ML20003C354

Interrogatories Directed to NRC Re Christianitos Fault & Earthquakes.Certificate of Svc Encl.Related Correspondence

ML20003C354
Person / Time
Site:	San Onofre
Issue date:	02/18/1981
From:	Raynard Wharton FRIENDS OF THE EARTH, WHARTON & POGALIES
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML13302B923	List: ML13302B922 ML20003C354 ML20003C355 ML20003C357
References
ISSUANCES-OL, NUDOCS 8102270811
Download: ML20003C354 (33)

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UNI"'ED STATES OF AMERICA T, . N

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EEFORE THE ATOMIC SAFETY AND LICENSING 3 CARD ,\ ', V! ' t-In the Matter of )

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SOUTHERN CALIFOR!TIA EDISCN CCMPANY' )

Docke*' Nos* 50-361 OL

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50-362 OL

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(San Onofre Nuclear Generating Station )

Units 2 and 3) )

)

INTERVENOR, FOE ET_AL . ,

INTERROGATO.4IES TO N.R.C. STAFF Intervenors Friends o f the Earth, et al, hereby requests that the N.R.C. Staff, pursuant to 10 CFR 52.740(b) answer, separately and fully, in writing under oath or affirmation, the following inter -

rogatories wi. thin fourteen (14) fays after service Sereof. Each response to t'1e interrogatories below sball be under oath or affirma-tion of the individual (s) who contributed thereto. For all references requested in thqse interrogatories, identify them by author, title, da*= of publication and oublisher, if the reference is published, and if not publisPed, identify the document by the author, title, the date it was written, the <palifications of the author relevant to this proceeding, and where a cocy of the document may be obtained.

The interrogatories set forth below are to be considered N.R.C.

Staff's continuing obligation. Accordingly, if, after the N.R.C. Staff bas answered these interrogatories, additional information comes to their attention with respect to one or more of the answers the answers should be amended in a timely manner to provide such additional informatic:

0827f)fl\ l

INSTRUCT!CNS AND CEFI:i!TIINS For purposes of these Interregatories and ycur respenses thereto, the follcwing definitions and instructicns shall apply:

(a) The term "N.R.C.", "You" and "Your" refers to the United States Nuclear Regulatory Cc= mission Staff.

(b) The term "persen" means any natural persen and any private or public entity of any nature, including, withcut limitatien, corpora-tions, firms, partnerships, sole prcprietorships, asscciations, groups, organizations, trusts and estates.

(c) The term " document" means:

(1) The original, or (2) If the original is not in your custody or under your control, then a copy thereof.

(d) As used herein unless the centext otherwise requires, the singular number includes the plural and the plural includes the singular; the =asculine gender includes the feminine, and the feminine includes the masculine.

(e) When you are requested to " identify" any document, you shall include in your respense a description sufficient to satisfy the " reasonable particularity" requirement found in Title 13, Part 2, Section 2.741(c) of the Code of Federal Regulations, including without limitation, the follcwing information with respect thereto:

4 (1) The nature of the document:

(2) Its dater (3) The names of its addressor(s) and addressee (s), if any; (4) The name(s) of the persen(s) who prepared it; (5) The name(s) a5.d addres's(es) of the present custodian (s) of the original and any copies thereof; and 2

(6) A summary of its contents.

In lieu of providing the information specified in Paragraph (3),

Items (1) - (6), you may attach to your responses to these Interroga tories a true copy of such document, identifying the Interrogatory to which it is responsive and stating'in your answer only such of the information specified in Paragraph (e), Items (1)-(6) as does not clearly appear on the face of such document.

If you claim a document is privileged or attorneys' work product, describe the same generally and state all facts upon which you base the claim of privilege or the claim such document ccnstitutes work product.

(f) When you are requested to " identify" any person, you shall set forth the full name and last kncwn business address and employer of such person you are asked to identify.

(g) The term " expert" refers to a persen who by virtue of his knewledge, skill, experience, training or education has acquired a scientific, technical or specialired kncwledge which can assist the Nuclear Regulatory Commission Licensing Board in understanding the evidence or determining a fact, opinion, or scientific theory relevant to an issue in this proceeding.

(h) When you are requested to " identify" an " expert" as that latter' term is defined in paragraph (g) above, you shall set forth the full name and last known business address, academic affiliations, and present employer of each such " expert" ycu are asked to identify.

(i) In answering these Interrogatories, you shall furnish all information available to you, your respective agents, employees, investigators, representatives and attorneys, and not =erely such information as is known from personal knowledge.

(j) The term "SCNGS 2 and 3" refers to the San Gnofre Nuclear Generating Station, Units 2 and 3.

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9 (k) The term "SCE" refers to the Scuthern California Edison Company.

(1) The term "FSAR" refers to the " Final Safety Analysis Report, San Cnofre Nuclear Generating Station, Units 2 and 3" which Intervenors believe is currently available to the public in the Public Documents Rocm of the Mission Viejo Public Library.

(m) Where the Interrogatories ask whether N.R.C. has

" analyzed" a document or subject, Intervenors define " analyze" to be where N.R.C. has reviewed the document er subject in the context of SCNGS 2 and 3 and have submitted a written report of that review. .

(n) Offshore Zone of Deformation ("CZD") as used in this proceeding is a hypothesized zone of deformation which as defined by the United States Geological Survey ("USGS") consists of the Newport Inglewood Zone of Deformation, the South Coast Offshore Zone of Deformation and the Rose Canycn Fault Zene.

i l INTERROGATORIES INTERRCGATORY NO. 1 Define the following terms:

(a) structurally related (b) wrench fault I

(c) wrench fault system l

(d) wrench fault tectonics (e) active tectonic system (f) branch or splay -

(g) seismic gap I

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(h) en echelon (i) plate boundary INTERRCGATCRY NO. 2.

For each of the terms listed in Interrogatory No. 1, (a) Identify each and every document. written authority or cemmunication upon which you rely in defining each term; (b) Identify each and every person. expert or otherwise, upon whom you rely in defining each term; and (c) Identify any writings, opinions, or testimony of the person (s) you have listed in Interrogatory 2(b) upon which you rely in defining each term.

INTERRCGTCRY NO. 3.

Do you contend that the Cristianitos Fault does not extend southward for a distance greater than 6000 feet offshore from its coastal expression? If so, (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:

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(i) State the substance of the facts and cpiniens to which you expect the witness to testify; (ii) 5c=marize the factual and theoretical basis, as well as any other grounds, for each cpinion to which the witness is expected to testify.

INTERROGATORY NO. 4.

What do you contend is the minimum age of last displacenent on the Cristianitos Fault?

(a) State each and every fact upon which you base this contention; (b) Identify each and every document or comnunication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions. or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whcm you expect to call as a witness at the hearing I before the Atomic Safety and Licensing Scard in support of this contention, and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each epinion to which the witness is expected to testify.

6 l.

INTERRCGATORY NO. 5 Do you contend that the Cristianitos Fault is not a

" capable fault" If so, (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, cr on whose writings, opinions, or testimony you base this contention; and (d) Identify each and every person. expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the follcwing information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.

INTERRCGATORY NO. 6.-

Do you contend that the OZD is the controlling geologic structure for seismic design of SONGS 2 and 3? If so:

(a) State each and every fact upon which you base this centention; 7

(b) Identify each and every document or communication upon which you base this contention; ,

(c) Identify each and every person with knowledge of the factual basis or bases for this contention, or en whose writings, opinions or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify.

INTERROGATORY NO. 7.

What do you contend is the maximum magnitude earthcuake l

that could occur on the OZD?

( (a) State each and every fact upon which you base this l

! contention; l (b) Identify each and every document or communication upon which you base this contention:

l (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions, or testimony you base this contention; and l

(d) Identify each and every person. expert or otherwise, whom you expect to call as a witness at the hearing 8

before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis.

as well as any other grounds. for each cpinion to which the witness is expected to testify.

INTERROGATORY NO. 8.

What do you contend is the maximum magnitude earthruake that could occur on the geolcgic structural relationship between the OZD and the Cristianitos Zone of Eeformation?

(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knewledge of

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the factual basis or bases for this contention, or on whose writings, opinions, or testimony you base this contention; and l (d) Identify each and every person expert or l otherwise. whom you expect to call as a witness at the hearing l

before the Atemic Safety and Licensing Board in support of this contention and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testifyr l

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(ii) Sumnarize the factual and theoretical basis as well as any other grounds, for each opinion to which the witness is expected to testify.

INTERROGATORY NO. 9.

What do you contend is the minimum age of last displacement on the South Coast Offshore Zone of Deformation portion of the CZD?

(a) State each and every fact upon which you base this contention; (b) Identify each and every document or conmunication upon which you base this content _on; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions

! to which you expect the witness to testify;

( (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify; and l (e) Identify each and every event upon which you base this contention 10 l

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i INTERRCGATORY NO. 10.

1 What do you contend is the minimum age of last l

displacement on the Newport Inglewood Zone of Ceformation portion of the OZD?

(a) State each and every fact upon which you base this contention; (b) Identify each and every document or ccmmunication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings, opinions, or testimony you base this centention; and (d) Identify each and every person, expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention. and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Senmarize the factual and theoretical basis, as well as any other grounds for each opinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.

INTERROGATORY NO. 11.

What do you contend is the minimum age of last displacement on the Rose Canyon Fault Zone portion of the CZD?

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(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings. opinions or testimony you base this contention; and (d) Identify each and every person expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention. and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and cpinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis.

as well as any other grounds, for each epinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base l

l this contention.

l ITEmROGATORY NO. 12.

1 l

Is it your contention that the postulated zone of i

1 deformation which extends from the coastal exposure of the l

l Cristianitos Fault toward the OZD dies out before reaching the OZD? If so:

(a) State each and every fact upon which you base your contention; 12

(b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose writings. opinions, or testimony you base this contention; and r

(d) Identify each and every person, expert or otherwise, whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing 3 card in support of this contention, and as to each potential witness so identified provide the folicwing information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify.

INTERROGATORY NO: 13.

Do you contend that there is not a structural relation-ship between the Cristianitos Fault and the OZD? If.so.

(a) State each and every fact upon which you base this contention; (b) Identify each and every document er communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this contention. or on whose writings, opinions, or testimony you base this contention; and (d) Identify each and every person expert or 13

otherwise. whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) St=marize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify.

(e) Identify each and every event upon which you base this contention.

INTERROGA'"ORY NO. 14.

Do you contend that the OZD does not extend south of the Rose Canyon Fault Zone? If so (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention or on whose writings- opinions. or testimony you base this contention; and (d) Identify each and every person. expert >r otherwise whom you expect to call as a witness at rne hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified

provide the follcwing information

i. .

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(i) State the substance of the facts and cpiniens to which you expect the witness to testify; (ii) Sun =arize :ne factual and theoretical basis, as well as any other c. rounds for each ce.. inion to which the witness is expected to testify.

INTERRCGATORY NO. 15.

Do you contend that there is no structural relationship between the Rose Canyon Fault 2cne and the Vallecitos Fault in Baja, California? If so.

(a) State each and every fact upon which you base this contenticn; (b) Identify each and every docu=ent or cc==unication upon which you base this centention

-(c) Identify each and every person with 'xnewledge of the factual basis or bases for this contention- or en whose writings. cpinions . or testi=cny you base this centention; and (d) Identify each and every person. expert or otherwise. whc= you expect to call as a witness at the hearing before the Atemic Safety and Licensing 3 card in support of this contention. and as to each potential witness so identified provide the following infor=ation:

(i) State the substance of the facts and epinions to which you expect the witness to testify; l (ii) Su==arize the factual and theoretical basis, as well as any

• other grounds. for each epinion to which the l witness'is expected to testify.

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INTERRCGATCRY L'O. 16.

Do you contend that there is not a structural relationship becween the Rose Canyon Fault Zone and the San Miguel Fault in Baja, California? If so, (a) State each and every fact upon which you base this contention; (b) Identify each and every document or cc==unication upon which you base this centention:

(c) Identify each and every person with knowledge of the factual basis er bases for this contention, or on whose writings cpinions, or testimony you base this contention; and (d) Identify each and every person expert or otherwise. whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention and as to each potential witness so identified provide the follcwing infornation:

i (i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, I

i as well as any other grounds, for each opinion to which the i

l witness is expected to testify.

I M 90GATORY NO. 17.

Do you contend that there is not a relationship between the OZD and the San Andreas. If so i (a) State each and every fact upon which you base this contention; 1

(b) Identify each and every document or co==unication i

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upon which you basa this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention or on whose writings opinions or testimony you base this contention; and (d) Identify each and every person expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contentiori, and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the witness is expected to testify; and (e) Identify each and every event upon which you base this contention.

INTERRCGATORY NO. 18.

Do you contend that .67 g is the proper design acceleration value for SCNGS 2 and 3?

INTERROGATORY NO. 19.

l l If your answer to Interrogatory No. 19 is Yes.

(a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this centention; (c) Identify each and every person wi$h knowledge of t

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the factual basis or bases for this contention, or on whose writings opinions, or testimony you base this contention; and (d) Identify each and every person, expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention- and as to each potential witness so identified provide the folicwing information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Su=marize the factual and theoretical basis, as well as any other grounds for each opinion to which the witness is expected to testify.

INTERRCGATORY No. 20.

Do you contend that there is no possibility of ground displacement within the plant site? If so (a) St$to each and e'rery fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with kncwledge of the factual basis or bases for this contention, or on whose I

writings opinions, or testimony you base this contention; and l

l (d) Identify each and every person expert or otherwise whom you expect to call as a witness at the hearing h

i before the Atomic Safety and Licensing Board in support of this contention and as to each potential witness so identified

. provide the following information:

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(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds, for each opinion to which the j witness is expected to testify; and (e) Identify each and every event upon which you base this contention.

INTERRCGATORY NO. 21.

Have you contracted with or contacted any consultants to analyze any aspect of the Imperial valley eartheuake of October 1S 1979? If so.

(a) Identify each and every consultant who has conducted such analysis on your behalf; (b) Identify each and every document. writing or acommunication arising out of the analysis performed by your consultants on the Imperial Valley earthcuake which you expect to use at the hearing on the seismic contention before the Atomic Safety and Licensing Board; (c) Summarize the substance of the findings and/or conclusions of your consultants which they have derived frcm their analysis of the Imperial valley earthcuake l

(1) with respect to SONGS 2 and 3 (2) with respect to any other nuclear power plant site in California; and l (d) Summarize the factual and theoretical bases as well as any other grounds upon which your consultants base their 19

findings and/or conclusions on the Imperial valley eartheuake (1) with respect to SONGS 2 and 3 (2) with respect to any other nuclear power plant site in California.

INTERROGATORY NO. 22.

Do you contend that the Cristianitos Fault is only about 32 kilcmeters (20 miles) in length? If so (a) State eacl. and every fact upon which you base this contention; (b) Identify each and every document or communication upon which fou base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention or on whose writings opinions, or testimony you base this contention; and (d) Identify each and every person. expert or otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention. and as to each potential witness so identified provide the following information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis, as well as any other grounds for each opinion to which the l

witness is expected to testify.

INTERROGATORY NO 23.

i l Do you agree that the OZD is located 7 kilometers i

20 t

O offshore as described by Dr. Gary Greene and Or Michael Kennedy in their report to the NRC in August 1980? If you do not agree state the basis for your disagreement including all documents on which you rely and identify all expert witnesses on whom you rely l and the substance of their expected testimony.

l INTERRCGATORY NO 24.

Do you contend that the Cristianitos zone of Deformation's structural relationship with the CZD is not the controlling geologic structure for the seismic design of SCNGS 2 and 3? If so (a) State each and every fact upon which you base this contention; (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person with knowledge of the factual basis or bases for this contention, or on whose

! writings. opinions- or testimony you base this contention; and (d) Identify each and every person expert or l

otherwise whom you expect to call as a witness at the hearing before the Atomic Safety and Licensing Board in support of this contention, and as to each potential witness so identified l aprovide the folicwing information:

(i) State the substance of the facts and opinions to which you expect the witness to testify; (ii) Summarize the factual and theoretical basis as well as any other grounds for each opinion to which the witness is expected to testify.

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INHRRCGATCRY NO. 25 2

At the time of the initial selecticn of the San Cnefre site for the construction of Nuclear Pcwer plants, including Units 2 and 3, what data base existed to determine the suitability of the site and to determine or predict the ground =ctions that could cccur at the site ani to-determine the S.S.E.

INTERRCGATCRY NO. 26 Cces the staff agree that since the issuance of the construction permit for SCNGS 2 and 3 that there has been a tremendcus increase in scientific understanding of plate tectenics and that because the SCNGS 2 and 3 site is within the plate tectenic boundary rene that this new infer-ation shculd be cen-sidered in esti=ating the Safe Shundcwn Earthquake and respense spectra for SCNGS 2 and 3?

Iy"ERRCGATCRY No. 27 If your answer to question 26 is yes, set forth with particularity how this increased scientific understanding was integrated and utilized in deter s ing the ground =ctions, the response spectra and the Safe Shutdown Earthquake for SCNGS 2 and 3.

INURRCGATORY NO. 28.

Did the N.R.C. staff provide a formal written notice to 1

L the A.S.L.S. cr to the Ccmmissioner in the centext of the Ccnstruction Licensing Preceedings for Songs Unit ?so and Three that in Cctcher 1967, the repartment of the Interior published a report (hereinafter referred to as the Bolsa Island report) which would require the Bolsa Island reactor to be designed for an S.S.E. of =agnitude 3.0 en the Newport-Inglewcod Faul: 2cne. If the answer is yes, cite the precise reference where this notice was given.

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ITERRCGATORY No. 29 Was the scisa Island Report or the centents of said report increduced as evidence in the Construction Licensing hearings for SCNGS 2 and 3? If not, why not?

INTEUCGATCRY NO. 30 Was the N.R.C. staff cr the applicant aware of the ex-istence of the Bolsa Island Report at the time of the Constructicn Licensing hearing for SCNGS 2 and 3?

IN"'ERRCGATCRY NO. 31 If the N.R.C. was aware of the existence of the Bolsa Island report at the time of the Construction Licensing did they inform the Intervenors of its existence?

INTERRCGATORY No. 3 2 Does the N.R.C. staff admit that the Bolsa Report is relevant evidence and is admissable as evidence in the Cperating Licensing hearings regarding SCNGS 2 and 3?

If the staff dces not so admit state with particularity s

including any legal arguments you will rely en as to why the Bolsa t

l Island report is not admissable evidence in the SCNGS Cperating i

I License hearings.

IN"TERCGATCRY NO. 33 Eas the N.R.C. staff, or any of their censultants studied, l

! investigated or analyzed the ground motions at the site of SCNGS 2 and 3 that would result from a magnitude 8.0 earthquake en the Newport-Inglewcod Fault Zone?

INTERRCGATCRY NO. 34 If the answer to the foregoing interregarcry is in the affirmative, state:

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s a) the name, address, capacity, and occupation of each person making such study or investigation; b) the date or dates of such study or investigation; c) whether any reports of such persen or persons were reduced to writing; d) in whose possession or custcdy such reports presently repose; e) whether you will make such reports available to intervenors to inspect and copy withcut the necessity of a for=al motion to produce; and f) a summary of the findings of each study and investi-gation and the basis for such findings.

INTERRCGATCRY NO. 35 If the N.R.C. staff or its censultants have not performed such a study, do they plan to do so prior to the Operating Licensing hearings?

If you do not plan such a study, set forth your reasons for not performing such a study.

! INTERRCGATORY NO. 36 i

In light of the A.S.L.B. ruling regarding Su= mary Disposition of the dewatering cavity contention, does the Staf f j eentend that there is no possibility that the plant design will not i

withstand an earthquake on the 0.2.D. that is greater than a magnitude 6.5 and/or ground motion in excess of .67g?

INTERROGATCRY NO. 37 What evidence does the NRC Staff have that personnel at SONGS 2 and 3, during future operations, could perform necessary 24 i

emergency procedures during and folicwing a severe earthquake, when their lives are being threatened by the circumstances?

INTERRCGATCRY NO. 38 Coes the NRC Staff agree that personnel would be cre likely to =ake mistakes in precedures during an earthquake j scenario than under " normal accidental conditions?"

l n'"ERRCGATORY NO. 39 What psychological studies can the NRC Staf f cite that support their arguments that operating personnel could respond effectively to Earthquake circumstances at SCNGS 2 and 3, during a threat to their safety?

INTERRCGATCRY NO. 40 What peak and effective ground accelerations (g values) were the spent fuel rod pools at SCNGS Units 2 and 3 designed and built for?

INTERRCGATORY NO. 41 Provide the names and qualifications of the AEC-NRC Staff geologists, seismologists, and geophysicists who were involved in

! any way in the analysis of the San Cnofre site as a suitable location for constructing several nuclear reactors (including SCNGS 2 and 3) during the original siting analysis and decision-making by the AEC Staff between the February 1, 1963 application from Southern Cal.

Edison for a permit to construct a group of reactors (then projected to eventually include five reactors, including SCNGS 2 and 3) and the 1964 issuance of a construction permit by the AEC for the first reactor of the group.

25

IN"'ERRCGATCRY NO. 42 Provide the names and qualifications of the AEC Staff geologists, seis=clogists, and geophysicists who were involved in the AEC Staff analysis of geo-seismic hazards at the San Cnofre site and preparation of the SER during the Cperating License Review period from 1965 to 1968.

INTERROGATCRY NO. 43 Provide the nanes and qualifications of any independent censultants in the fields of geology, seismolegy, and gecphysics, or USGS scientists who were requested by the AEC or NRC te analy=e geo-seismic hararcs in the San Cnofre site selection precess he-

ween the February, 1963 applicatien by SCE to construe: a grcup of nuclear reactors including SCNGS 2 and 3 at the San Cnofre site and the 1973 issuance by the AEC of the construction permit for the second and third reactors of the planned group.

INTERRCGATCRY NO. 44 Is it true that the NRC's predecessor, the AEC, negotiated a for=al Memorandum of Agreement with the USGS which is still the practice of the NRC-Staff under current practice that limits the USGS role in analyzing the geologic and seismic harards to a nuclear reactor site such that USGS scientists can participate in the review precess "only upon specific request frem the NRC" and "only to the extent and under such circumstances and constraints as are specified by the NRC"?

INTERROGATORY NO. 45 Explain and document exactly when, where, hew, and who among the USGS scientists was asked to cenduct research independ-ently of the Edison Company's censultants pric: to 1980, during

. dhe OL review for the SER, 26

.. . :. .wrce. . n.,

. . . . . s. v .

o prev:.de the nanes and 7 al:. fica:icns of any 75GS scie:-

ists who were regaested by the AIC  : NRC Staff :: review the Idison Cc=pany's Censul: ants' Reports regarding earthquake hazards at the San Cncfre (SCNGS 2 and 2) site he: ween the Februarv., 1963 an..cligation .hv SCI for a .ce rit := construe: a g cup of reacecrs including SCNGS 2 and 3 at the San Cnefre site and the 1964 perr.it frc= the AIC to the Edisen 0==pany c begin censtructicn of the first reacecr cf the planned group of reae:::s.

!N"IRRCGA Z RY NO. 47 Provide the names and qualifica:icns of any USGS scientists who have been requested by the AIC c: NRC Staff ::

review the Idisen C==pany's Censultants' Repcrts regarding earthgaake hazards at the SCNGS 2 and 3 site since the AIC issued the SCNGS 2 and 3 Cons.raction Per=it in 1973.

!.T"IRRCGA" CRY NO. 48

~4hy has the NRC Staff never regaested the USGS feder-ally ec:plcyed scientists to cenduct research regarding the earth-gaa%e harards to the SCNGS 2 and 3 site that is totally independen:

cf the Edisen Cceny's Censultants, fer exa=ple,in the way tha:

the Copartment of Interier has the USGS ccnduct independen research on offshore regicns before issuing leases and perits to the cil industrf for offshore cil drilling?

IN"'IPSCGATCRY NO. 49 Oc you agree that in 1979 -the Intervencrs regaested a

=eeting with the NRC Staff Oc discuss cartain new inic.=atien

,~i o

regarding earthquake hazards to the San Cnofre reactors, and that that meeting was scheduled for March 5, 1900 to follcw a March 4, 1900 meeting with the Applicants and their consultants?

NTE7?CGATC9? NC. 50 Do you agree that on March 5, 1980, the Intervenors requested that the NRC Staff require the Applicants to conduct research offshore frem the San Cnofre reactor sito regarding the Intervenors' hypothesis that there exists an offshore extenston of the Cristianitos Fault Zone which provides a structural relationship and a new fault gecmetry between the Cristianitos Fault Zone and the Offshore Fault Zone (the Newport-Inglewood Fault or CZD)? .

IN"ERRCGATCRY NC. 51 Do you agree that the Intervenors based their hypothesis of a new structural relationship becween these two fault zones on a new map which was published La November, 1979 (which the Intervenors' showed to the NRC Staff on March 5, 1980) in a report by four USGS scientists and a COMG marine geologist entitled:" Earthquakes and Other Perils San Diego Region" which is part of a research project being funded by the cepart=ent of Interior to study the Outer Continental Shelf for Oil Leasing l information?

IN"ERRCGATCRY NC. 52 Do you agree that the authors of that map and tr- port had not yet been consulted by the NRC Staff about their new geological-map of the region offshore frem the San Cnofre site but that on March 5, 1980, the NRC Staff agreed to request the 28

cpiniens of the CSGS Scientists who wrote the report about whether or not the NRC should require the Applicants te conduct research offshore?

INTERRCGATCRY NO. 53 Do you agree that follcwing that March 5, 1980 =eeting with the Intervenors, the NRC Staff requested the Applicant to provide the Staff with ecpies of all of the offshore seismic reflection profiles that were available to the Applicant regard-ing the fault gecmetry offshore from the San cnofre reactors?

!N'"ERRCGATCRY NO. 54 Co you agree that the NRC conducted a meeting about

'this issue en May 21, 1980 in 3ethesda, Md., during which the Edison Company presented certain offshore profiles and inter-

-pretations of the offshore fault gecmetry?

INTERRCGATCRY NO. 55 Do you agree that during the concluding statements by j the Staff to the Applicant after the Applicants' presentation, that the NRC Staff Geosciences 3 ranch Chief Bob Jackson said (according to the transcript) : '"de have not had ample opportunity to review all cf the data provided (by the Applicant) in the last several weeks. . .a lot more work needs to be done with the USGS reviewers and the staff reviewers--with USGS assistance."?

INTERRCGATORY NO. 56 Do you agree that after that meeting, the NRC Staff requested the USGS scientist Gary Greene and his co-author Michael Kennedy to write a report and produce a map making use of all of the available data to review the potential i

1 29 l l

9 for a structural relationship between the Crist ani:cs anf the CZD?

TrERRCGATCRY NC.57

o you agree that the Applicant agreed to conduct =cre seismic reflection profiles offshore and tha: they hired Nekten, Inc. as consultants?

!NTERRCGATCRY NO. 58 Do you agree that the NRC censultants Greene and Kennedy p cduced a repert, entitled " Review cf Cf f shcre Seismic Reflection Profiles in the vicinity of the Cristianitos Fault, San Cnofre, California" which was mailed to the NRC by the USGS on August 13, 1980?

INSJtCGATCRY NO. 59 Do you ag:;ee that the Applicants requested a meeting which was held in Bethesda, Md. , en August 14, 1980, to present their censultant's. (Nekten) new report and interpretations of offshore seismic reflection profiles, which were = ailed to the NRC Staff en July 29, 1980, in a report entitled " Interpretive

-Results High Level Resolution Gecphysical Survey in Selected Areas between Dana point and Cceanside and offshore California."

prepared by the Edison Cc=pany's censultants Nekten about new profiles which were taken by Nekten in June 1980?

INTERRCGA T RY No. 60 Do you agree that the Greene and Kennedy report mailed by the USGS on August 13, 1980 was written independently of the Applicant's consultant report by Nekten = ailed by Edisen en July 29, 1980?

, 30

Cated: February 19, 1981 sy U Al RICHARD J. 'fHARTCN A orney fcy Intervenc s

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I e v e t. . -.

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I CERTIFICATE CF SERVICE '

ll I hereby certify that en the 24th day of February, 1981, a ccpy of the foregoing INTERVINCR, FCE ET AL. , IN'"ERRCGATORIES TO N.R.C. STAFF, Attorney RICHARD J. WHARTCN, was served upon each of the following by depositing in the United States mail, first-class, postage prepaid, addressed as fellcws:

Ivan W. Smith, Esq., Chair =an Atomic Safety and Licensing Scard U. S. Nuclear Regulatory Cc= mission Washington, D. C. 20555 Dr. Cadet H. Hand, Jr., Member Director, Sodega Marine Laboratcry University of California P. O. Sex 247 sedega Say, California 92923 Dr. E=meth A. Luebke Atomic Safety and Licensing Scard Panel U. S. Nuclear Regulatory Cc= mission Washington, D. C. 20555 Lawrence J. Chandler, Esq.

Office of the Executive Legal Directer U. S. Nuclear Regulatory Commission Washingten, D. C. 29555 Janice E. Kerr, Esq.

J. Calvin Simpson, Esq.

Lawrence Q. Garcia, Esq.

California Public Utilities Cc= mission 5066 State Building San Francisco, California 94102 David W. Gilman Rchert G. Lacy San Diego Gas & Electric Ccmpany P. O. Box 1831 San Diego, California 92112 James H. Drake, Vice President Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 92770 32

~

Jchn R. Sury, General Ccunsel Charles R. Kccher, Esq.

Ja=es A. 3eclette, Esq.

Southern California Edisen Cc=pany P. O. Ecx 800 2244 Walnut Greve Avenue Rosemead, California 91770 Alan R. Watts, Esq.

Rcurke & Woodruff  ?

California First National Bank Building 1055 North Main Street, Suite 1620 Santa Ana, Califernia 92701 .

Ms. Lynn Harris Hicks GUARD -

3908 Calle Ariana San Clemente, California 92672 -

Mr. Llcyd von Haden 2089 Foothill Crive vista, California 92083  ;-

Atomic Safety an'd iicensing Scard Panel' U. S. Nuclear Regulatory Cc==ission Washington, D. C. 20555 i Decketing and' Service Section Office of the Secretary U. S. Regulatory Cc=missien Washington, D. C. 20555 David R. Pigott, Esq.

7 Chickering and Gregory Counsel for San Diego Gas and Electric Cc=pany and Southern California Edison C~=pany c l

Three e-barcaderc Center, 23rd Flec:

j San Francisco,- CW11f6rnia 94112' ~

and ~

2501 M Stree: N.W. -- -

Suite 560 .

Washingten, D. C. 20037~ M i .

l Phyllis M. Ga1Fagher,'Esq.

1695 West Crescent Avenue Suite 222 Anaheim, California 92801 19 February 40, 1981 J l

DATED:

l c .

.- j 1

• /sh '/

• RICHARD J. NEARTCN, A :cIney for Intervepers FRII27CS OF U.E EARTH, ET A L .

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