicant to disabuse Dr. Housner of this error.
One object of this portion of our discussion is to show that the Commis-sion's conclusion given in Interim Opinion No, 64537 regarding the foundacions for the proposed facility is belied by the Commission's own record. To do so we must show that (1) the four.dation for the reactor is in fact nat solid rock and (2) what passes for rock on Bodega Head is much deeper than Applicant's testimony has led the Commission to believe. The first part of this demonstration is not toe difficult; but the second part involves pinpointing the precise location of the facility, since the " bedrock" which forms the sediment filled valley at Campbell i
Cove is not' level but varies sharply in elevation.
The problem of locating bedrock was again described in Dames and Moore's f
third and final report, " Foundation Investigation," dated 30 = April 1962, "the case on the ' mis sing layer'. " (Ex. 48, Sec. 17). Certain peculiarities of the site had twice led Dames and Moore to discard the conclusions from preceding seismic
- su rve y s. This last report notes, for example, "the additional borings drilled for final design purposes indicated a serious discrepancy between the actual bedrock-i
. -. _. -..,,.. ~. _. -.
-,.--.,_..,._.,,,,.,n.,.--
r surface and that wnich was based on the preliminary studies." T: eir report con-cluded that the earlier conclusions should be abandoned and that there was no sound way to resolve the ambiguities between the earlier and later data, Some of the data from the last Dames and Moore investigation were made available to Applicant in the form of sketched cross-sections of the reactor, showing tne level of bedrock and overly 1rg material, dated 2 February 1962, be-fore the final report was submitted (Ex. 48, Sec. '15). They included the find-ings of additional borings at the reactor site, including Boring 16 at the geo-metric center of the reactor capsule, Boring 14 at the juncture of ine reactor and turbine-generator buildings, and Boring 20 rear the south end of the turbine-gen-erator. (Ex. 4 8, Sec. 17. )
The layout plans given in Dames ard Moore's report of 30 April 1962 are chronologically the first evidence given in Exhibit 48 of the at.tual location cf the proposed facility. The report notes that "With the exception of the fresher portions of the rock (i.e., the bottom 20 to 35 feet), it is anticipated that the entire excavation can be made without the necessity for blasting." The Ameri-can Geological Institute's Glossary of Geology and Related Scie'nces states that "to the engineer, the term rock signifies firm and coherent or consolidated sub-stances that cannot be excavated normally by manual means. " Not only would the bedrock on which the reactor would be founded not meet this definition, but
- as noted earlier, the rock-such as it_is-is m_uch _ deeper than the record _of Ap-plicant's formal testimony. would lead one to believe. At the center of the re-actor, the depth to " bedrock" is approximately 30 feet below sea level and the rock is described by Dames and Moore as follows (Ex. 48, Sec.17, Log of Boring 16):
-____ ____N_O
" white and black quartz diorite (severely jointed into mod, fresh blocks up to 3") with small shear zones (joints 6 1
shear zones altered to clay) (grading into harder & fresh blocks up to 8") (little or no alterationin joints) (few shear zones)"
Besides showing the " bedrock" to beof poor quality, Dames & Moore's investigation also showed that.as the bedrock crosses the site of the reactor vee-sel at from 50 to 65 fem below yard level, it inclines sharply downward in a scuth-erly direction. As a result, the turbine-generator foundation slab does not lie on even the poor quality rock found in Bodega Head. The turbine-generator slab e
is founded 5 feet below yard level, 20 feet above sea level, and, according to Boring 14 is underlain by approximately 65 feet of sands and clays at the point of juncture with the reactor building. At the southern extremity cf the turbine-l generator building, the depth to bedrock is even greater. At no level in Boring i
l 14 was rock of satisfactory compressive strength discovered.
i The record shows that Mr Worthington was fully cognizant of this fact 1
f when he wrote to Dr. Housner on 27 February 1962 (Ex. 48, Sec.15): "There is l
evidence of some clay material at the depth at which the turbine generator founda-i tion slab will be four.Jed. "- Thir seems to us to be a misleading description at best.
4 In the same letter, Mr. Wortnington also wrote: "The quality of the rock is inferior Lq our original assumption of ' solid rock. ' [ Quotes in the original.] Actu-ally,_ the granite rock is highly weathered at the earth-rock contact and 1s-highly jointed at lower elevations " (Emphasis added.)
l 2
Applicant's Testimony Concernino Foundation Material 4[
Despite these remarks, Mr. Worthington testified under oath several times j
during proceedings before the Commission that the facility would be founded on
.,._._.._m
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solid rock. With only seven days intervening from the time he signed the i
above quoted letter to Dr. Housner, Mr. Worthington took the stand in hear-
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ings before the Commission (7 March 1962) and testified under direct examina-l 3
tion (Tr. 42):
I I
j, Morrissey:
"So, the plant will be situated on a rock base of j
this type rock, is that right ?" (Emphasis added.)
s Worthington: "The foundation will be located in solid orano-j diorite. " (Emphasis added.)
l j
Turther, under cross-examination by the Commission's staff engineer.
F Hollis, regarding possible future changes in the plant design, Mr. Worthington I
l said (Tr. 383), "the one thing that will not change is the fact that we are found-I l
Ing the reactor structure on solid rock and surrounding it with very heavy con-l crete structures. "
Mr. Hollis had been quite thorough in his cross-examination. Earlier while cross-examining Mr. Worthington, he had asked a question concerning the compressive strength and integrity of the underlying rock. Exhibit 48 shows that although the final Dames and Moore report of 30 April 1962 had not been submitted to Applicant, the data it contained had been made av'allable to Mr. Worthington when he replied to the above mentioned question concern-
.ing compressive strength and integrity of the underlying rock. He said- (Tr. 376) s that borings { Dames and Moore's) had been made and " indicate no leakage of water. This shows the formation is tight. It doesn't have any open seams or anything that would indicate that this not a 100 percent suitable foundation m aterial. " (Emphasis added.)
Yet in his letter.to Dr. -Housner of 27 February 1962 (Ex. 48, Sec.15),
in.which he had said that the foundation was " inferior to... ' solid rock '
highly. weathered,... hichly loin _ted.... "_ M__r._nWonhi
._*,n k aa a c e. 4.. s + m
~~
"When the rock at the base cf the reactor structure is exposed,.we can,11 found necessary, grout any seams or take other measures to improve the quali-ty of the rock. "
This statement may have been prompted by tne fact that only one bor-ing, Number 16, conduc'ed by Darr.es and Moore, showed such a " tight" condi-tion, and only between elevations -48 and -62, (below mean low low tide) (73 to 87 feet below yard level of 25 feet) ( Ex. 48, Sec.17).
-Mr. Worthington was consistent in his testimony as to the " solid rock' foundations at Bodega Bay. Late in the proceedings (Tr.1004), under cross-ex-amination by a member of the audience...
Q.
"Is this a better site than the Humboldt Bay {eacto] site as far as the foundation is concerned ?"
Worthington:
"I believe so, yes. "
Q.
"In what respect ?"
Worthington: "Well, it's on solid rock. " (Emphasis added.)5 5
The authors:of this memorandum have not been able to make an analy-sis of Applicant's Humboldt Bay Unit No. 3, a nuclear power plant which is un-dergoing final fuel loading at the time of this writing, However, the AEC pub-11 cation, Nuclear Safety, contains a discussion of the Humboldt Plant with re-spect to earthquake hazards, which suggests conditions remarkably similar to those we have discovered at Bodega Bay. Portions of this document are repro-duced below for the Commission's convenience:
"The possibility of earthquake damage has aroused' considerable interest, probably more than it generally deserves. Most of the hazards reports provide the information required on this subject by_
a short statement that the site is in an area where earthquakes are infrequent and of low intensity, and therefore.the hazard from them is negligible. Such statements-are usually based on dati taken from publications of the U.S. Coast and Geodetic Survey. In any case, reactors are constructed so that they are not susceptible to damage from any but the most intense shocks.. There might,. however, be.
an indirect hazard through damage to und ground pipes or wires
l i
~
i Other references of Applicant's witnesses to solid rock or a synonymous term occur as follows: Worthington, Tr. 169, 376 and 996; and Nutting, Tr.1233.
outside the reactor or through landslides or tidal waves, either of which might cause flooding; but, even including these somewhat re-mote possibilities, the total earthquake hazard is very small in most areas.
"An exception to this generalization would be the case of a i
l reactor built b2 the water's edce on weak foundation material in an area of frequent earthouakes of high intensity. One succested l-site nearly meets these conditions. It is on the edge of a bay j
and is underlain to a depth of 20 ft. largely by recently deposited l
unconsolidated beds of clay and silt. The nature of the material below this is not clear. In the geology section of the safeguards, l
report (footnote at this point in the text refers to Table V-1, page 76 of the document, reactor No.11 of 20 reactors considered, wnich is identified in the table as 'Humboldt Bay, BW.4,163 My (t).], the material is described as 'slightly consolidated gravels, l
sands, and clays with the majority consisting of the finer grained materials;' that is, largely clay and silt. In the section on earth-quake hazards, however, the same material is referred to as rock l
and is described as a ' fairly well indurated series of mudstones, siltstones, sandstones, and conglomerates. ' The drilling record l
calls the material clay and sandy soi;s with some sand and gravel.
l "There is also some ambiaulty as to the intensities of the earthquakes to be expected. The section on earthquake hazards lists eight shocks of intensity VIII (modified Mercalli scale) and one of intensity IX over roughly the last hundreo years, but the shock of intensity IX is discounted because the record is old and uncertain.- The authors conclude that intensity VIII is the maxi-l mum shock which should be expected in the future. The ambiguity as in the word ' expected. ' With at least nine shocks of intensity VIII a matter of record, more shocks should certainly-be expected, but the report appears to give the impression that there is no need to plan for anything of greater intansity. There is a very creat difference between a reactor situated on rock and subjected to an earthquake of intensity VIII and one situated on water-i.aturated clay and silt and subjectea to a' shock of intcnsity IX.... "
(Emphasis added.)
" Geologic and Hydrologic Cons'iderations 2n Power Reactor Site Selection," Nuclear Safety, A Review of Recent Develop-ments: Prepared for U.S. Atomic Energy Commissisn by Oak Ridge National Labo.atory: June 19 60, V.1, No, 4;- pp. 64-76.
. ~
I The f;tst reply given above (Tr. 42) is misleading s;.ce the term " plant" throughout the proceedings was generally used to refer to the reactor and related structures; yet tne closely related turbine-generator will not, contrary to Appl 1-3 cant's testimony, be founded on solid material of any kind b : will be underlain p
by more than 60 feet of sand, silt, clay and decomposed wo:t before even badly decomposed granodlorite is reached. The other testimony ccncerning " solid rock" flatly contradicts the results of Dcmes and Moore's foundation investiga-tion and the resulting letter from'Mr. Worthington to Dr. Housner. Altogether a melancnoly demonstration.
For example, when cross-examined by Mrs. Rose Gaffney of Bodega Bay, (a portion of whose land on Bodega Head had been condemned by Appli-cant for the proposed facility site-See Appendix K, pp.18-19), Mr. Nutting hed the following to say (Tr.1233):
Mrs. Gaffney: "Mr. Nutting, you were a witness in my eminent do-main proceedings when P G. &E. took my land by condemnation proceedings ? "
Nutting: - Yes, Mrs. Gaffney, I was. "
Mrs. Gaffney: "And you testified at that time as to :ne qualifications of what made it.an excellent site for your plant, did you not?"
Nutting: "I believe I did, yes. " ~
Mrs. Gaffney: "And you found it was a very suitable site because of the solid-granitic basement upon which the plant woulc be lo-cated ? "
-Nutting:
"I would have to check on it, precacely wha:! Mid, but in.
. general, yes. "
Mrs'. - Gaf f ney: "It had to be or P.G. 6E. wouldn't be considering.2t, wouldn't it ? "
Nutting: "Tha t's correct. "
)
i 30 1
.i i
Under direct examination during the second set of hearings (Tr. 528),
I Mr. Worthington had appeared somewhat more certain of the foundations than i.
Mr. Nutting, when he testified:
l "The foundations of the Bodega site are particularly suita -
l ble, since it will be possible to place the plant and its reactor l
j en a solid cranitic formation. This is important, since the l
ability to locate the plant p_r1 rock will_ greatly reduce.the effect of_ shaking, which may occur as a resalt of ta earthquake."
(Emphasis added.)
This misapprehension was compounded sev>ral times by Applicant's i
nunsel, Mr. Morrissey. At the conclusion of the untire-proceedings, aftec the Commission had ordered rubmission of Exhibit 48, he cited (Tr.1480) the
)
testimony given by Mr. Worthington on Tr. page 159. And in summary of the first set of hearings (Tr. 504),-he concluded that "The plant is a nuclear plant l
ar.d is to be located on a very firw ack_ base... " Kmphasis added.)
It should be reiterated that by Mt havin's had access to the substance
[
l j
of Exhibit 48 at the time of the proceedings,-we were precluded from the oppor-
~
l tunity to cross-examine Mr. Worthington and Mr. Nutting by confronting them with their prior signed statements which were inconsistent with_ their testimony.
l We also feel compelled to re-emphasize our earlier inference in this memorandum that Applicant. proceeded with plans for the Bodega Bay reactor de-l spite grave reservations from his own consultants.
I Eor example, in the conclusion of the; discussion section of their report -
of 14 September-1960, Tocher and Qualde recommended the location of six bore holes.(Ex. 48, L Sec. 8, p. l0), four on land and two under water in Campbell l-Cove "to confirm the existence of quartz-diorite'at shallow depth-under the cove and adjacent beach."' In light of the above evidence regarding the ex-
~
.u.-..
j 31
~
tremely poor quality of and the great depth to bedrock at Campbell Gove, the i
two concluding paragraphs of Tocher and Quaide's report (p. ll) are of singular interest:
"The primary purpose of the recommended borings on land also is to confirm the conclusions drawn from available geo-logic and seismic evidence regarding the shallow depth of the top of the quartz-diorite under the proposed site of initial con-struc* ton (Unit #1, as shown on Drawing SK 8098-7-A).
"It is important from the standpoint of ability to withstand strong ground shaking that the buildings and any other larce appurtenances be constructed on foundations resting on the hard quartz-diorite bedrock. Should the borinos reveal that bedrock will not be reached at practicable depths where it is proposed 10, erect structures, serious consideration should be given to 0
alternate sites. " (Emphasis added.)
l As we nave shown, the worst fears possible concerning the foundations were confirmed by Dames and Moore's later studies. The approximate borings recommended by Dr. Tocher were not performed until a year and a half after Toch-er and Qualde's report was submitted. No hard bedrock is present; what passes I
i l
for bedrock is not on?y very deep but, rather than being a " platform" it slopes l
l steeply under the reactor and misses the tilrbine-generator-a large appurtenance
-by 60 feet or more. Despite Tocher and Qualde's conclusions; despite the evi-L dence; despite the world-renuwned treacherousness of the San Andreas Pault; despite an 8 billion curie fission-product inventory; despite the great public in-terest in this, the largest nuclear reactor yet approved; and despite the location of this reactor upwind from a city of several mil!W inhabitants, Applicant has actively and cynically misled both the general pubi.e and the Commission and-l has anxiously accelerated its plans and its actual construction at the site. The 1
authors of this memorandum are prompted to observe that if all the data were dis-played before the public eye, the Bodega Bay Atomic Park may easily' stand as an
~
l 1
l-l 32-l i
j irresconsible project indeed.
Anticipated Seismic Shock at Bodega Bay t
i Tocher and Qualda's report of 14 Sep' ember.960 contains a comprehen-i sive survey of "Earthqual as Felt at or Near Bodega Hsad" from 1838 to 1960.
Two different scales are t. sed by experts to describe carthquake shocks,_ in J
a
{
terms of different application. " Magnitude" of a snon. is generally described t
l by the f amiliar Richter Scale measured on seismograp s.
The " intensity" of a i
j shock may also be described, but this is a more or leis subjective description of the damage caused by the shock and may vary in ddierent localities for the 4
l same shock as measured on a Richter Scale. The sca;e for " intensity" is the Modified Mercalli Scale, employed in the United States since 1931.
i On the basis of their preliminary conclus;ons-before borings-as to i
the nature of bedrock at Campbell Cove, Tocher and Guaide anticipated that an-other earthquake comparable to the famous San Francisco earthquake of April 18, J
1906, would result in damage at a maximum Modified Mercalli Intensity of about l-Vill.
However, in light 55 lato. evidence, principa.!y the Dames and Moore report of 30 April 19 62, Dr. Tocher wrote to Mr. Wort.:.ngton on 10 June' 1962, after the close of the Commission's hearings and apparently while Exhibit 48 was being assembled, as follows (Ex. 48,_ Sec. 21):
...The highly unusual design cf the s:ructure (un'1que in my experience, but perhaps similar in some respects to underground ICBM launching ' silos') and tne ;ossible ' gravi-ty of the consequences of wall failure lead rne to urge strong-ly that special consideration and analysis be given to the possibility of such failure because of the str:ng shaking-and'possible mass movements of the sands and clays by a-
-major ;arthquake in the nearby San Andreas f ault zone...
_.-_______.._._____7
.I l
j-33
,i J
"With regard to conclusion no. 6 (p.12) (of the 14 J
j September 1960 report)...and inasmuch as muen of the-yard i
i r
I surf ace as it is now being considered will be underlain by j
40 to 80 feet of (possibly water saturated)' sedimentary de--
posits, I feel that a Modified Mercalli Intensity of IX should i
j be anticipated... "
An abridged description of Modified Mercalli I. tensity IX is given in 4,
l Tocher and Quaide's report as follows:
1 j.
" Damage considerable in specially designed-structures; j
weil designed frame structures thrown out of plumi : great l
in substantial buildings with partial collapse. Bundings shifted off foundations. Ground cracked conspicuously, i
Underground ripes broken. " (Emphasis added.)
i b
The Commission's attention is directed to Exhibit 2-B (Appendix C) l showing a cross section of the proposed equipment location, with the proposed 1
i novel containment system underground, i
Tocher and Qualde's report also lists a severe earthquake scalewhere i
f in the region in June 1838 when the country was uninhabited by whites. The i
available evidence lead Tocher and Quaide to conclude, however, that the in-tensity was approximately comparable to Modified Mercalli Intensity X.
They f
also give an abridged description of this intensity as follows:
i l
"Some well-built wooden structures destroyed; most masonry and frame structures destroyed with foundations; ground-'
r badly cracked. Rails bent. Landslides considerable from f
river banks _ and steep slopes. Shif ted sand and mud. Water -
splashed (slopped) over banks. "
(Emphasis added.)
Of course, it is impossible to predict with' great accuracy. the intensity of future earthquakes, Nevertheless, the similarity.of certain features in the vicinity of the Bodega Bay and Point Reyes region to conditions in the Se>uthern
(
Region of the Earthquake Zone where the catastrophic Chilean ear *hquakes of l
l May 1960 occurred, make it not unreasonable to assume that eventually there i
will be a shock at Bodega Bay ranging possibly up' tc Modified Mercalli 4
,e--,
e
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a,
,.--o-e--
r-:,
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..we,,w. m w. nw w w..v r w
-,v- - +-a =
- s s w a - v r e
- Intensity XII. The description of this damage is eloquently abridged in Tocher and Quaide's report:
" Damage total. Waves seen on ground surf aces. Lines of sight and level distorted. Objects thrown upward into the air."
A Possible Reason for Applicant's Action J
The material presented in this memorandura suggests that Applicant is prepared to run considerable risks in his expanding nuclear power program. -It -
is well known that the potential for wide public opposition is always present.
Therefore, there is a considerable incentive to continue with a program once launched, ratner than chance the public attention which would be drawn to a major change in plans.
i i
Exhibit 48 shows that at the time Applicant was proceeding with court action to condemn the land owned on Bodega Head by Mrs.' Rose Gaffney,.he first anticipated placing the power plant at Horseshoe Cove, at a point strad-l dling the San AndreasTault in an area that is clearly and abundantly fractured, it is reasonable to assume that the decision to move the plant' location from Horseshoe Cove to Campbell Cove was prompted by the discovery of the mag-nitude of potential seismic activity at' Horseshoe Cove, i
lt was not until after Applicant had purchased the Stroh property on the l
l tip of Bodega Head and was proceeding with his condemnation suit against Mrs.
Gatiney that the later reports of-Dames and Moore began to show that Campbell Cove, too, was a thoroughly unsuitable site for a nuclear power plant..-
Tocher arid Qualde's report, alone, should have been enough to deter Applicant from ~ proceeding at-Bodega Bay. 'And the reasons to abandon the site.
increased with each succeeding report from Dames and Moore-until the' third.
~..,
,...,_w_,_,,_,---_-,w___,_..._.,.,__._,-._,-.,_,_,,
i and final report of Dames ar.d Moore, completed while proceedings were underway t
before the California Public Utilities Commission, showed that nature had con-spired to deprive Applicant of the " bedrock" he had been confident of finding at Campbell Cove. By this time, however, it was too late; there was fierce momentum accumulated behind the project: land had been purenased and land costs were rising; consultants had been paid substantial fees for their services; extensive legal costs had been incurred; public attention to the pioject had been magnified by the heroic resistance put up by Mrs. Gaffney; the University of -
California's activities at the site had drawn further attention; the project had-been celebrated in the trade journals as a " breakthrough" in nuclear power; and the public relations effoct which accompanied the project had been vigorously launched-including an exuberant display in the August 1961 issue of PG&E Procress, a document distributed monthly to several million of the utility's customers.
And Atomic Energy Commissioner Leland J. Haworth had just previous-ly testified before the Joint Committee on Atomic Energy, pointing to the pro-posed Bodega Bay reactor 'as one of the more resplendent jewels in tne AEC's
[
civilian nuclear crown:6 F
I Commissioner Haworth:
"We' are talking here about a real installation; i
that is the first one is not particularly different from the second-
)
i one. Real prototypes in the true sense of the word.
"The proposed Pacific Gas & Electric plant at Bodega Bay will be one such plant, but others are needed. If they are built and if they operate a_s we expect, our early goal will have been -
i met. Data from full-scale plants, and-extrapolation from~ small-scale pilot plants, will be available, and utility managements-6Hearings before the Joint Committee on Atomic Energy,- 87th Congress,
~
~
t' 2d Sess., pursuant to Sec. "202" of the Atomic Energy Act of 1954: Mar. 20-23, 19 62, p. 48.
p L
,,a.-..--.-
_,_-..._..,......a.._.........-,,_..,_,._,.
..,,.u..,-._.._.~,-._.-
could make tnear decisions with greater certainty."
Representative Van Zandt: "What is the status of the Pacific Gas
& Electric plant?"
Commissioner Haworth: "They have had the:r hearings before the California Public Service Commission on Marcr. 7, I believe.
As far as I know, there is r.o decision t.anded down. There was apparently not much in se way of protest or anything of that sort. So it seems to be fang smoothly."
Altogether, according to the evidence submitted by Applicant's Vice President and General Manager, Mr. Shermer L. Sibley, in a recent proceed-ings in the Superjor Court of Sonoma County, Applicant had invested approxi-mately $1 million in the Bodega Bay project by the time the final Dames and:
Moore report indicated that the Campbell Cove site was generally unsuitable.
Applicant has formally averred in substantiation of this inferrence. In a declaration dated 28 March 1963 by Applicant's Vice President and General Manager, Shermer L. Sibley, filed in the Superior Court of Sonoma County in connection with a petition for writ of mandate or certicrarl brought by the As-sociation et. al. vs. The Board of Supervisors of the County of Sonoma, Ap-plicant states that between 9 February 1960 and 9 February 1961 alone, he in-curred extensive costs in connection with the project:
"(1) extensive site exploration and test borings were ac-complished for the sole purpose of constructing the afore-mentioned facility; (2) detailed engineering, geological and seismological studies were conducted."
At this point, herefore, nature had progressively conspired to. deprive Applicant of the foundations for the facility. _He was inen confronted _with two unsavory alternatives: (1) to abandon the site and acknowledge a gross error in -
planning, or (2) to proceed on the expectation that the error would lie undiscov-ered. Application to the AEC for a construction permit is proof of the choice I
4 Applicant has made.
But the decision to orient the p. ant layout in the worst possible way, considering the formerly unsuspected d rpth, coor quality, and steep inclination of " bedrock," as revealed by Dames and Mocre's last report, may have been prompted by future economic considerations.
Applicant has testified that he plans to install three additional nuclear units at Bodega Head (Worthington, Tr. 36) and that " Additional units which will be installed will be relat4vely less expensive because they wor t have to bear the initial site development costs. "
The early drawings of the plant layout contained in Exhibit 48, such as Scheme Vil, contain broken-line outlines of subsequent units planned for Bo-dega Head. Scheme VII, it will be recalled, is the layout showing the turbine-generator extending in a westerly direction from the reactor vessel. The layout shown for a subsequent unit would require (-xtensive excavation.
The summary of Exhibit 48 prepared.by Mr. Worthington notes that the later sections of Exhibit 48 deal with " variations in design from ' Scheme 7' and presentation of new information to the consultants."
Actually, the " variations" shown would be more accurately described as variations of Scheme VI, which shows tne turbine-generator extending in 'a southerly direction. The only evidence of-a " variation in design" is.the layouts provided in the extensive diagrams attached to Dames and Moore's Foundation Investigationi These diagrams show the plant in its proper location with the -
turbine-generator extending in a southerly direction.
They also show broken-line layouts of the subsequent plants which Ap-plicant planned to install at Bodega Head. Three additional reactors are shown
_=-
i each abutting the next, an a row extending westward e:ross tne' head like, so l
to speak, piglets at a trough. Attached to each of the subsequent reactors is a turbine-generator building, extending southward frc= the reactor buildings, i
l This arrangement, as the Dames and Moore layouts s.ow, permits cheap con-l struction by simply extending the present excavation westward. Pour reactors 4
}
can, by this scheme, be constructed in_a pit that wou'.d only nave accommo-l i
dated two plants as oriented on the earlier schemes.
1 l
The advantages of_ this arrangement measured in terms of the cost of-installation for additional units is clearly substantial. The advantage in terms i
of reliability of operation and of public safety is ques:lonable at best, I
DLscrepancies between Exhibit 18 and Preliminary Hazards Analysis Submitted
.t_o the AEC As noted earlier in this memorandum, the Commission's ' Interim Order i
No. 64537 stants a certificate of public convenience and necessity to Appil-cant, subject to certain conditions, including "that proper authority hes been j
secured from the Atomic Energy Commicsien to construct the nuclear energy i
1 l
Pla nt,,.. "
i As we also noted, Applicant has pursued sat:sfaction of this condition through application on 28 December 1962 to the AEC f:r a Class:104b (con-
[
struction) license -(AEC Docket No. ' 50-20 5). This ap;;ication includes:an i-Exhibit C, '.' Preliminary Hazards Analysis," which conveys certain data to the AEC regarding earthquake hazards.
This document, on file for pubLc inspection at the U.S. - Atomic _ Energy L
Commission's San Francisco Operations Office, appears to be the Applicant's i
l complete report to the AEC. The fact that its treatment of earthquake-hazards -
.._-_.-._..._,__1,.
..;., -.a,.-.._...-..._;
u
-. ~..
jz ciffers substantially from Exhibit 48, submitted to the CPUC, snould be of la-tarest t a.he Public Utilities Commission-particularly.in light of the way 'n which it differs.
1 The Preliminary Hazards A*alysis contains two appendices related to earthquake hazards. One consists of Dr. George Housner's report of. January 1961: the other is the report of Drs. Tocher_ and-Quaide. Both of these ceports l
are mentio1.ed earlier in this memorandum and are included in Exhibit 48'of CPUC Application No. s ~808. However, _it is of considerable significance that Applicant has not-so far as the public record _ shows-submitted any of the Dames and Moore reports to the Atomic Energy Commis sion.
Further, the report of Dr. Housner which is _inclu'ded in the " Preliminary Hazards Analysis" is the same re,trt, discussed earlier in this memorandum, snowing the plant oriented 90 degrees from its propecposition at Campbell l'
Cove, and showing the " bedrock" at levels where. Dames and Moore later found water saturated sand, silt, decomposed wood and;so.forth. _-The Hazards An-c alysis contains no discussion of the fact, shown in CPUC Exhibit 48, that Dr.
Housner's report had to be largely discarded in light of'the April 1962 Dames and Moore report.
Further, the conclusions which Tocher and Quaide. arrived at in their-14 September 1960' report to Applicant have been altered in the AEC Preliminary Hazards Analysis, without discussion of the reasons.and in an apparent attempt-to minimize their significance.
Tocher and Qualde's report contained 7 conclusions, which were partly in the nature of implied recommendations for further investigation into the foundations for the proposed facility. When the Dames and Moore report.
~
of 30 April 1962 was made available, Applicant's Chief Civil Engineer, J. Dean
-Worthington, wrote to Dr. Tocher on 15 May 1962 (Ex. 48, Sec.18) asking if any of his seven conclusions would change in light of the latest Dames and Moore report.
Dr. Tocher replied in a letter dated 10 June 1962 7 (Ex. -48, Sec. 21)-
-that Conclusions 1, 2, 4, 5, and 7 remained unchanged. His letter then dis-cussed Conclusions 3 and 6, the original versions of which were as follows:-
"3.
The quartz-diorite thought to underly the site near sea level-will provide a much better foundation than any other geologic formation en Bodega Head. If borings fail to show quartz-diorite near sea level at the site (as suggested by. seismic and geologic evidence) the characteristics of the unexpected material should be studied carefully to determine if it is suitable foundation material for massive structures so close to the San Andreas fault zone."
"6.
All power plant buildings and appurtenant structures should be designed to resist an earthquake of Modifaed Mercalli Intensity VIII, or to provide a margin of safety, IX.-
(The quartz-diorite should provide as good foundation with respect to the hazards of ground shaking in earthquakes, as any rock formation to be found in the Bodega Bay region. This fortunate circumstance is largely counter-balanced by the immediate proximity of the San Andreas i
fault zone.)"
i l
Dr. Tocher discussed his earlier Conclusion No. =3 at considerable L
length, but with the clear purpose of stating that conditions revealed by Dames
{
and Moore's investigation made the Campbell Cove site -a less favorable o'ne I
than the earlier Conclusion No. 3 had indicated. He observed, for example, s
that further studies recommended-by Dames and Moore would " involve collabora-tive efforts by a structural engineer and a soil mechanics engineer. -In the event l
- their findings were unfavorable or inconclusive, then serious consideration should 7We consider it to be of especial significance to the substance of this j
memorandum that the correspondence-herein discussed took place after the close of hearings before the CPUC.
I
l be given to re-siting the reactor in a location where tne quartz-diorite bedrock lies at a depth shallow enough that there can be no ;;ossibility of wall f ailure from seismic forces acting on the sands and clays. "
4 And with respect to his earlier Conclusion No. 6, regarding the an'-
ticipated intensity of an earthquake, he replied that inasmuch as much of i
the yard surf ace as it is now being considered will.e underlain by 40 to 80
~
a 1
i feet of -(possibly water saturated) sedimentary depos;ts, I feel'a modified.
s.
Mercalli intensity _ of IX should b'e anticipated at 'the site with the plantLlay--
q out as shown on Plate 1 of the April 30, 1962 Dames and: Moore report. "
t l
Nevertneless, these conclusions, as they are presented to the_ Atomic
"?.ergy Commission in the " Preliminary Hazards Ana;ysis" have been unexplain-1 i
edly altered to give the impression of more favorable conditions than would i
1 have ben suggested by the original version of the conclusions, before the i
l April 1962 report of Dames and Moore confirmed the worst possible fears about b
the site.
I For example, Conclusion No. 3 as given in the " Preliminary Hazards r
Analysis" reads as follows (compare with the versi:n given above):
e i
The quartz-diorite thought to underly. ne site near sea level l
"3.
will provide a much better foundation than any'other geologic l
formatton on Bodega Head. (The presence -of quartz-diorite has been positively identified by detailed exp;aratory borings.)"
i In Conclusion No. 6, given above, regare:ng good foundations pro-vided by solid bedrock, the sentence,"This fortunate: circumstance is largely counterbalanced by the immediate proximity of the San Andreas fault zone,"
j..
has been deleted from the version of Tocher and Qualde's report submitted to l
l the AI'C.
f Other of Tocher and Qualde's conclusions have been altered as well.
L
! 4 j-f Conclusion No. 4 in the original contatns the statement that "The quartz-diorite l
1s strongly jointed and is faulted otrold minor faults;" which is changed.in the f
" Preliminary Hazards Analyst. " toi "The quartz-diorit'e shows evidence of old 1
minor faults. "
4 l
Conclusion No. 5 in the originel Tocher and Quaide report contains the l'
j following sentences: "At least one and perhaps two or more major earthquakes F
can be expeued near the site within the next century.' These may be as strong 2
i-l or even somewhat stronger than the California earthquake of April 18,-1906."
j These have been deleted from the version of Tocher and Quaide's report sub-mitted to the TEC.
i l
And a plural reference to the frequency of future earthquakes' in Tocher i
[
and Quaide's original report is changed to:a singtlar reference in the version d;-
rubmitted to the AEC.
l There is no public record, either at the CPUC or the AEC, to indicate i
a
[
any basis for these changes. Indeed, the record whien is available would sug-ll gest that any justified changes in Tocher and Quaide's conclusions would be i
in the opposite direction-toward pointing to the Campbell Cove _ site as less
~
i suitable than originally assumed.
I It should be noted that Dr. George Housner nad advised-Applicant that I
he can design a " safe" facility at the Campbell Cove site, despite the evi-dence from Dames and Moore's investigation. However, ~certain language in
~
the correspondence from-Dr. Housner included in Exhibit 48 ' leads' the authors a
i of this memorandum to be strongly dubious of the information Applicant may i
_ have forwal ded to Dr. Housner.
i F<.
~ ample, the preliminary sketches of cross-sections.of the reactor k
a.-
l-1 4 3-l 1:
i-(Appendix I), showing the nature of earth and bedrock crossing.the site-as.de -
E_
1 termined from borings 12,13, - 14,- and 16-describe the quartz-diorite as " coa'rse-i
- grained, slightly_ weathered, fractured & jointed." Purportedly, these ' sketches were prepared by Dames and _ Moore on~ 2 February 1962 and forwarded to Dr.
{
Housner by Mr. Worthington-in his letter of-27 February '1962 (Ex. 48, Sec.15);
(
l but the final Dames' end Moore report submitted in April describes this 'same
}.
j material as " white and black quartz.diorite-(severely jointed into. mod, fresh i
i
)
blocks up to 3") with small shear zones (joints and ' shear zones altered to clay).
I i
(grading into harder and. fresh blocks up to'8") (little or no alteration in joints).
1
)
i (few shear zones). "
~
The record provides-no means for verifping the nature of the 1nforma-l tion of foundation conditions sent to Dr. Housner by Applicant. It also pro-t j
vides no evidence, as noted earlier, of any active attempt by Applicant to' dis-l l
abuse Dr. Housner of his impression that the, ;nt >
out would be similar to 1
f'
--the abandoned Scheme VII, rather than Scheme VI, which approximates the de-1 l
signs submitt'ed to the Atomic Energy Commission.
1 i
f' V.
l ARGU MENT -
3 j.
We feel compelled to draw the Commission's attention to a document which has received wide acclaim within the more responsible elements of the i
engineering profession. This is the amicus curiae br:ef before the United States 4
Supreme Court in Power Reactor Development Company vs International-Union.of Electrical, Radio and Machine Workers, AFL-CIO, Jej _ab (No. 315 and 454, s
- April 1961) by Professional Engineer Adolph J. Ackerman.
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i Mr. Ackerman argues persuasively that the Price-Anderson amendment J
to the 1954 Atomic Energy Act, providing, at a token premium, $500 million in-4 J
demnity coverage to a privately constructed nuclear power plant, has encouraged unprecedented abandonment of engineering responsibility in the atomic power 4
field. A copy of a popular version drawn from Mr. Ackerman's brief and. pub-i l
lisned in the American Engineer (Jan.1963) is attached as Appendix J to this i
memorandum.
We feel that the situation outlined in this memorandum regarding Ap-4 plicant's choice of the Bodega Bay site-his misuse of the Commission's-trust i
.}
during testimony under oath, and his misuse of the trust implied in deferring i
l certain concerns for safety of the facility to the Atomic Energy Commission-l
]
is the clearest example to yet appear in the ' atomic power field of the situation j
described by Mr. Ackerman.
)
The Commission is reminded that there have been no public hearings l
on the material in Exhibit 48, that the Exnibit was lete-filed more than 30 days i
after the close of the hearings, and that its contents are ' extremely complex, i
The summary of the exhibit is not consistent with the exhibit itself, the organ-i 3
ization of material in-the exhibit is confusing, and, therefore, the layman.is likely to be intimidated from probing it further. We were stimulated to inves--
y tigate the exhibit to the degree evidenced in this memorandum after having in-spected the " Preliminary Hazards Analysis" to the AEC.
j' A close reading of the Commission's Interim Opinion No. 64537 sug-5 gests that the Commission also. turned away from the body of the Exhibit. On page 4 of the Interim Opinion, the Commission takes specific notice of Ap-plicant's testimony regarding the desirability-of Bodega Head for a nuclear
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-1+a'-SL Jf-=i-e power plant, because it possesses "a solid granitic type of rock providing an excellent foundation. "
d On page 19 of the Interim Opinion, the Com:2ssion takes especial note of concern over.'?the serious consequences which could ensue to Bodega Bay, to Sonoma County, or to an.even larger area, if high-level radioactive materials a
were released as a result of damage to the plant from earthouake. "'
4 This concern was-accentuated by 'introductior. of Exhibit 39, a map from the California Division of Mines and Geology Bulletin No.118, showing "a trace of a fault running directly through Bodega Head in a northwesterly di-rection. " The Commission notes with respect to this map that " applicant's civil engineering witness testified that the consulting geologist enga'ged by applicant to specifically study the area in' question reported that he could find i '
no signs of active faulting on Bodega Head...This testimony was supplemented and substantiated by applicant's late-filed Exhibit 48."
(Emphasis added,)
And yet Applicant's civil engineering witness nad also testified that the foundations for the proposed facility were '" solid rock," while Exhibit 48 shows that this same witness had corresponded with= Applicant's consultant,-
Dr. George Housner, to the effect that the foundations were inferior to solid' rock. This correspondence was based on detailed studies of the site, which are also included in Exhibit 48.
The Commission's Interim Opinion notes that the San Andfeas~ Fault Zone "according to the record is more than one-fourth mile east of the proposed reactor site. " Yet, Exhibit 48, which is' also part of tr.e record, contains clear -
and unimpeachable evidence that the fault zone'is less than one-fourth mile from the proposed ~ reactor site. That Applicant relied on this evidence is shown i
by his specific reference to it in Amendment No. I to the " Preliminary Hazards Analysis" submitted to the AEC in March 1963.
The Commission-is further anprised of the fact that the matter described above concerning the actual location'of the proposed facility at Bodega Bay, the actual nature of the foundations, the actual orientation of the reactor's related-structures, and the new material concerning possible earthquake intensities at the site have all been deleted from the seismological sections of Pacific Gas & -
Electric Company's Preliminary Hazards Analysis, Ext.ibit C, application to the Atomic Energy Commission for a Class 104b (construction) license. The AEC has been given only material up to Dr. Housner's report of January 1961, which, for example, shows the turbine-generator founded on " rock" in a wrong location and 90 degrees out of its actual orientation, rather than on 60 feet of possibly.
water saturated sands and silts.
In addition, the Applicant has altered the conclusions from Tocher and Quaide's report to lend an entirely different impression from that given by the original. No explanation for either the deleted or-altered data is given in the AEC application.
Therefore, the California Public Utilities Commission possesses in its files more recent, more accurate, and more pertinent infonnation concerning
~
the safety of the_ proposed installation than-do the Atomic Energy Commission.
or the Advisory. Committee on Reactor Safeguards.
VI PRAYER FOR' RELIEF As we observed in the argument above, there have been no public hear-i ings on the material submitted in Exhibit 48. The Exhibit'was late-filed = more
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than thirty days after the close of the proceedings on Application No. 43808.
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The Commission's Interim Decision No. 64537 was made on 8 November 1962, l
j _-
five montns after the close of the proceedings, p
As we also noted, the exhibit is exceedingly complex and confusing.
j At first, these qualities of the exhibit turned us away from it. But an inspection cf recent material submitted by Applicant to the Atomic Energy Commission re-3 lating to geologic and seismologic considerations brought us back to Exhibit 48.
1 The Association has been thorough and diliger.t in its attention to the s
4 subject matter of this memorandum, i
j The Northern California Association to Preserve Bodega Head and Har-i bor is prepared to present expert testimony of the highest calibre in support-of any or all of the technical statements made in this raemorandum, i
We are further prepared to submit additional dvidence showing that there has been in the recent past and will be in the near future active faulting at or i
j near the proposed reactor site on Bodega Head itself.
Due process compels that we enjoy the rightif cross-examination on f
all evidence submitted by Applicant to the proceedings of Application No. 43808.
i Tne subject material was delivered into the Commissior.'s hands more than a 4
month after the proceedings were concluced, i
p The Association' urges the Commission in the firmest possible terms to l
take all necessary steps to prevent a recurrence of the kind of sorry affair-4 which would appear to be characteristic in the embryonic nuclear power field-apparent from a reading of this memorandum, j
The Association urges the Commission in tre strongest possible terms to retrace its steps in granting ~ Application No. 43808, and to deny Application.
i
4 e
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4 1
[
'.No. 43808 on the grounds that the certificate with wn:ch it deals was obtained-1:
?
l through transparently misleading and impeachable te'snmony. The Commission l-is respectfully reminded that the subject testimony has misled the Commission -
3 itself, and that the Commission itself appears to have eschewed a close read-4 j!.
ing of Exhibit 48.-
The evidence suggests that a close reading of Exhibit 48 alone' l.
would have been grounds for the Commission to deny Application No. 43808.
~
l I
- The Association urges the Commission to re-open public hear.'.ngs on-i Application No. 4 3808-in light of (1) late-filed Exhib:t 48, '(2) new' evidence made available through Applicant's necessary relations with the Atomic Energy 9
j Commission, (3) the Association's unqualified assurance that new and related J
4 evidence can be brought to bear on this matter by experts with credentials of-j world authority in seismology and geology, and-(4) the grave and unprecedented k
l consequences to the public safety, convenience and necessity which would en-3 i
sue from an error in judgment on this matter.
h The history of the California Public Utilities' Commission is.a long i
l and noble one in the public service. The Commission is regarded throughout the Nation as a standard in public utility regulation. The Commission's powers l
are broad and are known to be broad. But these powers will be narrowe'd pro-1
' gressively--in proportion as they neglect to be exercised, ii Respectfu'ly submitted, i
David E Fesonen Executive Secretary i
I Samuel J. Rogers-Member, Board of Directors l'
The -Northern California Association to 1
Preserve, Bodega Head and Harbor, Inc.
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