ML20003B259
| ML20003B259 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/02/1981 |
| From: | Raynard Wharton FRIENDS OF THE EARTH |
| To: | SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8102100562 | |
| Download: ML20003B259 (89) | |
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UNITED STATES OF AMERICA FES 41981 p NUCLEAR REGULATORY COMMISSION g~
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BETORE THE ATOMIC SAFETY AND LICENSING BOARD 4 Br.-:
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N j M In the Matter of
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SOUTHERN CALIFORNIA EDISCN COMPANY, ) Docket Nos. 50-361 OL
) 50-362 OL
_ET _AL.
(San Onofre Nuclear Generating Station,')
Units 2 and 3) )
ANSWERS TO INTERRO ETORIES PROPOUNDED BY SOUTHERN CALIFORNIA EDISON TO: SOUTHERN CALIFORNIA EDISON COMPNAY, et al. :
Pursuant to Title 10, Part 2, Section 2.7406 of the Code of Federal Reguations, Intervenors, Friends of the Earth, et al., in the above-entitled action hereby respond to "Second Set of Inter-rogatories to Intervenors, Friends of the Earth, Mr. and Mrs. August Car-stens" which were served by mail on Intervenors on November 24, 1980.
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INTERROGATORY NO. 1 ,,
Define the following terms which have been used by you in the four previous sets of interrogatories to Applicants:
(a) structurally related (b) wrench fault .a (c) wrench fault system ,
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1 Answer to Interrogatory No. 1, De finitions :
(a) The term " structurally related" refers to a structural configuration involving two or more faults, folds, or zones of defor-mation. The config'uration or structural relationship includes the geometric patterns as portrayed in various geologic maps of the area of interest.
(b) Wrench faults are high angle strike-slip faults of great linear extent which involve deformation of the basement (invariably).
Examples of wrench faults are the Newport-Inglewood and the San Andreas Faults.
(c) A " wrench fault system" includes the main wrench fault,
! parallel or subparallel faults within the wrench ene, co-existing normal faults, en echelon folds conjugate faults, en echelon con-jugate shear joints, reverse faults, tension joints, and en echelon normal faults. In " simple parallel wrenching" the " wrench fault system" involves crustal blocks moving parallel with the wrcnct, fault, and sometimes a series of parallel wrench faults such as e~xists'in Southern California including the Newport-Inglewood and San Andreas faults.
(d) " Wrench' fault tectonics" involves both extension and compres-sion, complex secondary faulting, and co-existing normal faults, reverse faults, and dip-slip components. " Wrench fault tectonics" is a term that is defined and discussed at great length and in great detail, including particular references to the Newport-Inglewood and San Andreas Faults, in " Wrench Fault Tectonics: by Moody and Hill (1956) published by the Geological Society of America Bulletin and in " Basic Wrench Tectonics" by Wilcox, Harding, and Seely, e
2
o published. in the Bulletin of the American Association of Petroleum Geologists, 1973.
Another article entitled "The Newport-Inglewood Trend, California
--An Example of Wrenching Style of Deformation" by T.P. Harding describes " wrench fault tectonics".
(e) An " active tectonic system" involves a system of faults, plates, and crustal blocks,'with current tectonic activity, or recurring deformation of the earth's crust.
(f) " Branch or splay" refers to a geologic configuration in which one earthquake fault or fold branches from another.
(g) The term " seismic gap" is defined as any region along a fault within an active plate boundary that has not experienced a large thrust or strike-slip earthquake for more than 30 years.
Plate boundary margin fault zones are divided into a series of neighboring rupture zones, with varying conditions of stress and strength in and near a seismic gap. Structural barriers involved in stress concentration along seismic gaps include fault bends, junctions, and ductile and brittle inhomogeneous barries. A seismic gap can develop along a known active fault zone or zone of deformation that is seismicly active at one or both ends of the zone, but not in between, or that.is seismicly active in one rupture zone but is l not active in another rupture zone.
(h) The term "en echelon" refers to an overlapping or staggered arrangement in a zone of geologic features which are oriented obliquely to the orientation of the zone as a whole. The individual features are short, relative to the length of the zone.
(i) " Plate boundary" refers to an area or region that is along
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the margin of any one of the tectonic plates which are moving about the lithosphere of the earth's surface. A plate boundary can be quite wide depending on the nature of the characteristics and history of the region.
- INTERROGATORY NO. 2.
For each of the terms listed in' Interrogatory No. 1, (a) Identify each and every document, written authority or communication 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-4 rely in defining each term.
Answer to Interrogatory No. 2:
(a) (a) Structural and Field Geology by J. Geikie, Edited by R. Campbell and R.M. Craig, published by Oliver and Boyd,1953; Outlines of Structural Geology by E.S. Hills, published by Wiley and Sons, 1959; Structural Geology by M.K. Hubbert, D.G. Willis, W.W. Rubey, and W. Hafner, published by Hafner, N.Y., 1972; Structural Geolocy by L.U. De Slitter, published by McGraw-Hill,1956; Structural Geologv of North America, by A.J. Eardley, Harper and Row, 1957;_
Structural Geology, An Introduction to Geometrical Techniques, by D.M. Ragan, published by Wiley, N.Y., 1973; International Tectonic i Dictionary, by John Denniss, published by American Association of .
Petroleum Geologists, 1967; Glossary of Geology, by J.V. Howell, published by American Geological Institute, 1960; International
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Dictionary of Geophysics, Zdited by S.K. Runcorn, 1967; Diction:rv 4
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of Geological Terms, by American Geological Institute, Dolphin ..
Books, 1962.
(a) (b) Intervenors relied on research performed by consultant Glenn Baricw to define this term, based on the documents listed above.
(a) (c) Same as answer to Interrogatory No.1 (a) above.
(a)
" Wrench Fault Tectonics" by Moody.and Hill, published in (b) the Geological Society of America Bulletin, volume 67, #9, pp.
1207-1246, September, 1956; " Basic Wrench Tectonics" by Wilcox, Harding, and Seely, published in the Bulletin of the American 74-96, 1973; "The Association of Petroleum Geologists, volume 57, p.
Newport-Inglewood Trend, California--An Example of Wrenching Style of Deformation" by T.P. Harding, published in the Bulletin of the 57, 1973, p.
American Association of Petroleum Geologists, volume 97-116.
(b) (b) Same as 2(a) (b) above.
(b) (c) Same as Answer 1(b) above.
i.e., " Wrench Fault Tectonics",
(c) (a) Same as answer 2(b) (a) above, I
and " Basic Wrench Tectonics", plus another article entitled "The Newport-Inglewood Trend, California--An Example of Wrenching Style of Deformation" by T.P. Harding, published in the Bulletin of the 57, 1973, p.
American Association of Petroleum Geologists, volume I
97-116.
(b) Intervenors relied on research by Glenn Barlow to define this term.
(c) Same as answer to Interrogatory No.1(c) above.
i.e., " Wrench (a) Same as answer 2 (b) (a) and (c) (a) above, (d)
Fault Tectonics," " Basic Wrench Tectonics," and The Newport-Inglewood 5
Trend, California-- An Example of Wrenching Style of Deformation. "
(b) Same as (b) (b) and (c) (b) above.
(c) Same as answer to Interrogatory No. 1(d) above. ^
(e) (a)
" Continental Drift and Plate Tectonics" by William Glen, -
1975.
College of San Mateo, by C.E. Merrill Publishing Co., _.
(b) Same as (d) (b) above.
(c) Same as answer to Interrogatory No. 1(e) above.
(f) (a) Same as answer 2 (a) (a) .
(b) Same as (e) (b) above.
(c) Same as answer to Interrogatory No.1(f) above.
(g) (a) " Seismic Gaps and Plate Tectonics: Seismic Potential For Major Plate Boundaries", by ML; ann, Nishenko, Sykes, and Krause:
1978; Transactions, American Geophysical Union, Fall Meeting, What Initiates and Stops a rupture
" origin of the Seismic Gap:
propagation along a plate boundary 7" by Keiiti Aki, MIT, June 1978.
(b) Same as (f)(b) above.
(c) Same as answer to Interrogatory No.1(g) above.
(h) (a) Same as answer 2 (a) (a) .
(b) Same as answer 2(g) (b) above.
3 (c) Same as answer to Interrogatory No.1 (h) above.
(i) (a)
" Continental Drift and Plate Tectonics:" by William Glen, College of San Mateo, by C.E. Merrill Publishing Co., 1975; and Fischer and
" Petroleum and Global Tectonics" edited by Alfred G.
Sheldon Judson, published by Princeton University Press, 1975.
(b) Same as answer 2(h) (b) above. .
above.
(c) Same as answer to Interrogatory No.1(i)
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INTER.ROGATORY NO. 3:
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Do you disagree with the following as an accurate descrip-tion of the Cristianitos Fault:
j "The Cristianitos Fault is an expression of crustal extension with the block on the west moving down relative to the block on the 4 east. The fault trends approximately north 20 degrees west for about 32 kilometers (20 miles) inland from its coastal exposure. Within the site area, the fault juxtaposes Eocene and middle Miocene rocks, the Santiago and San Onofre Breccia, respectively, against upper Miocene Capistrano and San Mateo Formations (of probable Pliocene age). Investigations have demonstrated the age of the fault to be greater than 120,000 years old, based on the overlying terrace material which has not been offset wherever the contact with the underlying formation is exposed. In addition, there is no evidence of any fault i
movement in the past 500,000 years."
Answer to Interrogatory No. 3: Yes, we disagree with your description of the Cristianitos Fault.
INTERROGATORY NO. 4:
If you disagree with the description of the Cristianitos i Fault set forth in Interrogatory No. 4 as accurate, state that which i
l you contend is inaccurate and the basis for your contention.
l Answer to Interrocatorv No. 4: James Davis, California State Geologist, and Michael Kennedy, CDMG Senior Marine Geologist, state in a letter to Bob Jackson of the NRC Staff, dated August 11, 1980, i
that the Cristianitos fault is " mapped for a distance of more than fifty kilometers onshore." This description disagrees with the Applicants' description of "about 32 km" as a proposed length for the onshore Cristianitos. We believe that there - has . been inadequate 7
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research to demonstrate that the age of the most recent movement on ,
i the fault is greater than 120,000 years. We believe that independent research is required to date the soils and terraces in the area of the fault. Reports by the scientists from the California Division of Mines and Geology, (Fife, 1974; Morton et al., 1974) present evidence that suggest that there has been Holocene movement on the Cristian-itos Fault.
Furthermore, Intervenors disagree with the Applicant's statement that "there is no evidence of any fault movement in the past 500,000 years". On the contrary, there is no evidence that the Cristianitos Fault has not moved many times during the past 500,000 years, based on the fact that there is a hiatus or gap in the sedimentary markers. Also, the fact that Cal Tech has located epicenters of Twentieth Century seismic events on the Cristianitos Fault disagrees with the Applicant's statement that "there is rgo evidence of any fault movement in the past 500,000 years."
INTERROGATORY NO. 5:
Do you content that the Cristianitos Fault extends south-ward for a distance greater than 6,000 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, 8
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.
Answer to Interrogatory No. 5: Yes, Intervenors contend that the Cristianitos Fault extends southward for a distance greater than .
6,000 feet offshore from its coastal expression.
(a) The analysis of offshore seismic profiles conducted for the NRC by Gary Greene and Michael Kennedy is the basis for this contention. The map produced for the NRC by Greene and Kennedy, dated September 1980 shows a fault trend labeled as "A" which extends offshore along the projected strike of the Cristianitos Fault, (" restricted use") for a distance of at least 30,000 feet from the coastal expression.
. (b) 1. The transcript of the May 21, 1980, meeting between the NRC Staff, Gary Greene, and the Applicant.
- 2. The transcript of the August 14, 1980, meeting between the NRC Staf f, Gary Greene, and the Applicant and its consultants.
i 3. The tape recordings of the September 23, 1980, meeting between the NRC Staff, Gary Greene, Michael Kennedy, and the Applicant.
- 4. The initial report by Greene and Kennedy, entitled .
" Review of offshore seismic reflection profiles in the vicinity of _
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I the Cristianitos Fault, San Onofre, California."
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- 5. The second report by Greene and Kennedy, entitled,
" Addendum to" the report listed in No. 4 above.
- 6. The letter from J.F. Davis and M.P. Kennedy to Bob Jackson, dated August 11, 1980.
- 7. The map produced by Greene and Kennedy for the NRC, dated September, 1980, entitled, " Geologic Structure Map-San Onofre Offshore."
- 8. Unpublished data and maps prepared by Russell Miller, CDMG Geologist, for the Upper Half El Toro Quadrangle Map for future publication.
(c) Michael P. Kennedy, H. Gary Greene.
(d) (1) Michael P. Kennedy (i) Answer 5(a)
(ii) Answer 5(b) Nos. 4, 5, 6, and 7.
(2) H. Gary Greene (i) Answer 5(a)
(ii) Answer 5(b) Nos. 1, 2, 3, 4, 5, and 7.
INTERROGATORY NO. 6:
I What do you conuend is the minimum age of last displacement on the Cristianitos Fault?
(a) State each and every fact upon which you base this contention; (b) Identify e'a:h and every document or communication uponwhichyoubasethiscfontention; (c) Identify edch and every person with knowledge of the factual basis or bases for this '.0,. .ancion,- or on whose writings, opinions, or testi s .2 you ha .e C- . contention; and (d) Identify each and every person, expert or otherwise, 10
l 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.
Answer to Interrogatory No. 6: (a) The minimum age of last movement and displacement on the Cristianitos Fault has been during the Holocene epoch'of the Quarternary Period. The most recent movement at depth on the Cristianitos Zone of Deformation was during two episodes of seismic activity during 1975 and 1977.
The Cristianitos Fault is part of the Cristianitos Zone of Deformation wnich shows evidence of Holocene offsets in the near surface sediments as mapped by Greene and Kennedy 1980.
Geologists and Seismologists throughout Southern California agree that the Newport-Inglewood Fault Zone has a minimum age of last movement in the Holocene epoch. Yet, as the USGS summarizes in Open File Report 81-115, "No Holocene tectonic rupture is documented for faults of the Zone, although most are well expressed physiogra-phically and cut to the surface in pre-Holocene deposits". That description for the Newport-Inglewood fault zone could apply equally to the Cristianitos Fault Zone which is a secondary branch of the OZD.
Answer 6 (b) : The initial report by Greene and Kennedy, entitled
" Review of offshore seismic reflection profiles in the vicinity of the Cristianitos Fault, San Onofre, California"f the second report 11
by Greene and Kennedy, entitled, " Addendum to" the report listed in No. 4 above; the letter from J.F. Davis and M.P. Kennedy to Bob Jack-son, dated August 11, 1980; the map produced by Greene and Kennedy for the NRC, dated September, 1980, entitled, " Geologic Structure Map-San Onofre Offshore;" NUREG - 0712, December 31, 1980, SER on Geologic and Seismic Aspects, SONGS: Geology of the South Half of the El Toro Quadrangle Orange ' County, CA, CDMG California Division of Mines and Geology (CDMG) Special Report 110, by D.I. Fife, 1974; Geology of and Engineering Geologic Aspects of the San Juan Capistrano Quadrangle, Orange County, CA, CDMG, Special Report, 112, 1974, by P.K. Morton, W.J. Edgington, and D.I. Fife; California Institute of Technology records of Seismic Events in Orange County in the 1970's.
Answer 6(c) Don L. Fife, Geologist, H. Gary Green, USGS, Menlo Park, CA, Michael Kennedy CDMG, Sacramento, CA.
Answer 6 (d) : Same individuals listed in Answer 6 (c) .
(d) (i) Each witness will testify according to the facts and opinions that they have discovered during their individual and collective research. Don Fife will discuss the offsets observed in the Holocene sediments along the Cristianitos Fault. Gary Greene and Michael Kennedy wil) discuss the offsets observed in their maps and reports.
(d) (ii) The factual and theoretical basis for the opinion that there has been seismic activity on the Cristianitos Fault is con-tained in the records of the Cal Tech seismic netwoz .. The factual basis for " holocene movement" on the Cristianitos Fault is based on field observa'tions of four scientists from the CDMG who have investigated and trenched along the Cristianitos Fault. Zone.
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The " Geologic structure map-San Onofre Offshore" prepared by Greene and Kennedy, September 1980 presents a factual basis for Holocene offsets on the Cristianitos Fault Zone of Deformation.
INTERROGATORY NO. 7:
Do you contend that the Cristiaaitos Fault is a " capable f a " '_ t " . If so, (a) State each 'and every fact npon 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 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.
Answer to Interrogatory No. 7: Yes, the Intervenors do conter.d that the Cristianitos Fault is a " capable fault".
(a) The Cristianitos Fault Zone of Deformation meets the 13
e criteria for a capable fault as defined in 10 CFR Part 100, Appendix A.
There has been seismic activity on the Cristianitos Fau26 during the past six years. On January 3, 1975, two earthquakes of Magni-tudes 3.3 and 3. 8 occurred on the Cristianitos Zone of Deformation.
Again in 1977, a swarm of five small earthquakes with Local Magni-tudes ranging from Mg 1.9 to M3 2.7 occurred on the Cristianitos The nearby Capistrado Embayment is seismicly
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Zone of Deformation.
active. There is evidence of Holocene Offset on the Cristianitos Fault Zone as referenced and discussed in Answer to Interrogatory No. 6 above. Thus, there has been movement at or near the ground surface at least once in the past 35,000 years. There is absolutely no evidence that there has not been multiple movements during ths past 500,000 years. The burden is on the applicants to show that there has been no movements in the past 500, mJ0 years. The Cristianitos Faul as mapped onshore is a part of the Cristianitos Zone of Deformation (CZD) which has been mapped offshore by Gary Greene of the USGS and by Michael Kennedy of the CDMG. The CZD has a structural relationship with the Offshore Zone of Deformation (CZD) which is classified by the NRC and the USGS as a capable fault. This structural relationship between the CZD and the OZD is such that movement on the OZD can reasonably be expected to be accompanied by movement on the CZD. The CZD is a secondary fault within a wrench tectonic system which. includes the OZD, the Newport-Inglewood Fault, the other offshore wrench
' faults zones, out to the San Clemente Fault Zone, and the inland I
wrench fault zones including the Whittier-Elsinore Fault, _the San Jacinto Fault and the San Andreas Fault. Each of the parallel main wrench faults- in this parallel series of faults from the San Andreas i
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4 Fault to the San Clemente Fault, including the OZD, is a main wrench fault with parallel or subparallel faults within the wrench zone, with co-existing normal faults with en echelon folds, conjugate faults, en echelon conjugate shear joints, reverse faults, tension joints and en echelon normal faults. It is characteristic of the Newport-Inglewood--OZD Fault Zone to have numerous smaller second-order faults intersecting 'the primary faults and generally trending in the northern direction. This is characteristic of such a wrench fault. The Cristianitos Fault Zone of Deformation is a north trending normal secondary fault within the wrench fault systems Of the Newport-Inglewood.
This zone, CZD Fault Zone, is a seismicly active wrench fault system. Therefore, movement on the OZD can reasonably be expected to be accompanied by movement on the CZD. Furthermore, the Cristianitos Fault Zone of Deformation appears to be a Zone of Deformation that represents a complex secondary fault zone of I
deformation forming a structural relationship between two parallel wrench faults, namely, the OZD and the Whittier-Elsinore Fault.
Zone. The El Modina segment of the Cristianitos-El Modina Zone is similar in style to the Whittier-Elsinore Fault Zone.
Answer to Interrocatory No. 7 (b) : California Institute of Technology
! Bulletin Documents produced by the CDMG as referenced in answer 6 (b) ;
all documents produced by Applicants regarding the Cristianitos Fault Zone of Deformation, including the contents of meetings between the Applicant and the Staff; the NRC Staff SER on Geology and Seismo-logy, NUREG 0712, December 31, 1981; Records of meetings ' between NRC, USGS, and Applicants during 1980; verbal communications with Don Fife and Michael Kennedy, in January,1981; and Gary Greene and Michael
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, <nr -r , , - - - ,
l 1980, 1981. " Wrench Fault Tectonics" Kennedy in 1980 and Jim Davis,
" Basic Wrench Tectonics" by Wilcox, Harding, by Moody and Hill; and Seeley,1973; "The Newport-Inglewood Trend, . California-- An 1973; Example of Wrenching Style of Deformation" by T.P. Harding, Michael Kennedy and E.E. Welday,1980, Recency and Character of Faulting Of fshore San Diego.
Answer to Interrogatory 7(c) : The individual scientists identified five, and six.
in answers to Interrogatories numbers four, Answer to Interrocatory 7(d) : The individual scientists who were identified in responses to Interrogatories four,' five, and six.
Same as responses to Interroga-Answer to Interrocatory 7(d) (i) : _
tories numbers 4, 5 (a) (b) (d) (i) and (d) (iii) , 6 (a) (b) (d) (i) , and (d) (iii) .
Same as answer 7(d) (ii) above, same Answer to Interrocatorv 7(d) (ii) : _
as responses 4, 5, 6, and 7 (d) (ii) above.
Two Earthquakes on January 3, 1975, Answer to Interrocatorv 7(e) : _
as recorded by the California Institute and five earthquakes in 1977, of Technology Bulletin; Meetings between Applicants, NRC and USGS on September 13, 1979, regarding the June 1979 document by the Meetings on March 4, and 5, 1980 between Applicant's consultant; and the Intervenors; Meetings between the Applicants, NRC Staff, 21, 1980, USGS, NRC and the Applicants in Bethesda, Maryland on May and August 14, 1980; Meeting between the USGS, CDMG, NRC and the 1980; verbal Applicants in Menlo Park, California, Septenber 23, (c) and communications with the eleven scientists listed in Answer 7 above; November,1979 publication of new offshore mapping by the (d)
USGS and CDMG, August 1980 release by the USGS of-the NRC consultant 16
report performed for the NRC by the marine geologists from the USGS and the CDMG, which was not released to the Intervenors until 4
January 7, 1981.
INTERROGATORY NO. 8:
- Do you agree with the United States Geological Survey's (U.S.G.S.) definition of the OZD as an extensive, linear zone of p
.I deformation at least 240 kilometers (km) long extending from the Santa Monica Mountains to at least Baja, California, and located about five miles offshore from the SONGS 2 and 3 site?
Answer to Interrogatory No. 8: We believe that the USGS definition is outdated, because of the research done since that 1972 definition by the USGS for the Conctruction Permit hearings.
INTERROGATORY NO. 9:
If you do not agree with the U.S.G.S. 's definition of the OZD as set forth in Interrogatory No. 9, state that which you contend is inaccurate and the basis for your contention.
Answer to Interrogatory No. 9: The statement that the OZD is " located about five miles offshore from the SONGS 2 and 3 site" is inaccurate because the reports from the USGS to the NRC in 1980 which are included in NUREG 0712, state that the OZD "is located on the distal part of the nearshore shelf approximately 7 km'from SONGS at its closest' point". According to our calculations, 7 kilometers is "about 4 miles" rather than "about 5 miles". '
The Santa Monica to Baja Fault Zone of Deformation ' described as the OZD extends for a length of 390 kilometers instead of 240 kilo-meters as described in the outdated definition referred to by the Applicant. The basis for this ~ contention is the measurements made on several geologic maps of the distences between the Santa 17
Monica Fault at the northern end of the Newport-Inglewood Fault and the Agua Blanca Fault at the southern extent of the Santa Monica-4 Baja Zone of Deformation.
INTERROGATORY NO. 10:
Do you contend that a " seismic gap", as that term is defined by you, in Interrogatory No. 2(g), exists offshore the SONGS 2 and 3 site? If so, (a) State each and every fact upon which you base dais 4
contention; (b) Identify each and every document or communication upon which you base this contention; Ic) 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 i (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 f actual and theoretical basis, as well as any_ other grounds, for each opinica to which the witness is expected to testify.
Answer to Interrogatory No. 10: Yes, the Intervenors contend that a
" seismic gap" exists offshore from the SONGS 2 and 3 site, on the Santa Monica to Baja Zone of Deformation.
Answer'10 (a) : The Santa Monica to Baja' Zone of Deformation is 18
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1 part of the active plate boundary which stretches from east of the i San Andreas Fault in California through the San Jacinto and Whittier-Elsinore Faults out to the San Clemente Fault and possibly to the Patton Escarpment. The plate boundary is quite wide in southern California and the portion of the Northern Baja California from San Diego to the Agua Clanca Fault Zone near Ensenada, and south-east into the Gulf of California is onb of the most interesting seismic zones in the world. The cpreading centers along the plate boundaries in the waters beneath the Gulf of California are powerful evidence of the power of the interaction between the drif ting tec-tonic plates that meet at this wide plate boundary. The historical tectonic reason why the Baja California Peninsula has separated from the mainland is due to plate tectonics and the interactions of the spreading centers in the Gulf of California with the movements on the San Andreas and other parallel strike slip wrench fault zones in Southern California and Northern Baja. It is generally recognized that the southern California segment of the San Andreas Fault System is in a state of seismic gap. Major earthquakes of Magnitudes 8.5 and 8.3 have occurred on the northern and central segments of the San Andreas Fault in 1857 and 1906, but no quakes larger than about Magnitude 7.0 have struck the Southern San Andreas during that time. The plate boundary is wide in southern California and many scientists have postulated that the plate boundary movement
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is being distributed among the parallel wrench faults from the San Andreas to the San Clemente Fault offshore. Several scientists believe that a significant portion of the plate boundary move:nents is actually accommodated on the offshore fault zones in the southern California Continental Borderland. This entire southern segment 19
i l
l of the Southern California Plate boundary is in a state of seismic gap. Along the Santa Monica to Baja Zone of Deforamtion, there is evidence of strong earthquakes on the northern and southern segments cf the Zone, but not in the central segment of the zone. This indicates that the central portion of this zone along an active major component of the plate boundary is in a seismic gap offshore from the reactors. The Newport-Inglewood Fault experienced moderate earthquakes of around mag: *.tude 6.5 in 1800, 1812, and 1933. The southern segment in Baja has experienced moderate earthquakes of magtitude 6 and above in the 1950 's.
Answer to Interrogatory 10(b): The width of the plate boundary in southern California has been discussed in the following documents:
Tanya Atwater, " Implications of Plate Tectonics for tMe Cenozioc Tectonic Evolution of Western North America," in the Geological Society-of America Bulletin, v. 81, p. 3515-3536; J.G. Anderson, 1979,
" Estimating Seismicity from Geologic Structure for Seismic Risk Studies" in the Bulletin of the Seismolocical Society of America,
- v. 69, p. 135-158; "Neogene Tectonic Evolution of the California Continental Borderland and Western Transverse Ranges," by J.K. Crouch, 1978, 'M95 Open File R3 cort 73-506, 22 pp.; Moore and Kennedy, 1975, "Quarternary Faults at San Diego Bay, California" USGS Journal of Research, v. 3, p. 589-595; Art Luchenburch, USGS, Journal of Geophysical Research, December, 1980; Buckley and Kohlenberger,
" Application of Tiltmeters as an Inertial'" published in the May 1980 AGU National Meeting Abstracts; "Scenaries of Possible Earth-quakes Affecting Major California Population Centers, with Estimates of Intensity.and Ground Shaking" by U9GS, Ocen File Renort 081-115, 1981; " Aspects of the Geologic History of the California Continental 20
Borderland," edited by David G. Howell, USGS, 1976, published by the American Association of Petroleum Geologists; Journal of Geo-ohysical Research, 1968, by Oliver and Sykes; ' Charles Richter in textbook, Elementary Seismology. Maps by Greene, Ziony, et al.
of USGS and Michael P. Kennedy of CDMG, 1979, in an article entitled
" Implications of Fault Patterns of the Inner California Continental Borderland between San Pedro and San Diego" by H.G. Greene, K. A.
Bailey, S.H. Clarke, J.I. Ziony, of the USGS, and M.P. Kennedy of the CDMG, November, 1979, in cook entitled Earthquakes and other Perils, San Diego Region, edited by Patrick L. Abbott and William J. Elliot, for the GSA meetings in November,1979.
Answer to Interrocatory No. 10 (c) : Dr. James, Brune SIO-IGPP, Dr. Richard Simons , SIO-IGPP, Dr. Gary Greene, USGS, Dr. J. I. Ziony, USGS, Dr. Michael Kennedy, CDMG, Dr. Jim Davis, CDMG, Mark Legg, SIO-IGPP, Dr. Tanya Atwater, Dr. Art Luchenburch, USGS, Dr. D.G.
Mcwell, USGS, Dr. J.G. Vedde r, USGS.
Answer to Interrocatory No. Aj (d) : Some of the same scientists who are identified in answer 10(c) above.
Answer to Interrocatorv No. 10 (d) (i) : Intervenors are not sure of the. precise facts and opinions of each of these potential witnesses, because most of them are not consultants to the Intervenors, but have published extensively about the concepts involved and we believe that they will' be in substantial agreement with the facts and opinions stated in Answer 10 (a) .
Answer to Interrogatory No. 10 (d) (ii) : The factual and theoretical basis as well as other grounds for their expected testimony is summarized in Answer 10 a, b, c, and d(i) above, and in documents listed in 10(b).
21
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INTERROGATORY NO. 11:
Do you admit that the OZD is the controlling geologic structure for siecmic design of SONGS 2 and 3?
Answer to Interrocatorv No. 11: Nc.
INTERR0GATORY NO. 12:
If you do not admit that the. OZD is the controlling geologic structure for seismic design of SONGS 2 and 3 what do you contend is the controlling geologic structure?
(a) State each and every fact upon which you base this contention; (b) Identify each and every doc 6 ment 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 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.
Answer to Interrogatory 12: Intervenors contend that the controlling geologic structure for the seismic design of the SONGS 2 and 3 0
22
l 1
i l
l nuclear reactors should be the Cristianitos Fault Zone of Deforma-tion which is a complex secondary fault in the wrench fault system known as the OZD or Santa Monica-Baja Fault Zone of Deformation.
Also, Intervenors contend that the controlling geologic struc-ture for seismic design of SONGS 2 and 3 should be the structural relationship between the Cristianitos Fault Zone of Deformation and the OZD, a wrench fault system.
Answer to Interrogatory No. 12 (a) : The Offshore Zone of Defor-mation, sometimes referred to as the Newport-Inglewood-Rose Canyon Fault Zone, is commonly recognized, described and identified as being an active wrench fault, involved in parallel wrenching which -
involves other active wrench faults in this region of the San Andreas plate boundary. The OZD is structurally related to the Cristianitos Zone of Deforamtion, as mapped and described in the reports to the NRC by marine geologists from the USGS and the CDMG which are included in the NRC Staff SER on Geologic and Seismic Aspects.
Answer to Interrogatory No. 12 (b) : The wrench fault tectonics of the OZD-CZD wrench fault system are described in a report by T.P.
! Harding entitled "The Ne rt-Inglewood Trend, California--An Example of ' renching Stylc of Deformation," published by the American Association of Petroleum Geologists (AAPG) Bulletin, volume 57, 1973, p.97-116; and in another article in that same volume of the l same publication, p. 74 to 96, entitled " Basic Wrench Tectonics" i
by R.E. Wilcox, T.P. Harding, and D.R. Seely; and in another publi-l
! cation " Basic Wrench Tectonics" by Moody and Hill published in the.
Geolocical Society of America Bulletin, volume-67, #9, p. 1207-1246.
The structural relationship of the Newport-Inglewood-OZD to the Cristianitos Fault Zone.of Deformation is discussed and documented
! 23 i
l - -~ - -
in the following documents and communications:
- 1. The map produced by the USGS and the CDMG, which was published in the Geological Society of Americd publication, in November 1979, entitled, " Earthquakes and other Perils in the San Diego Region," page 22.
- 2. The article entitled " Implications of Fault Patterns of the Inner California Continental Borderland between San Pedro and San Diego" by U.S. Geological Survey scientists H.G. Greene, K.A.
Dailey, S.H. Clarke, and J.I. Ziony, and by the senior marine geologist from the state CDMG, M.P. Kennedy, November, 1979, GSA..
- 3. The transcript of the May 21, 1980, meeting between the NRC Staff, the USGS, and the Applicant.
- 4. The transcript of the August 14, 1980 meeting between the NRC Staff, the US GS , and the Applicant.
- 5. The tape recordings and other records of the September 23, 1980 meeting between the NRC Staff, the USGS, the CDMG, and the Applicant.
- 6. The initial report by Greene and Kennedy, entitled,
" Review of Offshore Seismic Reflection Profiles in the Vicinity
(
l of the Cristianitos Fault, San Onofre, California, which was sent by the USGS to the NRC Staff on August 13, 1980.
- 7. The Nekten report and profiles submitted by the Applicant to the NRC Staff, 1980.
- 8. The second report to the NRC Staff by the marine _ geologists from the 'USGS and the CDMG, entitled, " Addendum"to the report' listed in No. 12b-5 above.
- 9. The' letter from James--F. Davis, State Geologist of the State of California, and Michael P. Kennedy, Senior Marine Geologist of the' I
i 24 l
l
s CDMG, to Bob Jackson, Chief Geologist of the NRC Staff, Geosciences Branch, dated August 11, 1980.
- 10. All other references to OZD as a wrench fault by NRC, USGS, and Applicant.
Answer to Interrcgatory No. 12 (c) : The authors of the reports listed above in Response 12 (b) including H. Gary Greene, Marine Geologist, USGS, Menlo Park, Ca; Joe I. Ziony, Regional Geologist, USGS, Menlo Park, CA; Michael P. Kennedy, Senior Marine Geologist, CDMG, Depart-ment of Conservation, 1416 Ninth Street, Room 1341, Sacramento, CA; James F. Davis, State Geologist, Department of Conservation, 1416 Ninth Street, Room 1341, Sacramento, CA.
Answer to Interrogatory No. 12 (d) : H. Gary Greene, Marine Geologist, USGS, Menlo Park, CA; Joe I. Ziony, Regional Geologist, USGS, Menlo Park, CA; Michael P. Kennedy, Senior Marine Geologist, CDMG, Depart-ment of Conservation, 1416 Ninth Street, Room 1341, Sacramento, CA.; James F. Davis, State Geologist, Department of Conservation, 1416 Ninth Street, Room 1341, Sacramento, CA.
~
Answer to Interrogatory No. 12 (d) (i) : We expect these witnesses to testify regarding the substance of the facts and opinions which they have authored as listed in detail in Answer 12(b) above.
t
( Answer to Interrogatory No. 12 (d) (ii) : These witnesses are expected to testify as to the factual and theoretical basis on the grounds of the best of their accumulated knowledge after many- years of working as government scientists investigating th'e ' area of interest.
INTERROGATORY NO. 13:
What do you contend is the maximum magnitude earthquake that could occur on the-OZD?
(a) State each and every fact upon which you base ~this 25 L j
contenti an; (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 persen, expert or otherwise, whom you expect to call as a witness at the hearing before the Atonic 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.
Answer to Interrogatory No. 13: Intervenors contend that the maximum magnitude earthquake that could occur on the OZD is greater than Magnitude 8. The length of the OZD, also known as the Santa Monica-Baja Fault Zone, is approximately 390 km long, because it extends into Baja along the Agua B?.anca Fault Zone. Based on the various length versus magnitude relationships, including the method i used by Burt Sle= mons for the NRC, this length of the Fault Zone gives a Magnitude 8 quake easily, and under some calculations, larger l
i than an 8. Considering the possibility that the Agua-Blanca is structurally related to the plate boundary spreading center in the f Gulf of California, the Agua Blanca could be a major structural l '
element in the plate boundary that extends from the San Andreas 1 .
26 i
l l
[-
\
I Fault to the San Clemente Fault Zone offshore.
Answer to Interrogatory 13 (a) : A report on Scismological Considerations for Siting nuclear reactors near the Newport-knglewood Fault Zone was published in October, 1967, in a Special Report to then Secre-tary of the Interior Stewart Udall. The " Reporter to Secretary of the Interior Stewart L. Udall," dated October, 1967, entitled
~
" Geological-Seismological Factors Pertaining to the Proposed Con-struction of a Nuclear Power and Desaltin,g Plant at Bolsa Island, California," analyzed the risk to the public health and safety of siting a nuclear re. actor along the Newport-Inglewood Fault Zone in southern California. This report stated, in a section entitled
" Seismological Considerations" that "In specifying the maximum earthquske for which public safety must be assured, a highly conser-vative approach has been adopted for two principal reasons:
(1) the consequences of some types of serious failure in a nuclear facility must be guarded against even if their likelihood is very remote; and (2) the historic record of earthquake occurrence is so short that it cannot encompass the entire spectrum of possible events."
"In view of the mandatory conservatism, we suggest that the maximum earthquake for which public safety must be assured should be a magnitude 8 shock on the Newport-Inglewood Fault or on one of the parallel offshore faults (Palos Verdes, San Pedro faults).
In addition, a magnitude 8 1/2 earthquake must be assumed on the more distant San Andreas Fault or on one of its major branches."
In an article in Engineering and Science map? tine, entitled
" Earthquakes, Faulting and Nuclear Reactors," Clarence ?.. Allen, 27
Seismologist at the California Institute of Technology, states that:
"In California and many other parts of the world, the largest earthquakes have been associated with the longest faults. Thus, the length and continuity of nearby faults have been major con-siderations in attempting to specify the maximum credible earthquake for a given locality. This generalization appears to be particularly valid for strike-slip faults as are common throughout most of California. Despite the many geological problems in trying to apply this type of criterion for establishing the maximum credible ear thquake , it certainly has more justification in most areas than merely assuming that the largest nearby earthquake in the historic past is representative of the largest possible event in the future.... In the case of nuclear reactors, the specifi-cation of the maximum credible earthquake for which public safety must be assured demands extreme conservatims for two principal reasons: (1) the consequences of some types of serious failure in a nuclear facility must be guarded against even if their like-lihood is exceedingly remote; and (2) the historic record of earthquake occurrences is so , aort that it cannot encompass the entire spectrum of possible events. " " Almost every earthquake that has occurred in California has proved to be surprising in terms of what would have been expected by geologists, seismolo-gists, and engineers at the time. For this reason, the present state of knowledge demands an unusually conservative approach to the specification of seismic siting and design criteria for structures such as nuclear reactors and dams that are critical to public safety. "
Answer to Interrogatory No. 13 (b) : "A Report to Stewart L. Udall, Secretary of the Interior, Geological-Seismological Factors Pertaining i
l l
i I
28 l -
~ _ _ _ ._ _ _ _ _
to the Proposed Construction of a Nuclear Power and Desalting Plant at Bolsa Island, California," released in October, 1967 by the Department of Interior, as comments to the AEd about reactors siting evaluations. The quotes from Clarence Allen are in an article printed in Engineerinc and Science Macazine, November, 1967, pages 10 through 16.
Answer to Interrocatorv No'. 13 (c) : Clarence Allen, Seismologist, at Cal Tech. , Stewart Udall, lawyer, former Secretary of Interior, law firm of Brown et al. , Washington, D.C.
Answer to Interrogatory No. 13 (d) : Stewart L. Udall, former Secretary of the Interior, Law firm of Brown, et al. , Washington, D.C., Clarence Allen, Seismologist, California Institute of Tech-nology, Pasadena, CA.
Answer to Interrogatory No. 13 (d) (i) : We expect these witnesses to confirm the statement that is quoted above in 13(a) regarding siting a nuclear reactor along the Newport-Inglewood Fault Zone.
Answer to Interrogatory No. 13 (d) (ii) : The witnesses are expected to testify on the factual and theoretical bases that were grounds for the formation of the opinion that is expressed in the Report to the Secretary of the Interior regarding earthquake hazards to nuclear reactors sited near the Newport-Inglewood Fault.
INTERROGATORY NO. 14:
'4 hat do you contend is the maximum magnitude earthquake that could occur on the controlling geologic structure you have described in Interrogatory No. 12?
(a) State each and every fact upon which you base this contention; 29
4 (b) Identify each and every document or communication upon which you base this contention; (c) Identify each and every person'with kr / ledge 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 t .tness 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.
Answer to Interrogatory No. 14: We contend that the maximum magni-tude earthquake that could credibly occur on the controlling geologic structure is in the range of magnitude 6.5 to magnitude 7.
Answer to Interrogatory No. 14(a): The Cristianitos Fau'.t Zone of Deformation is at least 64 kilometers long from its intersection with the OZD offshore to its northern mapped trace past the Santiago l
l Creek. Because the El Modina Fault shows clear evidence of Holocene l
l movements and the offshore Cristianitos CZD shows evidence of i
shallow near surface movements or offsets, the Fault Zone is con-sidered capable of generating earthquakes, and in its tectonic context in a wrench fault system relationship with the OZD which is capable of generating a magnitude 8 or larger quake, with a higher probability of a magnitude 7.5 quake, the Cristianitos Fault Zone 30
[
of Defornacion is considered capable of experianring sympathetic secondary faulting during the larger event on the OZD. Tne phenomena of secondary and sympathetic faulting occurring during earthquakes on other faults, has been noted by many scientists, e.g., re: the Borrego Mt. Earthquake, 1968. See Response #27. Based on the length versus magnitudes estimates using various methods, the Cristianitos Fault Zone of Deformation is capable of generating a maximum credible earthquake in the range of magnitude 6.5 to 7.0.
Note that the San Fernando Earthquake in February, 1971, was a magnitude 6.5 and the surface rupture was only 15 kilometers.
The Cristi1nitos Fault Zone of Deformation 4.s longer than the one-third to one-fourth formula used by D. Slemmons for the OZD calculations in the SER.
INTERROGATORY NO. 15:
What do you contend is the minimum age of last displace-ment on the South Coast Offshore Zone of Deformation portion of the OZD?
(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; 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 (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, 31
. -.~ .- . . _ -
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; i
(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.
Answer to Interrogatory No. 15: In 1969 and duri.ig the Holocene epoch of the Quarternary Period.
Answer to Interrogatory No. 15 (a) : Displacements of shallow sub--
surface sediments including Pleistocene and Holocene' sediments have been observed on the South Coast Offshore Zone of Deformation portion of the OZD. This observation has been made by marine geo -
logists from the USGS and the CDMG and by consultants to the Applicant.
Answer to Interrogatory No. 15 (b) :
(1) The map produced by the USGS and the CDMG which was published in San Diego Association of Geologists publication, in November, 1979, entitled, " Earthquakes and other Periols in the San Diego Region," page~22.
(2) The article entitled, " Implications of Fault Patterns of the Inner California Continental Borderland:between San Pedro and San Diego, by U.S. Geological. Survey scientitsts H.G. Greene, K.A. Bailey,'S.H. Clarke, and J.I. Ziony, and by;the Senior Marir Geologist from the state CDMG, Michael P. Kennedy, November,.1979,
- published by.the San Diego Association of Geologists, edited by 32
Patrick L. Abbott and William J. Elliot.
(3) The transcript of the August 14, 1980 meeting between the NRC Staff, the USGS and the Applicant.
(4) All communications and documents and visual aids, graphs, charts, photographs, maps and printed handouts used in the September 23, 1980, meeting in Menlo Park, CA, between the NRC Staff, the USGS, the CDMG, the California Department of Conservation, and the Applicant.
(5) The re: rt by H. Gary Greene and Michael P. Kennedy, entitled "Revir.w of Offshore Seismic Reflection Profiles in the Vicinity of the Cristianitos Fault, San Onofre, California" which was sent by .the USGS to the NRC on August 13, 1980.
(6) The Nekten report by SCE to the NRC, entitled "Interpre-tive Results High Level Resolution Geophysical Survey in Selected Areas Between Dana Point and Oceanside ~ and Offshore California".
(7) The Nekton data that was collected by Nekton, entitled,
" Geophysical drawings and data of area offshore from site. Sixty-I nine seismic and subbottom profiles."
(8) Applicants' consultant's data and profiles and all pro-files which were reviewed by Gary Greene and Michael Kennedy in the preparation'of their report listed in No. 15 (b) 5 above.
(9) The map prepared by Greene and Kennedy for the NRC dated September,1980, entitled " Geologic Struc,ture Map-San Onofre, Offshore."
(10) The NRC' Staff SER, NUREG-0712.
Answer to Interrocatorv No. 15 (c) : H. Gary Greene,1 USGS, Menlo Park, CA, Mic'hael Kennedy, Mark Legg, David Moore, consultant to the Applicant, Li Jolla, CA. , ,
33
Answer to Interrogatory No. 15(d) same as 15 (c) .
Answer to Interrogatory No. 15 (d) (i? Their interpretations of the seismic profile data, and of the statements they made in meetings and in written reports.
Answer to Interrogatory No. 15 (d) (ii) : The seismic profile data that have been reviewed by Gary Greene, Michael Kennedy, Mark Legg, and David Moore, and dhat have been translated into offshore geologic
(
structure maps by Greene, Ziony, Bailey, Clarke, and Kennedy of the USGS and the CDMG, reveal that there are displacement of shallow subsurface sediments along the SCOZD near SONGS (and near the junction of the OZD and CZD) . Each of the witnesses has indicated that the displacements could include Holocene offsets.
Answer to Interrogatory No. 15 (e) : The 1969 earthquake referred to occurred offshore from Laguna Beach on the SCOZD and was a magni-tude 4.5.
INTERROGATORY NO. 16:
What do you contend -is the minimum age of last displace-ment on the Newport-Inglewood Zone of Deformation portion of the OZD?
(a) State each and every fact upon which you base this cc stention; (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, 34
. . _ , . _ _. . . ~ _ - ~.
._. _ - =. . - .
and as to each potential witness so identified provide the following information:
J (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.
Answer to Interrogatory No. 16: 48 years ago, in 1933.
Answer to Interrogatory No. 16(a): The 1933 'Long Beach" Earthquake occurred on the Newport-Inglewood Fault and caused the last major displacement on that Fault.
Answer to Interrogatory No. 16 (b) : Many documents produced by consultants to the Applicants, the NRC Staff, and many scientists from California have referred to the fact that at the 1933 earthquake was a very real and well-documented event in seismic history.
Answer to Interrogatory No. 16 (c) : Any geologist, . geophysicist, or i
seismologist knows that the 1933 "Long Beach" earthquake occurred on the Newport-Inglewood Fault.
Answer to Interrogatory No. 16 (d) : Rich Simtas, Jim Brune, seis-mologists at SIO-IGPP.
Answer to Interrogatory No. 16 (d) (i) : That the last displacement on the Newport-Inglewood Fault was in 1933.
Answer to Interrogatory No. 16 (d) (ii) : The data base is large anc
! varied, but the basic data is available through the data collections
- at Cal Tech.
I .
. Answer to Interrogatory No. 16 (e) : The event occurred on March 11, 35
9 1933 near Newport Beach and Long Beach, California.
INTERROGATORY NO. 17:
s What do you contend is the minimum age of last displace-ment on the Rose Canyon Fault Zone portion of the OZD?
(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 faces and opinions to which you expect the witness to testify; I (ii) Summarize the factual and theoretical basis, 1
~ 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. .
Answer to Interrogatory No. 17: During th' Bolocene epoch of he Cuarternary Period.
Answer to Interrogatory No. 17 (a) : Kennedy and others (1975) have shown that the early Pleistocene Linda Vista Formation north and e
36
east of San Diego Bay is offset. The youngest deposits reported faulted in the onshore part of the area are terrace deposits (Bay Point Formation) of Sangamon age (Kern, 1973).' It is suggested from offshore observation, however, that Holocene sediments are faulted on the sea floor north of La Jolla.
"It is suggested from offshore observations that Holocene sediments are faulted on the sea floor north of La Jolla (Moore, 1972) and west of Coronado (Moore and Kennedy,1975)" (Kennedy and Welday, 1980). In a report for the CDMG in 1980, entitled
" Recency and character of Faulting Offshore Metropolitan San Diego, CA. ," Kennedy and Welday state in their abstract " Numerous faults within the area displace near surface sediments and are considered to have had their most recent movement in late Pleistocene or Holocene time."
In a report published in November, 1979, entitled, " Faulting Offshore San Diego and Northern Baja California", Kennedy and Legg, state that "A nearshore sub-zone of northwest trending faults" (within the Rose Canyon Fault Zone) . . . "disple.y surface manifesta-tions such as sea floor scarps and small submarine canyons.
Reflection profiles indicate these faults to be nearly vertical with the faulting extending into the near surface, Quarternary sediments."
Answer to Interrocatorv No. 17(b): " Geology of the San Diego Metro-politan Area," by M.P. Kennedy, 1975, CDMG Bulletin 200 A, p. 38-39; "Charac'.er and Recency of faulting, San Diego area," by M.P. Kennedy, S.S. Tan , R.H. Chapman, and G.W. Chi , 1975, CDMG Special Report 123; " Offshore extension of the Rose Canyon Fault," by G.W. Moore, 1972, USGS, Professional Paper 800-C, p. 113 to p. 116; " Quaternary Faults at San Diego Bay," by M.P. Kennedy and G.W. Moore, 1975, 37
USGS Journal of Research, v. 3, p. 589-595; " Acoustic-reflection profiles, scripps utility boat, San Diego Bay," by M.P. Kennedy and G.W. Moore, USGS Open File Report 76-562, " Preliminary report on Recency of faulting in the greater San Diego Area," 1972, by J,I. Ziony, and J.M. Buchanan, USGS Open-File Report; " Faulting Offshore San Diego and Northern Baja California" by M.R. Legg and M.P. Kennedy, November 1979, in publication of the San Diego Asso-ciation of Geologists, fot the Geological Society of A=erican, entitled " Earthquakes and other Perils, San Diego Region. "; and
" Recency and Character of Faulting Offshore Metropolitan San Diego, CA.", by M.P. Kennedy and E.E. Welday for the CDMG I'ap Sheet 4J, 1980, by CDMG.
Answer to Interrocatorv No. 17(c): The authors of the documents listed in 17 (b) .
Answer to Interrocatorv No. 17(d): The authors of the documents listed in 17(b).
Answer to Interrogatory No. 17 (d) (i) : The witnesses could testify concerning facts and opinions that are expressed in the documents listed in 17(b).
Answer to Interrogatory No. 17 (d) (ii) : The witnesses could testify as to the basis of the summaries, opinions, and the factual and theoretical da . 2 that are described in their reports listed in 17(b).
Answer to Interrogatory No. 17(e): The p'ublications of the documents listed in 17(b).
INTERROGATORY NO. 18:
Do.you contend that there exists geomorphic expressions or other geologic evidence on the OZD that could have resulted from 38
- ,.a..
w..
ground motion related to an earthquake on the OZD of magnitude:
M 6.57 i
(a)
(b) M 7.0?
(c) M 7.57 _ ... .
(d) M 8.07 Answer to Interrogatory Nc. 18:
(a) Yes (b) Yes (c) Yes (d) Yes INTERROGATORY NO. 19:
20(b),
If any of your answers to Interrogatories 20(a),
20 (c) or 20 (d) is yes, for each yes answer, (a) State each and every fact upon which you base this contention; 4
(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, and opinions, or testimony you base this contention; (d) Identify each and every person, expert or otherwise, the hearing before.the whom you expect to call as a witness at l
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; O d 39
+ = n -- - , - ,
r , ,-
(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; and (e) Identify each and every event upon which you base this contention.
Answer to Interrocatory No. 19: This Interrogatory refers to Inter-rogatories No. 20(a), 20(b), 20(c), and 20 (d) , and requests infor-mation about responses to those questions. However, Interrogatory No. 20 does not have an a, b, c, or d,; Therefore, the question is unintelligible and ambiguous and the Intervenors cannot answer Interrogatory No. 19 as phrased.
INTERROGATORY NO. 20:
Is it your contention that there is a postulated zone of deformation which extends from the coastal exposure of the Cristianitos Fault toward the OZD but dies out before reaching the OZD?
Answer to Interrocatory No. 20: No, Intervenors do not agree that the Cristianitos Fault Zone of Deforamtion dies out before reaching the OZD.
E TERROGATORY NO. 21:
If you do not subscribe to the contention set forth in Interrogatory No. 20, (a) State each and every fact upon which you base your disagreement with the contention; (b) Identify each and every document or communication upon which you base your disagreement with the contention; (c) Identify each and every person with knowledge of the factual basis or bases for your disagreement with the contention, or on whose writings, opinions, or testimony you base your disagreement 40 L
with the 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 your disagreement with the 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, i as well as any other grounds, for each opinion to which the witness is expected to testify.* .
Answer to Interrogatory No. 21(a) : Marine geologists from the USGS and the CDMG have performed analyses in 1980 for the NRC regarding the extension of the Cristianitos Fault Zone of Deformation. They have concluded that the Cristianitos Zone of Deformation merges with or is truncated by the Of fshore Zone of Deformation. The USGS position paper in the NRC Staff SER notes that the Cristianitos Fault as used in a restricted sense by the Applicant is one of several faults within the Cristianitos Zone of Deformation.
Answer to Interrogatory No. 21(b) : Staff SER, December-13, 1981, t
NUREG-0712; Geologic Structure Map--San Onofre Offshore, September
- 1980, prepared for the NRC by Greene and Kennedy.
Answer to Interrogatory No. 21(c) : H. Gary Greene, USGS, Menlo Park, CA. Michael P. Kennedy, CDMG, Sacramento, CA.
Answer to Interrogatory No. 21(d) : H. Gary Greene, USGS, Menlo Park, CA. - Michael P. Kennedy, CDMG, Sacramento, CA.
Answer to Interrogatory No. 21(d) (i) : _
The witnesses are expected to testify as to the substance of the' facts and opinions reported ,
41'
in documents listed in 21(b) above.
Answer to Interrogatory 21(d) (ii) : The witnesses could testify as to the factual and theoretical basis that are summarized in the documents listed in 21(b) above.
INTERROGATORY NO. 22:
Do you contend that there is .a structural relationship between the Cristianitos Fault and the OZD? If so, 4
(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 i 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.
(e) Identify each and every event upon which you base this contention.
Answer to Interrogatory No. 22: Yes, the Intervenors contend that there is a structural relationship between the Cristianitos Fault 42
and the OZD.
Answer to Interrogatory No. 22 (a) : Several different maps that have been prepared since the AEC ASLB issued the Construction Permit in 1973 indicate that there is definitely a structural relationship between the Cristianitos Fault and the OZD. Marine goelogists from the USGS and the CDMG conducted analyses in 1980, at the request of the NRC, regarding the proposed structural relationship between the Cristianitos Zone of Deforamtion (CZD) and the Newport-Inglewood-Rose Canyon Fault Zone or the OZD. They concluded that there is a structural relationship be+. ween the CZD and the OZD.
Answer to Interrogatory No. 22 (b) (1):: Staff SER, December 31, 1981, NUREG-0712; (2) Geologic Structure Map-San Onofre Offshore, September, 1980, prepared for the NRC by Greene and Kennedy; (3) The map pro-duced by the USGS and the CDMG marine geologists, a map' that was published for the Geological Society of America by the San Diego Association of Geologists, in November 1979 in a book entitled
" Earthquakes and other perils in the San Diego Region," page 22; (4) The transcript of the August 14, 1980 meeting between the NRC Staff, the USGS, and the Applicant; (5) The initial report by H.G.
Greene and M.P. Kennedy, entitled, " Review of Offshore Seismic Reflection Profiles in the Vicinity of the Cristianitos Fault, San Onofre, California," which was sent by the USGS to the NRC Staff on August 13, 1980.;-(6) The Nekton report and profiles submitted by the Applicant to the NRC Staff,1980; (7) The second report to the NRC Staff by the marine geologists from the USGS and the CDMG, entitled, " Addendum to" the report listed in No. 22 (b) (5) above.;
(8) The USGS postion pacer on SONGS 2 and 3 dated November 26, 1980, from the USGS to the NRC,; (9) The map entitled Geologic Map of 43
California compiled by Charles W. Jennings , R.G. Strand, and T.H.
Rogers, for CDMG, dated 1977; (10) The map entitled Southern Cali-fornia Offshore Area, prepared for the Proposed OCS Sale 48 ES by the Department of the Interior, dated 1975; (11) The map prepared by Michael Kennedy and Mark Legg in their report of November,1979, entitled " Faulting Offshore San Diego and Northern Baja California:.
(12) Several newspaper interviews of Gary Greene and Michael Kennedy .
published between August and October, 1980, in California.
Answer to Interrogatory No. 22 (c) : H. Gary Greene, USGS, Menlo Park, CA; Michael P. Kennedy, CDMG, Sacramento, CA; Mark R. Legg, SIO-IGPP.
Answer to Interrogatory No. 22(d): E. Gary G'reene, Michael P.
Kennedy, Mark R. Legg.
Answer to Interrogatory No. 22 (d) (i) : The witnesses are expected to testify that the substance, facts, and opinions, as expressed in the above (22.b) list of maps and documents, are accurate.
Answer to Interrogatory No. 22 (d) (ii) : The witnesses could testify as to the f actual and theoretical bases that are summarized in the maps and documents listed in 22.b above.
Answer to Interrogatorv No. 22 (e) : The publication dates of the documents and maps listed in 22.b above.
INTERROGATORY NO. 23:
At what location (s) along the OZD, do you contend there f exists a structural relationship between the OZD and the Cristianitos?
Answer to Interrogatory No. 23: 14.666 kilometers south of the l SONGS reactors, as measured along the strike of the Cristianitos Zone of Deformation, as mapped by Greene and Kennedy in the September, 1980 " Geologic Structure Map-San Onofre Offshore".
44
INTERROGATORY NO. 24:
Do you contend that the OZD extends south of *.'in 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 co-munication 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 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.
Answer to Interrogatory No. 24: Yes, the Intervenors contend that the OZD extends south of the Rose Canyon Fault Zone.
Answer to Interrocatorv No. 24 (a) : The Newport-Inglewood-Rose Canyon-Agua Blanca-San Miguel Fault System is an active component -
of the Pacific-North American Plate Boundary. Several different investigations by various geologists and seismologists in Southern California and northern Baja have suggested evidence (see documents listed in 24.b) that- the Newport-Inglewood-Rose Canyon Fault Zone 45
i .
4 continues into Baja along the Tiajuana Lineament into Miguel Fault Zone which includes at least four en echelon faults : rom north to south, the Calabasas, Vallecitos, San Miguel, and Tres Hermanos Faults. There are some data voids and areas that are
} not mapped very well, so there are some unanswered questions and more research needs to be done, but the data indicates that the structural relationship of the San Miguel' Zone to the Rose Canyon Zone is a reasonable postulation. It is quite possible that the Rose Canyon Fault Zone has a structural relationship both with the San Miguel Fault Zone and with the Coronado Banks-Agua Blanca Fault Zone offshore from northern Baja. There is strong evidence supporting the continuation of the Rose Canyon Fault Offshore to a structural relationship with the Coronado Banks-Agua Blanca Fault Zone. Kennedy and Welday (1980) have mapped three strands of the Rose Canyon Fault Zone which continue offshore to the West of the San Diego Bay, and are named the Spanish Bight Fault, the Coronado j Fault and the Silver Strand Fault. The details about these faults are discussed in their report listed in 22.b. These faults are en-echelon wrench faults and these faults appear to form a structural l relationship between the Rose Canyon Fault Zone, - and the Coronado Banks-Agua Blanca Fault Zone. They first seem to intersect offshore from the Mexican-American Border with two subparallel . northwest trending faults that constitute a major fault zone (according to Kennedy and Weld'ay) that is offshore from the onshore portion of the Rose Canyon Fault Zone, and mapped approximately 13 kilometers southwest of the tip of the Point Loma Peninsula. This fault zone is strike slip in nature and Quarternary in~ age.. It joins with-the three offshore extensi . : lof the Rose Canyon Fault and continues 46-
South to the Agua Blanca Fault. A northward continuation of the Agua Blanca Fault has been shown by Legg and Ortega (1978) and by Krause (1965). There seems to be a large clustering of seismic activity on the .%gua Blanca Fault offshore near Punta Salsipuedes.
"This cluster of epicenters is dominated by an earthquake swarm occurring in April, 1968, comprised of.four events with magnitudes between 4.0 and 4.5 and man? smaller events." (Legg, 1980). (This structural relationship between the Rose Canyon and the Agua Blanca Faults is also suggested by the NRC consultant, David Slemmons (Appendix E, NUREG-0712, SER, 12-31-80)).
Answer to Interrogatory No. 24(b): Documents: Implications of Fault Patterns of the Inner California Continental Borderland Between San Pedro and San Diego, by H.G. Greene, K.A. Bailey, S.H. Clarke, J.I. Ziony, and M.P. Kennedy; Faulting Offshore San Diego and Northern Baja California by Mark R. Legg and Michael P. Kennedy, Active and Potentially Active Faults: San Diego County and Northernmost Baja California" by R. Gordon Gastil, Ronald Kies, and Douglas J. Melius; " Seismicity and Faulting in Northern Baja
( Califorr.ia," by James N. Brune, Richard S. Simons, Cecelio Rebollar and Alfonso Reyes; " Instrumental Seismicity of the San Diego Area" by Richard S. Simons; Note. numbers 1, 2, 2, 4, and 5 were published by the San Diego Association of Geologists for the Geological Society -
of America, in November 1979,, in a nook entitled " Earthquakes and Other Perils in the San Diego Region; (6) " Seismicity and Tectonics-of the Inner Continental Borderland of Southern California and
_ Northern Baja California' Mexico" by Mark R. Legg, Master's Thesis, 1980, SIO-IGPP.
47
Implications of Fault Patterns of the Inner California Continental
- Borderland between San Pedro and San Diego, by H.G. Greene, K.A.
Bailey, S.H. Clarke, J.I. Ziony, and M.P. Kennedy Faulting Offshore San Diego and North'ern Baja California by Mark R. Legg and Michael P. Kennedy, Active and Potentially Active Faults: San Diego County and Northernmost Baja California." by R.G. Gorden Gastil, Ronald Kies, and Douglas J. Melius; " Seismicity and Faulting in Northern Baja California," by James N. Brune, Richard S. Simons, Cecello Rebollar and Alfonso Reyes; " Instrumental Seismicity of the San Diego Area," by Richard S. Simons; Note numbers 1, 2, 3, 4, and
^
5 were published by the San Diego Association of Geologists for the Geological Society of America, in November 1979, in a book entitled " Earthquakes and Other Perils in the San Diego Region."
(6) " Seismicity and Tectonics of the Inner Continental Borderland of Southern California and Northern Baja California, Mexico" by Mark R. Legg, Master's Thesis, 1980, SIO-IGPP.
J e
e 9
48
a
[-
r b
E Allen, C.R., Silver, L.T., and Stehli, F.G.,1960, The Agua Blanca fault -
A major transverse structure of northern Baja California, Mexico: Geol- t ogical Society of ~ America Bulletin, v. 71, p.357-482.
Anderson, J.G., 1979, Estimating the seismicity from geologic structure for seismic risk studies: Seismological Society of America Bulletin, ..
- v. 69, p. 135-158. ;
1 Atwater, T.,1970, Implications of plate tectonics for the Cenozoic tectonic evolution of western North America: Geological Society of America Sul- l letin, v. 81, p. 3515-3536.
Atwater, T., and Molnar, P.,1973, Relative motion of the Pacific and North American plates deduced from sea-floor spreading in the Atlantic, In- ,
dian and South Pacific Oceans, in Kovach, R.L., and Nur, A., eds., Con-ference on Tectonic Problems of the San Andreas Fault System, Proceed- I ings: Stanford University Publications in Geological Sciences, v.13 <
- p. 136-148.
Brune, J.N., Simons, R.S., Rebollar, C., and Reyes, A.,1979, Seismicity and faulting in northern Baja California, in Abbott, P.L., and Elliott, t W.J., eds., Earthquakes and Other Perils - San Diego Region: Geological '
Society of America Annual Meeting Guidebook, p.83-100.
Byerly, P.,19P, The California earthquake of November 4,1927: Seismo-logical Society of America Bulletin, v. 20, p. 53-66. ,
Clements, T., and Emery, K.0.,1947, Seismic activity and topography of the sea floor off southern California: Seismological Society of America Bulletin, v. 37, p. 309-313. i I
Crouch, J.K.,1978, Neogene tectonic evolution of the California continental borderland and western Transverse Ranges: U.S. Geological Survey Open File Report 78-606, 24 pp.
Dickinson, W.R. , and Snyder, W'.S.,1979. Geometry of triole junctions and l subducted slabs related to San Andreas transform: Journal of Geophysi-cal Research, v. 81, p. 561-572. l Ellsworth, W.L., Campbell, T.H., Hill, D.P., Page, R.A., H., Alewine, Minster,R.W..III, B. , and Hanks, T.C., Heaton, T.H., Hileman, J.A. , Kanamori, '
Whitcomb, J.H.,1973, Point Mugu, California, earthquake of 21 February, 1973, and its aftershocks: Science, v.182, p.1127-1129.
Friecan , M.E. , Whi tcomb, J .H. , Allen, C.R. , and Hileman, J. A. ,1976, Sei s-micity of the southern California region 1 January 1972 to 31 December 1974: California Institute of Technology, Division of Geological and Planetary Sciences Contribution 2734, 404 pp.
49 .
I l
Gawthrop, W.,1978, The 1927 Lcepoc. Californie earthquake: Seismological Society of America Bulletin, v. 68, p.1705-1716.
Greene, H.G. , Bailey, K.A. , Clarke, S.H. , Ziony, J. I. , and Xennedy, M.P. ,
1979, Implications of fault patterns of the inner California conti-nental borderland between San Pedro and San Diego, in Abbott, P.L.,
and Elliott, W.J., eds., Earthquakes and Other Perils - San Diego Region: Geological Society of America Annual Meeting Guidebook, p.
21-47.
Gutenberg, B., and Richter, C.F.,1944, The frequency of earthquakes in
~
California: Seismologica1 Society of America Bulletin, v. 34, p. 185-188.
Hanks, T.f.., Hileman, J.A., and Thatcher, W.,1975, Seismic moments of the larger earthquakes of the southern California region: , Geological Soci-ety r f America Bulletin, v. 86, p.1131-1139.
Hileman, J.A., Allen, C.R., and Nordquist, J.M.,1973, Seismicity of the soulhern California Region,1 January 1932 to 31 December 1912: Cali-fornia Institute of Technology, Division of Geological and Planetary Sciences Contribution 2385.
Howell, D.G., Stuart, C.J., Platt, J.P., and Hill, D.J.,1974, Possible strike-slip faulting in the southern California borderland: Geology,
- v. 2, p. 93-98.
Junger, A.,1976, Tectonics of the southern California borderland, in Howell, D.G., ed., Aspects of the Geologic History of the California Continental Borderland: American Association of Petroleum Geologists Special Publication 24, p. 486-498. .
Krause, D.C.,1965, Tectonics, bathymetry and geomagnetism of the southern continental borderland west of Baja California, Mexico: Geological Society of America Bulletin, v. 76, p. 617-650.
Kennedy, M.P., Clarke, S.H., Greene, H.G., and Legg, M.R., 1980, Recency and character of fault h- snore metropolitan San Diego, California (area 3 of 3, Point La Jolla to Mexico): California Division of Mines and Geology Map Sheet 42, in press.
Legg, M., Agnew, D., and Simons, R.,1977, Earthquake history and seismi-city of coastal San Diego County, California, '800-1976, in Kuhn, G.,
ed., Coastal Zone Geology and Related Sea-Cliff Erosion: San Dieguito
~
River to San Elijo Lagoon, San Diego County, California: San Diego County Board of Supervisors Project Study ll596-0800E-KUHN.
Legg, M.R., and Ortega, V.W.,1978, New evidence for major faulting in the inner borderland off northern Baja California, Mexico [ abs.]: ISS (American Geochysical Union transactions), v. 59, p.1134 50
'L*Q K-i -19: ;
. ' DK ;? L'-y,*8di$$&[&&(g& .Q$&&Mfk~i a
li Legg, M.R., and Kennedy, M.P.,1979 Faulting offshore San Diego and g.~
northern Baja California, in Abbott, P.L., and Elliott, W.J., eds., +
Earthquakes and Other Perils - San Diego Region: Geological Society ;e of America Annual Meeting Guidebook, p. 29-46. C S
Legg, M.R., and Wong, V.,1979, Faulting in the inner continental border- '
i land offshore northern Baja California, Mexico: Geological Society of ."
America Abstracts with Programs, v. 11, p. 464.
p.
Lomnitz, C., 1974, Global Tectonics and Earthquake Risk: Developments in my Geotectonics v. 5, Elsevier, New York, 320 pp. Y 2
Lonsdale, P.,1979, A deep-sea hydrothermal site on a strike-slip fault: i; Nature, v. 281, p. 531-534. ].;
Luyendyk, B.P., Kamerling, M.J., and Terres, R.,1980, Geometric model for M Neogene crustal rotations in southern California: Geological Society i of America Bulletin, v. 91, p. 211-217. s h
McKenzie, 0.6'., and Parker, R.L.,1967. The North Pacific: An example of $
tectonics on a sphere: Nature, v. Zi6, p. 1276-1280. g; m
McKenzie, D.P., and Morgan, W.J.,1969. Evolution of triple junctions: }i Nature, v. 224, p. 125-133. $
Minch, J.A.,1975, Transpeninsular faulting and the continental borderland: s~'
Geological Socie: of America Abstracts with Programs, v. 7. p. 350.
e and Sykes, L.,1969, Tectonics of tne Caribbean and Middle ;
Molnar, P.,
America regions from focal mechanisms and seismicity: Geological f Society of America Bulletin, v. 80, p.1639-1684, p -
Mo' ore, D.G.,1969, Reflection profiling studies of the Califo-nia conti-nental borderland: Structure and Quaternary turbidite basins: Geolo- b gical Society of America Special Paper 107, 142 pp.
{
Reichle, M.S.,1975, A seismological study of the Gulf of California:
p Sonobuoy and teleseismic observations, and tectonic interpretations:
University of California, San Diego, Ph.D. dissertation, 249 pp.
L Richter, C.F., 1958 Elementary Seismology: San Francisco, W.H. Freeman, 768 pp. ,
[
Rusnak, G.A., Fisher, R.L., and Shepard, F.P.,1964, Bathymetry and faults l
l of Gulf of California, fr. van Andel, T.H. , and Shor, G.G., Jr., eds., 4 i Marine Geology of the Gulf of California - A Symoosium, p. 59-75. -
Scholz, C. ,1968, The frequency-magnitude relation of micro-fracturing 6-in rock and its relation to earthquakes: Seismological Society of I I America Bulletin, v. 58, p. 399-415.
l i.
51 i i
. l Simons R.S.,1977, Seismicity of San Diego, 1934-1974, Seismological Society of America Bulletin, v. 67, p. 809-826.
Simons, R.S.,1979, Instrumental seismicity of the San Diego area: 1934-1978, in Abbott, P.L., and Elliott, W.J., eds., Earthquakes and Other Perils - San Diego Region: Geological Society of America Annual Meet- ;
ing Guidebook, p. 101-105. L Stauder, W.,1962 The focal mechanism of earthquakes, in Landsberg, H.E.,
and van Miegheim, J., Advances in Geophysics, v. 9: New York, Academic Press, p. 1-76.
Sykes, L.R.,1967, Mechanism of earthquakes and nature of faulting the mid-ocean ridges: Journal of Geophysical Research, v. 72, p. 2131-2153.
Thatcher, W.,1972, Regional variations of seismic source parameters in [
the northern Baja California area: Journal of Geophysical Research, '
- v. 78, p. 1549-1565.
. I Thatcher, W., and Hanks, T.C.,1973, Source parameters of southern Cali- ,
fornia earthquakes: Journal of Geophysical Research, v. 77, p. 8547-8576.
Vedder, J.G., Beyer, L.A., Junger, A., Moore, G.W., Roberts, A.E., Taylor, J.C., and Wagner, H.C.,1974, Preliminary report on the geology of the cor.tinental borderland of southern California: United States Geologi-cal Survey Miscellaneous Field Studies 624 Wilcox, R.E., Harding, T.P. , and Seeley, D.R.,1973, Basic wrench tectonics:
American Association of Petroleum Geologists Bulletin, v. 57, p. 74-96.
r l
Yeats, R.S.,1976 Extension versus strike-slip crigin of the southern California continental borderland, in Howell 0.G., ed., Aspects of the Geologic History of the California Continental Borderland: Amer-1 ican Association of Petroleum Geologists Special Publication 24, p.
455-485.
Yegulalp, T.M., and Kuo, J.T.,1974, Statistical prediction of the occur- '
rence of maximum magnitude earthquakes: Seisrological Society of America Bulletin, v. 64, p. 393-414 l
i a
52 l
l i
- w. . , _.
bi
' frj5 ~
Silver, L. T. , and Stehil , F. G. ,1960, Agua Blanca f ault - a :'n Allen, C. R.,
major transverse structure of northern Baja California, Mexico: Geological '-
$v Society of Arierica Bulletin, v. 71, p. 457-482. W
' WA
- r-Brown, L. G.,1978, Recent fault scarps along the eastern escarpment of the Sierra San Pedro Martir, Baja California
- Master's Thesis (unpub.), $.l San Olega State University. Fi k-Elliott, W. J.,1970, Gravity survey and regional geology of the San Diego embay- ' I}(-I ment, southwest San Diego County, California, In, Allison, E.
C., et al.
(eds.) Pacific Slope Geology of Northern California and Adjacent AITa- @JF Cali fornia: AAPG, SEPM, and SEG Pacific Sections Guidebook, p.10-22.
M 9.4 fs Elliott, W. J., and Hart, H. W.,1977, New evidence cone' rning age of movement "g of the La Nacion fault, southwestern San Diego Cmty, California, In, -
. fi M
Farrand, G. T. (ed.) Geology of Southwestern San Diego County, California and Northwestern Baja California: San Diego Association of Geologists S Guidebook, p. 53-60.- , nm
~
M
~s=
Evens, M.,1976, Geology of the Cerro Colorado - Cerro Jesus Maria area southeast of Tijuana: Senior Report (unpub.), San Diego State University,16 p. j 2 W Flynn, C. J.,1970, Post-bathol. thic i geology of the La Gloria-Presa Rodriguez .
Q area, Baja California, Mexico: Geological Society of America Bulletin, ;
H($
- v. 81, p.1789-1806. W Frezer, M.,1972, Geology of Valle de las Palmas:
Senior Report (unpub.), :-
O M
San Diego State University,18 p. . ]h G
} T(
G3stil, R. G., Phillips, R. P.,
and Allison, E. C.,
logic map of the State of Baja California, Mexico:
1975, Reconnaissance geo-Geological Society 7r g
C o
Americe Memoir 140, 170 p.
Gtstil , R. G. , Krummenacher, D. , and Minch, J. A. ,1979, The record of Cenozoic ,g, volcanism around the Gulf of California: Geological Society of America }
ke Bulletin (in press). 5 B.,1977, Geochemical evaluation of subsurface temperature from well %
g water in the southwest corner of San Diego County, California: Senior Harbert, Report (unpub.), San Diego State University, 23 p. d.l
. , Q.
1971, A gravity and ma;netic study of the Laguna Salada area, Baja pO Ke i n, D. L.,
California, Mexico: Master's Thesis (unpub.), San Diego State Universi ty, 103 p.
1975, Character Yl g.
Ksnnedy , M. P. , Tan, S. S. , Chapman , R. H. , and Chase , G. W. , Cala- k and recency of .aulting, San Diego metropolitan area, California: .
fornia Division of Mines and Geology Special Report 123, 33 p. t.
j.
Kern, J. P., 1973, Late Quaternary deformation of the Nestor terrace on the east 1. g.
side of Point Loma, San Diego, California, In, Ross, A. and Dowien, P. t.g (ecs.), Studies on the Geology and Geologic Hazards of the Greater San Diego p Area, California: San Diego Association of Geologists Guidebook, p. 43-45 i 1979, The Rose Canyon f aul t zone from Pt. La Jolla to Balboa Ave. ,
dies, R. P.,
San Diego: Senior Report (unpub.) , San Diego State University , 57 p. j b
e e
53
i l
. l
. i
. l I
I Liem, T. J., 1977, Late Pleistocene uaximum age of faulting, southeast flission
? Say area, San Diego, California, In, Farrand, G. T. , (ed.), Geology of Southwestern San Diego County, California and Northwestern Baja California:
San Diego Association of Geologists Guidebook, p. 61-66.
t L
', Melius, D. J.,1979, A study of the Rose Canyon and associated faults: Senior
] Rerert (unpg.), San Diego State University.
Minen, J. A.,1972, The Late Mesozoic-early Tertiary f ramework of continental sedimentation, northern Peninsular Ranges, Baja California, Mexico: Ph.D.
< dissertation (unpub.), University of California, Riverside,192 p.
Moore, G. W. , and Kennedy, M. P. ,1975, quaternary faults at San Diego Bay, California: U.S. Geological Survey Journal of Research, v. 3, p. 589-595 Peterson, G. L.,1970, Quaternary deformation of the San Diego area, southwestern California, In, Allison, E. C., et al. (eds.), Pacific Slope Geology of J'
idorthern Baja California and AdjEeE Alta California: AAPG, SEPM, and SEG Pacific Sections Guidebook, p. 10-22.
. Reyes, A. , Brune, J. N. , Barker, T., Canales, L. , Madrid, J. , Rebo11ar, J. ,
g and Mungula, L.,1975, A micro-earthcuake ' survey of the San Miguel fault
-X zone, Baja California, Mexico: Geophysical Research Letters, v. 2, p.
-t 56-59.
Scheidemann, R. C., Jr.,1975, Correlation of the Otay and Rosarito Beach formations: Senior Report (unpub.), San Diego State University.
, O]
"~ "
i.
i Shor, G., and Roberts, E. E.,1958, San Miguel, Baja California Norte, earth-quakes of February,1956: a field report: Seismological Society of
- g America Bulletin, v. 48, p.101-116.
Slyker, R. G.,1964, A gravity investigation of the western part of the La
[)'
rc
?
Jolla quadrangle, San Diego County, California: Senior Report (unpub.),
San Diego State University.
- %.q Van der Hurst, L.,1976, A map of post San Diego ' Formation vertical separation l
45 on the La Nacion fault zone, southwest Srn Disgo County: Senior Report
- .y (unpub.), San Diego State University, 24 p.
M Voorhees, B. J.,1975, Stratigraphy and structure east of La Presa Rodriguez, northwestern Baja Cglifornia, Mexico: Senior Report (unpub.), San Diego M "
.: ? State University.
{d Wiegand, P., 1970, Evidence of a San Diego Bay-Tijuana Fault: Association of l . _] ,
Engineering Geologists Balletin, v. 7, p. 107-121.
l 9?
1
-}
.y 1
1 y 54 3
! l
\
i INTERROGATORY NO. 25:
Do you contend that there is a structural relationship 1
between the Rose Canyon Fault Zone and the Vallecitos Fault in 1
Baja, California? If so, I
(a) State each and every fact upon which you base this contention; l (b) Identify each and every docurent or communication i upon which you base this contention; (c) Identify each and every persen 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, I
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 1
! information:
(1) 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 i
witness is expected to testify.
Answer to Interrogatory No. 25: Yes, the Intervenors contend that 1
I
' there is a structural relationship between the Rose Canyon Fault i
Zone and the Vallecitos Fault in Baja, California.
l Answer to Interrogatory No. 25(a): As suggested by Gordon Gastill i
et al. - 1979, and Brune et al. , L 1979, ' there are several features that l ,
are ; suggestive of the ' existence of a "Tiajuana Valley Lineament" .
~,
< 55
,.ama w g .- -=v- = -pwy w- +=m-4 .v%, , . - - - - - - -, .-eeg -.w , , - - - -wgy g.--- - we e- ,c., -w-%.-
. A First, there are northwest trending faults or fault-like features in the San Ysidro area (Kennedy, ei al. ,1975, Washburn,1979) .
Second, there are warm wells in the San Ysidro area (Herbert, 1977) and a large hot spring at Agua Caliente. Third, the northwestern trend of the Tijuana Valley is suggestive of northwest trending faulting which would be consistent with regional structures and with the Vallecitos Fault. Fourth, the differences in Eocenestratigraphy between the north and south sides of the "Tijuana Valley Lineament";
to the north are the Powar and La Jolla groups with the distinctive Powar-rhyolite clast population and to the south are the Delicias and Buenos Aires formations (Flynn, 1970) with the Las Palmas clast population (Minch, 1972). Also, to the south, basalt (circa 14 m.y.) (is interbedded with marine and non-marine Miocenestrata and to the north andesigte (circa 8 m.y.) overlies non-marine Miocene strata. No basalt occurs within the area of south o'f the lineament.
Fifth, a set of faults mapped by Flynn (1970) southwest of the lineament do not cross the lineament (Voorhees, 1975, Evans, 1976),
Scheidemann, 1976, unsubmitted MS thesis, Higley, 1979). Finally, the distribution of the Pacific boundary faults (Kennedy, et al.,
1975, Vanderhurst, 1976, Kennedy, et al., 1975, Minch,_1972) south of the lineament suggest one or more kilometers of right-lateral separation. There is evidence of Pleistocene and Holocene movements cn a variety of interconnected faults." (Gastil et al, 1979, p. 58.)
On August 19, 1978, an earthquake of approximate magnitude 3.5 occurred in an area midway between the southernmost known extension of the Rose Canyon Fault in San Diego and the northernmost' trace of the San Miguel Fault Zone in Baja, California area, the Ensenada station, and selected stations of the Cal Tech. network. The 56
locale of this event is distinguished by a sharp topographic feature trending northwest-southeast (Canon de la Presa). All available first motion data are consistent with right lateral-strike slip, Robert Washburn of San Diego State University (personal communication) has reported evidence of recent landslides in Canon de la Presa dn for strike-slip faulting in the Canon. The geological and the seismological fault between, and possibly' connecting, the Rose Canyon Fault and the San Miguel Fault Systems. (P. 90 in Earthcuakes and other Perils in the San Diego Region, in an article " Seismicity and Faulting in Northern Baja California" by Brune, Simons, Rebollar and Reyes.) .
Answer to Interrogatory 25 (b) (1) : " Seismicity and Faulting in Northern Baja California" by J.N. Brune, R.S. Sismons, Cecelio Rebollar, and Alfonso Reyes, 1979; (2) " Active and Potentially Active Faults: San Diego County and Northernmost Baja California" by R. Gordon Gastil, Ronald Kies, and Douglas J. Melius. Both (1) and (2) were published for the Geological Society of America by the San Diego Association of Geologists, in a book entitled " Earthquakes and other Perils in the San Diego Region, in November, 1979.
Answer to Interrogatory 25 (c) : The authors of the reports listed in 22.b.
Answer to Interrogatory 25 (d) : The authors of the reports listed in 22.b.
Answer to Interrogatory 25 (d) (i) : The witnesses could testify as to the basis of the facts and opinions stated in their publications.
Answer to Interrogatory 25(d) (ii) : We expect the witnesses to testify i
regarding their factual and theoretical basis and other grounds as-e 57
summarized in the documents listed in 22.b.
INTERROGATORY NO. 26:
Do you contend that there is a structural relationship between 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 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 opinions to which you expect the witness to testify; l
(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.
l Answer to Interrogatory No. 26: Yes, we contend that there is a structural relationship between the Rose Canyon Fault Zone and i
the San Miguel Fault Zone in Baja California.
Answer to Interrogatory No. 26 (a) : See 24(a) and 25(a).
Answer to Int'errogatory No. 26 (b) : See 24 (b) and 25 (b) .
Answer to Interrogatory No. 26 (c) : The authors of the reports 58
listed in 24(b) and 25(b).
Answer to Interrogatory 26 (d) : The authors of the reports listed in 24(b) and 25(b).
Answer to Interrogatory 26 (d) (i) : We expect the authors witnesses to testify regarding the substance of the facts and opinions as stated in their publications.
Answer to Interrogatory 26 '(d) (ii) :
The witnesses could testify as to the factual and theoretical basis, as well as other grounds, as summarized in the documents listed in 24(b) , 25(b), and 26(b).
INTERROGATORY NO. 27:
Do you contend that there is a relationship between the OZD and the San Andreas such that an earthquake on the San Andreas would generate an earthquake of M 6.5 or larger on the OZD and cause ground motion in excess of .67g at the SONGS 2 and 3 site? 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 infor(mtion:
(i) State the substance of the facts and opinions to 'which you expect the witness to testify; 59
(ii) Summarize the factual and theoretical basir, 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.
Answer to Interrogatory No. 27: We contend that there is a rela-tionship between the OZD and the San Andreas such that an earthquake on the San Andreas could cause an earthquake on the OZD which could cause ground motions in excess of the ground motions that SONGS 2 and 3 were designed for, that is, .67 g horizontal and .44 g vertical. That sympathetic earthquake would not nei ;;;arily have to be as large as a M 6.5.
Answer to Interrogatory No. 27 (a) : The San Onofre site is only about 57 to 60 miles from the Southern San Andreas Fault. A powerful earthquake on the San Andreas Fault similar to the 1857 earthquake (Fort Tejon) would cause " strong ground shaking (above the threshhold for causing damages) that would extend in a broad strip along the Southern San Andreas Fault System about 250 miles long and 100 miles wide." An Assessment of the Consequences
& Preparations for a Catastrophic California Earthquake, Findings and' Actions Taken prepared by FEMA. Jan. 9, 1981, p. 3.
Following the Borrego Mt. Earthquake of 1968, sympathetic faulting was discovered on several faults that were various distances away.
from the epicenter fault.
When earthquakes occur on the Southern San Andreas System, strain is shifted to the west. The OZD is part of the Plate Ecundary System which includes the San Andreas Fault and all of the parallel wrench faults extending out to the San Clemente Fault Zone. If there were a major earthquake alon,g the San Andreas Fault, then it is 60
'. t possible that there could be a major readjustment of the strain and there could be after-shocks triggered off over quite a large area region. It is possible that there could be an aftershock triggered off on the OZD. The OZD could potentially slip as a result of the readjustment of the strain.
Answer to Interrogatory No. 27 (b) : Geologic Map of California, Jennings, R.G. Strand, and T.H. Rodgers,
~
compilation by Charles W.
CDMG, 1977; Report of January ,1981, from FEMA to the California DES and CDMG and to the public and the press; "The Borrego Mountain,
- California, Earthquake of April 9,1968;" Bulletin seismological Society of America, Volume 58, 1968; " Displacements on the Imperial, Superstition Hills, and San Andreas Faults Triggered by the Borrego
- Mountain Earthquake", by J.N. Brune, C.R. Allen, M. Wyss, A. Grantz, and R.E. Wallace, In USGS Professional Paper #787, pp. 870-104 (1972);." Application of Tilt =eters as an Inertial" (May 1980 Abstracts of the AGU National Meeting) by Buckley and Kohlenberger. Testi-l many by James N. Brune to the ASLB on SONGS 2 and 3, March 15, 1973. Answer to other Interrogatories in this set explain how the OZD is a wrench fault in a parallel series, and how the OZD is part of the Plate Boundary System.
Answer to Interrogatory No. 27 (c) : The authors of the reports referenced in 27(b).
! Answer to Interrogatory No. 27 (d) : The authors of the reports i
referenced in 27(b).
Answer to Interrogatory No. 27 (d) (i) : We expect the witnesses to
.i testify regarding the substance of the facts and opinions as stated 4
in their publications.and former testimony to the AEC.
w.
61
__ ._. . . - . . . m _. . _ _ _ . _. _. _ _ . _- __ _
i i
Answer to Interrogatory No. 27(d) (ii) : We expect the witnesses to i ~
testify regarding their factual and theoretical bases, as well as j other grounds, as summarized in the documents listed in 27(b) .
i Answer to Interrogatory No. 27 (e) : The 1857 Fort Tejon Earthquake i
on the San Andreas Fault, the April 9, 1968, Borrego Mountain Earthquake, the fourt to six million years that the Plate Boundary has been causing major earthquakes and sympathetic faulting in Southern California.
! INTERROGATORY NO. 28:
Do you admit that .67 g is the proper design acceleration value for SONGS 2 and 37 Answer to Interrogatory No. 28: No, we do not admit that.
i I
\ ,
- i h
C I-f e
62
_ _ _ . _ _ - _ - . _2 . -_- - - - - - _ - - _ _ _ _ - - . _ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ . . _ _ -
Answer to Interrogatory No. 29: Intervenors contend that the proper design acceleration values for SONGS 2 and 3 should be between 1.5 y; 4 p gu .c a us t.: 2 y ,
- 1;ie -
and 2.0 g-with peaks above 2.9 'possible y for the vertical accelera-tions. For the horizontal design acceleration, we contend that the SONGS 2 and 3 should be designed for an effective acceleration of between 2.0 g and 3.0 g for horizontal ground motions with possible peak accelerations between 3.0 g and 5.0 g.
Answer to Interrogatory No. 29 (a) : Earthquakes t.s s=all as Magnitude 4.5 can produce horizontal ground accelerations as large as 0.5 g (e.g. the 1975 Oroville quake of Magnitude 4.3 produced a .47 gd.)
Tnus, the Applicants' claim that a Magnitude 6.5 quake would create maxi =um horizontal accelerations of .57 g is incorrect. A Magnitude 4.9 quake in 1978 al 99 the Imperial Fault in Northern Baja, caused a .6 g horizontal acceleration at a distance of 11 to 15 kile=eters from the epicenter. The Melindy Ranch quake in Bear Valley in 1972 was a Magnitude 4.7 and created horizontal accelerations of
,69 g. A Magnitude 5.5 quake in Iran in 1977 caused horizontal accelerations of .95 g and vertical acceleratiens of 1.08 g. The Pacoima Dam records from the 1971 San Fernando earthquake recorded horizontal accelerations of 1.25 g from a Magnitude 6.4 quake..
The 1976 Gazli earthquake, Magnitude 7.1, caused horizontal accelerations of .75 g and vertical acceleratiens of 1.3 g. The Imperial Valley quake of October, 1979, produced data recoridng a vertical acceleration of 1.78 g and horizental accelerations of
.8 g. Because the Richter scale is logarithmic, a Magnitude 6.5 earthquake releases approximately 1,000 times as much energy as does a Magnitude 4.5 quake. A Magnitude-7.5 releases 33 times as
=uch energy as a Magnitude 6.5 quake. The Applicants =aintained-63
through 1980 that the maximum credible earthquake on the OZD was a M. 6.5. Then, late in 1980, they agreed reluctantly to consider a M. 7.0. Their formula for going from M. 6.5 horizontal accelerations to M. 7.0 horizontal g values was to multiply the M. 6.5 values by one of the following ratios: 1.08, 1.10 or 1.12.
Intervenors contend that that formula is not adequate. Hanks, and Johnson, 1979, estimated that a reasonable limit to ground acceler-ations caused by sources of faulting at a source to site distance 1 of 10 kilometers would be a 1.8 g depending on the assumption that there is saturation of accelerations at a certain level. They say that quakes larger than approxi.nately 4.5 could yield g values in excess of 1.0. In their testimony and consultant's advice to the NRC ' s AC RS , Dr. M. Trifunac and Dr. E. Luco have noted that an
- " effective" acceleration level of 0.75 g has been assigned for the Diablo Canyon Reactors and that this acceleration level and the corresponding rr:ponse spectra correspond to a magnitude M. 6.5 earthquake. So if the Safe Shutdown earthquake for SONGS 2 and 3 is M. 6.5, then the "ef fective" horizontal acceleration level should be at least .75 g., not .67 g. If the maximum earthquake is going to be larger than that, and the Intervenors contend that the Safe Shutdown Earthquake should be in the range of M. 7.5 to M. 8.0, then the proper design accelcration values should be higher. The USGS Circular 672, by Page, Boore, Joyner,and Coulter, recommends the use of 1.15 g for the horizontal acceleration from a M. 7.5 quake.
Dr. James N. Brune, in testimony to the NRC-ASLB-Diablo Canyon states:
G 64
4 "For large earthquakes, (M. 7) at close distances ( 10 km), peak accelerations and velocities could be a factor of 2 greater than
.J postulated in USGS Circular 672. Uncertainty stems from both the lack of a sufficient data base and lack of knowledge about para-meters necessary for theoretical modeling. Theoretical and numer-ical calculations suggest that accelerations and velocities of 2.0 g and 200 cm/sec, respectively, are possible." (for a Magnitude 7.5 earthquake of fshore from California) . " Focusing of energy (or directivity) associated with fault propagation can lead to accelerations and velocities amplified by more than a factor of 2 in a sector of about + or - 5' from the direction of fault propagation... Constructive interference.of wave packets from discrete bursts of energy released on a fault can lead to accelera-tions and velocities more than a factor of 2 higher than observed on complex seismograms "
at azimuths where constructive interference is not maximized." . . . the possibility exists that such high stress drops could lead to unexpectedly large accelerations and velocities."
Dr. F.D. Trifunac, in an article published by the Bulletin of the Seismological Society cf America, entitled, " Preliminary Analysis of the Peaks of Strong Earthquake Ground Motion--
Dependence of Peaks on Earthquake Magnitude, Epicentral Distance, '
and Recording Site Conditions" (February, 1976) states that:
"It has been found that for an approximate 90 per cent confi-dence level the presently available data suggest that peak accel-erations, velocities, and displacements at the fault and for the frequency band between 0.07 and 25 Hz probably do not exceed about 3.0 to 5.0 g, 400 to 700 cm/sec, and 200 to 400 cm, respectively.
The logarithms of the peaks of strong ground motion seem to depend in a linear manner on earthquake magnitude only for small shocks.
For'large magnitudes this dependence disappears gradually and maximum amplitudes may be achieved for M. approximately 7.5. The
- infidence of geological conditions at the recording site appears to be insignificant for peak accelerations but becomes progressively more important for peaks of strong-motion velocity and displacement. "
(Abstract) f l Answer to Interrogatory No. 29(b): Documents and
References:
" Testimony by Dr. James N. Brune to the AC,RS on June 23, 1977; Testimony by Dr. James M. Brune to the NRC-SASLB on Diablo Canyon, November 10, 1978 and January 1979; " Geophysical Assessment of Peak Accelerations" by T.C. Hanks and D.A. Johnson, Bulletin of the Seismological Society of America, Volume 66, No. 3, pp. 959-968, June 1976; " Ground Motion Values for Use in the Seisedc Design of 65
the Trans-Alaska Pipeline System, USGS Circular 672, 1972; "A Review of the Proposed Seismic Design Criteria for Reevaluation of the Diablo Canyon Nuclear Power Plant," Report to the ACRS, October 11, 1976, by J.E. Luco; Also for ACRS: " Comments on the Proposed Seismic Design Reevaluation of the Diablo Canyon Nuclear Power Plant," oy J.E. Luco; " Review of the Seismic Evaluation for the
! Postulated 7.5M Hosgri Ear'thquake, Units I and 2, Diablo Canyon Site" by J.E. Luco, A Report to the ACRS, NRC, May 30, 1978; A September 22, 1978 report to the NRC's ACRS by J.E. Luco which included his " Comments on the ACRS Subcommittee Meetings of June 14-15 and July 6-7, 1978, regarding the Diablo Canyon Nuclear Power Plant."; " Correlations of Peak Acceleration, Velocity and Dis-placement with Earthquake Magnitude, Distance and Site Conditions" by M.D. Trifunac and A.G. Brady, in Earthquake Engineering and Structural Dynamics, Volume 4, p. 455-471, 1976; " Preliminary Analysis of the Peaks of Strong Earthquake Ground Motion--Dependence of Peaks on Earthquake Magnitude, Epic 3ntral Distance, and Recording Site Conditions: by M.D. Trifunac, in the Bulletin of the Seismolo-qical Society of America, Volume 66, No. 1, pp. 189-219, Feb ruary ,
1976; " Comments and Recommendations for the Proposed Seismic Design Criteria for the reevaluation of the Diablo Canyon Site" by M.D.
l Trifunac, Prepared for the NRC's ACRS, November 11, 1976.
l Answer to Interrogatory No. 29 (c) : The authors of the reports and testimony listed in 29 (b) .
l Answer to Interrogatory No. 29 (d) : The authors of the reports and l testimony listed .in 29 (n) .
Answer to Int'errogatory No. 29 (d) (i) : The witnesses may testify _
as to the substance of the facts and opinions as stared in the i
66
I .
i .
documents and testimony to the NRC, ACRS, and ASLB as listed in 29(b).
Answer to Interrogatory No. 29 (d) (ii) : Thewktnessesmaytestify regarding the factual and theoretical bases, as well as other grounds, as they have summarized in the documents and testimony to the NRC, ACRS, and ASLB as listed in 29 (b) .
i e
9 D
4 67
4 INTERROGATORY NO. 30:
Do you disagree that the likelihood of ground displacement within the SONGS 2 and 3 site is negligible?
Answer to Interrogatory No. 30: Yes, the Intervenors disagree with the statement that the likelihood of ground displacements within the SONGS 2 and 3 site is negligible.
INTERROGATORY NO. 31:
- Do you contend that there is a_ likelihood of ground dis-placement within the plant site? 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:
(i) State the substance of the facts and opinions to which you expect the witness to t,estify; (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 co'ntention. ,
i 68
a..
Answer to Interrogatory No. 31: Yes, the Intervenors contend that there is a likelihood of ground displacement within the plant site.
The SONGS 2 mui 3 plant site Answer to Interrogatory No. 31(a) :
The is located within the Cristianitos Fault Zone of Deformation. .
Zone of Deformation is structurally related to ~.
Cristianitos Fault the OZD or Santa Monica to Baja Fault Zone which is active and The Cristianitos Fault capable of a magnitude 7.5 to 8 earthquake.
Zone of Deformation could experience sympathetic faulting and after-shock faulting during and following a major magnitude 7.0 to 8.0 quake on the OZD, which could trigger ground displacements on "The Type A shear zones which occur in four the strands of the CZD.
principal strands, converge northerly in the site area and completely Their northerly and southerly extent has not traverse the site.
been determined.
Six strands of the Type B shears are exposed in Where the site.
These continue beyond the site to the northwest.
The the two sets of shear zones intersect, r ich of fsets the other.
sense of displacement is consistently lef t lateral for the Type A shears and right lateral for the Type B shears, indicating the development of a conjugate set of fractures." (from the NRC Staf f Safety Evaluation of the Geologic Features at the Site of SONGS, July 8, 1975).
I In addition, a future earthquake on the Newport-Inglewood I
l OZD is expected to_ have characteristics similar to the 1933 lateral earthquake which caused ground damages, liquefaction, spreading, differential subsidences, and ground displacements over a length of 50 km along the trend of the zone and 15 km to either a major quake - on the side. Since ' SONGS is only 7 km f rom the OZD, OZD could be reasonably expected to cause ground displacements at l
69
the site.
Answer to Interrogatory No. 31(b) : NRC SER, NUREG-0712, 12-31-81; NRC Staff Safety Evaluation of 'the Geo".ogic Features at the site of the SONGS, July 8, 1975; USGS Open-File Report 81-115, 1981; The two Greene and Kennedy reports to the NRC, 1980; the series of meetings held between the Applicants and the NRC Staff and the USGS during 1980 regarding the structural relationship of the CZD cnd the OZD; the USGS position paper on SONGS; the " Geologic Structure Map-San Onofre Offshore," September,1980, by Greene and Kennedy; the references cited in Answer No. 27(b); all of the reports by Fugro, . consultants to the Applicants, during 1974, 1975 and 1076, regarding the A, B, C, and D features at the SONGS site.
O e
70
Answer to Interrogatory 31 (c) : The authors of the reports listed in 31(b). ,
Answer to Interrogatory 31 (d) : The authors of the reports listed in 31 (d) (b) .
Answer to Interrogatory 31 (d) (i) : The witnesses could testify to the basis of the facts and opinions 'as stated in their published documents and cc=munications listed in 31 (b).
Answer to Interrogatory 31 (d) (ii) : The witnessses could testify to the factual and theoretical basis, as well as other grounds, for each opinion summarized in the-documents and com-munications listed in 31 (b).
Answer to Interrogartory 31 (e) : The events upon which this contention is based are noted in the documents listed in 31 (b) .
INTERROGARTORY NO. 32:
Have you contractcd with or contaced any consultants to analyze any aspect of the InpeyIal Valley earthquake of October 15, 1979? If so, (a) Identify each and every consultant who has conducted such analysis on your behalf;
.(b) Identify each and every doeurent, writing, or f communication arising out of the analysis performed by your consultants on the Imperial Valley earthquake which you expect i
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 from f
l .
their analysis of the Imperial Valley earthquake, 71 i
l
. 1
. 1 (1) with respect to SONGS 2 and 3 (2) with respect to any other nuclear power plant
[
site in California; and I (d) Summarize the factual and theoretical bases, as well as any other grounds, upon which your consultants base their findings and/or conclusions on the Imperial Valley earthquake, (1) with respect to SONGS 2 and 3 (2) with respect to any other nuclear power plant site in California.
Answer to Interrogatory 32: Yes, we have contacted Dr. James N. Brune, Professor of Geophysics, UCSD, SIO-IGPP, La Jolla, CA, to share with us his understandings and independent studies of the Imperial Valley Earthquake of October 15, 1979; we have contacted Dr. Chris Buckley, Professor of Geophysics, California State University at Fullerton, Department of Earth S'ciences, to share with us his independent research on the Imperial Valley Earthquake, IV 79.
Answer to Interrogatory 32(a) : Intervenors have not contracted with any consultants to specificly conduct analyses of the Imperial Valley earthquake of October 15, 1979, specificly on our behalf or specificly for these Proceedings.
Answer to Interrogatory 32 (b) : Dr. Brune has prepared testimony and affadavits and participated in cross-examination which-testimony has been recorded in transcripts on behalf of the Intervenors and the Governor of California for the Proceedings of the ASLB and Appeals Board of the NRC regarding the Diablo Canyon Dockets Nos.-50-275 0.L. and 50-323 0.L. regarding the l
72
_ _ -_m
i Various aspects of the Imperial Valley quake of 1979. Dr. Brune has also independently published a report entitled "Straig Motion Data Recorded in Mexico during the October 15 Main 6 hock" (by ;
J.N. Brune, Jorge Prinece, Frank L. Vernon III, Enrique Mena, and Richard S. Simons), Dr. Brune is preparing other documents to be published in the future' on the IV 79 quake. This work is not being sponsored or contracted for b'y the Intervenors, but we do expect to submit the documents . for the SONGS hearings.
One of Dr. Brune's future reports will be published by the USGS.
Dr Chris Buckley was the principal author in a report by Buckely and Kohlenberger, published in the May 1980 AGU National Meeting Abstracts, entitled " Application of Tiltmeters as an Inertial."
Answer to Interrogatory 32 (c) 1: The documents written thus far by these consultants are not specificly with respect to SONGS 2 and 3.
Answer to Interrogatory 32 (c) 2: Dr. Brune has submitted f
l tes,timony to the ASLB and Appeals Board of the NRC regarding the implications of the IV 79 data'to the Diablo Canyon l
reactors and the summaries and substance of his~ findings and or conclusions are a matter of public record'and and available
~
to the Applicants under the NRC Docket No. 50-275 0.L. and l
50-323 0.L. . .
Answer to Interrogatory 32 (d) 1: same as 32 (c) 1.
Answer to Interrogatory 32 (d) 2: The testimony of Dr. Brune l
in the Diablo Canyon Dockets is available to the Applicants.and in fact their consultants and staff were present at-the Appeals i
73 t-
d Board hearing in San Luis Obispo during Octcber 1980 when Dr.
Brune was testifying and being cross-examined.
4 INTERROGATORY NO. 33:
At the present time do you contend that the seismic design basis for SONGS Units 2 and 3 is inadequate to protect the public health and safety and does not comply with 10 C.F.R.,
Part 100,-Appendix A, in that the earthquake which could cause the maximum vibratory ground motion has not been assigned as the safe shutdown earthquake? If so, (a) State each and every fact arising after July 28, 1978 upon which you base this contention; (b) Identify each and every document or communication that has come to your attention, subsequent to July 28, 1978 upon which you base this. contention; (c) Identify each and every seismic event or geologic evidence subsequent to July 28, 1978 upon which you base this contention; (d) Identify each and every person with knowledge of the factual basis or-bases for this contention or on whose wri' tings, opinions , or testimony you base this contention that you did not identify in your response to Interrogatory No. 1, Intervenor, FOE et al. answers to Interrogatories propounded by Southern California Edison, July 28, 1,978.
(e) Identify each and every person whom you expect to call as witness, expert or otherwise, at the hearing on this contention before the Atomic Safety and Licensing Board, and as to each potential witness so identified, provide the following information: ,
74
(i) State the precise subject matter on which the witness is expected to testify ,
(ii) State the substance of the facts and opinions to which you expect the witness to testify, and, (iii) Summarize the factual and theoretical bases as well as any other grounds, for'each opinion to which the witness is expected to testify.
Answer to Interrogatory 33: Yes, Intervenors do contend that the seismic design basis for SONGS Units 2 and 3 is inadequate to protect the public health and safety and does not comply with 10 CFR, Part 100, Appendix, A, in that the earthquake which could cause the maxumum vibratory ground motion has not been assigned as the safe shutdown earthquake.
Answer to Interrogatory 33 (a) : By this response intervenors incorporate their answers as set forth in responses 1-33 as though fully set forth and further answer that SONGS 2 and 3 reactors have been designed under the assumption by the Applicant, until 1980, that the maximun credible earthquake
- on the OZD near the site would be a Magnitude'6.5. as the acceptable value for the maxumum credible earthquake, and by December 31, 1980, the NRC Staff made . its position public that it thought at that time that the maximum credible earthquake should be a Magnitude 7.0. The fact is that there are t
several other estimates of the maximum credible earthquake on the OZD or the Santa Monica to Baja Zone of Deformation-which passes near the nuclear reactors at San Onofre.
75
1 There are several different methodologies for predicting these estimates of maximum credible earthquakes of the Safe Shutdown Earthquake.
(1) A " Report to Secretary of the Interior Stewart Udall" analyzed the risk to public health and safety of siting a nuclear reactor along the Newport-Inglewood Fault Zone in Southern California.
This report stated in a section entitled " Seismological Con-siderations" that "In specifying the maximum earthquake for which public safety must be assured, a' highly conservative approach has been adopted for two principal reasons: (1) the consequences of some types of serious failure in a nuclear facility must be guarded against even if the likelihood is very remote; and (2) the historic record of earthquake occurrance is so short that it cannot encompass the entire spectrum of possible events."
"In view of the mandatory conservatism, we suggest that the maximum earthquake for which public safety must be assured should be a Magnitude 8 shock on the Newport-Inglewood Fault or on one of the parallel offshore faults (Palos Verdes, San Pedro Faults). In addition, a magnitude 8.5 earthquake must be assumed on the more distant San Andreas Fault or on one of its major branches. "
At about the same time that that report was prepared for the Secretary of the Interior, a report was prepared for the . Department of the Interior and the U.S. AEC and .the Southern California Utilities, by the Bechtel Corporation, consultants to the Applicants, which was also analyzing the Seismic Hazard to siting a nuclear i
reactor along the Newport-Inglewood OZD Fault Zone, which stated in a.section entitled, " Seismic Design Criteria": "The design should
- be such that there is no loss of function of the nuclear systems vital to public safety in the event of a local earthquake of mag-nitude 7.5 cr from an earthquake of magnitude 8.5 on a distant great fault."
Intervenors interpret this statement to mean -that the Safe .
Shutdown Earthquake for a nuclear reactor sited near the OZD should i ~be a magnitude 7.5 on the Newport-Inglewood-OZD Fault Zone.
More.recently, in late January, 1981, the USGS, in cooperation
- j. 76
with the efforts by the State of California and another federal agency, FEMA, has published the Open File Report 81-115, " Scenarios of Possible Earthquakes Affecting Major Population Centers, with Estimates of Intensity and Ground Shaking. "
In this .USGS report and in a companion report by FEMA for federal, state, regional and local gove,rnment emergency response planning agencies, the USGS states that "An earthquake of magnitude 7.5 can be expected to be produced by a 110 kilometer long rupture along the Newport-Inglewood Fault Zone. The 110 kilometer length i
would integrate both onshore and-offshore reaches of the fault zone."
In a section entitled ." Quantitative Ground Motions" .this new USGS report states:
l "In analyzing'the response of individual structures to earth-quakes, engineers typically characterize ground shaking in terms of -
peak recorded motions or of response spectra, either scaled.from peak-motion parameters or calculated directly from ground motion l records. Instrumental strong motion records have now been obtained from many earthquakes. Most of the records, however, are from M S and M 6 earthquakes and at distances beyond which' shaking causes significant damage to structures. Thus, the existing ' instrumental data provide limited guidance in assessing the level, nature, and variability of damaging ground shaking that might be expected close l
to the fault in a M 7 or M 8 earthquake.
l Instrumental records obtained from earthquakes smaller than M 7 during the last decade demonstrate that ground motion close to a fault that slips during an earthquake 'is .more severe than had been l
generally assumed. Four earthquake sequences in California'during the past-year have nearly doubled the data base'for M 5 and M 6 earthquakes. Accordingly, it has been necessary to revise peak.
ground motion estimates as a function of distance and corresponding i estimates of the procedures for designing ' earthquake resistant-
! structures."
i l
On the basis of these reports from the - USGS and the . Department I ..
l of Interior, and as further set forth in these interrogatories, the f
Intervenors contend that the - seismic design basis for SONGS Units l
- 2~and 3 is inadequate to protect the public health and safety and l.
i l +
77
4 does not comply with 10 CFR, Part 100, Appendix A, in that the earth-quake which could cause the maximum vibratory ground motion has not been assigned as the safe shutdown earthquake.
In addition to the above cited reports, cther information points to the fact that the Applicants have not designed for the maximum credible or Safe Shutdown Earthquake at San Onofre. In the summer of 1978, consultants to the California Coastal Commission concluded that the OZD Newport-Inglewood Fault Zone is capable of generating a magnitude 7.25 earthquake offshore from Camp Pendleton about five miles south of San Onofre.
Other calculations of the maximum credible earthquake on the OZD-Santa Monica to Baja Zone of Deformation, predict earthquakes ranging from Magnitude 7.2 to Magnitudes in excess of 8.1, based on the potential length of ruptures, at the lengths 75 kilometers to 90 kilometers.
In addition, data from the Imperial Valley Earthquake of October 15, 1979, indicates that the seismic design basis for SONGS 2 and 3 for the vertical ground accelerations are totally inadequate.
SONGS 2 and 3 were designed for a .44g vertical acceleration, based-
! on the assumption that the vertical accelerations would never exceed 2/3 of the horizontal accelerations. This assumption has been proven wrong during several recent earLhquakes, including the Victoria l
earthquake of June, 1980 in Baja, where the vertical accelerations exceeded 1.0g se'veral' times. During.the IV 79 quake, the vertical accelerations reached a record 1.78 g and exceeded the horizontal accelerations on many of the records that were obtained by the USGS, CDMG, Cal Tech, Scripps and CICESE.
I 78
New earthquake data obtained since July 28, 1978, brings into doubt many of the assumptions that the NRC and the Applicants have depended on in evaluating the seismic design bases for SONGS 2 and 3.
In addition to the above cited reasons for the Intervenors seismic contentions, everything that has been stated in our Responses to the Interrogatories One. through Thirty-Two in this set of Responses applies to this contention.
In addition, because of the new data and concepts recently pub-lished by the USGS in January 1981, the Intervenors are planning to undertake a new and more detailed analysis of the inadequacies of the seismic design bases for SONGS' 2 and 3'.
Under our continuing obligation to update responses, we will keep you informed and updated when we have new reports and results from our new analyses.
Answer to Interrogatory No. 33 (b) : All documents and data that have been produced by the NRC, USGS, CDMG, Cal Tech, Scripps, CICESE other university scientists and consultants to the Applicants at San Onofre and at Diablo Canyon as a result of the Imperial Valley Earthquake of October 15, 1979, including documents that are now i
in preparation by these agencies.
All documents listed in Intervenors Responses to Applicants Interrogatories One through Thirty-Two in this current set of Responses.
All testimony submitted in writing and in transcripts from meetings and hearings since July 28, 1978, in the Diablo Canyon-Nuclear Reactors Proceedings, Docket Nos. 50-275 0.L. and 50-323 0.L.,
including but not limited to testimony submitted in 1978, 1979, and 1980 and 1981 by the following experts: Dr. James N. Brune, Dr.
Enrique Luco, Dr. M.D. Trifunac, Dr. Gerald Frazier, Dr. J.G. Anderson, 79
and Dr. Steve Day. Intervenors are aware that the Applicants had consultants and staff persons who attended most, and perhaps all, of these meetings and hearings and thus have access to the information and documents contained and rnferenced herein.
All documents produced by the TERA-DELTA consultants for the Applicants in regards to the Seismic Hazards at SONGS One.
And the following publications:
"How much is Too much when the Earth Quakes?" Science Magazine, Volume 209, p. 1004, August, 1980.
" Estimation of Ground Motion Parameters," USGS Circular 795;
" Peak Acceleration from Strong Motion. Records: A Postscript" by Boore and Porcella, December 1980, Bulletin of the Seismological Society of America." " Processed Data from the Strong Motion Records of the Santa Barbara Earthquake of August 13, 1978, CDMG Special Report 144; " Engineering Features of the Santa Barbara Earthquake of August 13, 1978, by Miller and Felszeghy, published by EERI, December 1978; "Geotechnical Evaluation of Pctential Isl'and and -
Offshore California LNG Import Terminal Sites" by Woodward-Clyde Consultants, July,1978, Prepared for the California Coastal Com-mission; " Strong Ground Motion N.S.F. Seminar-Workshop" published by Cal Tech 1978; " Application of Seismic Risk Procet .2res to Problems in Microzonation" by J.G. Anderson and M.D. Trifunac; " Estimating the Seismicity from Geological Structures for Seismic Risk Studies" by J.G. Anderson, February,1979; Bulletin of the Seismological Society of America; " Uniform Risk' Absolute Acceleration Spectra for the Diablo Canyon Site, California," by J.G. Anderson and M.D.
Trifunac, December 30, 1976; " Consistency of Probabilistic Seismic Risk Methods" by J.G. Anderson; "A Comment on the Relationship between 80 t
Earthquake Magnitude and Rupture Length" by J.G. Anderson, in Earthquake Notes , Vol. 50, No.2, 1979; " Regression Analysis of Earthquake Magnitude and Surface Fault Lengths using the 1970 Data of Bonilla and Buchanan" USGS Open File Report 77-614; "Aseismic Design Implications of near-fault San Fernando Earthquake records" by Hertero, Mahin and Herrera, Earthquake Engineering and Structural Dynamics, 1978. "The Guadalupe Victoria Strong Motion Record from the Near Field of the June 9, 1980, Northern Baja California Earth-quake" by R.S. Simons, J.N. Brune, and J.G. Anderson, IGPP-SIO, and J. Prince and E. Mena, Institute of Engineering, Universidad Nacional Autonoma de Mexico, Mexico City, Mexico, 1981; "A review of*
Geological Effects and Damage Distribr. tion of the June 9, 1980 Victoria Earthquake" by F. Suarez, J. Gonzalez, and D. Chavez, Centro de Investigaciones Cientificas y de Educations, Ensenada, Baja, Mexico, and K. Sieh Seismological Lab, Cal Tech; and W. Siders, IGPP, UC Riverside; " Main Event and Aftershock Distribution of the
^
June 9, 1980 Northern Baja California, Mexico (" Victoria") Earthquake, by V. Wong, J. Frez (CICESE) and M. Reichle and R. Simons, IGPP, SIO, UCSD, La Jolla, CA 92093; USGS Open-File Report 81-115, 1981.
"The Problems of Uncertainties in the Use of Seismic Risk Procedures" by Donovan and Bornstein, ASCE Fall Convention, 1977, EE77-4; "The Greenville Earthquake Sequence of January, 1980, California," by Bolt, McEvilly, and Uhrhammer, UC Berkeley, February, 1980; " Abstracts with Programs" of the 1979 annual meetings of the Geological Society of America in San Diego; the publications of abstracts from the 1978, 1979, and 1980 meetings of the American Geophysical Union, as published in the AGU magazine EDS.; " Environmental Geology of Orange County",
CDMG open file report 79-8 LA, by Morton, Miller, Evans, Fife, Green, Felder and Wellday.
81.
i
" Relationship between Seismicity and Geologic Structure in the St. Amand, C.F. Richter, Southern California Region" by C.R. Allen, P.
and J.M. Nordquist published in the Bulletin of the seismological California Society of America, Volume 55, No. 4, pp. 753-797.
Quake by Larry L. Meyer with a foreword by Senator Alan Cranston, published by Sherbourne Press, Nashville. Tennessee, 1978; Earthquake Country, How, Why and Where Earthquakes Strike in California by Robert Iacopi, published by Sunset Books and Lane Books, Menlo Park, CA. , with a Foreword by Dr. Charles Richter, September,1971; Reading and Interpreting Strong Motion Accelerograms by'D.E. Hudson published by the Earthquake Engineering Research Institute; Strong Motion Earthquake Instrument Arrays published by the International D.
Association for Earthquake Engineering, May, 1978, edited by W.
Iwan; Peace of Mind in Earthquake Country _ by Peter'Yanev, with Foreword by Dr. Charles Richter, by Chronicle Books, San Francisco, 1977; and Siting Energy Facilities by Ralph L. Keeney, Woodward-
" Application Clyde Consultants, 1980, published by the Academic Press; of linear statistical models of earthquake magnitude versus fault length in estimating maximum expectable earthquakes," by Robert K.
l I
Mark, USGS, Geology. v. 5, p. 464-466, August 1977; Atomic Power l
Present, and Future, a Plants and Earthquake in California, Past, Pering, T. Collins, R. Engle, Report to State Government, 1976, by K.
Elements of
! a Honea and P. St. Amand; Policies for' Seismic Safety:
a State Government Program, by Stanley Scott published by Institute of Governmental Studies, University of Cal. , Berkeley,1979.
e 82 1
i i .,
" Newport-Inglewood Structural Zone",
CDMG, Special Report 114; " Seismicity, Tectonics and Seismic Hazards in Baja California , " Brune, Simons, Reichel. " Recency of Faulting in the Greater San Diego Anub Ziony, USGS; " Late Quaternary Deformation of the Nestor Terrace on the East side of Point Loma" by J.P. Kern, San Diego State University, Department of Geology.
All Documents listed in Inte'rvenors Responses to Applicants Inter-rogatories Set No. 1, in 1978; All Documents listed in Intervenors Interrogatories to Applicants which were served by mail on Applicants on August 11, 1980.
Answer to Interrogatory No. 33 (c) : Angust 13, 1978, Santa Barbar'a Earthquake; August, 1979, Coyote Lake Earthquake, California; October 15, 1979, Imperial Valley Earthquake and aftershocks; January 24 and 27, 1980, Livermore Valley Earthquakes; May, 1980, Mammoth Lakes Earthquakes; 1980 and 1981 Siesmic Activity associated with Volcanoes from Mt. 'St. Helens in Washington to Mt. Shasta in California; the June, 1980 Victoria Quake in Baja California; 1980 earthquake, magnitude 7+ near Eureka California Offshore, 1979 and 1980 earthquakes offshore from LA..
Answer to Interrocatory No. 33 (d) : These persons with knowledge of
! the factual basis for this contention or on whose writings, - opinions l
l or testimony Intervenors base this contention that were not I identified in 1978, are' identifed in *.his Set of Answers as authors of the documents that have been referenced herein.
i Answer to Interrogatory No. 33(e) : Intervenors expect to call Dr. James N. .Brune, Professor of Geophysics, Scripps Institute of Oceanography, Institute of Planetary Physics _ (SIO-IGPs) , University of California at San Diego (UCSD); Richard Simons, ' Seismologist at 83
at SIO-IGPP, UCSD; Dr. Chris Buckley, Professor of Geophysics, California State University at Fullerton; Dr. M. P. Kennedy, Senior Marine Geologist of the California Division of Mines and Geology, 1416 9th St., Sacramento, CA 95814. (In addition, we may make arrangements for other expert witnesses in the future, and we will update this answer when we 'have that information)
Answer to Interrogatory No. 33 (e) (i) : (1) Dr. James Brune will testify regarding ground motions that should be considered in deciding on the proper seismic design basis for SONGS 2 and 3, including his concepts about directivity and seismic focusing, and his analyses of the Imperial Valley Earthquake. (2) Richard Simons will testify according to his knowledge and publications and studies of Seismicity in the Southern California and Baja Calif-ornia Records. Dr. Chris Buckley will testify as to-his understandings of the geophysics of the Southern California region, and as to his studies of seismic events in Southern California including his recent analysis of the transfer of strain following the Imperial Valley 1979 earthquake which he observed to be on an order of magnitude greater than would be expected under the currently accepted theoretical models. The actual date exceeded the predicted.
Drs. M. P. Kennedy and J. F. Davis, will testify on the i
s abject matter of the Cristianitos Zone of Deformation and the
~
structural relationship between the CZD and the OZD.
Answer to Interrogatory No. 33 (e) (ii) : The witnesses will testify as to the substance of the facts and opinions which they have already
! 84 l
's expressed in testimony to the NRC, ACRS, AS LB , and NRC Staff during' meetings and in published reports, and according to the facts and opinions which are expressed in the published documents which have been authored by these witnesses and which are referenced in this set of Answers.
Answer to Interrogatory No. 33 (e) (iii) :- The witnesses are expected to testify as to the grounds' and factual and theoretical basis which are summarized in the documents, publicationr, a transcripts and submitted testimony which each of these witnesses have authored or been responsible for and which are listed and referenced within the Answers provided in this current set of Answers to Applicants' Interrogatories.
INTERROGATORY NO. 34:
State the name and position or title of each individual who participated in responding, in whole or in part, to these interroga-tories, and (a) Specify the interrogatory answered or responded to by such individual; (b) If any individual participated in answering or responding to part of an interrogatory, specify each such part as to each individual.
Answer to Interrogatory No. 34: Responses to Interrogatories 1 through 34 were prepared by J. Glenn Barlow, research consultant for the Intervenors. The Respcnses were reviewed by a Graduate Student in Geophysics, Rick Adrian, from the SIO-IGPP at UCSD.
Various authors of documents referenced in these Responses were communicated with in regards to our interpretations of their publications. These authors include Dr. J.N. Brune, Dr. R.S. Simons, 85
. l Dr. J. Anderson, Dr. H. Greene, Dr. M.P. Kennedy, Mark Legg, Dr.
Chris Buckley, Don Fife, and Dr. G. Gastil.
O e
O 4
86
's VERIFICATION Richard J. Wharton, affirms that
- 1. That he is counsel for Intervenors, Friends of the Earth et al.,
in this proceeding.
by
- 2. That he is authorized /Intervenors F.O.E. et al., to execute and verify the foregoing "INTERVENOR, F.O.E. ET AL. , ANSWER TO INTERROGATORIES PROPOUNDED BY SOUTHERN CALIFORNIA EDISON".
. 3. That he is informed and believes and upon such information and belief affirms that the foregoing "INTERVENOR, F.O.E. ET AL.,
ANSWERS TO INTERROGATORIES I *.JPOUNDED BY SOUTHERN CALIFORNIA EDISON" is true and correct.
Dated: February 2, 1981
/ 1YM i ji RICHARD J. WHA TON O
w k
e
~
87
~
l r
CERTIFICATE OF SERVICE I hereby certify that on the 2nd day of February 1981, a j copy of the foregoing INTERVENOR, F.O.E. ET AL. ANSWERS TO INTERRO-GATORIES PROPOUNDED BY SOUTHERN CALIFORNIA EDISON, Attorney, RICHAFS J. WHARTON was served upon each of the following by depositing in the United States mail, first-class, postage prepaid, addressed as follows:
I4t .
Ivan W. Smith, Esq., Chairman a Q)C' Atomic Safety and Licensing Board W_ _
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 b.'.
- W.- *-
m g[*,.'*4 %.N E Dr. Cadet H. Hand, Jr., Member h .
Director, Bodega Marine Laboratory University of California 0
7.,y;.3,g.
D 7. yhts S
g.,: dst P.O. Box 247 Bodega Bay, CA 94923 4
to h@
d Dr. Emmeth A. Luebke Atomic Safety Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence J. Chandler, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Janice E. Kerr, Esq.
J. Calvin Simpson, Esq.
Lawrence Q. Garcia, Esq.
California Public Utilities Commission 5066 State Building San Francisco, CA 94102 David W. Gilman Robert G. Lacy San Diego Gas & Electric Company P.O. Box 1831 San Diego, CA 92112 t
James H. Drake, Vice President Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue Rosemead, CA 92770 l
T
. John R. Bury, General Counsel Charles R. Kocher, Esq.
James A. Beoletto, Esq.
Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue Rosemead, CA 91770 Alan R. Watts, Esq.
Rourke & Woodruff California First National Bank Building 1055 North Main Street, Suite 1020 Santa Ana, CA 92701 Mrs. Lynn Harris Hicks GUARD 3908 Calle Ariana San Clemente, CA 92672 Mr. Lloyd von Haden '
2089 Foothill Drive Vista, CA 92083 ,
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 David R. Pigott, Esq.
Chickering and Gregory Counsel for San Diego Gas and Electric Company and Southern California Edison Company .
Three Embarcadero Center, 23rd Floor San Francisco, CA 94112 and 2501 M Street N.W.
Suite 560 Washington, D.C. 20037 Phyllis M. Gallagher 1695 West Crescent, Avenue Suite 222 Anaheim, CA 92801-Dated: February 2,-1981 '
RICHARD J. W ARTON, Attorney for Interve FRIENDS OF THE EARTH, ET AL.
1