ML20237G730

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Addl Comments of Scenic Shoreline Preservation Conference Filed After Receipt of Applicant Proposed Findings of Fact & Conclusions of Law & Request to Reopen Hearing
ML20237G730
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 04/05/1970
From: Eissler F
SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
To:
US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20236J368 List: ... further results
References
FOIA-87-214 NUDOCS 8708140172
Download: ML20237G730 (4)
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g IN TIIE MATTER OF PACIFIC GAS AND ELECTRIC COMPANY Docket No. 50-323 (DIABLO CANYON NUCLEAR POWER PLANT UNIT No. 2)

Additional comments of Scenic Shoreline '

Preservation Conference filed after the receipt of the applicant's proposed l 1

findings of fact and conclusions of law-Request for reopening of hearing. ,

(1) Scenic Shoreline received an order dated March 18, 1970 i

" terminating recess of hearing." The order states: "On l

January 14, 1970, the Board recessed the hearing in this proceeding in order to evaluate the record and receive additional i information requested from the parties. The evaluation having been corapleted and information received, the Board has concluded that the recess should be terminated and the record of the hearing closed and it is so ordered."

Procedure requires that " additional information requested from the parties" be circulated to the interveners. In-formation requested from Pacific Gas and Electric Company by the Atomic Safety and Licensing Board has not been received i

by Scenic Shoreline Preservation Conference. Scenic Shoreline now requests this information.

(2) The March 18, 1970 order by your Board states that

.. to grunt the intervenor's request (for a third day of hearing) would be destructive of an orderly hearing procedure. . . " The Rec'd Ott.

l hearing was cricinally recessed without a My set for Date d jC Dirfof

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81 2 070729 J CONNOR 87-214 PDR (/fb -

-2 continuance in contemplation of possibly calling at least another day of hearing, Later evidence requires that another day of hearing be scheduled Scenic Shoreline requests that the hearing be reopened.

(3) Development of new evidence unknown to the parties at the previous hearings is necessary at a reopened hearing.

Within four miles of the proposed Diablo site is an earth-quake fault zone (Edna Pault) that has not been taken into account in the studies by Pacific consultants. Studies now i

indicate that this fault zone may have been active within the last 100 years. An offshore fault pointing toward the vicinity of Diablo Canyon has been active within the past year.

There is reason to believe that the plants" seismic design criteria are not stringent enou6h to assure struchral integrity in the event of the magnitude of shock that could be expected along these faults. Pacific testimony is deficient in failing to present information on these zones. It seems an untoward J rush to consider the building of a second unit without further data on this rnatter, It would be far wiser to defer construction  ;

until the evidence has been heard in view of the magnitude of potential damage from a powerplant accident. To be taken into consideration Art' the scentiness of data on the record to dateregardingthegAologyoftheregionsurroundingDiablo  !

Canyon, the lack of a Port San Luis Quahdrangle showing  ;

i detailed fault mapping, and the difficulty'of obtaining geologi-  ;

cal evidence because of the reluctance nC land owners to permit entry. The potential impact of these newly reported seismic factors should be reviewed at a new hearing. '

(4) The public is entitled to see Pacific's evacuation plans

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for the communities likely to be affected by an accidental releace of radionuclides., These plans should be displayed i and explained at a reopened hearing on plant safety factors prior to the construction stage. i l (5) Pacific asserts ("Froposed Findings of Fact and Conclusions of Law", March 20, 1970, section 23, p. 12) :

"This (reactor containment) structure assures that essentially no leakage of radioactive materials to the environment would result even if gross failure of the reactor coolant system l were to occur." In view of the findin6s of Advisory Task Force on Power Reactor Emergency Cooling (" Emergency Core Cooling", j

! p, 6,b) further data on Pacific's conclusion seem warranted at a reopened hearing.,

(6) New evidence on dispersal of radioactivity in the atmosphere over the San Luis Obispo-Santa Maria air basin in the event of an accidental release of radioactivity should be investigated especially in view of Pacific's assertion that ventilation at the plan + site is adeouate.

(7) The Federal Radiation Council has now decided to study the Gofman-Tamplin findin6s that recommend at least a tenfold increase in the strictness of powerplant radiation standards.

The anticipated costs both to Pacific and the power consumer of retrofits and planUredesign to accommodate new standards j offecting workers at the facility, the 6eneral public, and the environment )

justify further public airing of these considerations.

b (8) Further discussion and cross-examination of witnesses

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on the subject of on-site storage and off- cite transportt. tion and disposal of low and hiGb level radiation wastes are essential since the record on these ' matters is presently inadequate.

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Frederick Elti.Iler President Scenic Shorelitte Preservation Conference, Inc.

Dated at Santa Barbara, California April 5, 1970 l

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