ML24067A066

Petition by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group for Shutdown of Diablo Canyon Nuclear Power Plant Due to Unacceptable Risk of Seismic Core Damage Accident

ML24067A066
Person / Time
Site:	Diablo Canyon
Issue date:	03/07/2024
From:	Curran D, Leary C, Templeton H Environmental Working Group, Friends of the Earth, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, San Luis Obispo Mothers for Peace
To:	NRC/OCM
SECY RAS
References
RAS 56941, DCPP 50-275 & 50-323 Seismic Shutdown, 50-275-LR, 50-323-LR
Download: ML24067A066 (0)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION

In the matter of Pacific Gas and Electric Company Docket Nos. 50-275, 50-323 Diablo Canyon Nuclear Power Plant March 4, 2024 Units 1 and 2

PETITION BY SAN LUIS OBISPO MOTHERS FOR PEACE, FRIENDS OF THE EARTH AND ENVIRONMENTAL WORKING GROUP FOR SHUTDOWN OF DIABLO CANYON NUCLEAR POWER PLANT DUE TO UNACCEPTABLE RISK OF SEISMIC CORE DAMAGE ACCIDENT

I. INTRODUCTION

San Luis Obispo Mothers for Peace (SLOMFP), Friends of the Earth (FoE) and

Environmental Working Group (EWG) (collectively Petitioners) hereby petitions the

Commissioners of the U.S. Nuclear Regulatory Commission (NRC or Commission) to

exercise their supervisory authority to order the immediate closure of Pacific Gas & Electric

Companys (PG&Es) Diablo Canyon nuclear power plant Units 1 and 2 (DCPP) due to the

unacceptable risk of a seismically induced severe accident. Petitioners became aware of this

unacceptable risk in the course of preparing a hearing request regarding PG&Es application for

renewal of the DCPP operating licenses, and now bring the matter to the Commissions urgent attention. 1

The petition is supported by the attached expert declaration of Dr. Peter Bird, Professor Emeritus of Geophysics and Geology at the University of California at Los Angeles (UCLA). 2

1 Petitioners Hearing Request was also filed today with the Secretary of the Commission.

Petitioners Hearing Request includes Contention 1, which asserts that the NRC should deny PG&Es application on safety and environmental grounds due to the high seismic accident risk posed by its continued operation.

2 Declaration of Dr. Peter Bird,Section I (March 4, 2023) (Bird Declaration). Dr. Birds Declaration is attached as Exhibit 1.

As set forth in his Declaration and curriculum vitae , Dr. Bird is highly qualified through 46 years

of training and experience in the fields of geology and geophysics and direct experience with the evaluation of seismic risks in California and at DCPP in particular. 3

II. FACTUAL GROUNDS FOR IMMEDIATE CLOSURE OF REACTORS

PG&Es most recent publicly available seismic risk analysis - its 2018 Seismic Probabilistic Risk Assessment (SPRA) - estimates a value of 3x10 -5 per year for seismic core

damage frequency (SCDF). 4 A similar value of 2.96x10 -5is reported in PG&Es Environmental

3 As discussed in Dr. Birds attached Declaration, his focus is on technophysics and seismicity, including plate motion and plate deformation. And Dr. Bird has done extensive work on the geology of California, including a number of academic papers on computer modeling methods and applications, including studies of the ongoing (neotectonic) deformation in California. He has also been a member or officer of several professional organizations relating to his expertise, including the Geological Society of America, the American Geophysical Union and the Southern California Earthquake Center. The former two organizations have recognized Dr. Birds work with two fellowships and an award.

In 2012, Dr. Bird participated in a Senior Seismic Hazards Analysis Committee (SSHAC) review sponsored by PG&E and run by Lettis Consultants International, regarding seismic hazard at DCPP. He presented results on both strike-slip and compressional deformation rates affecting the region, which were derived from his computer models of neotectonics. These models were prepared for the Southern California Earthquake Centers project Unified California Earthquake Rupture Forecast, and also for the US Geological Surveys 2013 Update to the National Seismic Hazard Model. See Bird, Declaration,Section I.

In addition to supporting this request for closure of the DCPP reactors, Dr. Birds declaration has been submitted by Petitioners in support of their Hearing Request regarding PG&Es license renewal application.

4 PG&E Letter DCL-18-027 re: Seismic Probabilistic Risk Assessment for the Diablo Canyon Power Plant, Units 1 and 2 - Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1: Seismic of the (sic) Near-Term Task force Review of Insights from the Fukushima Dai-ichi Accident, Encl. 1 at 52 (Apr. 24, 2018) (NRC Accession No. ML18120A201) (SPRA).

The SPRA relies in turn on PG&Es Seismic Source Characterization for the Diablo Canyon Power Plant, San Luis Obispo County, California; report on the results of SSHAC level 3 study, (Rev. A, March 2018) (Available online at http://www.pge.com/dcpp-ltsp) ( SSC); and PG&E Letter DCL-15-035 re: Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)

Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of 2

Report for its November 7, 2023 license renewal application. 5 As set forth in the attached Bird

Declaration, however, PG&Es SCDF estimate is too low by a factor of 47~70. 6

PG&Es significant and alarming underestimate of SCDF arises principally from its

misplaced assumption that the majority of large earthquakes affecting DCPP are strike-slip

earthquakes and its disregard of the significant contribution of thrust-faulting earthquake sources

under the DCPP site and in the adjacent Irish Hills. But the January 2024 occurrence of the Noto

Peninsula earthquakes on analogous faults in Japan now demonstrates in no uncertain terms that

PG&Es assumption is both unfounded and dangerous. As discussed below, these thrust-faulting

earthquakes produce strong shaking that leads to a much higher probability of seismic core damage than the strike-slip faults assumed by PG&E to predominate at DCPP. 7

Applying the experience of the Noto earthquakes to the thrust-faulting earthquakes at and near DCPP, a reasonable SCDF estimate could be as high as 1.4x10 -3/year. 8 As stated by Dr. Bird:

In the 2024 Noto Peninsula earthquake, we have the advantage of the finite-fault solution (USGS, 2024), which maps the amount of coseismic slip onto the active fault plane. This study showed maximum slip of 3.7 m under the center of the Noto Peninsula, with a mean slip that I visually estimate as 2.0 m (or 2000 mm) in the seismogenic depth range.

Insights from the Fukushima Dai-ichi Accident: Seismic Hazard and Screening Report (Mar. 11, 2015) (NRC Accession No. ML15071A045).

5 Environmental Report at 4-62. The Environmental Report is included as Appendix E to PG&Es license renewal application, NRC ADAMS Accession No. ML23311A154.

6 Bird Declaration, ¶ 4.

7 Bird Declaration , ¶¶ 14(5), 18-21.

8 Id., ¶¶ 4, 6, 29-30. As stated in ¶¶ 32-34 of Dr. Birds Declaration, his SCDF estimate is based on information provided in the SPRA, for which some questions about the meaning of PG&Es terminology exist. And there may be differences of opinion about the appropriate interpretation of Noto Peninsula seismographs that should be resolved by further study. In the meantime, for purposes of evaluating PG&Es Environmental Report, it is reasonable to assume that the levels of shaking seen in the Noto Peninsula earthquake will cause seismic core damage at DCPP if and when they occur in the Irish Hills of California.

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Dividing this mean slip of 2000 mm by the long-term tectonic slip-rate of 2.8 mm/a in the Irish Hills, the inferred recurrence rate for Noto-type earthquakes under the Irish Hills is 715 years. In other words, the inferred probability of Noto Peninsula-type earthquakes under the Irish Hills is the inverse of this, which is 1.4x10 -3 /yr.

Again, reasonably presuming that the Noto Peninsula earthquake is a characteristic earthquake for this tectonic setting (shared by the Irish Hills in California), PGA values of 1.0~2.3 g (see section 1 above) must be expected with probability 1.4x10 -3 /yr.

However, in the 2015 SSC (specifically, in Figure 2.3.7-1 of PG&E, 2015L), we see that this outdated modeling associated this probability level with a PGA of only 0.32 g.

Consequently, it appears that the 2015 SSC severely underestimated (by a factor of 3~7) the severity of shaking (PGA) that must be resisted every ~715 years. 9

In other words, as Dr. Bird asserts, the severe accident that PG&E asserts will occur only once in 33,000~50,000 years may actually occur every ~715 years. 10

In Section IV of his Declaration, Dr. Bird sets forth in detail the basis for the data and

analyses supporting his expert opinion and this contention. To summarize:

(1) The Noto Peninsula earthquake in Japan (2024.01.01, m7.5, 10 km deep) produced peak ground accelerations (PGA) of 1.0~2.3 g (that is, 100~230% of gravity) at 5 modern digital strong-motion seismometers as far as 42 km from the rupture.

(2) This strong shaking occurred in the Noto Peninsula, which is part of the hanging-wall (upper block) of two en-echelon thrust faults that run parallel to its two coasts.

(3) The Irish Hills, San Luis Range, and DCPP site in California are at risk for similar earthquakes and similar shaking because they are underlain by similar thrust faults, including the inland Los Osos thrust fault and the Inferred Coastline thrust running along the shore by DCPP. 11

(4) The expected recurrence interval between such events at DCPP can be roughly estimated by dividing the expected fault slip (averaging 2 m in the Noto earthquake, according to the USGS finite-fault solution) by the total heave rate of the thrust

9 Id., ¶¶ 4, 6, 29-30.

10 Id., ¶¶ 14(6), 4, 6, 29-30.

11 Inferred Coastline thrust is Dr. Birds own term for a distinct fault surface whose trace follows the coastline opposite DCPP. Unlike the Shoreline fault in the same area, the Inferred Coastline thrust dips at a gentle angle beneath DCPP and has the up-dip rake of a thrust fault.

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faults under DCPP, which is about 2.8 mm/year (as I will justify below). The result is 715 years. The inverse of this is the rate: 1.4x10 -3 /yr.

(5) In the existing SSC (PG&E, 2015; 2015L), the intensity of shaking at this return period of 715 years has been underestimated by a factor of 3~7. This means that the chance of seismic core damage is much higher when thrust-faulting earthquake sources are included.

(6) Applying Dr. Birds analysis to these facts, the probability of a severe accident of earthquake origin at DCPP has been underestimated by a factor of (1.4x10 -3 /yr) /

(2~3x10 -5 /yr) = 47~70. In other words, the severe accident that PG&E asserts will occur only once in 33,000~50,000 years may actually occur every ~715 years. That means that a license extension for 20 years would incur a ~2.8% probability of a severe accident.

III. LEGAL GROUNDS FOR IMMEDIATE CLOSURE OF REACTORS

As recognized in Yankee Atomic Electric Co. (Yankee Rowe Nuclear Power Station), CLI-

91-11, 34 N.R.C. 3, 12 (1991), the Commission has an ongoing responsibility to ensure the safe

operation of the facilities that it licenses. Here, under established NRC guidance, such a high core damage frequency as 1.4x10 -3/year is unacceptable and calls for immediate regulatory action to

maintain the plant in a safe condition. 12

In these circumstances, immediate shutdown is warranted by the potential for devastating

consequences if a large earthquake causes core damage at DCPP. That risk is magnified by

indications of embrittlement in the Unit 1 reactor vessel, or at the very least PG&Es failure to

monitor the condition of the Unit 1 pressure vessel since those indications of embrittlement were

12 NRC Office Instruction LIC-504, Integrated Risk-Informed Decision-Making Process for Emergent Issues at 4 (Rev. 6, Sept. 7, 2023) (ML23165A117) (LIC-504). LIC-405 characterizes the risk impact from external events as high and therefore warrants immediate regulatory action to place or maintain the facility in safe condition if:

Conditional core damage frequency (CCDF) (i.e., CDF because of the issue) is high (e.g.,

greater than or on the order of 1x10 -3/year). 12

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seen more than 20 years ago. A prior petition by SLOMFP and FoE to close Unit 1 pending resolution of those issues is currently pending before the Executive Director for Operations. 13

IV. GROUNDS FOR EXERCISE OF COMMISSIONS SUPERVISORY AUTHORITY OVER THIS PETITION

Exercise of the Commissions supervisory authority to consider and grant this Petition is consistent with Commission precedent. 14 This authority is underscored by the commitment made

by Chairman Hanson on behalf of the Commission during an April 19, 2023 hearing before the

Senate Committee on Environment and Public Works . This commitment bound NRC, at the highest level, to review seismic safety risks at DCPP before re-licensing DCPP. 15

At that hearing, California Senator Alex Padilla questioned Chairman Hanson regarding the

NRCs plans for ensuring that DCPP is operationally safe with specific concern about seismic risk. 16 On behalf of his fellow Commissioners, Mr. Hanson responded that in addition to ongoing

safety oversight:

Were going to be looking at updated safety information as part of that license renewal process . We did require all plants to take a look at the enhanced . . . you know to relook at

13 Request to the NRC Commissioners by San Luis Obispo Mothers for Peace and Friends of the Earth for a Hearing on NRC Staff Decision Effectively Amending Diablo Canyon Unit 1 Operating License to Extend the Schedule for Surveillance of the Unit 1 Pressure Vessel and Request for Emergency Order Requiring Immediate Shutdown of Unit 1 Pending Completion of Tests and Inspections of Pressure Vessel, Public Disclosure of Results, Public Hearing, and Determination by the Commission That Unit 1 Can Safely Resume Operation (Sept. 14, 2023).

See also Order by the NRC Secretary (October 2, 2023).

14 See Yankee Atomic Electric Co. , CLI-91-11, 34 N.R.C. at 12 (The Commission has the ultimate responsibility to ensure the safe operation of the facilities that it licenses.).

15 A recording of the hearing is posted on the Committees website at:

https://www.epw.senate.gov/public/index.cfm/hearings?ID=DD1B6EC6-588A-4A56-9961-F9961BE12270 .

16 Id. Senator Padillas question can be found at approximately 1:45:26.

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their risks after Fukushima; Diablo, of course did look at their seismic risk again, and well take another look at that as part of the license renewal process . . . 17

Mr. Hansons fellow Commissioners who were seated with him in the hearing room, made no

objection or qualification to his statement.

The unacceptable seismic risk of operating DCPP has been revealed through Petitioners

technical review of PG&Es license renewal application as well as the recent Noto earthquake and

its implications for the Irish Hills where DCPP is located. The Commissions unequivocal public

commitment to address seismic risks in the license renewal context, made through the Chairman in

the April 19, 2023 hearing, carries with it the implicit responsibility to address urgent safety

matters that arise as a result of that review and new and significant information about reactor risks

that comes to light during that review or in any other manner.

V. CONCLUSION

For the foregoing reasons, the Commission should order the immediate closure of the DCPP

reactors for posing an unacceptable risk of an earthquake-caused accident. Operation should not

be allowed to resume unless and until the NRC determines that the reactors can be operated safely.

This determination should address the contribution of Unit 1 embrittlement to the potential for an

earthquake-caused core damage accident at DCPP.

17 Id. (emphasis added). Chairman Hansons response can be found at approximately 1:45:55.

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Respectfully submitted,

__/signed electronically by/___

Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com Counsel to San Luis Obispo Mothers for Peace

__/signed electronically by/___

Hallie Templeton Friends of the Earth 1101 15 th Street, 11 th Floor Washington, DC 20005 434-326-4647 htempleton@foe.org Counsel to Friends of the Earth

__/signed electronically by/___

Caroline Leary Environmental Working Group 1250 I St N.W.

Washington, DC 20005 202-667-6982 cleary@ewg.org Counsel to Environmental Working Group

March 4, 2023

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EXHIBIT 1 - DECLARATION OF PETER BIRD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION AND BEFORE THE SECRETARY

In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant 50-323-LR Units 1 and 2

DECLARATION OF PETER BIRD, Ph.D

Submitted to the U.S. Nuclear Regulatory Commission By San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group

March 4, 2024 This page intentionally left blank TABLE OF CONTENTS

I. EXPERT QUALIFICATIONS..1

II. PURPOSE AND DESCRIPTON OF MY DECLARATION.......2

III. BACKGROUND REGARDING PG&E AND NRC SEISMIC STUDIES AND ENVIRONMENTAL DOCUMENTS.....3

A. PG&Es Public Seismic Risk Studies......3

B. Environmental Documents.......3

IV. SCIENTIFIC ANALYSIS.....4

A. Abstract4

B. Detailed Scientific Argument.......5 (1) Accelerations in the 2024 Noto Peninsula earthquake.....5

(2) Factors responsible for unusually strong shaking.5

(3) Tectonic analogy between the Noto Peninsula and the Irish Hills of California.....6

(4) Thrust-fault slip-rates and earthquake recurrence intervals.....8

(5) Susceptibility of DCPP to seismic core damage..9

(6) Risk of external seismic severe accidents at DCPP has been grossly underestimated...10

C. Figure 1..11

V. ADDITIONAL OBJECTIONS TO APPLICANTS ENVIRONMENTAL REPORT12

A. Regarding adequacy of existing and planned deformation models.12

B. Regarding status of witness models in the seismicity/hazard communities...13

VI. REFERENCES..15

A. References cited in Sections I-IV..15

B. References cited in Section V16

i

VII. CURRICULUM VITAE..18

VIII. LIST OF PUBLICATIONS.20

ii

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION AND BEFORE THE SECRETARY

In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant 50-323-LR Units 1 and 2

DECLARATION OF PETER BIRD, Ph.D

Under penalty of perjury, I, Peter Bird, declare as follows:

I. EXPERT QUALIFICATIONS

1. My name is Peter Bird. For over 46 years, I have been a Professor of Geophysics and Geology at the University of California at Los Angeles (UCLA). I now serve as Professor of Geophysics and Geology, Emeritus at UCLA. I am qualified by training and experience as an expert in the fields of geology and geophysics with a focus on tectonophysics and seismicity, including plate motion and plate deformation. A copy of my curriculum vitae is included here as Attachment 1.

2. I have a Ph.D. in Earth and Planetary Sciences from the Massachusetts Institute of Technology (1976) and a B.A. in Geological Sciences from Harvard College (1972).

Over the past 48 years, I have published 76 academic papers, mostly about tectonics and seismicity, including the tectonics and seismicity of California. And I have authored or contributed to a number of academic papers on computer modeling methods and applications, including studies of the ongoing (neotectonic) deformation in California. I have also been a member or officer of several professional organizations relating to my expertise, including the Geological Society of America, the American Geophysical Union and the Southern California Earthquake Center.

The former two organizations have recognized my work with two fellowships and an award.

3. In 2012, I participated in a Senior Seismic Hazards Analysis Committee (SSHAC) workshop sponsored by Pacific Gas & Electric Co. (PG&E) and run by Lettis Consultants International, regarding seismic hazard at the Diablo Canyon Power Plant. I presented results on both strike-slip and compressional deformation rates affecting the region, which were derived from my latest computer models of neotectonics. These models were prepared for the Southern California Earthquake Centers project Unified California Earthquake Rupture Forecast version 3, and also for the US Geological Surveys 2013 Update to the National Seismic Hazard Model.

4. On April 28, 2023, on behalf of San Luis Obispo Mothers for Peace (SLOMFP), I prepared a declaration setting forth my criticism of the seismic risk analysis for DCPP that was presented by the U.S. Nuclear Regulatory Commission (NRC) in its Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437, Rev. 2, Feb. 2023) (Draft GEIS) (NRC 2023). SLOMFP submitted my declaration with its comments on the Draft GEIS on May 2, 2023. My declaration can be accessed on the NRCs Agencywide Data Access and Management System (ADAMS) at ML23123A410. My declaration in that rulemaking proceeding is relevant to this DCPP license renewal proceeding because the NRC relied heavily on PG&Es seismic analyses for its conclusion that the environmental impacts of an earthquake-induced or related accident at DCPP are SMALL. This matter is discussed in more detail below. I continue to stand by the facts and expert opinions expressed in my declaration.

II. PURPOSE AND DESCRIPTION OF MY DECLARATION

4. The purpose of my declaration is to explain why, in my expert opinion, the Environmental Report by applicant PG&E significantly underestimates the likelihood of a severe earthquake at DCPP, i.e. , an earthquake that could cause substantial damage to the reactor core. [ER p.

4-61]. PG&Es 2018 estimate and 2023 revision of the long-term rate of seismic core damage as 2~3x10 -5 /yr fail to take into account current information or to deploy a technically-defensible seismicity model that show the seismic severe accident rate is about 47~70 times higher, or ~1.4x10 -3/ year.

5. The fundamental problem with PG&Es seismic risk analysis is not any error in computations, but the use of incomplete deformation models to support the 2015 Seismic Source Characterization (SSC). These incomplete deformation models also biased PG&Es 2018 seismic probabilistic risk assessment (SPRA). PG&E mistakenly decided that strike-slip faulting is the only important kind of neotectonic activity in the vicinity of DCPP. 1 As I have previously discussed, these deformation models do not meet basic scientific standards for objectivity and reliability because are not geometrically self-consistent, nor are they consistent with GPS and regional stress directions. Instead, they appear to be custom-built to minimize seismic hazard at DCPP.

6. In my expert opinion, thrust-faulting (due to horizontal compression of the crust) is an equal contributor to overall seismicity in this area. More importantly, it implies a far greater increase in expected SCDF at DCPP due to the extreme accelerations that occur in hanging-walls of thrust faults, especially near their tips.

7. The basis for my expert opinion is set forth below, first briefly, and then in detail, following a necessary Background section.

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III. BACKGROUND REGARDING PG&E AND NRC SEISMIC STUDIES AND ENVIRONMENTAL DOCUMENTS

A. PG&Es Public Seismic Risk Studies

8. PG&Es public seismic risk studies are the post-Fukushima SSC (PG&E, 2015; 2015L) and the resulting SPRA (PG&E, 2018). According to the SPRA: The SPRA performed for DCPP shows that the point-estimate mean SCDF [seismic core damage frequency] is 2.8x10 -5 per year (page 52).

9. The seismic model presented in the SSC (PG&E, 2015 SSHAC Level-3) is notable for deformation models that focus almost exclusively on strike-slip faults, neglecting to consider thrust faults under DCPP as dangerous seismic sources. 1 This significant omission is addressed in (Bird, 2023) and will be discussed later in my declaration.

B. Environmental Documents

10. PG&Es SCDF estimate was accepted by NRC in the Draft License Renewal GEIS (NRC, 2023). Table E.3-11 , entitled Seismic (Full Power) Core Damage Frequency Comparison ,

lists expected severe seismic accident rates for every nuclear plant in the country. In the row labeled Diablo Canyon 1, 2 the value for the metric SAMA SCDF(a) is 1.3x10 -5 /yr, and the value for the metric SPRA Mean SCDF(b) is 2.8x10 -5 /yr. The mean of these two metrics is 2x10 -5 /yr.

11. Both the Draft License Renewal GEIS and Applicants Environmental Report (PG&E, 2023) describe the expected rate of severe accidents of external seismic origin as SMALL .2 In the Draft GEIS, this characterization can be found at page E-34 ( The NRC staff concludes that . . . external event risk is being effectively addressed and reduced by the various NRC Orders and other initiatives, and that, therefore external event risk is not expected to challenge the 1996 LR GEIS 95th percentile UCB [upper confidence bound] risk metrics during the initial LR [license renewal] . . . period. ) Also see page E-1 ( The 1996 LR GEIS concluded that the probability-weighted consequences were small compared to other risks to which the populations surrounding nuclear power plants are routinely exposed. )

12. In the Environmental Report, this characterization can be found in Section 4.15 Postulated Accidents / Section 4.15.2 Severe Accidents , on pages 4-61 (PDF page 455). The more specific statement of SCDF in PG&E (2023) is: As shown in Attachment G, Section G.2.1.17, the DCPP application model used for the SAMA analysis has an internal fire CDF of 4.6 x 10 -5 and a seismic CDF of 2.96 x 10 -5 which are less than the bounding CDFs in

1 Technically, a few of PG&Es 2015 deformation models did include thrust faults; however, they were uniformly parameterized as steeply-dipping, slow-slipping, not passing below DCPP, limited to low maximum-magnitudes, and/or low-weighted on the logic tree(s). Thus, their net impact on PG&Es SSC and SCDF estimates was insignificant.

2 In my understanding, the term SMALL is equivalent to insignificant from the standpoint of the severity of environmental impacts.

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Tables E.3-10 and E.3-11. Consistent with NRC's conclusions, these lower fire and seismic CDFs are also not significant compared to the previous LR GEIS revisions. (page 4-62; PDF page 456).

13. For brevity in this Declaration, I will refer to this old estimate as a seismic core damage frequency of 2~3x10 -5 /yr; that is, one severe accident of seismic origin per 33,000~50,000 years.

IV. SCIENTIFIC ANALYSIS

A. Abstract

14. The following is an abstract of my scientific analysis:

(1) The Noto Peninsula earthquake in Japan (2024.01.01, m7.5, 10 km deep) produced peak ground accelerations (PGA) of 1.0~2.3 g (that is, 100~230% of gravity) at 5 modern digital strong-motion seismometers as far as 42 km from the rupture.

(2) This strong shaking occurred in the Noto Peninsula, which is part of the hanging-wall (upper block) of two en-echelon thrust faults that run parallel to its two coasts.

(3) The Irish Hills, San Luis Range, and DCPP site in California are at risk for similar earthquakes and similar shaking because they are underlain by similar thrust faults, including the inland Los Osos thrust fault and the Inferred Coastline thrust running along the shore by DCPP. 3

(4) The expected recurrence interval between such events at DCPP can be roughly estimated by dividing the expected fault slip (averaging 2 m in the Noto earthquake, according to the USGS finite-fault solution) by the total heave rate of the thrust faults under DCPP, which is about 2.8 mm/year (as I will justify below). The result is 715 years. The inverse of this is the rate: 1.4x10 -3 /yr.

(5) In the existing SSC (PG&E, 2015; 2015L), the intensity of shaking at this return period of 715 years has been underestimated by a factor of 3~7. This means that the chance of seismic core damage is much higher when thrust-faulting earthquake sources are included.

(6) Applying my analysis to these facts, the probability of a severe accident of earthquake origin at DCPP has been underestimated by a factor of (1.4x10 -3 /yr) / (2~3x10 -5 /yr)

= 47~70. In other words, the severe accident that PG&E asserts will occur only once in 33,000~50,000 years may actually occur every ~715 years. That means that a license extension for 20 years would incur a ~2.8% probability of a severe accident.

3 Inferred Coastline thrust is my own term for a distinct fault surface whose trace follows the coastline opposite DCPP. Unlike the Shoreline fault in the same area, the Inferred Coastline thrust dips at a gentle angle beneath DCPP and has the up-dip rake of a thrust fault.

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B. Detailed Scientific Argument

15. In the following pages, I will demonstrate that PG&Es SCDF estimate is too low, by almost two orders of magnitude. PG&Es error lies in the subjective [i.e., committee-based, not algorithm-based] creation of deformation models that served as the basis for the 2015 SSHAC Level-3 SSC, and their almost total exclusion of shallow thrust faults under DCPP as dangerous seismic sources. While my previous criticisms of PG&Es seismic risk analyses (Bird, 2023) remain valid, it will not be necessary to evaluate every feature of the 2015 SSC here; rather, it will only be necessary to consider the kind of seismic source that was excluded.

(1) Accelerations in the 2024 Noto Peninsula earthquake

16. On 1 January 2024, at 07:10 UTC, a very large earthquake occurred beneath the Noto Peninsula on the northwest coast of Ishikawa Prefecture, Japan. Its magnitude was 7.6 on the moment-magnitude scale used by the Japan Meteorological Agency, and 7.5 on the moment-magnitude scale used by USGS. This thrust-faulting shock achieved a maximum JMA seismic intensity of Shindo 7 and Modified Mercalli intensity of IX (Violent) (Wikipedia, 2024). These intensities are very high.

17. Professor Shinji Toda of Tohoku University collected digital seismograms from the many strong-motion seismograph stations on and around the Noto Peninsula and reported them in Toda and Stein (2024). In their Figure 2, it can be seen that one station 42 km from the rupture experienced peak ground acceleration (PGA) of 230% of g; the next 4 highest PGA values observed were 150%, 140%, 120%, and 100% of gravity. 4 Toda & Stein noted that, in general, PGA values for this earthquake were about 4x greater than those anticipated by the well-known USGS ShakeMap algorithm at the same distances.

(2) Factors responsible for unusually strong shaking

18. According to the finite-fault solution computed by the U.S. Geological Survey (USGS, 2024), these high PGA sites were all located in the hanging-wall (upper block) of a thrust fault with SE dip. The reasons why unusually strong shaking should be expected in the hanging-wall of a thrust are well-understood, at least in qualitative terms:

19. First, it is common for thrust-fault ruptures to begin in the zone of highest stress-drop, near the base of the seismogenic zone at ~10 km depth. As the rupture expands up-dip, each

4 PGA, or Peak Ground Acceleration, is obtained from a seismogram either directly (if it is an accelerogram), or by taking the first time-derivative (if it is a velocity seismogram), or by taking the second time-derivative (if it is a displacement seismogram). Either way, it is a seismic acceleration in units of m/s 2. However, a common practice in this field of seismic hazard assessment is to normalize PGA by dividing it by the everyday (non-seismic) acceleration of gravity on the surface of the Earth, g = 9.8 m/s 2. After this normalization, PGA is expressed in units of g.

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increment of slip adds its seismic energy to a directivity-pulse of strong shear (S) waves.

Second, this shear-wave energy cannot escape into the atmosphere, because it is perfectly reflected by the free surface. Third, along the active fault at the base of the upper block, shear waves are also partially reflected upward by the low-velocity layer of fault gouge.

Where the fault is actively slipping, higher reflection coefficients are caused by temporary coseismic increases of pore pressure in this gouge layer, and by the fact that the fault has left the elastic domain and is in a state of frictional plasticity. Thus, the shear-wave seismic energy propagating up-dip in the upper block is largely confined to a wedge whose thickness and mass decrease towards its tip (at the fault trace). Fourth, conservation of energy then requires seismic wave amplitude, velocity, and acceleration to increase to high values. In fact, there is a loose analogy to the behavior of shear waves in a whip, where the tip is intended to reach supersonic velocities.

20. A necessary step in every seismic source characterization probabilistic seismic hazard assessment study is the use of ground-motion prediction equations (GMPEs) to estimate shaking from earthquake magnitude, distance, and other geometric factors. One of the most respected sources of GMPEs in the next-generation literature is Campbell & Bozorgnia (2014). This source recognizes the special hazard in the hanging-wall of a thrust; the Abstract states (in part): In addition to those terms included in our now-superseded 2008 GMPE, we include a more-detailed hanging wall model, scaling with hypocentral depth and fault dip, . Below, in their text: The hanging wall term was updated in part by empirically constraining the hanging wall model developed by Donahue and Abrahamson (2013, 2014) from ground motion simulations. In their equation (1), term fhng describes additional intensity for observers in a hanging-wall location. This term is itself the product of 6 factors defined by equations (7-16). Thus, modern practice provides ways to estimate the hanging-wall effect, although these were apparently not used in the 2015 SSC study.

21. Notably, high PGA above a thrust-fault has been observed in California, in the 1971.02.09 San Fernando (or Sylmar) earthquake of m6.6, which had a maximum Mercalli intensity of XI (Extreme). A strong-motion seismogram installed on a bedrock base next to the Pacoima Dam observed PGA of 125% of g (Cloud & Hudson, 1975).

(3) Tectonic analogy between the Noto Peninsula and the Irish Hills of California

22. According to Japanese geological sources summarized by Toda & Stein (2024), the Noto Peninsula is a crustal block that is being uplifted from beneath the Sea of Japan by the joint action of conjugate SE-dipping thrust faults just offshore its NW coast and NW-dipping thrust faults just offshore its SE coast. The driving force comes from horizontal convergence (estimated as ~10 mm/yr) between the island of Honshu and the Eurasia plate (or, more precisely, between the Amur and Okhotsk plates in the PB2002 global model of Bird, 2003).

23. The Irish Hills, San Luis Range, and DCPP site in California occupy a closely analogous tectonic setting, with a SW-dipping active thrust fault (Los Osos thrust) on the NE side, and the NE-dipping Inferred Coastline thrust [my proposed name for purposes of this Declaration] on the southwest side. This basic structure was mostly ignored by PG&E in creating deformation models for the 2015 SSC (PG&E, 2015).

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24. The Irish Hills and the San Luis Range are a dextral-transpressional orogen that has formed since ~3.5 million years (or mega annus, Ma) [ Page et al. , 1998], or possibly since 7.8~6 Ma

[Atwater & Stock , 1998; Bird & Ingersoll , 2022] when the motion of the Pacific plate changed its direction to become more compressional relative to North America. This means that the region can be expected to be cut by a number of both strike-slip and thrust (compressional) faults.

25. Evidence of compressional tectonic structures in the region includes the following eight significant elements:

a. The Pismo syncline is the primary structural feature exposed in the Irish Hills [ Pacific Gas & Electric , 2014]. Here beds have been rotated ~45 , which angle is supported by both mapped surface dips in outcrops (geologic map, ibid ), and by the overall dip of unit Tmo Obispo Formation in the borehole-controlled cross-section of Figure 13-17 of the SSC for DCPP. This folding began after deposition of the youngest strata in the core of the fold (Tmpm), and prior to deposition of the Squire Member of the (Pliocene) Pismo Formation (Tpps), probably ~5 Ma. This folding implies upper-crustal strains of ~0.8, and mean strain-rates of ~0.8 / 5 Ma = 5x10 -15 per second (/s). This is ~10x faster than rates of off-modeled-fault (or continuum) deformation that are typical in the long-term neotectonics of the western US [5x10 -16 /s per Bird, 2009]. This high rate of permanent straining implies a high rate of faulting and of earthquakes, even if the relevant thrust fault traces are not always exposed.

b. According to the geologic map [PG&E, 2014] and associated cross-section C-C in its Fig. 13-17, the apparent throw (vertical offset) of stratigraphic unit Tmo Obispo Formation is 1.6~2.2 km across the Shoreline fault trace. (This measurement is illustrated in my own Figure 1.) None of this can be explained by strike-slip on the Shoreline fault because its slip-rate is very low and because regional strikes of bedding are roughly parallel to it. Instead, the simplest explanation is thrust-faulting on the Inferred Coastline thrust that shares the complex, braided surface trace of the Shoreline fault. Assuming a typical thrust-fault dip of 25 , the amount of slip required to create this throw is (1.6~2.2 km) / sin(25 ) = 3.8~5.2 km. Then, assuming this occurred since ~5 Ma, the mean rate of slip on the Inferred Coastline thrust has been 0.76~1.04 mm/a. To the northwest of section C-C the throw of unit Tmo becomes much less, but the area of neotectonic uplift of the Irish Hills (Figure 7-4 in PG&E, 2015) continues to the northwest; so there the thrust fault probably does not terminate but merely deforms unit Tmo into a fault-initiation anticline above it. (In this area, complex older deformation associated with intrusions of Tmod diabase obscures the Pliocene-Quaternary structure, and makes balanced-section methods inapplicable.) In my professional judgment, this Inferred Coastline thrust fault continues, with the same rake and offset, northwest to the Hosgri fault.

c. The neotectonic uplift rate of the whole Irish Hills region is uniform at 0.2 mm/a (Fig. 7-4 in PG&E, 2015). Because the Franciscan Complex basement is weak, and because

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there is no large isostatic gravity anomaly over the Irish Hills [ Simpson et al. , 1986], this uplift process should be modeled with Airy isostasy. The implied rate of crustal thickening is then about 6 times larger, or about 1.2 mm/a. If this crustal thickening is occurring on a single thrust fault of dip 25 , then its rate of slip should be (1.2 mm/a) /

sin(25 ) = 2.8 mm/a. Or, if the crustal thickening is driven by two oppositely-vergent and overlapping thrust faults (as in my schematic section, Figure 1 at the end of this testimony), then each should have a slip-rate of ~1.4 mm/a. Obviously, more complex models with more thrust faults can be devised, but the implication for total strain and seismicity due to thrust-faulting will remain unchanged.

d. The southwestern front of the Irish Hills is a topographic scarp with a smooth arcuate shape, mirroring the slightly-lower scarp on the northeast which has been formed by slip on the Los Osos thrust fault. This suggests that the Inferred Coastline thrust is present under the southwestern front, at or near the coastline.

e. The 2003 San Simeon m6.6 and 1983 Coalinga m6.2 earthquake both had thrust mechanisms [Global Centroid Moment Tensor Catalog, Ekstrm et al. , 2012]. This is evidence of highly-compressive horizontal stresses in the Coast Ranges region, suggesting a likelihood of seismic thrust-faulting in other locations as well.

f. SSW-NNE directions of most-compressive stress shown by data in the World Stress Map

[Mueller et al. , 1997; Heidbach et al. , 2008, 2016], and by interpolation of stress directions using the method of Bird & Li [1996], are almost perpendicular to the traces of the regional fault grain (Shoreline, Inferred Coastline, San Luis Bay, and Los Osos fault traces). This strongly suggests that currently these faults are either purely or dominantly thrust faults.

g. Closer to DCPP, two recent small earthquakes had thrust-faulting mechanisms with the expected SSW-NNE direction of maximum horizontal compression: 2023.12.27 m3.1 at 6.2 km depth under the Irish Hills, and 2024.01.01 m5.4 slightly offshore from the NW end of the Irish Hills (D. J. Weisman, pers. comm., 2024.01.02). This shows that the regional stress regime and orientation documented above also apply in the immediate vicinity of DCPP.

h. Models of neotectonic deformation, informed and guided by GPS velocity data, include such long-term compression. Specifically, Shen & Bird [2022] computed a suite of kinematic finite-element (F-E) models of neotectonics across the western US based on geodetic, geologic, & stress data with program NeoKinema. Their preferred model, which has been incorporated into the 2024 update of the USGS National Seismic Hazard Model, shows convergence of crustal blocks on both sides of the Irish Hills/San Luis Range region at velocities of ~1 mm/a, for a total of ~2 mm/a of local horizontal convergence rate.

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(4) Thrust-fault slip-rates and earthquake recurrence intervals

26. The paragraphs above contain multiple arguments for horizontal convergence at ~2.0 mm/yr in the Irish Hills area, and for total thrust-fault slip rates of ~2.8 mm/yr. In addition, paragraph 25(b) shows that the slip-rate of the Inferred Coastline thrust must be 0.76~1.04 mm/yr. Therefore, deformation models like some of PG&Es in their 2015 SSC that attribute all uplift and shortening to the Los Osos fault are not defensible.

27. In SSC and PSHA studies that include fault seismic sources with very incomplete information, it is traditional to assume a periodic characteristic earthquake model. While this is only an approximation of the chaotic earthquake dynamics in the real Earth, it has the advantage of allowing simple arithmetical conversions between the triad of basic parameters:

slip, slip-rate, and recurrence interval. For example, to compute the recurrence interval for large characteristic thrust-faulting earthquakes under the Irish Hills (either on the Los Osos or Inferred Coastline thrust), it is sufficient to divide the mean coseismic slip by the long-term tectonic slip-rate.

28. In the 2024 Noto Peninsula earthquake, we have the advantage of the finite-fault solution (USGS, 2024), which maps the amount of coseismic slip onto the active fault plane. This study showed maximum slip of 3.7 m under the center of the Noto Peninsula, with a mean slip that I visually estimate as 2.0 m (or 2000 mm) in the seismogenic depth range.

29. Dividing this mean slip of 2000 mm by the long-term tectonic slip-rate of 2.8 mm/a in the Irish Hills, the inferred recurrence rate for Noto-type earthquakes under the Irish Hills is 715 years. In other words, the inferred probability of Noto Peninsula-type earthquakes under the Irish Hills is the inverse of this, which is 1.4x10 -3 /yr.

30. Again, reasonably presuming that the Noto Peninsula earthquake is a characteristic earthquake for this tectonic setting (shared by the Irish Hills in California), PGA values of 1.0~2.3 g (see section 1 above) must be expected with probability 1.4x10 -3 /yr. However, in the 2015 SSC (specifically, in Figure 2.3.7-1 of PG&E, 2015L), we see that this outdated modeling associated this probability level with a PGA of only 0.32 g. Consequently, it appears that the 2015 SSC severely underestimated (by a factor of 3~7) the severity of shaking (PGA) that must be resisted every ~715 years.

(5) Susceptibility of DCPP to seismic core damage

31. This raises the question of whether PGA of 1.0~2.3 g will cause seismic core damage (SCD) at Diablo Canyon Units 1 & 2. Answering this question quantitatively becomes technical and difficult, given that spectral accelerations critical to individual component failures are typically twice as large as PGA; that is, perhaps 2.0~4.6 g at vibration frequencies of 5~10 Hz in the Noto Peninsula case.

32. The 2018 SPRA (PG&E, 2018) is the most recent available to me. Within this document, Table 5.4-4 (page 65) shows how the overall SCDF of 2.8x10-5 /yr was obtained. In principle, it should be possible to use this information to estimate the probability of SCD at

9

each level of shaking. My interpretation of the table is that the probability of SCD is ~6% at 2 g, rising to ~73% at 3 g and to >98% at 4 g. The problem is that the acceleration levels quoted in this table are not clearly identified; are they PGAs or (more likely) spectral accelerations? The context in this SPRA report suggests that they are spectral accelerations:

the introductory section 3.1.3 Seismic Hazard Analysis Results and Insights only discusses 5 Hz spectral accelerations, and the primary graphs that it refers to (Figure 3 Reference Rock Hazard by Source for 5 Hz Spectral Acceleration and Figure 3 5 Hz Control Point Mean and Fractiles Horizontal Hazard) are plots of 5 Hz spectral acceleration.

33. Therefore, my interpretation of these reports is that a PGA event of 1.0 g would produce 5 Hz spectral accelerations of ~2 g, and incur ~6% of SCD. However, a PGA event of 1.5 g would produce 5 Hz spectral accelerations of ~3 g, and incur a ~73% chance of SCD. And the peak Noto-earthquake observation of PGA of 2.3 g would produce spectral accelerations of ~4.6 g, and incur >98% chance of SCD.

34. It will probably be controversial exactly which of the Noto Peninsula seismograms give the median and worst-case forecasts of shaking at DCPP. The paragraph above shows that this is a critical point. Clearly these questions need to be resolved by independent experts, preferably in a revised SSC study followed by a revised SPRA study. In the meantime, for purposes of evaluating PG&Es Environmental Report, it is reasonable to assume that the levels of shaking seen in the Noto Peninsula earthquake will cause seismic core damage at DCPP if and when they occur in the Irish Hills of California.

(6) Risk of external seismic severe accidents at DCPP has been grossly underestimated

35. The combined implication of the above-cited facts and analysis is that the probability of a severe accident of earthquake origin at DCPP has been underestimated by a factor of (1.4x10 -3 /yr) / (2~3x10 -5 /yr) = 47~70. In other words, the severe accident that PG&E asserts will occur only once in 33,000~50,000 years may actually occur every ~715 years.

That means that a license extension for 20 years would incur a ~2.8% probability of a severe accident.

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C. Figure 1

Figure 1. Revised geologic section through the Irish Hills near DCPP. The base for this figure is Figure

13-17 of the Seismic Source Characterization for DCPP (PG&E, 2015). Note that the fault dips suggested by black lines in their figure were not based on data, but were constrained by PG&Es (2015) a priori assumption that only strike-slip tectonics is active in the area. In red, I have suggested more plausible 25 dips for the Los Osos thrust (at right/North) and the Inferred Coastline thrust (at left/South). The upper-left portion of this figure is also edited to show the throw (vertical offset) of map unit Tmo across the Inferred Coastline thrust, discussed in my text paragraph IV.B.25(b).

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V. ADDITIONAL OBJECTIONS TO APPLICANTS ENVIRONMENTAL REPORT

A. Regarding adequacy of existing and planned deformation models

36. In my previous Declaration (2023.04.28) to NRC regarding their Draft Generic EIS (NRC, 2023), and in my Testimony (2023.06.30) to the California Public Utilities Commission regarding DCPP, I raised objections to the methodology of the SSC for DCPP (PG&E, 2015):

The 2015 SSC for DCPP was deficient and biased in 3 ways: (1) Fault slip-rates were selected subjectively and in isolation, without modern deformation-modeling (as used by USGS) to guarantee that all fault slip-rates and rates of distributed permanent deformation are self-consistent, and also consistent with geodetic-velocity and stress-direction data; (2) Seismicity from unexpected, undetected, and/or subterranean ruptures between the known faults was modeled based on projection of a few decades of microseismicity, ignoring globally-calibrated relationships between long-term tectonic strain-rate and (typically higher) long-term-mean seismicity which includes seismic crises; and (3) Despite several arguments and proposals for a thrust fault at shallow depths under DCPP with slip-rate of ~1 mm/a, no such seismic source was included.

Point (3) has been expanded in Section I of this Testimony, above.

37. However, I wish to restate my objections (1) and (2) above, because both systematic defects in deformation-modeling have the potential to seriously bias the estimated seismic hazard.

38. The response from PG&E appears in the following paragraph on page G-27 of Attachment G to Applicants Environmental Report (PG&E, 2023):

New or updated seismic methodologies and models developed since preparation of the SSC model will be considered as part of the SB-846-required seismic update. The DCPP seismic analyses, however, include a variety of well-established and vetted models rather than a single method. Therefore, additions or changes in data input from a single model typically result in slight to moderate changes in hazard calculations. If proposed new methods or models are determined to be viable and reliable, they will be integrated with other models so the impact of any single change is not expected to result in a significant change in the resulting seismic hazard.

39. The strong implication here is that PG&E intends to keep their old deformation models from 2015, and perhaps add one or two alternative deformation models (probably with small logic-tree weights), so that there is no material change in net seismic hazard. Actually, in a public presentation to the Diablo Canyon Independent Safety Committee of the California Public Utilities Commission on 23 February 2024, the PG&E presenters indicated that there would be no new deformation models, and the geometry of the old deformation models would be unchanged. As discussed above, I consider this unscientific and unacceptable because the

12

old deformation models were not internally self-consistent, and were not consistent with GPS data, and also because they appeared to be custom-built to minimize seismic hazard at DCPP.

40. In this regard, I advise that NRC should apply strong scrutiny to this planned SB-846-required seismic update (if and when it is released), and also carefully consider the anticipated reviews offered by the 3 outside experts of UCLAs Garrick Risk Institute, and also the anticipated opinions of the Diablo Canyon Independent Safety Committee of the California Public Utilities Commission, informed by their Independent Peer Review Panel.

C. Regarding status of witnesss models in the seismicity/hazard communities

41. Attachment G, page G-27 of Applicants Environmental Report (PG&E, 2023) contains a description of how the Technical Integration (TI) Team and the Participatory Peer Review Panel (PPRP) of the SSHAC Level-3 SSC program (2012-2015) considered a presentation I made at the November 2012 San Luis Obispo workshop, and decided to use some elements (rates of strike-slip) and decided to exclude other elements (rates of horizontal compression; computer algorithms for objective creation of optimal deformation models; global calibrations for converting long-term strain-rates to seismicity). The paragraph I object to is this:

Dr. Bird's modeling of off-fault deformation and alternative methods to calculate seismicity rates were not considered mature enough by the Tl Team at the time of the SSHAC to include in the SSC model. This is consistent with exclusion of these models and model elements from the Uniform California Earthquake Rupture Forecast (ver . 3) which is the basis for the 2014 update to the United States Geological Survey Seismic National Seismic Hazard Map (References 111 & 113)

42. The first problem is a misleading implication of the phrase, exclusion of these models. My deformation model, obtained with my dynamic finite-element code NeoKinema, was used by the USGS in their 2014 Update to the National Seismic Hazard Model (Field et al., 2013). It was assigned a weight of 0.3 in the logic tree, and no other deformation model had a higher weight. The necessary distinction is that USGS finally decided to use only the computed fault slip-rates, and not the self-consistent off-fault deformation field.

43. Second, the repetition of this criticism, not . mature enough , probably written in 2012, in the new Applicants Environmental Report (PG&E, 2023) written 11 years later is also misleading. My NeoKinema code for creation of deformation models was used again in the 2024 Update to the National Seismic Hazard Model (Shen & Bird, 2022), with a logic-tree weight of 0.32. (Again, no other deformation model had a higher weight.)

44. Also, my global-calibration method (Bird & Kagan, 2004; Bird & Liu, 2007) for converting long-term strain-rates to shallow seismicity has been developed into 3 global seismicity models of increasing sophistication (Bird et al., 2010; Bird & Kreemer, 2015; Bird et al.,

2015). These models have been registered with the Collaboratory for the Study of Earthquake Predictability (CSEP) and have proven successful in prospective tests by

13

independent experts (Strader et al., 2018; Bayona et al., 2023). The third of these models, named GEAR1, is currently the global standard.

Under penalty of perjury, I declare that the foregoing statements of fact are true and correct to the best of my knowledge and that the statements of opinion expressed above are based on my best professional judgment.

Executed in Accord with 10 CFR 2.304(d) by Peter Bird

Date: March 4, 2024

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VI. REFERENCES

A. References Cited in Sections I-IV Atwater, T., and J. Stock [1998] Pacific-North America plate tectonics of the Neogene southwestern United States: An update, Int. Geol. Rev., 40, 375-402.

Bird, P., 2003. An updated digital model of plate boundaries, Geochemistry Geophysics Geosystems, 4(3), 1027, doi:10.1029/2001GC000252.

Bird, P. [2009] Long-term fault slip rates, distributed deformation rates, and forecast of seismicity in the western United States from fitting of community geologic, geodetic, and stress direction datasets, J. Geophys. Res., 114(B11403), doi: 10.1029/2009JB006317.

Bird, P. [2023] Declaration of Peter Bird, submitted to U.S. Nuclear Regulatory Commission in support of Comments by San Luis Obispo Mothers for Peace on Proposed Rule and Draft Generic Environmental Impact Statement for Renewing Nuclear Power Plant Licenses, Docket No. 2018-0296, May 2, 2023 (NRC ADAMS Accession No. ML23123A410, https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23123A410 ).

Bird, P., and R. V. Ingersoll [2022] Kinematics and paleogeology of the western United States and northern Mexico computed from geologic and paleomagnetic data: 0 to 48 Ma, Geosphere, 18(5), 1563-1599, https://doi.org/10.1130/GES02474.1.

Bird, P., and Y. Li [1996] Interpolation of principal stress directions by nonparametric statistics:

Global maps with confidence limits, J. Geophys. Res., 101(B3), 5435-5443.

Campbell, K. W., and Y. Bozorgnia, 2014. NGA-West2 ground motion model for the average horizontal components of PGA, PGV, and 5% damped linear acceleration response spectra, Earthquake Spectra, 30(3), 1087-1115.

Cloud, W. K., and D. E. Hudson, 1975. Strong motion data from the San Fernando, California, earthquake of February 9, 1971: San Fernando, California, Earthquake of 9 February 1971, Bulletin 196, California Division of Mines and Geology, pp. 273-303.

Ekstrm, G., M. Nettles, and A. M. Dziewonski [2012] The Global CMT project 2004-2010:

Centroid moment tensors for 13,017 earthquakes, Phys. Earth Planet. Int., 200/201, 19.

Mueller, B., V. Wehrle, and K. Fuchs [1997] The 1997 release of the World Stress Map, http://www-wsm.physik.uni-karlsruhe.de/pub/Rel97/wsm97.html.

Heidbach, O., M. Tingay, A. Barth, J. Reinecker, D. Kurfe, and B. Müller [2008] The World Stress Map database release 2008, doi:10.1594/GFZ.WSM.Rel2008.

Heidbach, O., M. Rajabi, K. Reiter, M.O. Ziegler, and the WSM Team [2016] World Stress Map Database Release 2016, doi:10.5880/WSM.2016.001.

Pacific Gas and Electric Company [2014] Geologic Map of the Irish Hills and Adjacent Area, 1:32,000, DCPP Geologic Mapping Project, Ch9.GEO.DCPP.TR.14.01 R0, https://www.pge.com/includes/docs/pdfs/safety/systemworks/dcpp/report/Ch9.GEO.DCPP.TR.1 4.01_R0_Plates.pdf , NRC ADAMS Accession No. ML14260A068.

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Pacific Gas and Electric Company (PG&E), 2015. Seismic Source Characterization for the Diablo Canyon Power Plant, San Luis Obispo County, California; report on the results of SSHAC level 3 study, Rev. A, March; 652 pages plus Appendices. Available online at http://www.pge.com/dcpp-ltsp; downloaded 2023.05.11.

Pacific Gas and Electric Company (PG&E), 2015L. Letter DCL-15-035 re: Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident: Seismic Hazard and Screening Report (Mar. 11, 2015) (NRC Accession No. ML15071A045).

Pacific Gas and Electric Company (PG&E), 2018. Letter DCL-18-027 re: Seismic Probabilistic Risk Assessment for the Diablo Canyon Power Plant, Units 1 and 2 - Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1: Seismic of the (sic) Near-Term Task force Review of Insights from the Fukushima Dai-Ichi Accident (Apr. 24, 2018) (NRC Accession No. ML18120A201).

Pacific Gas and Electric Company (PG&E), 2023. Appendix E: Applicants Environmental Report, Operating License Renewal Stage, Diablo Canyon Power Plant Units 1 and 2, November 2023: NRC ADAMS Accession No. ML23311A154, dated 2023.11.07, 1,137-page PDF file, accessed 2024.02.

Page, B. M., G. A. Thompson, and R. G. Coleman [1998] Late Cenozoic tectonics of the central and southern Coast Ranges of California, Geol. Soc. Am. Bull., 110(7), 846-876.

Shen, Z.-K., and P. Bird [2022] NeoKinema deformation model for the 2023 update to the U.S.

National Seismic Hazard Model, Seismol. Res. Lett., 93, 3037-33052, doi: 10.1785/0220220179.

Simpson, R. W., R. C. Jachens, R. J. Blakely, and R. W. Saltus [1986], A new isostatic residual gravity map of the conterminous United States with a discussion on the significance of isostatic residual anomalies, J. Geophys. Res., 91(B8), 8348-8372 & 8407-8410.

Toda, S., and Stein, Ross S., 2024. Intense seismic swarm punctuated by a magnitude 7.5 Japan shock, Temblor, http://doi.org/10.32858/temblor.333 United States Geological Survey (USGS), 2024. Finite Fault model for 1 Jan 2024 M 7.5 earthquake, https://earthquake.usgs.gov/earthquakes/eventpage/us6000m0xl/finite-fault Wikipedia, 2024. Noto earthquake, https://en.wikipedia.org/wiki/2024_Noto_earthquake ,

accessed 2024.02.16.

B. References Cited in Section V

Bayona, J. A., W. H. Savran, P. Iturrieta, M. C. Gerstenberger, K. M. Graham, W. Marzocchi, D.

Schorlemmer, and M. J. Werner [2023] Are Regionally Calibrated Seismicity Models More Informative than Global Models? Insights from California, New Zealand, and Italy, The Seismic Record, 3(2), 86-95, doi: 10.1785/0320230006.

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Bird, P., and Y. Y. Kagan [2004] Plate-tectonic analysis of shallow seismicity: Apparent boundary width, beta, corner magnitude, coupled lithosphere thickness, and coupling in seven tectonic settings, Bull. Seismol. Soc. Am., 94(6), 2380-2399, plus electronic supplement.

Bird, P., and C. Kreemer [2015] Revised tectonic forecast of global shallow seismicity based on version 2.1 of the Global Strain Rate Map, Bull. Seismol. Soc. Am., 105(1), 152-166 plus electronic supplements, doi: 10.1785/0120140129.

Bird, P., and Z. Liu [2007] Seismic hazard inferred from tectonics: California, Seismol. Res.

Lett., 78(1), 37-48.

Bird, P., C. Kreemer, and W. E. Holt [2010] A long-term forecast of shallow seismicity based on the Global Strain Rate Map, Seismol. Res. Lett., 81(2), 184-194, doi:10.1785/gssrl.81.2.184.

Bird, P., D. D. Jackson, Y. Y. Kagan, C. Kreemer, & R. S. Stein [2015] GEAR1: a Global Earthquake Activity Rate model constructed from geodetic strain rates and smoothed seismicity, Bull. Seismol. Soc. Am., 105(5); 2538-2554, doi: 10.1785/0120150058.

Field, E. H., G. P. Biasi, P. Bird, T. E. Dawson, K. R. Felzer, D. D. Jackson, K. M. Johnson, T.

H. Jordan, C. Madden, A. J. Michael, K. R. Milner, M. T. Page, T. Parsons, P. M. Powers, B. E.

Shaw, W. R. Thatcher, R. J. Weldon, II, and Y. Zeng [2013] Unified California Earthquake Rupture Forecast, version 3 (UCERF3)-The time-independent model, U.S. Geol. Surv. Open-File Rep., 2013-1165 (and Cal. Geol. Surv. Spec. Rep. 228, and Southern California Earthquake Center Pub. 1792), 97 pages (main report) + 20 Appendices; http://pubs.usgs.gov/of/2013/1165/

Nuclear Regulatory Commission (NRC) [2023] Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants: NUREG-1437, Rev. 2, Feb. 2023.

Pacific Gas and Electric Company (PG&E) [2023] Appendix E: Applicants Environmental Report, Operating License Renewal Stage, Diablo Canyon Power Plant Units 1 and 2, November 2023: NRC ADAMS Accession No. ML23311A154, dated 2023.11.07, 1,137-page PDF file, accessed 2024.02.

Shen, Z.-K., and P. Bird [2022] NeoKinema deformation model for the 2023 update to the U.S.

National Seismic Hazard Model, Seismol. Res. Lett., 93(6), 3037-3052, https://doi.org/10.1785/0220220179, 16 pages.

Strader, A., M. Werner, J. Bayona, and D. Schorlemmer [2018] Prospective evaluation of global earthquake forecast models: Two years of observations support merging smoothed seismicity with geodetic strain rates, Seismol. Res. Lett., 89(4), 1262-1271, doi: 10.1785/0220180051.

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VII. CURRICULUM VITAE

CURRICULUM VITAE OF PETER BIRD Department of Earth, Planetary, and Space Sciences Mail Code 156704 University of California Los Angeles, CA 90095-1567 e-mail: pbird@epss.ucla.edu website: http://peterbird.name EDUCATION Massachusetts Institute of Technology: Ph.D. in Earth and Planetary Sciences, 1976 Harvard College: B.A. in Geological Sciences, 1972

EMPLOYMENT University of California, Los Angeles:

Professor Emeritus, 2011-Professor of Geophysics and Geology, 1985-2011 Vice-chairman, Dept. of Earth and Space Sciences, 1994-2002 Associate Professor of Geophysics and Geology, 1981-85 Assistant Professor of Geophysics and Geology, 1976-81

HONORS Woollard Award, Geological Society of America, 2013 Fellow, American Geophysical Union, 1990 Fellow, Geological Society of America, 1989

RESEARCH AREAS (CHRONOLOGICAL FROM 1973)

Lateral refraction and attenuation of surface waves 1973-1977 Marine paleomagnetism and seafloor spreading 1974-1975 Thermal modeling with finite differences 1975-1977 Dynamic modeling with finite elements 1975-Tectonophysics of continental collisions 1975-Formation of marginal basins 1976-1977 Stress and temperature in subduction zones 1976-2009 Continental delamination 1977-1982 Neotectonic models of California 1978-Hydration state and friction of montmorillonite clays 1979-1984 Mechanism of Laramide orogeny 1982-Mechanism of Basin/Range taphrogeny 1986-Solution transfer experiments on quartz 1986-1993 Lateral extrusion of lower crust 1987-1991 Regional neotectonic models: Africa, Alaska, Asia, Europe, ... 1989-Global dynamic lithosphere models with plates & driving forces 1992-Inverse or kinematic tectonic models from geologic & paleomag data 1994-Global long-term seismicity forecasts from geodesy & plate tectonics 2000-Long-term seismicity forecasts for Europe, especially Italy 2009-

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CONSULTING EXPERIENCE ON SEISMIC HAZARD (FROM 2009 TO PRESENT)

GeoPentech, Lettis Consultants International, FM Global, Temblor, San Luis Obispo Mothers for Peace

UNPAID AFFILIATIONS Southern California Earthquake Center (2000-present; Board member 2004-2012)

Collaboratory for the Study of Earthquake Predictability (model contributor, 2015)

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VIII. PUBLICATIONS (CHRONOLOGICAL FROM 1975; OMITTING MOST ABSTRACTS)

Bird, P., and J. D. Phillips [1975] Oblique spreading near the Oceanographer Fracture, J.

Geophys. Res., 80 , 4021-4027.

Bird, P., M. N. Toksoz, and N. H. Sleep [1975] Thermal and mechanical models of continent-continent convergence zones, J. Geophys. Res., 80 , 4405-4416.

Toksoz, M. N., and P. Bird [1977] Modeling of temperatures in continental convergence zones, Tectonophysics, 41 , 181-193.

Bird, P., and M. N. Toksoz [1977] Strong attenuation of Rayleigh waves in Tibet, Nature, 266 , 161-163.

Toksoz, M. N., and P. Bird [1977] Formation and evolution of marginal basins and continental plateaus, in: M. Talwani and W. C. Pitman, III (Ed.), Island Arcs, Deep Sea Trenches, and Back Arc Basins, Maurice Ewing Series 1 , Am. Geophys. Union, Washington, 379-394.

Bird, P. [1978a] Initiation of intracontinental subduction in the Himalaya, J. Geophys. Res.,

83 , 4975-4987.

Bird, P. [1978b] Finite-element modeling of lithosphere deformation: The Zagros collision orogeny, Tectonophysics, 50 , 307-336.

Bird, P. [1978c] Stress and temperature in subduction shear zones: Tonga and Mariana, Geophys. J. R. Astron. Soc., 55 , 411-434.

Bird, P. [1979] Continental delamination and the Colorado Plateau, J. Geophys. Res., 84 ,

7561-7571.

Bird, P., and D. A. Yuen [1979] The use of the minimum-dissipation principle in tectonophysics, Earth Planet. Sci. Lett., 45 , 214-217.

Bird, P., and K. Piper [1980] Plane-stress finite-element models of tectonic flow in southern California, Phys. Earth Planet. Int., 21 , 158-175.

Bird, P., and J. Baumgardner [1981] Steady propagation of delamination events, J. Geophys.

Res., 86 , 4891-4903.

Bird, P. [1982] Reply re: Initiation of intracontinental subduction in the Himalaya, J.

Geophys. Res., 86 , 9323-9324.

Bird, P., and J. Baumgardner [1983] 3-D Finite element modeling of the Earth's free oscillations (abstract), Eos, 64 , 754.

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Bird, P. [1984] Hydration-phase diagrams and friction of montmorillonite under laboratory and geologic conditions, with implications for shale compaction, slope stability, and strength of fault gouge, Tectonophysics, 107 , 235-260.

Bird, P., and J. Baumgardner [1984] Fault friction, regional stress, and crust-mantle coupling in southern California from finite element models, J. Geophys. Res., 89 , 1932-1944.

Bird, P., and R. Rosenstock [1984] Kinematics of present crust and mantle flow in southern California, Geol. Soc. Am. Bull., 95 , 946-957.

Bird, P. [1985] Laramide crustal thickening event in the Rocky Mountain foreland and Great Plains, Tectonics, 3 , 741-758.

Bird, P. [1986] Tectonics of the terrestrial planets, in: M. G. Kivelson (Ed.), The Solar System: Observations and Interpretations, Rubey Volume 4 , Prentice Hall, Englewood Cliffs, New Jersey, 176-206.

Bird, P. [1988] Formation of the Rocky Mountains, western United States: a continuum computer model, Science, 239 , 1501-1507.

Bird, P. [1989] New finite element techniques for modeling deformation histories of continents with stratified temperature-dependent rheologies, J. Geophys. Res., 94 , 3967-3990.

Bird, P., and A. J. Gratz [1990] A theory for buckling of the mantle lithosphere and Moho during compressive detachments in continents, Tectonophysics, 177 , 325-336.

Bird, P., and D. R. Williams [1990] Lack of lateral extrusion on Venus limits thickness of the crust (abstract), Eos, 71 , 1423.

Gratz, A. J., P. Bird, and G. B. Quiro [1990] Dissolution of quartz in aqueous basic solution, 106-236 C: Surface kinetics of "perfect" crystallographic faces, Geochimica et Cosmochimica Acta, 54 , 2911-2922.

Bird, P. [1991] Lateral extrusion of lower crust from under high topography, in the isostatic limit, J. Geophys. Res., 96 , 10,275-10,286.

Bird, P. [1992] Deformation and uplift of North America in the Cenozoic era, in: K. R.

Billingsley, H. U. Brown, III, and E. Derohanes (eds.), Scientific Excellence in Supercomputing: the IBM 1990 Contest Prize Papers , Baldwin Press, Athens, Georgia,

v. 1, pp.67-105.

Kemp, D. V., and P. Bird [1992] Bending and dynamic support of subducted slabs (abstract), Eos Trans. AGU, 73 (43), Fall Meeting Suppl., 386.

Gratz, A. J., and P. Bird [1993a] Quartz dissolution: Negative crystal experiments and a rate law, Geochimica et Cosmochimica Acta, 57 , 965-976.

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Gratz, A. J., and P. Bird [1993b] Quartz dissolution: Theory of rough and smooth surfaces, Geochimica et Cosmochimica Acta, 57 , 977-989.

Bird, P. and X. Kong [1994] Computer simulations of California tectonics confirm very low strength of major faults, Geol. Soc. Am. Bull., 106 (2), 159-174.

Bird, P. [1994] Isotopic evidence for preservation of Cordilleran lithospheric mantle during the Sevier-Laramide orogeny, western United States: Comment, Geology, 22 (7), 670-671.

Bird, P. [1995] Lithosphere dynamics and continental deformation, Rev. Geophys. ,

Supplement: U.S. National Report to IUGG 1991-94, 379-383.

Kong, X., and P. Bird [1995] SHELLS: A thin-shell program for modeling neotectonics of regional or global lithosphere with faults, J. Geophys. Res., 100 , 22,129-22,131.

Bird, P., and Yao Li [1996] Interpolation of principal stress directions by nonparametric statistics: Global maps with confidence limits, J. Geophys. Res., 101 , 5435-5443.

Bird, P. [1996] Computer simulations of Alaskan neotectonics, Tectonics, 15 , 225-236.

Kong, X., and P. Bird [1996] Neotectonics of Asia: Thin-shell finite-element models with faults, in: An Yin and T. M. Harrison (ed.s) , The Tectonic Evolution of Asia , Cambridge University Press, p. 18-34.

Bird, P. [1998a] Testing hypotheses on plate-driving mechanisms with global lithosphere models including topography, thermal structure, and faults, J. Geophys. Res., 103 , B5, 10,115-1,129.

Bird, P. [1998b] Kinematic history of the Laramide orogeny in latitudes 35 -49 N, western United States, Tectonics, 17 , 780-801.

Bird, P. [1999] Thin-plate and thin-shell finite element programs for forward dynamic modeling of plate deformation and faulting, Computers & Geosciences, 25 , 383-394.

Bird, P. and Z. Liu [1999] Global finite-element model makes a small contribution to intraplate seismic hazard estimation, Bull. Seismol. Soc. Am., 89 (6), 1642-1647.

Jimenez-Munt, I., P. Bird, and M. Fernandez [2001] Thin-shell modeling of neotectonics in the Azores-Gibraltar region, Geophys. Res. Lett., 28 (6), 1083-1086.

Jiménez-Munt, I., M. Fernndez, M. Torne, and P. Bird [2001] The transition from linear to diffuse plate boundary in the Azores-Gibraltar region: Results from a thin sheet model, Earth Planet. Sci. Lett., 192 , 175-189.

Bird, P. [2002] Stress-direction history of the western United States and Mexico since 85 Ma, Tectonics, 21 , doi: 10.1029/2001TC001319.

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Bird, P., Y. Y. Kagan, and D. D. Jackson [2002] Plate tectonics and earthquake potential of spreading ridges and oceanic transform faults, in: S. Stein and J. T. Freymueller (editors), Plate Boundary Zones, Geodynamics Series, 130 , 203-218.

Negredo, A. M., P. Bird, C. Sanz de Galdeano, and E. Buforn [2002] Neotectonic modeling of the Ibero-Maghrebian region, J. Geophys. Res., 107 (B11), 2292, doi:

10.1029/2001JB000743.

Liu, Z., and P. Bird [2002a] Finite element modeling of neotectonics in New Zealand, J.

Geophys. Res., 107 (B12), 2328, doi: 10.1029/2001JB001075.

Liu, Z., and P. Bird [2002b] North America plate is driven westward by lower mantle flow, Geophys. Res. Lett., 29 (24), 2164, doi: 10.1029/2002GL016002.

Bird, P. [2003] An updated digital model of plate boundaries, Geochemistry Geophysics Geosystems, 4 (3), 1027, doi: 10.1029/2001GC000252.

Bird, P., and Y. Y. Kagan [2004] Plate-tectonic analysis of shallow seismicity: Apparent boundary width, beta, corner magnitude, coupled lithosphere thickness, and coupling in seven tectonic settings, Bull. Seismol. Soc. Am., 94 (6), 2380-2399.

Liu, Z., and P. Bird [2006] Two-dimensional and three-dimensional finite element modelling of mantle processes beneath central South Island, New Zealand, Geophys. J.

Int., 165 , 1003-1028.

Bird, P., Z. Ben-Avraham, G. Schubert, M. Andreoli, and G. Viola [2006] Patterns of stress and strain rate in southern Africa, J. Geophys. Res., 111 (B8), B08402, doi:

10.1029/2005JB003882.

Bird, P., and Z. Liu [2007] Seismic hazard inferred from tectonics: California, Seismol. Res.

Lett., 78 (1), 37-48.

Bird, P. [2007] Uncertainties in long-term geologic offset rates of faults: General principles illustrated with data from California and other western states, Geosphere, 3 (6), 577-595; doi: 10.1130/GES00127.1, + 9 digital file appendices.

Liu, Z., and P. Bird [2008] Kinematic modelling of neotectonics in the Persia-Tibet-Burma orogen, Geophys. J. Int., 172 (2), 779-797, doi: 10.1111/j.1365-246X.2007.03640.x.

Bird, P., Z. Liu, and W. K. Rucker [2008] Stresses that drive the plates from below:

Definitions, computational path, model optimization, and error estimates, J. Geophys.

Res., 113 , B11406, doi: 10.1029/2007JB005460, plus digital appendices.

Bird, P. [2009] Long-term fault slip rates, distributed deformation rates, and forecast of seismicity in the western United States from joint fitting of community geologic, geodetic, and stress direction data sets, J. Geophys. Res., 114 , B11403, doi: 10.1029/

2009JB006317.

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Bird, P., Y. Y. Kagan, D. D. Jackson, F. P. Schoenberg, and M. J. Werner [2009] Linear and nonlinear relations between relative plate velocity and seismicity, Bull. Seismol. Soc.

Am., 99 (6), 3097-3113, doi: 10.1785/ 0120090082.

Kagan, Y. Y., P. Bird, and D. D. Jackson [2010] Earthquake patterns in diverse tectonic zones of the globe, Pure Appl. Geophys. , 167 (6/7; Frank Evison volume), doi:

10.1007/s00024-0075-3.

Bird, P., C. Kreemer, and W. E. Holt [2010] A long-term forecast of shallow seismicity based on the Global Strain Rate Map, Seismol. Res. Lett., 81 (2), 184-194, doi:

10.1785/gssrl.81.2.184.

Howe, T. M., and P. Bird [2010] Exploratory models of long-term crustal flow and resulting seismicity across the Alpine-Aegean orogen, Tectonics, 29, TC4023, doi:

10.1029/2009TC002565.

Austermann, J., Z. Ben-Avraham, P. Bird, O, Heidbach, G. Schubert, and J. M. Stock [2011]

Quantifying the forces needed for the rapid change of Pacific plate motion at 6 Ma, Earth Planet. Sci. Lett., 307 , 289-297, doi: 10.1016/j.epsl.2011.04.043.

Chu, A., F. P. Schoenberg, P. Bird, D. D. Jackson, and Y. Y. Kagan [2011] Comparison of ETAS parameter estimates across different global tectonic zones, Bull. Seismol. Soc.

Am., 101 (5), 2323-2339, doi: 10.1785/0120100115.

Field, E. H., G. P. Biasi, P. Bird, T. E. Dawson, K. R. Felzer, D. D. Jackson, K. M. Johnson, T. H. Jordan, C. Madden, A. J. Michael, K. R. Milner, M. T. Page, T. Parsons, P. M.

Powers, B. E. Shaw, W. R. Thatcher, R. J. Weldon, II, and Y. Zeng [2013] Unified California Earthquake Rupture Forecast, version 3 (UCERF3)-The time-independent model, U.S. Geol. Surv. Open-File Rep., 2013-1165 (Cal. Geol. Surv. Spec. Rep. 228 ,

and Southern California Earthquake Center Pub. 1792 ), 97 pages (main report) + 20 Appendices; http://pubs.usgs.gov/of/2013/1165/ .

Petersen, M. D., Y. Zeng, K. M. Haller, R. McCaffrey, W. C. Hammond, P. Bird, M.

Moschetti, Z. Shen, J. Bormann, and W. Thatcher [2014] Geodesy- and geology-based slip-rate models for the Western United States (excluding California) national seismic hazard maps, U.S. Geol. Surv. Open-File Rep., 2013-1293, 38 pages (main report) + 5 Appendices; http://dx.doi.org/10.3133/ofr20131293 .

Curren, I. S., and P. Bird[2014] Formation and suppression of strike-slip fault systems, Pure Appl. Geophys., 171 (11), 2899-2918, doi: 10.1007/s00024-014-0826-7.

Bird, P., and C. Kreemer [2015a] Revised tectonic forecast of global shallow seismicity based on version 2.1 of the Global Strain Rate Map, Bull. Seismol. Soc. Am., 105 (1),

152-166, doi: 10.1785/0120140129.

Bird, P., D. D. Jackson, Y. Y. Kagan, C. Kreemer, and R. S. Stein [2015] GEAR1: A Global Earthquake Activity Rate model constructed from geodetic strain rates and smoothed seismicity, Bull. Seismol. Soc. Am., 105 (5), 2538-2554, doi: 10.1785/0120150058.

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Carafa, M., S. Barba, and P. Bird [2015] Neotectonics and long-term seismicity in Europe and the Mediterranean region, J. Geophys. Res., 120 (7), 5311-5342, doi:

10.1002/2014JB011751.

Rong, Y., P. Bird, and D. D. Jackson [2016] Earthquake potential and magnitude limits inferred from a geodetic strain-rate model of southern Europe, Geophys. J. Int., 205 (1),

509-522, doi: 10.1093/gji/ggw018.

Bird, P., and M. Carafa [2016] Improving deformation models by discounting transient signals in geodetic data, 1: Concept and synthetic examples, J. Geophys. Res., 121 (7),

5538-5556, doi: 10.1002/2016JB013056.

Carafa, M. M. C., and P. Bird [2016] Improving deformation models by discounting transient signals in geodetic data, 2: Geodetic data, stress directions, and long-term strain rates in Italy, J. Geophys. Res., 121 (7), 5557-5575, doi: 10.1002/2016JB013038.

Carafa, M. M. C., G. Valensise, and P. Bird [2017] Assessing the seismic coupling of shallow continental faults and its impact on seismic hazard estimates: a case-study from Italy, Geophys. J. Int., 209 , 32-47, doi: 10.1093/gji/ggx002.

Bird, P. [2017] Stress field models from Maxwell stress functions: southern California, Geophys. J. Int., 210 (2), 951-963, doi: 10.1093/gji/ggx207.

Tunini, L., I Jimenez-Munt, M. Fernandez, J. Verges, and P. Bird [2017] Neotectonic deformation in central Eurasia: A geodynamic model approach, J. Geophys. Res.,

122 (11), 9461-9484, doi: 10.1002/2017JB014487.

Carafa, M. M. C., V. Kastelic, P. Bird, F. Maesano, and G. Valensise [2018] A geodetic gap in the Calabrian Arc: Evidence for a locked subduction megathrust?, Geophys.

Res. Lett., 45 , 1794-1804, doi: 10.1002/2017GL076554.

Bird, P. [2018] Ranking some global forecasts with the Kagan information score, Seismol.

Res. Lett., 89 (4), 1272-1276, doi: 10.1785/0220180029.

Carafa, M. M. C., A. Galvani, D. Di Naccio, V. Kastelic, C. Di Lorenzo, S. Miccolis, V.

Sespe, G. Pietrantonio, C. Gizzi, A. Massucci, G. Valensise, and P. Bird [2020]

Partitioning the ongoing extension of the Central Apennines (Italy): Fault slip rates and bulk deformation rates from geodetic and stress data, J. Geophys. Res., 125 ,

e2019JB018956, https://doi.org/10.1029/2019JB018956 .

Bird, P., and R. V. Ingersoll [2022] Kinematics and paleogeology of the western United States and northern Mexico computed from geologic and paleomagnetic data: 0 to 48 Ma, Geosphere, 18 (5), 1563-1599, doi: org/10.1130/GES02474.1.

Shen, Z.-K., and P. Bird [2022] NeoKinema deformation model for the 2023 update to the U.S. National Seismic Hazard Model, Seismol. Res. Lett., 93 (6), 3037-3052, https://doi.org/10.1785/0220220179.

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Carafa, M. M. C., D. Di Naccio, C. Di Lorenzo, V. Kastelic, and P. Bird [2022] A meta-analysis of fault slip rates across the Central Apennines, J. Geophys. Res., 127 ,

e2021JB023252; https://doi.org/10.1029/2021JB023252.

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CERTIFICATE OF SERVICE

I certify that on March 4, 2024, I sent copies of the foregoing PETITION BY SAN LUIS OBISPO MOTHERS FOR PEACE, FRIENDS OF THE EARTH AND ENVIRONMENTAL WORKING GROUP FOR SHUTDOWN OF DIABLO CANYON NUCLEAR POWER PLANT DUE TO UNACCEPTABLE RISK OF SEISMIC CORE DAMAGE ACCIDENT to the Secretary of the Commission and counsel for PG&E and the NRC Staff as follows:

NRC Commissioners c/o Office of the Secretary, nrcexecsec@nrc.gov Paul Bessette, paul.bessette@morganlewis.com Ryan Lighty, ryan.lighty@morganlewis.com Timothy Matthews, timothy.matthews@morganlewis.com Jeremy Wachutka, jeremy.wachutk@nrc.gov Catherine Kanatas, catherine.kanatas@nrc.gov Adam Gendelman, adam.gendelman@nrc.gov

I further certify that on March 7, 2024, I posted the same PETITION on the Electronic Information Exchange. The pleading is unchanged except for three clerical corrections. The captions on the cover page of and page 1 of the attached Declaration of Peter Bird, Ph.D. now show that the Declaration was submitted on both the License Renewal docket and the Seismic Shutdown Petition docket. And the signature page of the PETITION was corrected to show the filing date of March 4, 2024.

Electronically signed by Diane Curran