ML24281A106

NRR E-mail Capture - (External_Sender) Public Letter to Petition Review Board Regarding the Diablo Canyon Seismic Core Damage Frequency 10 CFR 2.206 Petition - OEDO-24-00083

ML24281A106
Person / Time
Site:	Diablo Canyon
Issue date:	10/02/2024
From:	Nelson G Californians for Green Nuclear Power
To:	Perry Buckberg Office of Nuclear Reactor Regulation
Buckberg P
References
OEDO-24-00083, L-2024-CRS-0000
Download: ML24281A106 (6)

Text

From: government@cgnp.org Sent: Wednesday, October 2, 2024 11:16 PM To: Perry Buckberg Cc: Info; Peter Bird; Tanya Black

Subject:

[External_Sender] RE: Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 Attachments: CGNP to Perry Buckberg 10 02 24.pdf

Perry Buckberg

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

telephone: 301-415-1383

email: Perry.Buckberg@nrc.gov

RE: Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024

October 2, 2024

Hello, Mr. Buckberg: Please see the attached letter from CGNP regarding the matter shown in the subject line.

This letter is being CC:ed to the Diablo Canyon Independent Safety Committee, The California Seismic Safety Commission, and Dr. Peter Bird at UCLA. We look forward to your feedback.

Sincerely,

/s/ Gene Nelson, Ph.D. CGNP Senior Legal Researcher and President Californians for Green Nuclear Power, Inc. (CGNP) 1375 East Grand Ave Ste 103 #523 Arroyo Grande, CA 93420-2421 (805) 363 - 4697 cell Government@CGNP.org email https://CGNP.org website https://greennuke.substack.com Substack Hearing Identifier: NRR_DRMA Email Number: 2615

Mail Envelope Properties (0fe324c1f75baffc7d3c7589f9095382)

Subject:

[External_Sender] RE Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 Sent Date: 10/2/2024 11:16:12 PM Received Date: 10/2/2024 11:17:28 PM From: government@cgnp.org

Created By: government@cgnp.org

Recipients:

"Info" <info@dcisc.org>

Tracking Status: None "Peter Bird" <pbird@epss.ucla.edu>

Tracking Status: None "Tanya Black" <tanya.black@caloes.ca.gov>

Tracking Status: None "Perry Buckberg" <Perry.Buckberg@nrc.gov>

Tracking Status: None

Post Office: cgnp.org

Files Size Date & Time MESSAGE 993 10/2/2024 11:17:28 PM CGNP to Perry Buckberg 10 02 24.pdf 2748028

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Perry Buckberg Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 telephone: 301-415-1383 email: Perry.Buckberg@nrc.gov

RE: Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 October 2, 2024 Hello, Mr. Buckberg:

Independent nonprofit intervenor in the public interest Californians for Green Nuclear Power is concerned that Peter Bird, Ph.D.'s claims regarding the importance of active thrust faulting at Diablo Canyon Power Plant (DCPP) site are exaggerations based on making false analogies to the Noto Peninsula in Japan.

I observed and heard Dr. Bird's presentation regarding Agenda Item XXIX while attending in-person the June 21, 2024 Diablo Canyon Independent Safety Committee meeting which Dr. Bird attended remotely.

As one of CGNP's representatives, I have commented during earlier NRC proceedings regarding DCPP's seismic robustness.

This is the version of my comments that appeared in the NRC report released to the public regarding the 28 April 2015 meeting between the NRC, their consultants, and the owner of Diablo Canyon Power Plant.

The staff received a comment from Dr. Gene Nelson (Physical Sciences professor at Cuesta College and Government Liaison for Californians for Green Nuclear Power) via email during the meeting. The NRC staff inadvertently missed the opportunity to acknowledge Dr. Nelson's comment during the meeting.

According to Dr. Nelson, Diablo Canyon has favorable site conditions, which attenuate or dissipate earthquake energy over relatively short distances. Due to these favorable conditions, the primary earthquake forces seen by the plant would be dominated by nearby earthquake sources and energy transmitted to the plant would be dominated by CGNP to NRC Office of Nuclear Reactor Regulation October 2, 2024 Page 2 of 4

the small section of the earthquake rupture closest to the plant. Dr. Nelson stated that when considering the information presented at the meeting of overall plant ruggedness and the seismic hazard insights discussed above, Diablo Canyon will continue to operate safely - with generous safety margins - during anticipated earthquakes.

During his June 21, 2024 DCISC presentation, Dr. Bird asserted there were significant similarities between the tectonic setting at the Noto Peninsula in Japan and the present conditions at the DCPP site. I hold that is not the case.

1. The largest recent earthquake near the DCPP site was the Magnitude 6.6 San Simeon Earthquake on December 22, 2003. The epicenter was about 20 miles NNW of DCPP. The rupture propagated to the southeast for 12 miles. The shaking was sufficient to damage buildings in Paso Robles, California and kill two. Total damage was $250-300 million. DCPP's operations were unaffected by this earthquake. The plant operated at full power before, during, and after this earthquake. Essentially all of the active earthquake faults in the immediate vicinity of DCPP are strike-slip.

2. The Magnitude 7.5 January 1, 2024 earthquake on the Noto Peninsula caused at least 401 fatalities. Damage was about $17.6 billion. The Noto Peninsula is a complex tectonic setting which could be in the process of becoming a subduction zone. The Japan Meteorological Agency supplied the following earthquake swarm map of the Noto Peninsula. The earthquakes began in December, 2020.

2 CGNP to NRC Office of Nuclear Reactor Regulation October 2, 2024 Page 3 of 4

A May 5, 2023 Magnitude 6.5 earthquake preceded the January 1, 2024 earthquake. Thrust faulting and folding is apparent in the Noto Peninsula. The uplift at Kaiso Fishing Port in Wajima was 4 m (13 ft) exposing parts of the seafloor that were submerged before this earthquake.

3. One of the markers for active thrust faulting in California is the presence of commercially exploitable petroleum reserves. The nearest production fields to DCPP are in Carpenter Canyon, about 10 miles to the southeast of DCPP. There are also production fields in San Ardo, over 30 miles to the north of DCPP. There are also offshore production fields more than 30 miles to the south of DCPP.

4. I agree with Dr. Bird that there has been thrust faulting in the Irish Hills area. However, this thrust faulting likely antedates by millions of years the Holocene epoch, which began about 11,700 years ago. Active faulting during the Holocene epoch is a significant NRC regulatory concern.

Here's a photograph I took in December, 2022 of some compressionally-folded sedimentary limestone deposits at about the 600 foot elevation on a hill to the south of Avila Beach, California. This is a road cut. The width is about 2-3 meters.

3 CGNP to NRC Office of Nuclear Reactor Regulation October 2, 2024 Page 4 of 4

A bit further to the west on this road, the sedimentary deposits are completely vertical instead of horizontal. The edge of the road is at the bottom of the image which is 2-3 meters wide.

I'm confident the NRC is aware of this information, but I wished to insure this is the case.

Sincerely,

Gene Nelson, Ph.D. CGNP Senior Legal Researcher and President Californians for Green Nuclear Power, Inc. (CGNP) 1375 East Grand Ave Ste 103 #523 Arroyo Grande, CA 93420-2421 (805) 363 - 4697 cell Government@CGNP.org email https://CGNP.org website https://greennuke.substack.com Substack

CC:

Via email to The Diablo Canyon Independent Safety Committee California Seismic Safety Commission Peter Bird, Ph.D.

4