ML20236B116

Interrogatories Propounded to NRC by Several Intervenors Re Geology,Seismicity Qualification.* Requests NRC Answer Interrogatories,In Writing,Within 15 Days of Receipt

ML20236B116
Person / Time
Site:	Diablo Canyon, 05000000
Issue date:	03/22/1977
From:	Geocaris J CENTER FOR LAW IN THE PUBLIC INTEREST, SAN LUIS OBISPO MOTHERS FOR PEACE, SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20236A877	List: ML20236A874 ML20236A896 ML20236A920 ML20236A950 ML20236A959 ML20236A975 ML20236B012 ML20236B016 ML20236B024 ML20236B067 ML20236B072 ML20236B116 ML20236B278 ML20236B286 ML20236B312 ML20236B315 ML20236B345 ML20236B356 ML20236B362 ML20236B403 ML20236B420 ML20236B436 ML20236B440 ML20236B476 ML20236B480 ML20236B506 ML20236B514 ML20236B522 ML20236B539 ML20236B547 ML20236B550 ML20236B560 ML20236B571 ML20236B594 ML20236B612 ML20236B630 ML20236B635 ML20236B650 ML20236B655 ML20236B670 ML20236B686 ML20236B695 ML20236B701 ML20236B705 ML20236B708 ML20236B726 ML20236B737 ML20236B748 ML20236B755 ML20236B793 ... further results
References
FOIA-87-214 OL, NUDOCS 8707280347
Download: ML20236B116 (4)

Text

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o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS7SN BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-275 0.L.

PACIFIC GAS AND ELECTRIC COMPANY ) Z~50- 3_23) O . L .

)

(Diablo Canyon Nuclear Power Plant, )

Units Nos. 1 and 2) )

l

. INTERROGATORIES PROPOUNDED TO .

. i THE NUCLEAR REGULATORY COMMISSION BY SEVERAL INTERVENERS REGARDING GEOLOGY, SEISMICITY QUALIFICATION (2 1

Under the authority of 10 C.F.R. S2.7406, 10 C.F.R. Part 2 Appendix A, and the Federal Rules of Civil Procedure,

)

Interveners SCENIC SHORELINE PRESERVATION CONFERENCE, SAN LUIS q l

I OBISPO MOTHERS FOR PEACE, SANDRA SILVER, ECOLOGY ACTION CLUB, 4

and JOHN J. FORSTER ask that the Nuclear Regulatory Commission, I

their attorneys or other duly authorized agents or employees answer in writing, under oath, and within fifteen days from the receipt hereof, the interrogatories contained herein:

DEFINITIONS l

1. As used herein, "you" and "N.R.C." shall mean the United States Nuclear Regulatory Commission and any employees of, contractors or consultants to, or other agents of said Commission.

1. Y I

8707280347 Bio 721 PDR FOIA g CONNDRB7-214 PDR ,

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2. As used herein, " magnitude" and "M" shall mean the measure of earthquake magnitude according to the Richter scale.

3. As used herein, " items" shall mean structures, systems, components, and parts of the Diablo Canyon Nuclear Generating Station.

4. As used herein, "DCNGS" shall mean the entire >

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Diablo Canyon Nuclear Generating Station. ..

Interrogatory No. 1 .

'. What magnitude earthquake on the Hosgri fault near the DCNGS do you contend constitutes a proper, conservative value for use in evaluating the seismic safety of the DCNGS7 Please

' state cach and every fact upon which you base this contention. 1 1

Interrogatory No. 2 -

What ground acceleration from a 7.5M earthquake on the Hosgri fault do you contend constitutes a proper, conservative value for use in evaluating the seismic safety of the DCNGS?

Please state each and every fact upon which you base this l contention.

l l Interrogatory No. 3 What reductions in the' response spectra for the various buildings of the DCNGS, due to the large foundations of these buildings, constitute proper, conservative values for evaluating the seismic safety'of the DCNGS? Please state each and every fact upon which you base this contention.

Interrogatory No. 4 What value for structural dampi'ng for DCNGS do you L____ ____

..  ? .

}

J contend constitutes a proper, conservative val'ue, for use in evaluating the seismic safety of DCNGS? Please state each and every fact upon which you base this contention.

Interrogatory No. 5 Do you contend that the Hosgri fault is not linked {

. . - . to the. San Gregario fault to form one fault system? If so, l please state each and every fact upon which you base this 1 contention.

Interrogatory No. 6 {

Do you contend that the Hosgri fault is not linked to ,

the San Simeon fault to form one fault system? If so, please state each and every fact upon which you base this contention.

Interrogatory No. 7

~

Where do you contend is the location of the southeastern-most or downcoast end of the Hosgri fault? Please state each and every f act upon which you base this contention.

Interrogatory No. 8 What amount of strike-slip movement do you contend has occurred on the Hosgri fault since the Miocene geologic time period? Please state each and every fact upon which you base this contention.

Interrogatory No. 9 Do you Jontend that the strong (7.3M) ' earthquake  !

recorded near the central California coast on November 4, 1927 ,

took place on the Hosgri fault? If so, please identify the fault on which you contend this earthquake did take place

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.. t and state each and every fact upon which you base this contention.

Dated: March 22, 1977 Respectfully submitted, BRENT N. RUSHFORTH JAMES GEOCARIS Center for Law in the. Public Interest 10203 Santa Monica Boulevard Los Angeles, California 90067 (213) 879-5588

• By: e f$4L Aff&/fs' ,

James Geocarfs ttorneys for Several Interveners l

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