ML20236L986
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ . _ _ _ _ _ - _ _
'* "e UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION <
\
.r In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323
) i (Diablo Canyon Unit 2) )
)
SUPPLEMENTAL PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW SUBMITTED BY PACIFIC GAS AND ELECTRIC COMPANY a
PRELIMINARY STATEMENT '
- 1. Pursuant to notice duly published a public hearing on the application of Pacific Gas and Electric Company (PGandE) to install a second unit at its Diablo Canyon Site was held before an Atomic Safety and Licensing Board (Board) in San Luis Obispo on January 13 and 14, 1970. Among the organizations permitted to intervene in the proceeding was Scenic Shoreline Preservation Conference, Inc. (Con-ference), which appeared and offered evidence in opposition to the proposed project. At the conclusion of the hearing on January 14 the Board declared the hearing to be recessed for three weeks, and Conference and PGandE were each given one week within which to file answers to certain questions which had been propounded by the Board.
PGandE filed its answers January 22, 1970. No comments were sub-mitted thereon by Conference. ,
l
- 2. On February 3, 1970 Conference sent a telegram to the Board ]
l requesting that a third day of hearing be schedu)cd to permit Confererne 1
8708100434 870729 PDR FOIA CONNORB7-214 PDR
a ~
4 to present additional evidence. PGandE filed its response to this request March 2, 1970, not having received a copy of the Conference telegram until February 27, 1970. The AEC regulatory staff (Staff) filed its response March 4, 1970. Both responses urged that Con-ference's request be denied.
- 3. On March 9, 1970 Conference filed another request for an additional day's hearing and transmitted the responses of one of its witnesses to certain questions he was asked at the hearing. PGandE l
responded to this filing on March 13, 1970.
- 4. On March 18, 1970 the Board issued an order closing the hearing record on receipt of proposed findings of fact and conclusions of law from PGandE. These were file 6 Garch 20, 1970 and the Staff filed its findings and conclusions on April 13, 1970.
- 5. On April 5, 1970 Conference filed another request that the hearing be rcopcned. Paragraph (3) of this document stated there was new evidence on the Edna Fault and an alleged " offshore fault pointing toward the vicinity of Diablo Canyon." On April 15, 1970 PGandE filed its response to conference's latest request asking that it be denied.
In a response dated April 'O, 1970 the Staff stated it was making further investigations concerning the allegations in Conference's pleading, and in its reply dated May 7, 1970 the Staff stated that its investigation had revealed nothing to change the conclusion set forth in the Staff's proposed findings that the seismic design criteria proposed for the plant are adequate. The reports by the Staff's con-sultants, the Geological Survey and Coast and Geodetic Survey, were filed with the Board June 11, 1970 and June 15, 1970, respectively.
2
. j
~
)
)
- 6. On July 13, 1970 Conference addressed a petition to the
)
Atomic Energy Commission concerning the applicability of the National Environmental Policy Act to Diablo Units 1 and 2 and requesting the AIC to promulgate certain proposed rules. On July 20, 1970 PGandE responded to this petition insofar as it affected Diablo Unit 2.
The Staff response to the conference petition was filed July 23, 1970.
- 7. On July 15, 1970 the Board ordered an additional day's p
hearing to incorporate the Staff consultants ' reports into the record and to permit conference to offer evidence on the allegations con- ]
l tained in paragraph (3) of its pleading dated April 5, 1970. In an order dated July 20, 1970 the reopened hearing was set for August 7, 1970. On July 26, 1970 Conference sent a letter to the Chairman of the Board asking that the hearing be reset for a later date. PGandE's response to this request was filed July 29, 1970. On August 7, 1970 the hearing was held in San Luis Obispo pursuant to the Board 's order.
Testimony was given on behalf of Conference by Mr. Ralph Vrana, an.
instructor in physics at California Polytechnic Institute in San Luis Obispo. PGandE's witnesses were Dr. Richard H. Jahns, Professor of Geology and Dean of the School of Earth Sciences of Stanford University and Dr. Stewart Smith, Professor and Chairman of the Geophysics De-1 partment at the University of Washington. Testifying for the Staff were Mr. James F. Devine, a geophysicist in the Vibration and Engineer-ing Projects Branch of the Division of Seismology of the Coast and Geodetic Survey and Mr. Howard Waldron of the Engineering Geology E ranch , U. S. Geological Survey. At the conclusion of the hearing the Board closed the record upon submission by the parties of findings 3
i of fact and conclusions of law within 30 days. P0andE was also re-quested to file copies of certain maps. These maps are being filed concurrently with these Supplemental Findings of Fact and Conclusions of Law. (Map C; Tr. pp. 41, 101, 125, 205.)
- 8. The Supplemental Findings of Fact and Conclusions of Law submitted herewith cover only the matters discussed at the hearing on August 7, 1970. They should be read in conjunction with the findings and conclusions dated March 20, 1970.
FINDINGS OF FACT
- 9. The major offshore and onshore geologic structures in the general area of the Diablo Canyon Site have a northwest-southeast trend. A number of epicenters of offshore earthquakes were plotted l 1
by Mr. Vrana on a map, which has been labeled Map A l. A list of l
offshore epicenters is attached to the supplemental report of the U. S. Coast and Geodetic Survey dated June 11, 1970. The apparent northeast-southwest alignment of these epicenters is fortuitous, and there is no geologic evidence to support the thesis that the l
epicenters define a northeastward structural trend in the area off- l 1
shore from the Diablo Canyon site. The earthquakes plotted were j probably generated along the dominant northwest trending structures.
(" Supplement to the Seismic Evaluation of the Diablo Canyon Nuclear Power Plant Unit #2, AEC Docket 50-323", U. S. Coast and Geodetic 1 PGandE has not checked the accuracy of the location of the off-shore epicenters but is willing to accept ther as depicted.
Map h also indicates some onshore epicenters Encluding the ap-parent offshore epicenters in the upper right-hand corner) and certain other textual material has been added. No evidence was of fered concerning these data, and they should be disregarded.
4
- 4 Survey, June 11, 1970 (CGS Report); " Supplemental Geologic Report",
Geological Survey (GS Report); Tr. pp. 12 ( f f . ) , 53, 55, 56, 65, 106, 124, 125, 131.)
- 10. The cluster of epicenters in the area on Map A labeled i
" Santa Lucia Escarpment" and the cluster in the area labeled j I
" Santa Lucia Bank" probably represent two distinct zones of activity.
\
1 Because of their size and time sequence it also is-probable that some l
of the earthquakes in each cluster are aftershocks of other earthquakes in the same cluster. This provides further evidence that the earth- ;
quakes are related to the dominant northwest-southeast structural i
l trend. (Tr. pp. 131, 133, 191.)
! R l 11. The cluster of epicenters on Map A are not related to the Murray Fracture Zone, which is shown on Map B. The Murray Fracture Zone is a predominantly east-west feature with offshoots at angles of 5 -10 . To tie the offshore epicenters in with a branch of the !
Murray Fracture Zone would require an offshoot with an angle of about l 45 . The mechanics by which such a feature as the Murray Fracture Zone is generated preclude an offshoot at cuch an angle. Furthermore, l
such a branch has no onshore expression. The rec 0gnized onshore feature related to the Murray Fracture Zone as it touches the coast of California is the Santa Ynez Mountains, which are located about 100 miles south of the plant site. (Tr. pp. 52, 53, 56 59-6 1,
. 89-93, 100, 104-106, 108-111, 126.)
- 12. The geology of the site has been extensively investigated 4
by PGandE and its consultants. Almost one mile cf trenches was excavated through the terrace material a minimum of three feet into bedrock and extensively mapped. Additional geological maps of the 5
i i ,
area were prepared, including a map of ten square milee surrounding the site. Finally, a detailed reconnaissance of the entire area was !
made and other background maps studied. The geological study which i
has been made is s 7'icient, and it is highly unlikely that a further study would reveal features of greater significance than those which have been considered in the design of the plant. (Applicant's Exhibit 1, pp. 4-5; Tr. pp. 106, 113, 114, 120-123.)
i
- 13. The Edna Fault is a minor feature of less significance to 1
j the plant than certain other features which have been considered in i I
i 1 l the design of the proposed facility. It can be traced for about 20 l 1 l It was taken into I l miles and has a known offset of about 1000 feet.-
account in the original plant studies, and it has not been active l
within at least the last 100,000 years. At various stages in the proceeding attempts were made to relate several small earthquakes (less than magnitude 5) to the Edna Fault or some other geological feature. However, earthquakes of this size are very difficult to locate accurately. Consequently, association of t,ucit earthquakes j with a feature such as the Edna Fault is of doubtful validity. !
(CGS Report; GS F9 port; Tr. pp. 43-49, 66, 67, 95, 96, 101, 102, 125-127, 130, 131, 133, 136, 138, 141, 159, 190, 191.)
- 14. The Edna Fault appears to be connected to the West Huasna Fault. Movement on the West Huasna Fault has been predominantly strike-slip whereas movement on the Edna Fault has been predominantly dip-slip. The Edna Fault changes its trend in such a way, as traced along the ground , that it is physically impossible for it to have experienced much strike-slip displacement. Thus, although the 6
I i
l Edna Fault and West Huasna Fault may connect, it is less likely they are genetically related because of this difference in their basic senses of movement. The predominant dip-slip sense of movecent on the Edna Fault is also clearly documented on the unpublished map prepared by Clarence Hall, which has been marked Map F and is sub-mitted herewith.2 (Tr. pp. 162-165, 173, 178, 179.)
- 15. Mr. Ralph Vrana, the witness for Conference, testified to
! the existence of a fault in the Los Ocos Valley. It has been shown by him on the map designated as Map C and has been named by him the "Los Osos Fault Mr. Vrana is apparently the only person who has seen this " fault." He has not mapped the " fault," and it is not i
shown on any publiched maps. No epicentral activity of record l 1
l can be correlated with a "Los Osos Fault. " PGandE does not concede !
l l
that such a ' fault" exists. Mr. Vrana has also shown on Map C the Edna Pault as taken by him from the Hall map, which has been marked Map F. The repc . f the Geological Survey states that the Edna Fault exten, s frua the vicinity of Hazard Canyon which, as can be seenfromh(pC, is located about 5 miles due North of the site.
Mr. Vrana 's testimony also extends the Edna Fault to Hazard Canyon.
If the Edna Fault were thus extended on Map C and if in fact the sc-called "lfos Ozos Fault" exists, it would appear that the two faults are arallel and follow the typical northwest-southeast trend of gc) logical structurps in the area. There is no evidence y .
2 Anthough not reqAested by the Board the Hall nap is submitted herewith in view of the amount of testimony in the record con-corning it. (Tr. 83-87, 106, 114-116, 162, 167-169, 171, i72.,
7
i l
\
1 l
i that the two faults connect, and the testimony and Map C indicate (
they are about five miles apart.3 (GS Report; Tr. pp. 117, 118, 166.)
l I
- 16. Assuming, for the purposes of argument and against the weight of the evidence, that the West Huasna, Edna, and "Los Osos" Faults were all connected, and that there were a strike slip movement along the J l
entire feature, which would extend about 40 miles, the earthquake 1 resulting at the site would be about magnitude 6-1/2, which is less than the magnitude 6-3/4 earthquake at an equivalent distance which j was used in developing the seismic design for the proposed unit.4 f I
3 If the Los Osos Valley is a down-dropped block, as claimed by Mr. Vrana in an effort to connect the "Los Osos" and Edna Faults, then it must be along faults other than the Edna, because the Edna Pault is down on its southwest side. To fit Mr. Vrana's argument the Edna Fault would have to be down on its northeast side. In addition, the delineation of the "Los Osos Fault" by i Mr. Vrana on Map C is not consistent with the argument that the l Los Osos Valley is a down-dropped block, or graben, because he l shows the fault as running through the valley. (Tr. pp. 169-172.) l 4 The extreme nature of such a postulate is clear when one considers the evidence: there is disagreement over whether the "Los Osos
! Fault" exists; the " fault" is unmapped and no epicentral activity .
l l of record has been traced to it; there is no evidence that the "Los Osos Fault" connects to the Edna Fault; there is positive l evidence that the Edna Fault and West Huasna Fault do not have l the same sense of movement; any substantial amount of strike slip movement along the Edna Fault is virtually impossible be-cause of its characteristics; the Edna and West Huasna Faults l
have been inactive for at least the last 100,000 years and prob-l ably longer; the total displacement along the Edna Fault is well i documented and amounts to about 1000 feet; there does not exist in the State of California any fault with what amounts to such a
" weird, ratio" of exposed length (40 miles) to total displacement
- along some interior part of the fault (1000 feet) as this proposed '
combination. Doubtless, further exploration of the area would re-l veal other faults. However, the important fact is that the exten-1 -
sive geological investigation which has been conducted at the site and environs has been sufficient to give assurance that further investigation will not reveal any large-scale features which could create earthquakes of greater magnitude at the site than the features which have already been considered. In short, any such subsequently discovered features would have no significance as far as the plant's
! aseismic design is concerned. (GS Report; Tr. pp. 102, 114, 115, 117-124, 126, 128, 130, 136, 138, 158-160, 165-168, 173-179, 195-197.)
8
(Tr. pp. 129, 130, 167, 168, 173-179, 195-197.)
L 17. Mr. Vrana has also indicated on Map C possible seaward extensions of the "Los Osos Fault," which he has marked with question marks. He also testified that the "Los Osos Fault" could possibly be lined up with a feature that comes ashore at San Simeon, i
l 30 miles from Morro Rock. The possibility of such a connection, l
l however, is remote because of the large gap between the faults and j
the fact that the styles of the two faults and the amount of dis-
! placement along them (i.e., the Edna Fault and the feature to the nor th) are dissimilar. (Tr. pp. 180-183.)
CONCLUSION
- 18. The geology of the Diablo Canyon site has been studied in depth. It is unlikely that any further studies, however desirable scientifically, would reveal any information of greater significance than that which has already been considered in the design of the 3 plant. Because, among other things, of their varying characteristics, including the small total displacement along the Edna Fault and the apparent lack of connection between the "Los Osos" (if it exists) and Edna Faults, it is highly unlikely that an earthquake could occur simultaneously along the "Los Osos," Edna, and West Huasna Faults. Even if one did, assuming the three features total about 40 miles in length, the earthquake produced would have a lesser effect than the earthquakes that were considered in the aseismic design for the unit. Nothing was revealed at the hearing which caused the Staff or PGandE consultants to cl .ge the conclusions 9
- 1 l
I stated in their various reports. Accordingly, it is concluded that i
the aseismic design for the unit is adequate.
Respectfully submitted, l
RICHARD H. PETERSON JOHN C. MORRISSEY !
PHILIP A. C RANE , J R .
I Att'orneys for l PACI ;AS AND ELECTRIC COM ANY l
- . .. l By 4 s b Philip 7 Crane,{r. ./
Dated: September 4, 1970. 1 i
l 6
(
10
1 I
UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of )
)
Docket No. 50-323 i PACIFIC GAS AND ELECTRIC COMPANY )
(Diablo Canyon Unit 2) ) l
) I CERTIFICATE OF SERVICE i
The foregoing Supplemental Proposed Findings of Fact and Conclusions of Law Submitted by Pacific Gas and Electric Company has been served t 7 day on the following by deposit in the United States mail, properly stamped and addressed:
Mr. Jack M. Campbell Secretary Stephenson, Campbell & ulmsted U. S. Atomic Energy Commission 231 Washington Avenue Washington, D. C. 20545 P. O. Box 877 Santa Fe, New Mc::ico Attn.: Chief, Public Proceedings Branch Dr. Rolf Eliassen Department of Civil Engineering Mr. Martin Malsch l 3tanford University Trial Counsel
! Stanford, California 94305 U. S. Atomic Energy Commission Washington, D. C. 20545 Mr. Elston L. Kidwell (2 copies)
Chairman San Luis Obispo County Mr. James P. Gleason Board of Supervisors 205 Commonwealth Building County Courthouse 1625 K Street, N. W.
San Luis Obispo, California 93401 Washington, D. C. 20006 Dr. Peter A. Morris, Director Ian I. McMillan Division of Reactor Licensing Box 63 U. S. Atomic Energy Commission Shandon, California 93461 Washington, D. C. 20545 (2 copies) Dr. Hugh C. Paxton Los Alamos Scientific Laboratory Dr. Thomas H. Pigford P. O. Box 1663
~
Professor of Nuclear Engineering Los Alamos, New Mexico 87544 University of California Berkeley, California 94720
i 4
i
..* l' l
l 1
t l
San Luis Obispo Eay Properties, Inc.
and ,
Luigi Marre Land and Cattle Company l C/o Mr. Hal Stro'i;e Marre Ranch Avila Beach, California 93424 l
Scenic Shoreline Preservation Conference, Inc.
l 4623 More Mesa Drive l
Santa Barbara, California 93105 Mr. A. A. Wells, Chairman j Atomic Safety and Licensing J Board Panel U. S. Atomic Energy Commission l Washington, D. C. 20545
\
o
/ht !
M$' )
P/ilip A. Crane, Jr.
I Attorney for Pacific Gas and Electric Company Dated: September 4, 1970.
.