ML20236K008

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Supplemental Reply of PG&E to Scenic Shoreline Preservation Conference,Inc.,Dtd 710709.San Fernando Earthquake Not Relevant to Diablo Canyon Site.Certificate of Svc Encl
ML20236K008
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 07/28/1971
From: Crane P
PACIFIC GAS & ELECTRIC CO.
To:
US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20236J368 List: ... further results
References
FOIA-87-214 NUDOCS 8708060369
Download: ML20236K008 (9)
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UNITED STATES OF AMERICA h AUgg i ATOMIC ENERGY COMMISSION -

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In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 o l

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(Diablo Canyon Unit 2) )

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SUPPLEMENTAL REPLY OF PACIFIC GAS AND ELECTRIC COMPANY TO MOTION OF SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

DATED JULY 9, 1971 Pacific Gas and Electric Company's (PGandE's) pleading _

dated July 19, 1971 sets forth cogent and basic procedural reasons for denying the motion filed by Scenic Shoreline Preservation Con-ference, Inc. (Confa ence) dated July 9, 1971. A reading of the motion and affidavit filed by Conference, including the numbered referencen incorporated therein, together with the evidence already in the record in this proceeding reveals the following 1

substantive reasons for denying Conference's motion:

1. The high ground accelerations recorded during the San j l

Fernando earthquake were associated with a kind of faulting not ,

I present near Diablo Canyon, occurred in a structural province fundamentally different from that in which the Diablo Canyon .

site lies, and were recorded at points where the conditions of ground materials and topography were quite unlike those at the ]

Diablo Canyon plant. Even more important, no large fault of t

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1 any kind exists beneath or near the Diablo Canyon site. (PSAR Appendix B, Appendix C; Partial Summary of Application pp. 4-7; ASLB Initial Decision pp. 7, 8.) Thus, any attempt to relate the San Fernando earthquake to the Diablo Canyon site is vir-tually meaningless.

For example, at page 3 of reference 2 in the affidavit filed with the Conference motion the following appears:

" Damage in the San Fernando and Sylmar areas of Los Angeles County was severe because the epicenter lay only about 14 km (9 miles) north i of the center of San Fernando and because the fault which broke to produce the earthquake was a thrust that extended beneath these com- '

munities from the epicenter and intersected and ruptured the surface of the ground in  ;

heavily built-up areas within them. Ear th-  ;

quakes have been associated with thrust faults before in California but not as commonly as with strike-slip faults of the San Andreas type. Accordingly, comparative studies of the seismic and geologic character, secondary geologic effects, and patterns of damage pro-duced by these two tvoes of earthquakes will receive careful attention. Examples of such comparisons are the relative widths of the zones of broken ground along the two tvoes  !

of fault ructures and the relation of Richter j

magnitude and modified Mercalli intensity for the two tvoes of earthquakes. . . .

"[These records) will also provoke intensive )

study of the relation of these surprisingly j high accelerations to local geologic or topo-graphic conditions at the recording sites as well as to the characteristics of the earth-quake and its associated thrust faultina."

(Emphasis added)

It is well established that the faults which may influence the ,

1 Diablo Canyon site 'are the San Andreas and other strike-slip faults. (ASLB Initial Decision pp. 7, 8; PSAR Appendix '.)

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Thrust faults can be expected to produce generally greater accele-rations than strike-slip faults. Thus, observed effects of thrust faults are not. applicable to the Diablo Canyon - site.

An additional important difference lies in' the material on which the structures involved in the. San Fernando earthquake :

were founded. Reference 3, portions of which are quoted in the affidavit, indicates that the Olive View Hospital. was ' located on

. at least 100 feet of alluvium. On page 1 of Edhibit D to refer-ence 3 Ehe following quotation appears: '

"The modern Olive View Medical center complex suffered ' severe' damage as a result of the earthquake. of February 9, 1971. The structures were founded on the-upper or apex portion of an alluvial fan at the foot of the San Gabriel Mountains. These alluvial materials consist of uncemented and relatively unconsolidated sand and gravel with varying amounts of cobbles and small boulders. The thickness ~ef these alluvial materials is unknown,1but estimated'to be at least 100' in thickness in the vicinity of the main medical center structure. Underlying; these alluvial materials should be a sequence of sedimentary units which should increase in density and consolidation with depth and these-rock units, in turn, are underlain by the

granitic-metamorphic complex of the San Gabriel Mountains.

"The-source or origin of the seismic energy was apparently from fault movement within and/or in the frontal portion of the San Gabriel Mountain block . The direction of. energy propagation in this immediate vicinity. should have been upward .

and southerly. The amnlitude of the seismic waves should hav_e increased as the energy passed from censer [ sic) bedrock materials into and through the alluvial materials. From the avail-able data, i. t can be concluded that within the general vicinity of the site .tdue lateral accelera-tion associated with the main shock was at least

. 5 g and the vertical at least .25 g. " (Emphasis added) 3 l

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The Diablo Canyon units will be located on bedrock (ASLB Initial i

! Decision p. 7) and therefore would not be subject to amplifica- J l

tion of accelerations from bedrock up through alluvium as the above quote indicates was the case at Olive View Hospital.

The affidavit (p. 2) recites that the ground accelera- j tions in the San Fernando earthquake at the Pacoima Dam were the highest ever recorded. However, the references in the affidavit indicate that the Pacoima Dam instrument was on top of a rather slender rocky ledge and not at the dam abutments or foundation.  ;

Thus, the readings were probably a product of the geology and structure of the ground on which the instrument was located.

"At Pacoima Dam, 5 miles south of the epicenter, the earthquake accelerations were the highest ever recorded . . . . . The accelerograph . . .

is located on a small ledge above the east abut-ment of the concrete arch dam situated in the deep narrow Pacoima Canyon . . . . . Rock at the site is a gneissic granite-diorite complex, ,

with prominent jointing trends parallel to the canyon . . . . . some cracking, displacement, and subsequent tilting of the rock adjacent to the instrument housing was observed following the shock. " . . .

" Evaluation of the [Pacoima Daml record may prove to be difficult because of fracturina of rock I adiacent to the station durina the earthcuake."

(R,eference 2, pp; 163-164) (Emphasis added) 1 "There were no accelerographs in the general vicinity of this structure (the Olive View Hospital]. The nearest toward the epicenter was the one on the Pacoima Dam. Its record was extremely severe but around disruntion around the instrument indicated that the motion intensity is not representative of the general ground motion. The nearest competent record is that taken at the Holiday 4 .

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- i Inn adjacent to the San Diego Freeway, a little l

south of the City of San Fernando. This instru-1 ment recorded high lateral and vertical motion 3 intensity." (Dmphasis added) (Exhibit A, j Reference 3, p. 3) I i

2. As stated on page 2 of the affidavit, with the exception of the instrument at Pacoima Dam the maximum ground accelerations developed in the San Fernando earthquake were in the range of 0.20 g - 0.40 g. Under the seismic design criteria developed by PGandE's consultant for the Diablo Canyon units, the design is such that the plant may be shut down safely after a ground accele-ration of 0.40 g (PSAR Appendix D, pp. 8, 9). The affidavit refers I

to a value of 0.20 g, but actually the Diablo Canyon unit design )

'l is double this value. (ASLB Initial Decision pp. 8, 9.) There-fore, there is no error "by a factor of 2 or 3" as alleged in the ,

j affidavit and repeated in the Conference motion. On the contrary, )

even given the high accelerations specified above, the Diablo Canyon units could still be safely shut down. In other words, if the Diablo Canyon earthquake design criteria were being prepared today af ter the San Fernando earthquake and in view of all other knowledge that has been acquired since the criteria were developed, no changes from the criteria actually employed would be necessary to assure a safe shutdown of the plant. Thus, there is no reason i

to reopen this matter to consider the effect of the San Fernando carthquake on the design of the units since the design is adequate.

The reference at the top of page 3 of the affidavit to recordings indicating ground accelerations 5

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". . . two to three times greater than those l commonly assumed for seismic design criteria. I is taken from page 3 of reference 2 and relates to the readings l from the Pacoima Dam instrument. As indicated above, these readings are highly questionable because of ground disruption around the instrument.

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3. Accelerograph records for not only the San Fernando j earthquake but for many other strong earthquakes do indeed show ground acceleration much greater than the seismic coefficients required as minimum design standards by building codes. This has been known for many years and was carefully taken into account by PGandE consultants and the Atomic Energy Commission in the development and approval of seismic design criteria for the Diablo Canyon nuclear powcr plant. (PSAR Appendix D; Staff Safety Evaluation pp. 21-24, Appendix F. ) The affidavit seems to relate earthquake design criteria used for buildings such as the Olive View Hospital and those used for the Diablo Canyon plant; there is no similarity between the two criteria. Building code criteria are minimum standards which do not purport to pre-vent all damage even under less than severe earthquake motion.

1 The design factors employed in building codes are only a fraction I 1

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of those employed in the design of the Diablo Canyon plant. For example, reference 3 indicates that the Olive View Hospital was designed in accordance with the 1964 Los Angeles County Uniform Building Code. The Diablo Canyon design basis earthquake require-1 ment at 5% damping (PSAR Appendix D and Plates 1, 2, 3, and 5) is 1

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.. j from seven to- thirteen times that employed for the . hospital, 'and Ehe peak 5% damped spectral acceleration for the nuclear plant is about 20 times the most probable hospital design value. i In summary, because of significant differences in geology and seismology between the Diablo Canyon . site and the San Fernando earthquake site, the San Fernando earthquake is not relevant to Diablo Canyon. Thus, no useful purpose would be served in reopening the proceeding to consider the San Fernando earthquake. In addition, the nature of the seismic design criteria for the Diablo units makes such a reopening inappropriate and unnecessary.

Respectfully submitted, FREDERICK T. SEARLS JOHN C.-MORRISSEY l

PHILIP. A. CRANE, JR.

Attorneys for <

PAC . >AS AND ELECTDIC CO' ANY j

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' Philip A! Crane, (fr.

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Dated: July 28, 1971.

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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION l

i In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323

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l (Diablo Canyon Unit 2) )

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CERTIFICATE OF SERVICE I

The foregoing Supplemental Reply to Motion dated 1 July 9, 1971 has been served today on the following lar deposit j in the United States mail, properly stamped and addressed:

1 Mr. Jack M. Campbell Secretary

! Stephenson, Campbell & Olmsted U. S. Atomic Energy Commission ,

231 Washington Avenue Washington, D. C. 20545 j P. O. Box 877 I Santa Fe, New Mexico Attn.: Chief, Public Proceedings j Branch i Dr. Rolf Eliassen Department of Civil Engineering Mr. Martin Malsch Stanford University Trial Counsel ,

Stanford, California 94305 U. S. Atomic Energy Commission l Washington, D. C. 20545 l Mr. John Freeman (2 copies)

Chairman San Luis Obispo County Mr. James P. Gleason Board of Supervisors 205 Commonwealth Building County Courthouse 1625 K Street, N.W.

San Luis Obispo, California 93401 Washington, D. C. 20006 Dr. Peter A. Morris, Director Mr. Ian I. McMillan Division of Reactor Licensing Box 63 U. S. Atomic Energy Commission Shandon, California 93461 Washington, D. C. 20545 (2 copies) Dr. Hugh C. Paxton Los Alamos Scientific Laboratory Dr. Thomas H. Pigford P. O. Box 1663 Professor of Nuclear Engineering Los Alamos, New Mexico 87544 University of California Berkeley, California 94720 O

- _ _ _ - _ _ . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _ _ . _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ . . __]

San Luis,0bispo Bay Properties, 'Inc.

and Luigi Marre Land and Cattle Company c/o Mr. Hal-Stroube Marre Ranch Avila Beach, California 93424 Scenic Shoreline Preservation Conference, Inc.

4623 More Mesa Drive Santa Barbara,. California 93105 Mr. A..A. Wells,. Chairman Atomic Safety and Licensing Board Panel U. S.' Atomic Energy Commission Washington, D. C. 20545 Mr. Paul L. Clifton, Chairman State Power Plant Siting Committee The Pesources Agency of California 1416 Ninth Street Sacramento, California 95814 Dr. John M. Heslep,. Chief Environmental Health and Consumer Protection Program

' Department of Public Health 2151 Berkeley Way Berkeley, California 94704 i i

Phil V >%. Crane ttorney for{ Jr.

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Pacific Gas and Electric Company l

l Dated: July 28, 1971.

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