ML20236L689

Reply to AEC Regulatory Staff 700930 Supplemental Proposed Findings of Fact & Conclusions of Law Re Field Tests & Measurements

ML20236L689
Person / Time
Site:	Diablo Canyon
Issue date:	10/16/1970
From:	Eissler F SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
To:	US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
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References
FOIA-87-214 NUDOCS 8708100330
Download: ML20236L689 (2)

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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSICN .l In the matter of ) l

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PACIFIC GAS & SLECTRIC C011PANY ) . Docket 30 50-32;

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j (Diablo Canyon Unit 2) )

l Renly of Scenic Shoreline Preservation Conference. Inc. to

! "AEC Itegslatory_ Staff 's Sucolemental Pronosed Dindings l l of fact and Conclusions of Law (Sentember 30. 1970)". 1 Staff's comments almost exactly parallel those of Pacific. H Our response to Pacific's remarks apply with equal relevance to l:

those of Staff. The record with relation,to both the remarks of 3 Pacific and Staff is deficient in that untested judgments on crucial subjects are presented as an alternative to necessary ff ald tests and measurements. The public has a right to question whether its best interests are being served unless such studies are completed.

(1) Response to Finding of Jact No'. 5 The evident northeast alignment of the epicenters raises a significant question. To remark that "it is logical to conclude..." that the earthquakes were along dominant northwest trending structures substitutes forensics for field studies. Definite postive evidence can and must be otained j on an issue of this significance. Pro,,fessor Vrana has listed the necessary field studies. (Tr. 56, 93, 94, 95, 96). The commission regulations require the applicant to meet the positive standards of burden of proof. This positive' requirement presumably must also be met by Staff.

(2)- Response to finding No. 6 The mechanics by wich a 45 degree ,

offshoot of the Murray Fracture Zone could be generated has been 'i demonstrated' in references submitted by Vrana (Supplemental Statement Sept. 5,1970). 7there is some question whether the Santa 8708100330 870729 PDR FDIA -

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Ynez Mountains are an onshore expression of the Murray Practure Zone.

1 (3) itesponse to Findings No. 9 Clarence Hall iniicates the Edna j i

Sault Zone has been active within the last 10,000 years. It . 2 l not true that the small earthquakes mentioned by 3r, Vrana "were not instrumentally recorded."

('4 ) Response to Findings No. 10, 11, 12. Professor Vrana testified to the existence of a fault system in the Los Osos Valley region, i The Staff states, p. 9: "

. . . field-based geological mapping" has not been " performed by the intervenor which would supcort the allegation that such a fault exists. There is therefore insufficient evidence to support the existence of a 'Los Osos Pault' ani it is unlikelv i

that any fault of significance to the plant desig: cxists in the ,

1 Los Osos Valley." (Emphesis added) There is insufficient evidencs on the geology of this total region since the crucial Port San Luis Quadrangle has not yet been completed. The 3oard, however, felt it was necessary to hold additional hearings on findings by Professor 'Irana regarding the Edna Fault. Sufficienb evidence has  !

been presented to indicate the existence of the Los Osos Fault. The applicant, not the intervenor, has the postive bu. Men of proof providing assurances about this indicated structure. Until field i 1

studies are conducted the significance of the structure and its  !

possible relation to plant design cannot adequately be determined. '

Respectfully sub=1 tg.

7 s l 4?

Frederick Eiseler President Dated at Santa , Barbara, California this 16th day of October,1970 '

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