ML20236B476

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Motion of San Luis Obisbo Mothers for Peace for Imposition of Stop Work Order.* Motion for Imposition of Stop Work Order on Util & Contractors,Applying to Plant as Well as Transmission Lines Extending from Plants
ML20236B476
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 10/14/1974
From: Apfelberg E, Silver S
SAN LUIS OBISPO MOTHERS FOR PEACE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20236A877 List: ... further results
References
FOIA-87-214 OL, NUDOCS 8707290124
Download: ML20236B476 (7)
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BEFO!Us 'IME ATOMIC SAnNY AND LICENSING BOARD /

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In 'the Matter of AIC Dockets 50-275-OL .

i PACIFIC CA3 A E!JI TRIC CO. 50-323-OL Units 1 and 2 Diablo Canyon Site HOTION OF SAN IllIS OBISp0 M01HERS FOR PEACE .):

FOR IMPOSITION OF A STOP WOPK ORDER J In accordance with the provisiens of 10 CFR 2.730, San Luis Obispo Mothers ,

For Peace (MFP) hereby moves for the imposition of a step work order on Pacific Can and Electric and its contractors, and applying to the nuclear ,

power plant, units 1 and 2 and reinted facilities at and around Diablo Canyon, as well as well as the trananission lines extendin6 from the plants.

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1. AlthouCh the mont overriding and dominating basis supporting the motion is the disorderly and precarious t reatment, on the part of P.C. and E., of the effects of a deficiently explored and poorly understood seismic environment, on the Diablo nuclear central e tation and spent fuel storace complexes, other bases will aleo be presented. We feel that the aum total of these bases is -

of profound concern to those interested in the public health and safety.

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2. We are referrinC te, inter ,alin, the existence of the giant 9tknile Hodgri Fault Zone (called lloskins-Criffiths Fault in earlier literature) 1 oriented approximately parallel to the centrr.1 California coastline and located ]

within 2 to 4 miles offshore'from the Diablo complex e t its point of nearest approach.

I 3 Those structures, systems, and components of the nuclear plant which are l

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important to nuclear safety, i.e.,' failure of which micht increase the severity ,

of a losa-of-coolant accident or result in the relenne of excessive amounta of radioactivity, are tenned Class I. Included in this group are ' structures, syst' ens, and components whone absolute integrity are essential to the safe shutdown of the reactor and/or essential to the safe maintenance of a shut-down condition. It is obvious that the denien of Class I strvetures for i seismic loading in one of the most profound aspecta.of nuclear reactor safety.

4. De Pacific can and Electric Co., by application dated January 16, 1967, ,

requented a license to construct and operate unit 1, a FWH at the Diablo Canyon Site. An alleged technical safety study of the proposed plant was ,

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contained in the applicant's Preliminary Safety Analysis Report (PSAR) and the nine subsequent enendments, all of which were contriced in the application.

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5 ne applicant, prior to submitting the January 16, 1967 application allegedly made a limited study of the seismic history of the Diablo Canyon area and, according to the FOAR determined the maxinum earthquake relative j l

to the then known faults in the general area.'On the basis of this " study", '

the applicant concluded, and apparently still holds, that there are four -

possible types of earthquakes that would result in maxirum accelerations at the site.

6. ,0f the four possible typen of earthquakes, %rthquake C" is described (FSAR", p. 2.5-13) as "Possible larga earthquakes occurinc on offshore fault systems that any need to be considered for the Generation of seismic sea waves..." and three fault syntems are identified whose respective offshore distances to the site are listed an 50, 420, and 420 miles.' Ve would like to 0

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esNasize that the offahnre neismicity was, in Januan 1%7, considered to be of significance only with respect to tsunami generation and was dismissed as

. a source of ground acceleration at the site in a flippant and apparently.

compulsive manner.

7. The above disninnal coupled with P.C. and E 'a celebrated but tragic and aborted efforte to site nuclear stationn at Bodega Head as well as at Point Arena may account for the utter lack of confidence the public has in P.G.and E's geolocy consultants. ,
8. In any case, P.G.&.E.'s quick reveiw of the "four possible types of earth-quakes" coupled with the outdated methods cited in References 12 and 26, pages 2 5-80 and 2.5-81, respectively, of the PSAR, lead to untenable quanti-fication of ground accelerations and response spectra at the site.

The response spectra for the 0.15 g ground acceleration earthquake ("B Modified")andthoseforthe0.20ggroundaccelerationearthquake("D")

were presented in the application. Together, these responne spectra constitute

'(double design b asis) response spectmm was also included in the application, and was alleged in be the result of what could be caused by the maximum potential earthquake. ,

S. 'Ihe above seinmic engineering studien, done in a discipline where the state of the art ' tan not hichly advanced, were completed four or five yenro before the San Pemando earthquake of 1971. Seismic studies, resulting from this quake, had substantial impact on the state of the art; in particular s

the accelerograph record of Pacoima Dam should have been incorporated into g ee 6

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4 studies to determine maximum' credible ground accelerations at the Diablo site.

- 10. As one looks through the Diablo }YAR plus its 17 amendments, one looks in v sin for a nention of the 1(J71 San femando quake, and application of Pacoima Das studies to Diablo structural criteria. The complete and categorical exclusion of San femando data is sininter at best and ruthless at worst.

With respect to these proceedings, the exclusion of San Femando data makes a mockery of the concept of a sound and complete reconi.

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Furthemore, in looking over the entire transcript (construction pemit, ,

i environmental, and operating license) of these proceedings, it is seen that P.C. and E. Invyers have deliberately prevented the develoment of a sound i record by, inter alta, demandinC the complete rejection of any testimony by experts in the field of atmetural engineering who were not on the P.C. and E. j payroll. We deplore the fact that, up' to this time, the presiding Atonic q l

Safety and 1icensing Board, has not seen fit to help, assist, or at the least, i encourace, the intervening parties to introduce expert structural engineering ,

l testimony despite its entreatles on the necessity of developing a sound record.

11. We do note, however, the P.G. and S. has made some offshore e eismic studies over the past eicht nonths or so. The fact that these twelf th-hour studies are being made now, fully 7 or 8 years af ter ths adoption of the 0.40 g acceleration criterion, munt he considered hi 6hly disorderly and demonstrates that P.O. and ]

i E. has a cynical attitude toward the public's henith and safety.

12. Over the pnnt year, the Pacifie-Amtic Branch of Harine GeoloEy of the I

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U.. S. Geological Survey han conducted studies of the' marine geology between Cape Unn Martin and Pt. Sal, South-central California Offshore, and has a published a Preliminary Report dated August,1974'(Open file heport 74-252). .

These state of the art and on-going studies were made producing high energy-deep penetration na well an hich resolution records.

13 'Ihese records have been analyzed by the U.S.C.S. and confirm and elaborate f i

.f upon, the existence and nature of the giant Hoscri Fault Zone. We quote from p.16 of the above-referred-to report: "All datn taken together succest that activity along the Hongri zone and other offshore faults has taken place, at .

1 east locally, in Pont-Visconsinan time in the area studied. The additional seismic reflection data that became available in July,1974, will be interpreted, I

evaluated and compared with the results shown in this report." j The significance of the above quotation is that the sum of all data available, at the preatn time, suCdests that there exists, within 2 to 6 miles offshore from the Dinblo power and storAEe facility, an immense active and" capable" fault zone at leant 90 miles in length.

The offshore earthquake of Richter magnitude 2.9 widely reported in the press several weeks ago further testified to the activity of the Hoscri Zone.

Since the very exintence of the Hongri Zone was first publicly alluded to by Hoekinn and Griffiths in a 1971 petroleum journal it vna obviously a hidden varinble at the time the 0.40 g criterion was finalised in 1966-1 % 7.

14. Unless one postulaten the existence of a symbiotic dollusion between the utilities and the Air it becomes impossible to understand why there exists such g .

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. i 6 t a paucity of matarial on seismic data and the effects of potantial quakes on .

the plant facilities. It is easy to see the AIE caught with another North j

Anna seismic problem in their hands, at a time when public confidence in the Alt has f allen ' deeper than ever. .

15. Projected figures for the State of California indicate that a ery large number of reactors (perhapn an order of magnitude greater than six) will be sited, on the coant, in San luis Chinpo County, and, therefore, on a line i

1 parallel to the giant offshore e arthquake zones. Thus the seismic is. sue is .

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B. CONCLUSION 1

16. The Diablo seismic exploration deficiencies cannot be explained away an the product of extreme enmplexity, intractable subject matter, or unruly  !

struccles between irreconcilable engineering philosophies. The failures in I

this instance nre in the nature of inattention and indifference.

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17. For the above reasons, San luis Obispo Mothers For Peace submits that in l view of the extremely wide powers accorded Licensing Boards, and in view of

, the alleged reculatory obligations of Licensing Boards, that' the Presiding Board exercise its authority to issue a stop work order as defined on page one of this motion. Such order should remain in effect until rologists can speak knowledgeably and in agreement about the ceinnic field around Diablo and of the potential effects of the seiumic field'on Diablo Clana I structures.

It is hoped that thin notion will be processed with expeditiousness so that .

it will not becone a moot question.

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l The motion prenented herein is etade by Elizabeth E. Apfelberg and Candra l l

Silver netiric as individuni parties and as representatives of San tulo Obispo I l

Mothers For Peace. l Respectfully submitted, f., g (6 h. <t Elizabeth E. ApfelberE Sandra A. Silver 1 Dated: October 14, IW4 San IAlin Obispo ,

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Xcs Elizabeth S. liowers .

Richard Black Clenn O. Dricht William P. Cornwell Philip A. Crane, Jr.

Frederick Einaler John Forster William E. Hartin Richard S. Salem n Secretary, L'3Mr Andrew Skaff Lonnie Valantine l

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