ML20039B758

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Response to ASLB 811210 Order,Commenting on Earthquake Swarm.Applicants' Repts Should Not Be Included in Record. Repts Being Reviewed to Determine If Cause Exists to Reopen Record.Proof of Svc Encl
ML20039B758
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 12/21/1981
From: Pigott D
ORRICK, HERRINGTON & SUTCLIFFE, SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO.
To:
References
ISSUANCES-OL, NUDOCS 8112230526
Download: ML20039B758 (29)


Text

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US?M UNITED STATES OF8 AMERICA NUCLEAR REGULATOR C SI N BEFORE THE ATOMIC SAFETY 0AND(LICEN5i'G' N BOARD unai. . .

In the Matter of ) Docket'Nos. 50-361 OL

) 50-362 OL SOUTHERN CALIFORNIA )

EDISON COMPANY, ET AL. )

)

~(San Onofre Nuclear Generating )

. Station, Units 2 and 3.)- )

-~ ) & AQ, e:9 '

k APPLICANTS' RESPONSE TO BOARD ORDER 2 TIO l REQUESTING COMMENT ON EARTHQUAKE SWAR! ; g{,GS ,y .

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  • g d(D DATED: December 21, 1981. y DAVID R. PIGOTT EDWAPD.B. ROGIN SAMUEL B.-CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 600 Montgomery Street San Francisco,_ California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P.O. Box 800-2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1900 Attorneys for Applicants Southern California Edison Company and San Diego Gas _& Electric Company D503s g2%%f0 G

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DOLKETEC U%9C DAVID R. PIGOTT -

EDWARD B. ROGIN '81 DEC 22 All:25 SAMUEL B. CASEY JOHN A.-MENDEZ ~gg y Of ORRICK, HERRINGTON & SUTCLIFFE g.g gggyy jyg i serv!CE A Professional Corporation BRANCH 600 Montgomery Street San Francisco, California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P.O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1900 Attorneys for Applicants.

Southern California Edison Company and San Diego Gas & Electric Company l UNITED STATES OF AMERICA l

l NUCLEAR REGULATOPY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-361 OL

) 50-362 OL SOUTHERN CALIFORNIA )

EDISON COMPANY, ET AL. ) APPLICANTS' RESPONSE

) TO BOARD ORDER (San Onofre Nuclear Generating ) REQUESTING COMMENTS ON Station, Units 2 and 3.) ) EARTHQUAKE SWARM

)

By Order dated December 10, 1981 the Atomic Safety and Licensing Board (" Board") in the above-captioned docket called for comments concerning a swarm of earthquakes that occurred south of the San Onofre site on November 6-9, 1981.

Additionaly, the Board solicited comments related to Applicants' submittal of November 25, 1981 addre'ssing the

J concerns of Mr. D. W. Phifer. Applicants' Southern California

Edison Company,-San Diego Gas-& Electric Company, City of

. Anaheim and City of Riverside hereby respond to the Board's request for comments.

~

1. Applicants Reports Should Not Be Included -

in The-Record.

The Board.has questioned whether Applicants' November 18 and November 30, 1981 reports concerning the earthquake swarm should be included in the record on seismic.

issues. Applicants do not consider such a procedure to be necessary. There is no question that the reports are before.

the Board and are being considered. Such is reflected by the Board's Order of December 10, 1981. The parties' responses and.the Board's ultimate determination as to whether there is-good cause to reopen the hearing will reflect further that the earthquakes have been considered. If a hearing is required, the record will be reopened and supplemented.as necessary, no doubt including Applicants' reports.

~

j In the absence of a reopening of the hearing, no

purpose is served by opening the record to include Applicants' reports. The reports are being reviewed by the s

Board in the context of whether good cause exists for reopening the hearing. Assuming the answer is negative, the

,. docket will clearly reflect that the reports were considered, but determined not to constitute good cause for a reopening.

A. reopening of the record solely to include the reports could i

2 i.

. .. ~,_ - .. _ .- , _ . . _ _ . , , . . . _ . . , . . . _ , . , _

be construed as adding evidence to*the record without 4

according the due process right of cross-examination.

Applicants submit that the issue can be considered and determined without a reopening of the record and without risking procedural error.

2. Impact of Swarm on Proposed Findings of Fact and Conclusions of Law Applicants have reviewed the following documents and have found the following proposed Findings of Fact that pertain to or could be affected by consideration of the geology and seismology of the November 6-9, 1981 earthquake swarm:

(a) Applicants' Proposed Findings of Fact and Conclusions of Law on Geology / Seismology Issues (September 3, 1981).

Findings of Fact: 105-122, 124-126, 134-135, 178, 475-479, 481, 483, 487-488, 491-498, 502, 504-507, 559-568.

(b) NRC Staff's Proposed Findingslof Fact and Conclusions of Law in the form of a Proposed Initial Decision (October 9, 1981).

Findings of Fact: 34, 36,. 39, 96-99, 172-179, 260-266, 268-270, 275-277.

Applicants have reviewed "Intervenors Carstens, et al. Findings of Fact and Conclusions of Law on Geology / Seismology Issues" (September 23, 1981) and have not 3

found any proposed findings de'aling with microearthquakes in the region'of San Onofre. Applicants have also reviewed Intervenors' findings with respect'to their proposed structural relationship between-the OZD and CZD. . Applicants a

do not believe Intervenors' findings.are affected by the-occurrence of the swarm.

The findings listed above are.those which may be-i considered relevant to the swarm. The findings indicate that Applicants and'NRC Staff-anticipate:small. earthquakes will occur throughout the region on a continuing basis. -Neither i

the occurrence of these events nor the data collected controverts _the extensive geologic and seismic evidence currently before the Board.

.As a result of reviewing both Applicants' and NRC

' Staff's proposed findings of fact, it is the Applicants' opinion.that no change is required in the proposed findings.

-Further, since the Intervenors proposed no findings dealing with microearthq akes in the region of SONGS,.it would appear that e/en their proposed findings are not-altered. While differing views of the structural relationship of the OZD and the CZD remain, euch findings would not be affected by reopening the record for additional evidence'concerning the

, swarm.

4

3. Applicants Do Not Conhider the Earthquake Swarm to Constitute Good Cause for Further Hearings Small earthquakes such as those constituting the swarm of November 6-9, 1981 occur frequently in Southern California. Such microseismic events are not significant for the geologic and seismic review of the San Onofre region.

Intervenor's Exhibit No. 14, " Relationship Between Seismicity and Geologic Structure in the Southern California Region," by C. R. Allen, P. St. Amand, C. F. Richter, and J. M. Nordquist discusses the general level of seismicity in Southern California. Table 2, page 782 of Exhibit 14, indicates that for Southern California it can be anticipated that an average 1.5 earthquakes of magnitude 3 will occur annually per average 1000 square kilometers. Applicants have investigated an area of 200 mile radius surrounding the San Onofre site. (10 C.F.R. Part 100, App. A.Section IV(a)(6).) That area comprises 325,700 square kilometers.

Based on the Exhibit 14 study, an earthquake of magnitude 3 would be expected to occur within the investigated area-more frequently than once per day. This is consistent with Dr.

Biehler's testimony that a halo of seismicity is pervasive throughout Southern California. Biehler further stated that for the San Onofre region, the level of seismic activity is 4 to 5 times lower than the Southern California average discussed in Exhibit 14. (Tr. 3983) 5 t

Although seismicity in the San Onofre region is lower than the Southern California average, the area is not aseismic. Figure 1 - Epicenter Locations for the November 6-9, 1981 Swarm (originally submitted in Applicants' November, 1981 Report) attached hereto, shows a region within the dashed lines of 8,100 square kilometers. Based on the Southern California average, there should occur within that-region some 12 earthquakes per year of magnitude 3. In fact, as shown in Figure 6 - Historic Seismicity in the Rer; ion of SONGS, 1934-1977, inclusive (originally submitted in Applicants' November, 1981 Report) attached hereto, the recurrence period has been approximately 140 days.

With respect to the immediate area where the swarm occurred, six events have been recorded during the period 1934-1979, inclusive (Figure 8 - Summary of Historic Earthquakes that have occured in the Vicinity of the November 6-9, 1981 Swarm, attached). The largest of these events is magnitude 3.5 and occurred in 1934.

Applicants submit that the occurrence of the swarm is not surprising and, as will be shown, is not of

, significance to the San Onofre facilities.

4. Location of Swarm Applicants have located the swarm both on the map originally submitted by Drs. Greene and Kennedy (Figure 13.2, Applicants Report of November 18, 1981) and the map by 6

Dr. D. G. Moore (Figure 13.1, Applicants Report of November 18, 1981), both of which are attached.

The epicenters of the two largest earthquakes in the swarm are located 1.2 km southwest of the nearest fault associated with the CZD identified by Greene and Kennedy on their map of the CZD. These epicenters, however, are located only 0.4 km southwest of the nearest fault Greene and Kennedy mapped as part of the OZD. This latter fault is west of the syncline that parallels and is associated with.the OZD, and is Greene and Kennedy's northeast boundary fault of the OZD.

(See Plate 1, Appendix F-24, SER and Applicants' Figure 13.2.) Thus, the epicenters of the swarm lie within the Greene and Kennedy mapped location of the OZD.

Utilizing the structures map prepared by Dr. Moore (Figure 13.1), the center of the swarm is located 0.7 km northeast of the South Coast offshore Fault, which is a part of the OZD, and almost directly beneath the San Onofre Shelf Anticline, which is also part of the OZD.

The geometric position of the swarm with respect to mapped faults associated with the two zones of deformation clearly favors an association with the OZD rather than a southeast extension of the postulated CZD.

Applicants have reviewed the quantity and quality of geologic information in the area of the swarm. It is located in an area structurally well defined by high quality geophysical seismic profiling. Although the Greene and 7

Kennedy map shows " Data Void", adjacent to the epicenter plot, the center of the swarm lies only 0.3 km southwest of Nekton watergun line 30. Nekton line 28 is within 1 km of the epicenter of the largest event, as is Marine Advisors sparker line 3-141 (Section G-G' on Greene and Kennedy's Plate 1, Appendix F-24, SER Figure 13.2).

The term " Data Void" was discussed at length during the hearings. (cf. Applicants Proposed Findings of Fact and Conclusions of Law on Geology / Seismology Issues, Nos. 496-498; NRC Staff's Proposed Findings of Fact and Conclusions of Law in the Form of a Proposed Initial Decision, Nos. 260-263.) Generally, the term referred to a lack of seismic profiles, or, if data had been gathered, that it'was-not of sufficient quality to allow interpretation. However, with respect to the " data void" shown by Green and Kennedy-(Figure 13.2) in the area of the swarm, the term takes on yet a third meaning; Q. When it gets into this particular area of the postulated interconnection, is the data void there because there just wasn't a line that confirmed where you could see an interconnection? Is that what we're dealing with? And, for conservatism purposes, you didn't want to reach a definitive conclusion that it did not connect, truncate, merge?

A. (WITNESS GREENE) In that general region, recalling the best I can here, is looking at the density that is a variable density throughout the entire map.

We did not have the density of course there that we had elsewhere. And that,'yes, indeed, profiles did not cross the intersection per se. Therefore we did not say absolutely that the intersection was here or some other locality.

8

Q. Dr. Gre ene', that I can understand. With that specification, is that what you mean by data void with respect ~to the postulated interconnnection?

A. Yes, that would be included within our interpretation or our usage of data void.

Q. So you are not complaining of a lack of general data in that area.

A. No, we're not complaining of a lack of general data.

Q. But it just happened there wasn't a specific line that went through that spot that you would have been looking for.

A. Tnat's correct.- (TR 2285-86)

Applicants submit that the geologic data base is adequate. Further seismic profiling would not yield information relevant to this swarm.

5. Sense of Fault Motion The two largest events of the November, 1981 swarm were sufficiently well recorded to define the sense of motion. That motion was determined to be horizontal strike-slip. The orientation of the focal solution is concluded to be northwest trending, nearly parallel to.the trend of the OZD. The sense of motion is right-lateral, i

which is also consistent with the OZD. As discussed during-I I.

the hearings, the maximum compression axis for the San Onofre' region is oriented approximately north-south. The November, 1981 swarm is consistent with this stress pattern. (The focal solutions could also be interpreted to trend to the 9-h

$ EM' s 4

northeast, perpendicular to th'e OZD. This would be~very

.. ~ - ,

unlikely in this reglon.) '

o ,

This northwest > trending strikeislip[ sense of motion

./

is also incompatible"with both~the

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onshore Cristia.nitos fault and the deeper, older features' located $in the vicinity of'the Greene and Kennedy CZD.

Theolderfestdrei{andthe __

j ...

Cristianitos are primarily dip-slip, down to -Ehe east on the old faults and down to the west'on the Cristianitos'.' T'is d is

, ~

in conflict with the strike-sl.ip character of the swarm. "

Thus, with respect to sense of motion, the eventsf -

are consistent with the geology of the OZD anId,knconsistent '

with the onshore Cristianitos fault'and the older features' --

located in the area of the'-CZD. / .

6. Assessment of Fmiit Capability Microearthquakes (magnitiudes,of less than ab'out 3) such ac contained within'. tie swarm occur wtdely-ihroughout

> / / ,

Southern California. Although'.it is difficult ,to. generalize

> ,~r about the significance of such smali earthquaites, some - -

conclusions can be drawn. For example, a large number of -

small earthquakes which show a planar. distribution in space, and with supporting focal mechanisms consistent with that same plane, would'be taken as very strong evidence for the existence of a fault, even if geologic evidence of such a fault were absent. For situations such as in the current evaluation, one has to take all available seismological and geological information into account.in order to reach an 10

w interpretation. Consistency b*etween the spatial distribution

' of focal' mechanisms, and the geologic environment is always

. required if one is to use microearthquake data to reach conclusions regarding seismic risk.

In the current analysis, the hypocentral locations of the microearthquakes do not, by themselves, define a fault plane. The focal mechanism data are most consistent with the geologic conditions associated with the OZD. These earthquakes have occurred in an area of previous seismicity and hence do not represent "new" or heretofore unrecognized seismic activity. The occurrence of these earthquakes does not provide any new evidence bearing on the capability, as s

defined in 10 C.F.R. Part 100, App. A, Sec. III(g), of the postulated CZD. The data obtained from the swarm in no way controverts the extensive geologic and seismic data- -'

summarized in Applicants' Proposed Findings of Fact concerning the OZD. Based on Applicants' analysis of these events, we find no new information which causes us to change our position regarding either the existance or capability of

. the postulated Cristianitos Zone of Deformation. The : data does not support associating the swarm with the onshore Cristianitos fault. Applicants do not consider the swarm to in any way cast doubt on the adequacy of the Seismic. Design Basis for the SONGS 2 and 3 site.

11

. V

7. Geologic Features of hhr. D. W. Phifer on November 30, 1981 Applicants submitted to the NRC Staff a response to the letter by Mr. D. W. Phifer, dated

~

October 8, 1981. The Applicants conclude there is no evidence for the alleged " Mountain Top Fault Zone" and that the Aliso Canyon Fault, if indeed present, has no significance to the safety or seismic design of SONGS. The

' Staff in their reviewLdated December 9, 1981, determined that the Applicants' conclusion concerning the lack of evidence for the " Mountain Top Fault Zone" is reasonable and tre Aliso Canyon Fault is of no seismic significance to the San Onofre site. The Applicants agree with the Staff's conclusions.

8. Qualifications of Authors Two documents were prepared by Applicants on the earthquake swarm of November 6 through November 9, 1981.

These documents were authored under the direction of Dr.

D. M. Hadley of Sierra Geophysics with consultation and review by Drs. Shawn Biehler and Stewart W. Smith.

Discussion of geology in the reports was.done by Mr. J. L.

McNey. The Micro-seismic array installed at San Onofre on November 9, 1981 was done under the direction of Dr.

Biehler. Comments developed in response to the ASLB Order.of December 10, 1981 were prepared and/or reviewed by the above and Dr. D. G. Moore.

The professional qualifications of the participants are as follows:

12

Dr. David M. Hadley '

1971 Bachelors Degree, Physics, University of California at Riverside 1973 Masters Degree, Geophysics, University of California at Riverside 1978 Ph.D., Geophysics, California Institute of Technology 1975 - Consultant for U.S. Geological Survey, on present ground modeling and earthquakes and seismology of geothermal reervoirs; U.S.

Air Force oilfield waveform modeling; various major oil companies involving regional seismicity and strong ground motion models.

1978 - Visiting Associate, Seismological 1979 Laboratory, California Institute of Technology.

Published approximately 30 reports on regional tectonics, crustal structure, strong ground motion seismology, geothermal seismicity and regional seismicity. Consultant to the Applicants on regional seismicity, strong ground motion, detailed source-modeling, Coyote Lake earthquake, 1979, Mammoth Lakes earthquakes, 1980, Imperial Valley

'3

earthquakes,' 1979; witness'before the ASLB on seismology.

Dr. Shawn Biehler 1958 Bachelor of Science, Geological Engineering, Princeton University 1961 Masters degree, Geophysics, California Institute of Technology 1964 Ph.D., Geophysics, California Institute of Technology 1964 - Post-doctoral Research Assistant 1966 Seismological Laboratory of the California Institute of Technology 1966 - Assistant Professor of Geophysics, 1970 Massachusetts Institute of Technology ,

1970 - Associate Professor of geophysics, Present University of California Riverside Published or co-authored 15 papers and 20 abstracts in the field of applied geophysics. Among his professional projects are included WPSS Nuclear Project, Satsop, Washington, Sundesert Nuclear Project, California and several investigations for the Applicants.

Work for the Applicants included the earthquake swarms of Plano Trabuco in 1975 and 1977 which were the subject of 14 '

hearings in this docket.- He presented expert opinion before the Advisory Committee on Reactor Safeguards (ACRS) subcommittee and testimony before the ASLB concerning the 1975 and 1977 swarm-of earthquakes. He is a registered geophysicist in California.

Dr. Stewart W. Smith 1954 Bachelor of Science degree, Department of Geology and Geophysics, Massachusetts Institute of Technology 1954-1957 Geophysicist, Shell 011 Company 1959 Master of Science Degree, California Institute of Technology 1961- Ph.D., Geophysics, California Institute of Technology 1961-1964 Assistant Professor and Staff member, Seismological Laboratory, Califoria Institute of Technology 1964-1970 Associate Professor of Geophysics, California Institute of Technology 1970 - Professor of Geophysics at University Present of Washington 1970-1980 Chairman of Geophysics, University of Washington 15

1974 - Principal Scientist, earthquake Present seismology, Tera Corp. 1 Published approximately 40 articles in geophysics and participated on several panels and committees on seismic safety.

Has been a consultant on Diablo Canyon, Humboldt Bay Nuclear Power Plants.

Presented testimony at all hearings before the ASLB and ALAB for Diablo Canyon. A member of the Board of Technical Review on the original work on the San Onofre site in 1970. Presented expert opinion before the ACRS subcommittee and testimony before the ASLB at the construction and operating license hearings for San Onofre Units 2 &

3. He is a registered geophysicist in California.

Dr. David G. Moore 1950 Bachelor of Science, Geology, University l of Southern California 1952 Master of Science, Geology, University of Southern Califoria 1962 Ph.D. University of Gronigen, the Netherlands 16 -

1952-1955 Sedimentologist and Marine Geologist.for API Project 51, Scripps Institute of Oceanography 1955-1980 Research Oceanographer specializing in marine geology for the Naval Ocean Systems Center 1976-1979 Chief Scientist for Deep Sea Drilling Project of the National Science Foundation with Scripps Institute of Oceanography Present Research Associate, Scripps Institute of Oceanography, University of California at San Diego.

Dr. Moore has published over 50 articles, papers and special papers in his field of expertise. He has been a consultant to the Applicants on marine geology and geophysics and a member of the Baord of Technical Review during the construction licensing phase and has been a consultant since. He presented expert opinion before the ACRS subcommittee and presented sworn testimony before the ASLB. Dr. Moore is a registered geologist and geophysicist in California.

17

Dr. Jerrold L. McNey 1952 Bachelor of Arts, Geology, University of California at Los Angeles 1961-1963 County of Los Angeles Department of Building and Safety, Grading Inspector 1963-1970 Engineering Geologist, Moore and Taber Engineers and Geologist, Anaheim, California 1970 - Senior Engineering Geologist, Southern Present California Edison Company.

Mr. McNey has taken post-graduate study and selected courses work in rock mechanics,. soil mechanics and structural geology. He authored or co-authored papers on earth-work, earthquake effects and geology at San Onofre. Mr. McNey has made several presentations on the geology at San Onofre before the NRC Staff. He is a registered geologist and certified engineering geologist in California.

The Applicants also prepared a report concerning Mr. Phifer's Octcher 8, 1981 letter to the Nuclear Regulatory Commission. The report titled " Report on the 'Aliso Canyon Fault' and the Alleged ' Mountain Top Fault Zone', Camp Pendelton, California, November 25, 1981." Dr. P. L. Ehlig authored the discussion of the alleged " Mountain Top Fault" 18'

and Mr. J. L. McNey discussed the Aliso_ Canyon Fault. Mr.

McNey's qualifications are presented in the preceding section; qualifications for Dr. Ehlig are presented below:

Dr. Perry L. Ehlig 1952 Bachelor of Arts, Geology, University of California at Los Angeles 1958 Ph.D., Geology, University of California at Los Angeles 1956 - Professor, Geology, California State Present University, at Los Angeles 1956-1958 Field Geology Instructor,. University of California at Los Angeles.

1959 Field Geology Instructor, Lousiana State University.

Dr. Ehlig has been principal author on 20 professional papers or abstrac.ts concerning geology and structural interpretation in Southern California.

He has performed detailed geologic mapping of the San Onofre area and presented expert opinion at the ACRS subcommittee and testimony before the ASLB. He is a registered geologist and 19 L

certified engineering geologist in California.

Dated: December 21, 1981.

Respectfully submitted, DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCIFFE A Professional Corporatior, CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY Attorneys for Applicants SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY tmR3 R. PIG 0TT By David R. Pigott i

20

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FIGURE 13.1 - Fault plane orientation and location of the Nov. 6-9, 1981 swarm. The base map has been completed by D. Moore (DGM-D). The focal mechanism is centered on the location of the M L =3 event. The epicentral uncertainty of this location, as discussed in the response to Question 1, is about 1 km. The radius of the focal mechanism approximately represents the areal distribution of the swarm. The strike of the northwest trending plane is N43W, in good agreement- with the strike of the.OZD. Both the spatial relationship and the orientation of the strike-slip f ault plane,ctrongly suggest that this swarm was associated with the OZD.

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8 00tKETE0 4 uso c PROOF OF SERVICE BY MAIL'81 00) ,

4 I declare that: fch.[ . ec T TY

. I am employed in the' City and County of' San

. Francisco, California.

I am over the age of eighteen years and not a party t'o the within entitled action; my business address is 600 Montgomery Street, lith Floor, San Francisco, California 94111.

On December 21, 1981, I served the attached i'

APPLICANTS' RESPONSE TO BOARD ORDER REQUESTING COMMENT ON EARTHQUAKE SWARM in said cause, by placing a true copy-thereof enclosed in the United States mail at San Francisco,

California, addressed as follows

(except where indicated by *)

  • James L. Kelley, Chairman i- Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear-Regulatory Commission Washington, D.C. 20555 Dr. Cadet H. Hand, Jr.

Administrative Judge c/o Bodega Marine Laboratory University of california-P. O. Box 247 Bodega Bay, CA 94923 Mrs. Elizabeth B. Johnson L ,

Administrative Judge Oak Ridge National Laboratory P.O. Box X, Building 3500 L Oak Ridge, Tennessee 37830 .

I

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rw e v ,-, ,,--r,wm,, . , , , ,. e ar - _ , , , , _ _ , _ . , _ , , ,,, 4 o _,

David W. Gilman -

Robert G. Lacy San Diego Gas & Electric Company P.O. Box 1831 .

San Diego, California 92112  :

Robert Dietch, Vice President Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Alan R. Watts, Esq.

Rourke & Woodruff California First Bank Building 10555 North Main Street Santa Ana, California 92701

  • Lawrence J. Chandler, Esq.

Richard K. Hoefling, Esq.

Donald F. Hassell, Esq.

Nuclear Regulatory Commission Office of the Executive Legal Director 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, California 94102 Mr. Loyd von Haden 2089 Foothill Drive Vista, California 92083 Mrs. Lyn Harris Hicks GUARD 3908 Calle Ariana San Clemente,- California 92801 James F. Davis State Geologist Division of Mines and Geology ,

1416 Ninth Street, Room 1341 Sacramento, California 95814

  • Richard J. Wharton, Esq.

University of San Diego School of Law Alcala Park San Diego, California 921'9

Phyllis M. Gallagher, Esq.

1695 W. Crescent Avenue, Suite 222 -

Anaheim, California 92801 -

_ Atomic Safety and Licensing Board .

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 Richard K. Hoefling, Esq.

U.S. Nuclear Regulatory Commission Office of the' Executive Legal Director Washington, D.C. 20555

  • Charles E..McClung, Jr., Esq.

23521 Paseo de Valencia, Suite 308 Laguna Hills, California 92653 gNR5R.PlGMT 4

DAVID R. PIGOTT One of Counsel for Applicants SOUTHERN' CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC CO.

O

  • served by courier

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