response & objections to 791018 second set of ...15 (n) wrench fault tectonics -.crustal...

1 DAVID R. PIGOTT SAMUEL B. CASEY

2 CHICKERING & GREGORY Three Embarcadero Center

3 Twenty-Third Floor San Francisco, California 94111

4 Telephone: (415) 393-9000

5 CHARLES R. KOCHER JAMES A. BEOLETTO

6 LINDA THORNTON SOUTHERN CALIFORNIA EDISON COMPANY

7 P.O. Box 800 2244 Walnut Grove Avenue

8 Rosemead, California 91770 Telephone: (213) 572-1212

9 Attorneys for Applicants,

10 Southern California Edison Company and San Diego Gas & Electric Company

11

12 UNITED STATES OF AMERICA

13 NUCLEAR REGULATORY COMMISSION

14 BEFORE THE ATOMIC SAFETY AND.LICENSING BOARD

15

16 In the Matter of ) Docket Nos. 50-361 OL 17 )50-362 OL SOUTHERN CALIFORNIA EDISON

1 COMPANY, et al. (San Onofre ) RESPONSE AND OBJECTIONS OF 18 Nuclear Generating Station, ) SOUTHERN CALIFORNIA EDISON 19 Units 2 and 3) ) COMPANY AND SAN DIEGO GAS &

ELECTRIC COMPANY TO INTERVENOR 20 FOE, ET AL., SECOND SET OF

INTERROGATORIES

21

22 TO INTERVENORS FRIENDS OF THE EARTH, MR. AND MRS. AUGUST CARSTENS, MR. AND MRS. LLOYD VON HADEN, MRS. DONIS DAVEY AND 23 THEIR ATTORNEY OF RECORD:

24 Pursuant to 10 C.F.R. § 2.740b, Applicants Southern

25 California Edison Company and San Diego Gas & Electric Company in

26 the above-entitled action hereby respond to "INTERVENOR, FOE ET

27 AL. INTERROGATORIES TO SOUTHERN CALIFORNIA EDISON" which were

28 served by mail on Applicants on October 18, 1979.

Applicants have responded to virtually all the Inter

2 rogatories propounded. The fact that Applicants have so re

sponded to many of the Interrogatories that do not relate to 3

4 geologic discoveries or seismic events subsequent to issuance of

the Construction Permits for San Onofre Nuclear Generating Sta

tion Units 2 and 3 ("SONGS 2 and 3") should not be construed as 6

7 an admission by Applicants that an evaluation of such pre-Con

struction Permit matters is appropriate or within the scope of

this proceeding. Applicants specifically reserve the right to

object to the introduction into evidence of any interrogatory and 10

its response which goes beyond the issue of whether subsequent 11

seismic events or geologic discoveries show that the earthquake 12

that could cause the maximum vibratory ground motion at SONGS 2 13

and 3 has been assigned as the safe shutdown earthquake. 14

INSTRUCTIONS AND DEFINITIONS 15

For purposes of the responses contained herein, the 16

17 following definitions and instructions shall apply:

(a) The term "these interrogatories" refers to "INTER18

VENOR, FOE ET AL INTERROGATORIES TO SOUTHERN CALIFORNIA EDISON" 19 which were served by mail on Applicants on October 18, 1979.

20 (b) The term "FOE et al." refers jointly to the inter

21 venors propounding these interrogatories; namely, Friends of the

22 Earth, Mr. and Mrs. August Carstens, Mr. and Mrs. Lloyd Von

23 Haden, and Mrs. Donis Davey.

24 (c) The term "Applicants" refers jointly to the

25 co-owners of San Onofre Nuclear Generating Station, Units 2 and

26 3, Southern California Edison Company and the San Diego Gas &

27 Electric Company.

28

2.

1 (d) The terms "SONGS 2 and 3" refers,to the San Onofre

2 Nuclear Generating Station, Units 2 and 3.

3 (e) The term "SCE" refers to the Southern California

4 Edison Company. The term "SDG&E" refers to San Diego Gas &

5 Electric Company.

6 (f) The term "FSAR" refers to the "Final Safety Analy

7 sis Report, San Onofre Nuclear Generating Station, Units 2 and

-8 3," which Applicants believe is currently available to the public

9 in the Public Documents Room of the Mission Viejo Public Library.

10 (g) Applicants occasionally refer to "Response to.NRC

11 Questions, San Onofre Nuclear Generating Station, Units 2 and

12 3." The Responses are formal submittals prepared by Applicants

13 in response to formal written questions of the NRC. The Respon

14 ses are found in three separate volumes and are included as part

15 of the FSAR. Applicants believe that the Responses are currently

16 available to the public in the Public Document Room of the Mis

17 sion Viejo Public Library.

18 (h) The term "NRC" refers to the United States Nuclear

19 Regulatory Commission.

20 (i) To enhance the completeness and responsiveness of

21 its-answers to these interrogatories, Applicants in answering

22 some of the interrogatories have provided references to portions

23 of the PSAR, FSAR, and the Responses to NRC questions which

24 Applicants believe to contain some or all information requested.

25 (j) In all instances,'SCE in response to these interro

26 gatories has provided such relevant, unprivileged, non-confiden

27 tial information that is responsive to each of these interroga

28 tories and that has either been submitted to the NRC by or on

3.

1 behalf of SCE or is available from SCE files and personnel.

2 (k) Where the interrogatories ask whether Applicants

3 have "analyzed" a document or subject, Applicants have defined

4 analysis to be where Applicants or its consultants have reviewed

5 the document or subject in the context of SONGS 2 and 3 and have

6 submitted a report of that review.

7 (1) Wrench Fault - A steeply inclined strike-slip

8 fault.

9 (m) Wrench Fault System - A group of genetically re

10 lated, sub-parallel, wrench faults occurring within a zone of

crustal deformation. Members of the wrench fault'system must all

12 have experienced the same sense of displacement within a single

13 tectonic regime but need not have formed at the same time nor

14 have been active during the same time interval.

15 (n) Wrench Fault Tectonics -.Crustal deformation re

16 sulting from strike-slip displacement along a deep-seated wrench

17 fault. In the area of interest, the deformation typically in

18 volves sedimentary formations that were deposited across the top

19 of the wrench fault.

20 (o) The term "PSAR" refers to the "Preliminary .Safety

21 Analysis Report, San Onofre Nuclear Generating Stations, Units 2

22 and 3" which Applicants believe is currently available to the

23 public in the Public Documents Room of the Mission Viejo Public

24 Library.

25 (p) Offshore Zone of Deformation ("OZD") as used in

26 this proceeding is a hypothesized zone of deformation which as

27 defined by the United States Geological Survey ("USGS") consists

28

4.

of the Newport-Inglewood zone of folds and faulting, the South 1.

Coast Offshore fault and the Rose Canyon fault zone. 2

INTERROGATORIES AND RESPONSES 3

INTERROGATORY NO. 1 4

Have you analyzed the reports concerning ground motion 5

6 potentials at the Vallecitos Nuclear Center that have been pub

lished by the Nuclear Regulatory Commission, the USGS, Friends of 7

the Earth, and licensee consultants since September 1977? 8

9 If so, would you state the results of such analysis.

RESPONSE TO INTERROGATORY NO. 1 10

Applicants have not analyzed the reports referenced in 11

12 Interrogatory No. 1.

13 Some of Applicants' consultants have been involved and

are knowledgeable concerning the Vallecitos Nuclear Center pro14

ceeding, but have not analyzed the referenced reports on behalf 15

of Applicants or in the context of this proceeding.

INTERROGATORY NO. 2

Do you agree that the USGS and the NRC Geosciences 18

branch have predicted ground motion in excess of 1.0g and surface

offset of 3.5 meters for a fault that is short, but structurally 20

related to a branch of the San Andreas? 21

If you do not agree, set forth the basis for such dis22

agreement. 23


25 Interrogatory No. 2 is vague and ambiguous. In re

26 sponding to this Interrogatory, Applicants have assumed this

question is based on the Vallecitos Nuclear Center Proceedings 27

and base their answer on that assumption. Applicants do not

5.

1 understand either the USGS or the NRC to have predicted ground

2 motion in excess of 1 g or surface offset of 3.5 meters from a

3 "short but structually related . . ." fault that is ". . . a

4 branch of the San Andreas." Applicants assume the referenced

5 fault to be the 8 - 12 km long Verona fault that has been hypo

6 thesized and postulated to be a splay of the Calaveras fault.

7 Applicants understand that the NRC Geosciences Branch

8 has postulated a free field instrumental peak acceleration in

9 excess of lg at a distance of 3.0 km from a magnitude 7 - 7-1/2

10 earthquake on the Calaveras fault, which is a branch of the San

11 Andreas.

12 Neither the NRC nor the USGS has estimated the peak

13 accelerations from earthquakes on the Verona fault because of the

14 absence of definitive assessment of the width, length and geo

15 metry of the Verona fault Zone.

16 Furthermore, neither the USGS nor the NRC has postul

17 ated a 3.5 meter surface offset for the Verona fault. They have,

18 however, postulated a maximum surface offset of 2.5 meters for

19 the Verona fault based on conservative assumptions in the absence

20 of certain geologic and tectonic data.

21 INTERROGATORY NO. 3

22 Have you analyzed the seismic and geologic reports re

23 garding the Auburn Dam, the Humboldt Bay reactor, and the Diablo

24 Canyon reactors referred to by Burt Slemmons on September 13,

25 1979, the meeting with the NRC and USGS in Menlo Park?

26 If so, state the results of your analysis.

27 RESPONSE TO INTERROGATORY NO. 3

28 Interrogatory 3 is vague and ambiguous. In order to

6.

1 respond to the Interrogatory, Applicants have assumed the ques

2 tion to be whether Applicants have reviewed the.seismic and geo

3 logic reports regarding the Auburn Dam, the Humboldt Bay reactor

4 and Diablo Canyon reactor to determine whether such studies are

5 consistent with the slip-rate/magnitude findings that were set

6 forth at the referenced September 13, 1979 meeting.

7 Based on that assumption, Applicants respond as fol

8 lows:

9 (a) Auburn Dam. Neither Applicants nor their consult

10 ants have analyzed the geologic and seismic reports prepared for

11 that project in the context of this San Onofre proceeding. -Cer

12 tain of Applicants' consultants are familiar with the geologic

13 and seismic reports at Auburn Dam.

14 (b) Humboldt Bay. Neither Applicants nor their con

15 sultants have analyzed the geologic and seismic reports prepared

16 for the Humboldt Bay project in the context of the San Onofre

17 proceeding. Certain of Applicants' consultants are familiar with

18 the geologic and seismic reports concerning Humboldt Bay.

19 (c) Diablo Canyon. Neither Applicants nor their con

20 sultants have analyzed the geologic and seismic reports prepared

21 for that project in the context of the San Onofre proceeding.

22 Certain of Applicants' consultants are familiar with the geologic

23 and seismic reports concerning Diablo Canyon.


25 What was the maximum possible EQ that was predicted for

26 the Newport Inglewood fault zone by the consultant reports pre

27 pared for Southern California Edison in regards to the Bolsa

28 Island Floating Nuclear Reactor that was planned to be cited

7.

1 offshore from Newport Beach?


3 The maximum possible earthquake predicted in the Bolsa

Island Nuclear Power and Desalinization Plant Project was magni

5 tude 6.5. This prediction was set forth in the consultants'

6 report as follows:

7 "The 1933 Long Beach Earthquake of magnitude 6.3 was the strongest shock known to be associated with

8 the Newport-Inglewood fault zone. The historic record is all too short, but the length of this fault

9 system, its known displacements and the tectonic configuration of the region lead to the conclusion that an earthquake greater than magnitude 6.5 originating in the vicinity of plant site is highly improbable during the next 50 years. In neither its length nor in its behavior during the late Ter

tiary and Quaternary times has the Newport-Inglewood fault system been similar to the great faults along which more severe earthquakes can be expected

13 in Southern California. (Bechtel Corporation,

14 1967, Detailed Investigation of Bolsa Island Site.)

15 Further, the PSAR in section 2.3.3.4 states that:

"Based on the seismic history of the Newport-Ingle16 wood fault zone, the length of the fault system,

its known displacements, and the tectonic configu17 ration of the region, the conclusion has been

18 reached by Bechtel and its consultants that an earthquake greater than magnitude 6.5 originating in the vicinity of the plant site is highly impro

19 bable during the next 50 years." (PSAR, 1967 Bolsa Island Nuclear Power and Desalinization

20 Plant, Part B, Preliminary Safety Analysis Report, Volume I, Southern California Edison Company and

21 San Diego Gas & Electric Company, Section 2.3.3.4.)


23 Would you agree with the statement: "Off-shore subsur

24

25 face studies of the Capistrano embayment indicate that several

26 significant faults may underly the general vicinity of the San

27 Onofre Site?"

28

1 If you do not agree with the above statement please

indicate which part of the statement you disagree with and the 2

3 basis for said disagreement.


5 The Interrogatory is vague and undefined. Applicants

6 do not know what technical meaning should be placed on the terms

7 significant faults" and "general vicinity of the San Onofre

8 Site." Applicants assume in the context of this question that

9 the term "significant faults" refers to faults that influence the

seismic design of this plant. Based on that definition, Appli

cants consider the closest "significant faults" to be those that

12 are elements of the Offshore Zone of Deformation which is ap

13 proximately five miles from the San Onofre site.


15 Do you agree that there are many short faults in the

16 Capistrano embayment and that these faults are typical of a

17 wrench tectonic system?

If you do not agree with this statement, state that

19 which you do not agree with and the basis for your disagreement.


21 No. There are few faults in the Capistrano embay

ment. The faults in the Capistrano embayment are not wrench 22

23 faults and are not typical of what Applicants would consider a

"wrench tectonic system." 24

INTERROGATORY NO. 7

26 -Do you agree that there is micro-seismic activity in

the Capistrano embayment and that this indicates that it is part 27

of an active tectonic system? 28

9.

1 If you do not agree, please state that which you do not

2 agree and the basis for your disagreement.


4 The extremely low level of microseismic activity (less

5 than one microseismic event in three days) and the spatial scat

6 tering of the epicenters of these events does not indicate that

7 the Capistrano embayment is part of an active tectonic system.

8 The criteria that would be indicative of an active tectonic sys

9 tem is the presence of a high level (several events to tens of

10 events per day) of microseismic activity and the alignment of

11 these events along a planar feature.


13 Do you, at the present time, have an on-going micro

14 seismic survey of the Capistrano embayment?


16 No. It is unnecessary for Applicants to maintain an

17 on-going microseismic survey of the Capistrano Embayment because

18 earthquakes with magnitudes 2-2.5 are routinely recorded by the

19 California Institute of Technology network.


21 Did you at any time conduct a microseismic survey of

22 the Capistrano embayment?

23 If so, give a summary of the results of that survey.


25 A microseismic survey of the Capistrano embayment was,

26 undertaken from April through July of 1975. The results of this

27 study are presented in Recent Geotechnical Studies, Soulhern

28 Orange County, California, February 1976, Enclosure 4, pages 4-7.

10.


2 Why did you discontinue the microseismic survey of the

Capistrano embayment? 3


See the Response to Interrogatory No. 8. .5


What ground motion measurements were recorded on the 7

8 Applicants' seismic instruments during the following earthquakes:

9 (a) The 1969 Laguna Beach Quake.

10 (b) The earthquake which occurred on January 2, 1975.

(c) The Los Angeles earthquake which occurred in Feb11

ruary of 1971. 12


Ground motion measurements recorded on the Applicants' 14

seismic instruments are identified below: 15

16 (a) There was no record of ground motion measurement of

the Laguna Beach October 27, 1969 event. 17

18 (b) There was no record of ground motion measurement of

the earthquake on or about January 2, 1975.

(c) It is assumed that this question refers to the Feb20

ruary 9, 1971 Sylmar Earthquake. The ground motion measurements, 21

as published in "Strong-motion Instrumental Data on the San Fer22

nando -Earthquake of February 9, 1971, D. E. Hudson, editor, 23

1971," were: 24

Down N33E N57W 25

26 .01 g .01 g .02'g


State the make and model of all instruments used at San 28

Onofre Nuclear Generating Station to measure ground motion.


3 The instrumentation presently installed in Unit.1 are:

4 Kinemetrics SMA 2

5 Kinemetrics SMA 3

6 Instruments are being installed for Units 2 & 3, but

7 the system is not operational.


9 Are the instruments used to measure ground motion at

10 San Onofre considered the best that the state of the art has to

11 offer?


13 The instruments at San Onofre are fully adequate to

14 measure ground acceleration between .01g and 1g.

INTERROGATORY NO. 14

16 Do the instruments used to measure ground motion at San

17 Onofre have automatic gain control?


19 No.


21 Do you agree that the recently discovered unmapped

22 faults in the area of the Cristianitos and Mission Viejo faults

23 are part of an active wrench tectonic system?

24 If you do not agree to this statement please state that

25 with which you do not agree and the basis for your disagreement.


27 The question does not adequately identify the "recently

28 discovered unmapped faults" so that they may be addressed.

12.

1 Presumably, the "recently discovered unmapped faults" are the

2 faults identified during the photo-lineament analysis performed

3 at the request of the NRC. The interpretation and significance

4 of these features are presented in Response to NRC Question

5 361.27.


7 Do you agree that the Mission Viejo fault could be a

8 branch of the Cristianitos fault?

9 If you do not agree with this statement please state

10 that with which you disagree and the basis for your disagreement.


12 No. There is no evidence indicating that the Cristi

13 anitos and the Mission Viejo faults are interconnected either at

14 ground surface or at depth. They are judged, therefore, not to

15 be branch faults. In any case, there is no evidence of Quater

16 nary displacements on either fault.


18 Do you agree that the Cristianitos fault has multiple

19 branches with subparallel and en echelon strands?

20 If you do not agree to this statement please state that

21 with which you do not agree and the basis for your disagreement.


23 No. Strands of the Cristianitos fault are not en

24 echelon. The Cristianitos fault has one major branch, the

25 Forster fault, which has a curved surface interconnecting with

26 the Cristianitos fault at either end. This creates a lens-shaped

27 fault-bounded block about 4 miles long on subsurface maps pre

28 pared by Jack West (1978). Minor faults are present in the

13.

1 general vicinity of the Cristianitos fault, but these are short

2 and have little stratigraphic separation. The minor faults are

3 not arranged in an en echelon pattern suggestive of right-slip

4 faulting. They should be viewed as secondary features produced

5 by normal slip on the Cristianitos fault rather than as branches

6 of the Cristianitos fault.

7 The Cristianitos fault is a relatively discrete fault

.8 rather than a broad zone of diffuse faulting. The main trace of

9 the Cristianitos fault is a sharp rupture surface along which

10 most of the stratigraphic separation is taken up along a shear

11 zone that is a few feet wide.


13 Do you agree that Faults E and F are branches of the

14 Cristianitos fault?

15 If you do not agree with this statement please state

16 that with which you do not agree and the basis for your disagree

17 ment.


19 Applicants assume the question refers to the faults

20 east of the Cristianitos fault as mapped by Perry Ehlig and Tom

21 Farley (in Geotechnical Studies, Northern San Diego County, Cali

22 fornia, October 1977, Enclosure 3). Based on that assumption,

23 the answer is no. Faults E and F are not connected to each other

24 nor to the Cristianitos fault, and are not branches of the Cris

25 tianitos. The two faults are short, and of small displacement

26 relative to the Cristianitos fault. Although both the E and F

27 faults are steeply inclined with their surface traces oriented at

28 a low angle to the trace of the Cristianitos fault, the separa

14.

tion on the E fault is in the opposite direction (down on the 1

2 east) from that on the Cristianitos fault. The area between the

3 E and F faults constitutes a shallow graben down-dropped relative

to the areas on either side. This structure is probably the 4

5 result of east-west crustal extension and may have originated

about the same time the Cristianitos fault began to develop.

7 Thre is no evidence of Quaternary displacement on either the E or

8 F fault. Fault E has been demonstrated to not displace an ele

vated marine terrace platform estimated to be at least 300,000

10 years old.


Do you agree that the Cristianitos fault is part of an

active wrench tectonic system? 13

If you do not agree with this statement please state 14

that with which you do not agree and the basis for your disagree15

ment. 16


No. The Cristianitos fault is not a wrench fault and 18

19 is not a part of an "active wrench tectonic system". The Cris

20 tianitos fault shows no evidence of Quaternary activity. It

formed during the late Miocene in association with east-west 21

crustal extension. 22


Is it possible that the Cristianitos fault has other 24

25 subparallel branches that have not yet been mapped?


27 In view of the extensive mapping by several investiga

28 tors, Applicants do not believe it is reasonably possible that

15.

1 the Cristianitos has other significant subparallel branches that

2 have not yet been mapped.


4 What data do you have to disprove the hypothesis that

5 the type A features observed in the site of excavation beneath.

6 Unit 2 are evidence of a branch of the Cristianitos fault?


8 The type A features are not faults and are not branches

9 of the Cristianitos fault. They are discontinuous joints along

10 which there has been a very small amount (1/2 to 4 inches) of

11 horizontal slip and no vertical slip. Their sense and amount of

12 movement, and their size and physical characteristics are vastly

different from those of the Cristianitos fault. Also, they 13

14 formed in response to a chiefly compressional environment,

whereas the Cristianitos fault formed as a result of extension.


17 What are the northerly and southerly points of termi

18 nation of the four strands of the type A shear zones in the plant

19 site?


21 Type A features terminate at many points within the

22 site by: (1) dying out, (2) merging with other features, and

23 (3) truncation by type B features. Features A-1 to A-4 display

24 their greatest width and prominence in'the central part of the

site (near their intersection with features B-5 and B-6). They 25

26 narrow progressively toward the north and south where they are

overlain by old terrace deposits and/or modern beach sand before 27

28 they can be observed to die out completely or terminate.

16.


2 What data do you have to disprove the hypothesis that

the shear zones observed in the quarry and sea cliff approxi3

4 mately 1.7 miles northwest of the site are evidence of another

branch of the Cristianitos fault? 5

RESPONSE TO INTERROGATORY NO. 23

7 See the response to Interrogatory 21.


9 What evidence do you have to disprove the hypothesis

that because San Onofre Nuclear Generating Station are underlain 10

by conjugate sets of fractures and shear joints, and because 11

these features -are more exposed by excavations, that the struc12

tures and ground.surface may experience greater seismic shaking 13

effects than when they were still buried? 14


The conjugate sets of fractures and shear joints at the 16

site will not cause the site structures and ground surface to 17

experience any greater seismic shaking effects because: 18

(l) None of the features are open fissures. Those 19

that appear to have less strength than the parent rock formation 20

are the C and D features which are few in number and of limited 21

extent; 22

(2) The reduction of overburden pressure resulting 23

from site excavation (85 feet) is small relative to the several 24

hundred feet of overburden that has been removed by natural ero25

sion since the features were formed several hundred-thousand 26

years ago; and some of the recent unloading has been replaced by 27

the power plant structures; 28

17.

(3) The A and B features are not now planes of

2 weakness; they have greater strength and density than the parent

3 rock;

4 (4) No movement on any of these features has oc

5 curred during the last 125,000 years of regional tectonic stress

6 and earthquake shaking, as testified to by the undisturbed marine

7 terrace deposits of that age overlying the features at the site.


9 Has any study been made of those fractures known as

10 feature A, feature B, feature C and feature D which relates them

11 to potential rupture due to seismic shaking?

12 If so, please give a summary of the result of that

13 study.


15 No studies have been made of what are identified as the

16 A, B, C and D features which relate them to potential rupture due

17 to seismic shaking..


19 Do you agree that the faults to the east of the Cris

20 tianitos fault, but west of the San Andreas fault are features of

21 an active wrench tectonic system?


23 Only those faults that are genetically related, north

24 west-trending, subparallel, dominantly'right-hand, strike-slip

25 faults, such as the San Jacinto and Whittier Elsinore faults, are

26 features of the active San Andreas wrench fault system.

27

28

18.



3 that the Cristianitos fault and 3 of its branches are structur

4 ally related to the Off-shore Zone of Deformation-as subparallel

5 branches or splays that branched off from the main fault zone?


7 Applicants are unsure of the precise meaning of the

8 Interrogatory and have assumed its intended meaning to be: "Is

9 the Cristianitos Fault a branch or splay of the Offshore Zone of

10 Deformation?" The response to this question is no.

11 Whereas the OZD is considered to be dominated by

12 strike-slip faulting, the Cristianitos fault is a westward dip

13 ping normal slip fault, with no evidence of strike-slip displace

14 ment along it. Its normal-slip motions can be observed in

15 exposure within the seacliff at San Onofre where the fault plan

16 dips about 600 west with slickensides oriented down dip. Along

17 the entire onshore length of the Cristianitos fault the west side

18 of the fault is down. Displacement on the Cristianitos fault

19 decreases in a southward direction in the vicinity of the coast

20 and the fault dies out before reaching the OZD particularly in

21 the near surface sediments.


23 Have any reports or analysis been prepared regarding

24 the structural relationships between the Cristianitos and the OZD

25 as evidenced in the map produced by Woodward-Clyde Consultants

26 and submitted with the June 1979 report as figure D-l? If such

27 reports or analysis have been prepared, please send a copy along

28 with the answers to these interrogatories.

19.


2 The structural relationships between the Cristianitos

3 fault and the OZD have been analyzed. The reports were submitted

4 in the PSAR, Appendices 2B, 2C and 2E.



7 that an earthquake offshore from SONGS with its epicenter several

8 km south of the reactors and south of the point at which the

9 Cristianitos and .its branches intersect with the Offshore Zone of

10 Deformation could cause rupture propagation directed towards the

11 branches of the Cristianitos Fault and could cause amplification

12 of ground motions on the shoreline where the Cristianitos goes

13 out to sea?


15 As described in the response to Question 27 above, the

16 several million-year history of the Cristianitos fault and the

17 OZD demonstrates that movement on the OZD does not result in

18 movement on the Cristianitos.


20 Have you or your consultants ever analyzed the poten

21 tial ground motions that would result from directivity of seismic

waves from the Offshore Zone of Deformation with lesser motion 22

23 onto the Cristianitos Fault Zone?

24 If so, please submit a summary of said analysis.


26 Applicants are again unsure of the precise meaning of

27 the question and respond assuming the question to be: "Have you

28 or your consultants ever analyzed the potential ground motions at

20.

1 the San Onofre site resulting from earthquake rupture along the

2 OZD with sympathetic earth movement on the Cristianitos fault

3 zone?"

4 Applicants have analyzed every reasonably possible

5 ground motion that could result from movement-on the OZD. Appli

6 cants do not consider the hypothesis set forth in the Interroga

7 tory to be reasonable based on the structural relationship betwen

8 the OZD and the Cristianitos fault. If sympathetic motions along

9 the Cristianitos fault zone could reasonably occur as the result

10 of rupture along the Offshore Zone Deformation, then evidence of

11 such events should be recorded in the geologic record along the

12 Cristianitos fault zone. The geologic evidence indicates that no

13 movement has occurred on the Cristianitos fault zone for at least

14 125,000 years. During this period of time, there have been many

15 opportunities for sympathetic motions to have occurred on the

16 Cristianitos fault. The fact that such motions have not occurred

17 during at least the last 125,000 years is sufficient to conclude

18 that such a chain of events is implausible.


20 Have you or your consultants ever analyzed the ground

21 motions that would result at the site from focusing effects (as

22 described by Dr. Brune in Testimony on Ground Motions at the

23 Diablo Canyon hearings) that could effect the Cristianitos fault

24 or its branches during an offshore event on the Off-shore Zone of

25 Deformation?

26 If the answer to the above question is yes, please

27 submit the results of such analysis.

28

21.


2 Applicants have considered the potential effects at the

3 site of focusing related to an event on the OZD. Applicants do

4 not believe that focusing of energy related to an event on the

5 OZD would have any effect on the Cristianitos fault.



8 that the Cristianitos fault is a potentially active and capable

9 fault?


11 The Applicants have made several submittals that docu

12 ment that the Cristianitos fault is not active in accordance with

13 10 CFR 100, Appendix A. These submittals include:

14 Preliminary Safety Analysis Report, May 1970,

15 Final Safety Analysis Report, March 21, 1977,

16 Recent Geotechnical Studies, Southern Orange County,

17 California 1976,

18 Geotechnical Studies Northern San Diego County, Cali

19 fornia 1977,

20 Late Quaternary Evolution of the Camp Pendleton-San

21 Onofre State Beach Coastal Area, Northwestern San Diego County,

22 California 1978.

23 This conclusion was supported in the AEC Staff Safety Evaluation

24 Report, Construction Permit Stage.


26 What evidence do you have to disprove the theory that

27 the Rose Canyon Fault Zone includes the San Ysidro Fault, and is

28 structurally related to the Vallecitos Fault and the San Miguel

22.

1 Fault in Baja?


3 Although the Rose Canyon, Vallecitos and San Miguel

4 faults are crudely aligned along the same general trend, they are

5 characterized by small'displacements, by a lack of interconnec

6 tion and by apparent differences in their histories.

7 The Rose Canyon fault zone has been mapped from off

8 shore north of La Jolla southeasterly to just east of the Broad

9 way Pier near the northern end of San Diego Bay. It cannot be

10 traced farther to the south either by field mapping, examination

11 of aerial photographs, or from historic seismicity. Thus, there

12 is no apparent physical connection between the Rose Canyon and

13 San Ysidro faults.' The style of faulting is also different be

14 tween the two faults. The Rose Canyon fault is inferred to have

15 strike-slip displacement with variable amounts and sense of ver

16 tical displacement, characteristic of wrench fault tectonics. In

17 contrast, the northwest trending San Ysidro fault zone exhibits

18 only normal, down to the west, displacement and appears to be

19 more similar in style and tectonic setting to the adjacent north

20 trending normal La Nacion fault.

21 There is an approximate 34 mi (55 km) gap between the

22 south end of the mapped Rose Canyon fault zone and the northern

23 end of the Vallecitos fault, where no evidence has been found to

24 link these two faults. The northwestetn-most mapped trace of the

25 Vallecitos fault ends about 18 mi (29 km) southeast of Tijuana

26 and appears to either die out, or to be covered by Eocene age

27 conglomerates (Gastil et al., 1979).

28 The.San Miguel fault which lies farther to the south

23.

1 consists of two segments but does not connect with the Vallecitos

2 fault. Therefore, the San Miguel fault is not considered to be

3 associated with the Rose Canyon fault.

4 Applicants see no special significance in the approxi

5 mate alignment of the Rose Canyon, San Ysidro, Vallecitos and San

6 Miguel faults.



9 that the San Miguel fault is structurally related to the Plate

10 Boundary System or Transform Zone in the Gulf of .California?


12 The San Miguel fault has a mapped length of about 50 mi

13 (80 km), (Gastil et al., 1979). Its southeastern end would have

14 to extend an additional 55 mi (90 km) to reach the coast of the

15 Gulf of California. The absence of evidence indicating through

16 going fault within the 55 mi (90 km) interval argues against the

17 San Miguel fault being connected to a transform fault within the

18 gulf. The lack of significant strike-slip displacement (only 100

19 m) along the San Miguel fault, as mapped by Gastil et al.,

20 (1979), also argues against its being a transform fault. Fur

21 thermore, Gastil et al., (1979) state that "the concept that the

22 right-lateral motion on scattered fault traces through northwes

23 tern Baja Calfiornia is part of the plate boundary motion between

the Pacific and North American plates,' is hard-pressed to explain 24

25 the apparent discontinuity of these fault segments."


27 What research reports have you analyzed concerning the

28 active fault systems and historic seismicity in Northern Baja

24.

California?


3 Published research papers, analyzed and referenced in

4 preparation of the ,FSAR and the Woodward-Clyde Consultants June

5 1979 submittal that concern active fault systems and historic

6 seismicity in Northern Baja Calfiornia are presented below.

7 1. Shepard, F. P., and Emery, K. 0., "Submarine Topo

8 graphy of the California Coast," Geological Society of America,

9 Special Paper 31, 1941.

10 2. Moore, D. G., "Reflection Profiling Studies of the

11 California Continental Borderland: Structure and Quaternary

12 Turbidity Basins," Geological Society of America, Special Paper

13 107, 111. pp, 1972.

14 3. Jahns, R. H., "Investigations and Problems of.

15 Southern California," in Geology of Southern California: Cali

16> fornia Division of Mines, Bulletin 170, pp. 5-29, 1954.

17 4. Weigand, J. W., "Evidence of a San Diego Bay

18 Tijuana Fault" Association of Engineering Geologists, Bulletin 7,

19 pp. 107-121, 1970.

20 5. Allen, C.R., et al., "Relationship Between Seis

21 micity and Geologic Structure in the Southern California Region,"

22 Bulletin of the Seismological Society of America, Vol. 55, No. 4,

23 pp. 753-797, 1965.

24 .6. Richter, C. F., Elementary Seismology, W. H.

25 Freeman and Company, San Francisco, California, 768 pp., 1958.

26 7. Atwater, T., "Implications of Plate Tectonics for

27 the Cenozoic Tectonic Evolution of Western North America,"

28

25.

1 Geological Society of America Bulletin, Vol. 81, pp. 3513-3536,

2 1970.

3 8. Gastil, R. G., Phillips, R. P., and Edwin, C. A.,

4 "Reconnaissance Geologic Map of the State of Baja California,

5 Plate lA, Scale 1:250,0000," Geological Society of America,

6 Memoir 140, 1975.

7 9. National Oceanographic and Atmospheric Administra

8 tion Data File, 1975.

9 10. Emery, K. 0., 1960, The Sea off Southern Cali

10 fornia: John Wiley and Sons, New York, p. 366, cited in Albee,

11 A. L., and Smith, J. L., 1966, Earthquake Characteristics and

12 Fault Activity in Southern California, in Lung, R. and Proctor,

13 R., eds, Engineering Geology in Southern California: Association

14 of Engineering Geologists Special Publication.

15 11. Corey, W. H., 1954, Tertiary Basins of Southern

16 California, in Geology of Southern California: California

17 Division.of Mines and Geology Bulletin 170, Chap. 3, pp. 73-83.

18 12. King, P. B., 1969, "The Tectonics of North

19 America": U. S. Geological Survey Professional Paper 628, p. 94.

20 13. Moore, G. W., 1972, "Offshore Extension of the Rose

21 Canyon Fault, San Diego, California": U. S. Geological Survey

22 Professional Paper 800-C, pp. 113-116.

23 14. Moore, G. W., and Kennedy, M. P., 1975, "Quaternary

24 Faults at San Diego Bay, California": Journal of Research of the

25 U.S. Geological Survey, Vol. 3, No. 5, pp. 589-595.

26 .5. Allen, C. R., Silver, L. T., and Stehli, F. G.,

27 "Agua Blanca Fault, A Major Transverse Structure of Northern Baja

28 California, Mexico," Geological Society of America, Bulletin 71,

26.

pp. 457-482, 1960. 2 INTERROGATORY NO. 36

3 Have the applicants or their consultants analyzed any

of the reports listed in the enclosed "schedule of speakers" from 5 the recent symposium on the San Andreas Fault System sponsored

6 jointly by the States of California and Baja California?


8 The Applicants' consultant, Dr. Karen McNally, was a

9 participant in the referenced meeting. To the extent that Dr.

10 McNally presented one of the papers that particular paperwas

11 analyzed. No specific analysis has been carried out by the

12 Applicants or its consultants in the context of this proceeding

13 on any of the other papers (reports) listed.


15 What evidence do the Applicants have to disprove the

16 hypothesis that the Off-shore Zone of Deformation is one con

17 tinuous tectonic system including the Newport-Inglewood-Rose

18 Canyon-San Miguel segments?


20 The.meaning of "tectonic system" is ambiguous when

21 modified by the phrase "one continuous" and when it includes "the

22 San Miguel segment".

23 First, the "San Miguel (fault)" in Baja California is

24 not related to the Newport-Inglewood and Rose Canyon zones, as

25 explained in the response to Interrogatories Nos. 33 and 34.

26 Thus, it is not a part of the OZD.

27 The OZD is a "tectonic system", the characteristics and

28 geologic relationships of which vary along its length in ways

hat significantly bear on the question of its continuity. For 2

xample, the Newport-Inglewood segment of the zone displays many 3 well-defined faults and folds in the Upper Tertiary sedimentary

4 section, whereas such structural features are few and less well

5 Sefined in the southern segments of the OZD. While a major

6 7asement-rock discontinuity is presumed to directly underlie the

7 8Newport-Inglewood zone, no evidence of a similar coincidence is

8

apparent for the southern segment of the OZD.

Changes in tectonic style and degree of activity are 10

evidenced along the OZD with respect to terrace uplift and warp11

ing, density of faulting, and complexity of geology represented 12

in seismic profiling surveys. An example of this is to be found 13

in the San Joaquin Hills and its offshore extension, which lies 14

across the Offshore Zone of Deformation and intervenes between 15

the southern and Newport-Inglewood segments of the OZD. 16

As evidenced by the offshore mapping of Western Geo17

physical Company (Figs. 2E-2 and 2E-3, App. 2E, Amend. No. 11, 18

PSAR), there is no "one continuous" fault in the upper tertiary 19

sediments of Horizon B and the pre-upper tertiary acoustic base20

ment (Horizon C). 21

The foregoing contrasts indicate that, while the OZD is 22

a long zone of deformation, which may coincide with a basement23

rock discontinuity in its northern reach, the tectonic character 24

and activity along the zone is not continuous. The conclusion 25

can, therefore, be drawn that the OZD is not "one continuous 26

tectonic system". 27


How would the added length of this active tectonic zone

28.

increase the potential magnitude of a postulated maximum earth2

quake? 3 RESPONSE TO.INTERROGATORY NO. 38

4 It is not the total mapped or inferred length of a

5 tenuously connected tectonic zone that controls the magnitude,

6 but rather it is the area and slip of an individual rupture seg

7

8 ment which is related to the surface wave magnitude Ms. The

local magnitude ML, which is more closely related to peak ground

otion, is controlled by a number of other seismic parameters 10

involving rupture dynamics and is not significantly affected by 11

rupture lengths of more than 40-50 km. 12


What evidence do the applicants have to disprove the 14

hypothesis that .the Newport-Inglewood-Rose Canyon-San Miguel 15

fault zone could generate an earthquake of M8 or larger because 16

of its structural relationship to the San Andreas System and the 17

transform Plate Boundary tectonic of the Gulf of California? 18


Applicants are not aware of any evidence to support the 20

hypothesis that the Newport-Inglewood, Rose Canyon, and San 21

Miguel faults are connected and form a single fault zone. The 22

San Miguel fault cannot be traced on the ground to within 65 mi 23

of the Rose Canyon fault. The San Miguel fault is unrelated to 24

the SONGS site some 125 mi distant. 25

The regional tectonics of southern California are domi26

nated by the San Andreas fault system, which is believed to rep27

resent the boundary between the Pacific and North American 28

plates. This system consists of the large northwest-trending San

Andreas and San Jacinto fault zones and is paralleled to the west 2

by other smaller fault zones such as the Whittier-Elsinore fault 3

zone, and the Newport-Inglewood zone. The apparent uniformity in 4

deformational style among these zones suggests the presence of a 5

dominating regional-scale stress regime in southern California, 6

especially south of the Transverse Ranges. While these fault 7

zones show evidence of predominant right-lateral offset, the 8

faults to the west of the San Andreas zone show a progressive 9

westward decrease in the degree of fault activity. Such decrease 10

is reflected by decreases in total displacement, continuity of 11

surface trace,.long-term slip rate, and amount of seismic activ12

ity (including maximum earthquakes and historic rupture lengths). 13

Thus, the Newport-Inglewood and Rose Canyon zones, some 14

35-60 mi away from the San Andreas fault, are much less affected 15

by the stress regime from this plate boundary than are those 16

faults which are closer to or connect with the San Andreas 17

fault. The stress levels and earthquake potential are cor18

respondingly less for the Newport-Inglewood and Rose Canyon 19

zones. This, in the Applicants' view, precludes the possibility 20

of a great earthquake occurring on either the Newport-Inglewood 21

or Rose Canyon zones. 22


Do you agree that the faulting patterns around SONGS 24

are typical of faults in a wrench tectonic system common to the 25

Southern California Coastal Region? 26

If you do not agree, state the basis for your disagree27

ment. 28


2 No. There are some faults in the region "around" SONGS

3 that have some characteristics "common" to those of wrench faults

4 and wrench fault systems. However, such characteristics by them

5 selves are not diagnostic of wrench faulting, and do not indicate

6 whether the faults might be termed "wrench", "synthetic faults"

7 or "antithetic faults".

8 The "faulting pattern" offshore along the OZD is sug

9 gestive of wrench faulting. The "faulting pattern" onshore is

10 not. This is due chiefly to the dip-slip nature of most onshore

11 faults in the SONGS vicinity.


13 Has the applicant analyzed the following reports on

14 seismic gaps:

15 a. "Source of Seismic Gap--Rupture Propagation on

16 Plate Boundary" June 1978, MIT, Proceedings of the 5th, U.S. Council on Earthquake Engineering Re

17 search, by Akai.

18 b. "Seismic Gaps and Plate Tectonics: Seismic Potential for Major Plate Boundaries" by McCann,

19 Nishenko, Sykes, and Krause. Presented at the GSA Annual Conference in S.F. November 1978.

20 ANSWER TO INTERROGATORY NO. 41

21 Applicants have not analyzed the referenced reports in

22 the context of SONGS 2 & 3. Applicants' consultants are aware of

23 the referenced reports and are generally knowledgeable concerning

24 their contents.


26 What evidence do the applicants have to disprove tne

27 hypothesis that the Cristianitos Fault and its branches are part

28 of a seismic gap?


2 The term seismic gap refers to any region along an

3 active plate boundary that has not experienced a large thrust or

4 strike-slip earthquake for more than 30 years (McCann and others,

5 1978). The Cristianitos fault is not an active or inactive plate

6 boundary. Thrust or strike-slip motion is not compatible with

7 the geology of the Cristianitos fault. There is positive evi

8 dence of no surface faulting on the Cristianitos fault for at

9 least 125,000 years.


11 If either the Off-Shore Zone of Deformation or the

12 Cristianitos Fault were in aseismic gap, what do you estimate

13 would be the recurrence interval?


15 The term seismic gap as used in the reports referred to

16 in Interrogatory No. 41, has reference to plate boundaries. In

17 the Southern California region the plate boundary is clearly the

18 San Andreas fault zone in the Imperial Valley and not the OZD.

19 Applicants have taken the rate of deformation on the

20 more active Newport Inglewood zone to the north as a conservative

21 basis for estimating the maximum event on the OZD. In this

22. sense, Applicants have treated the OZD as a seismic gap and has

23 derived a recurrence rate of more thanseveral hundred years for

24 the maximum magnitude earthquake. See response to Interrogatory

25 No. 72 with respect to the Christianitos Fault.


27 What research have you done on the basement rocks be

28 neath the Off-Shore Zone of Deformation to determine if there is

1 one continuous fault at that depth?


3 Investigations have been conducted to the acoustic

4 basement beneath the Offshore Zone of Deformation to determine if

5 there is one continuous fault at depth. These investigations

6 included analysis of about 1275 miles of seismic reflection data,

7 several seismic refraction profiles and approximately 450 miles

*8 of seaborne.magnetometer data. These data resulted in a series

9 of structural contour maps, fault and structural lineament maps,

10 annotated seismic cross sections and magnetic anomaly maps.

11 In addition several reports were analyzed including:

12 Harrision, J. C., Von Huene, R. E., and Corbato,

13 C. E., 1966, Bouguer Gravity Anomalies and Magnetic Anomalies

14 Off the Coast of Southern California: Journal of Geophysical

15 Research, Vol. 71, pp. 4921-4941.

16 Hill, M., 1971, Newport-Inglewood Zone and Mesozoic

17 Subduction, California, Geological Society of America Bul

18 letin, Vol. 82, pp. 2957-2962.

19 Shor, G. G., and Raitt, R. W., 1958, Seismic Stu

20 dies in the Southern California Continental Borderland,

21 Section 9(2) - Geofisica Aplicada, International Geological

22 Congress Proc. (20th), Mexico, D. F.

23 The log from the San Clemente Core hole (Mobil Oil) was

24 reviewed and incorporated into the analysis.

25 Geophysical data of the shallow material were reviewed

26 for any possible correlation with fault continuity at depth.

27 These data included work by Woodward-Clyde Consultants and Fugro,

28 Inc.

33.

1 Review of USGS Preliminary Report on the Geology of the 2 Continental Borderland of Southern California (MF-624) by J. H.

Vedder, et al., was also completed in order to assess continuity

4 of faults beneath the Offshore Zone of Deformation.


6 How deep have your refraction and reflection techniques

measured the fractures?


The geophysical studies by Western Geophysical provided

10 information on fractures in the acoustic basement to a depth of

11 about 10,000 feet or more below the sea floor.


13 What evidence of thrust faulting have been observed

14 onshore and offshore?


16 There is no evidence of thrust faults within the on17 shore or offshore area surrounding San Onofre and no reason to 18 suspect that thrust faulting will occur within this area during 19 the foreseeable future. The nearest active thrust faults are 20 along the southern margin of the Transverse Ranges more than 50

21 miles to the north of San Onofre. No comparable feature is

22 present south of the transverse ranges and certainly none in the 23 San Onofre area.


25 Have you considered the possibility of thrust faulting 26 on the Off-Shore Zone of Deformation?

27

28

34.


2 Yes. The northernmost section, the Newport-Inglewood

3 Zone of Deformation, contains evidence of minor thrust fault4

ing. Further south there is no evidence of .thrust faulting 'in the offshore elements of the OZD.

6 6 INTERROGATORY NO. 48

7 What peak ground acceleration at SONGS would you pre8 dict from the maximum possible EQ due to thrust faulting on the 9

Offshore Zone of Deformation?


11 As explained in the Interrogatory No. 47, with the 12 exception of the northernmost section at the Newport-Inglewood

13 segment of the OZD, thrust faulting along the offshore zone of

14 deformation is not consistent with the geologic data. Applicants do not consider thrust faulting to be reasonably possible on the

16 OZD.

17 Estimates of peak ground acceleration for the San 18 Onofre site are based on strong motion recordings of past earth19 quakes. A significant portion of these data are associated with 20 thrust faulting. Furthermore, strike-slip earthquakes generally 21 have varying degrees of dip-slip components. Consequently,

22 estimates of peak ground acceleration at the San Onofre site are 23 not limited to strike-slip faulting.


25 Would you consider thrust faulting unusual or typical 26 of active wrench tectonic systems with conjugate faulting? 27 RESPONSE TO INTERROGATORY NO. 49

28 Thrust faults are not unusual in association with

35.

wrench fault tectonics. However, they are secondary and rela2 tively minor in number or in amount of slip. An exception occurs

in the Transverse Range Province where the "big bend" in the San Andreas fault causes interplate convergence resulting in exten

.sive thrust faulting along an east-west trending zone. 6 INTERROGATORY NO. 50

Do you agree that microseismicity can indicate the

8 presence of active faults?

If you disagree please state the basis for your dis10 agreement.


12 Microseimicity can indicate the presence of active 13 faults, but is not necessarily sufficient to determine the 14 activity of a specific fault. In order to show active faulting, 15 the seismicity must show both alignment along a subsurface planar 16 surface and also have focal mechanisms consistent with that 17 surface.


19 19Do you agree that accumulated stress on major faults

20 can be transferred to secondary faults or to en echelon strands 21 or to branches?


23 Yes, provided that the secondary, en echelon and 24 branching faults are presently active and are related both in 25 time and space to the major fault.


27 How wide do you calculate the plate boundary system to 28 be in southern California?

36.


2 The term "plate boundary" is ambiguous when modified by

"system" without explanation. There is a plate boundary in 4 Southern California, and there have been other plate boundaries

in the geologic past. Of relevance to the seismic potential at 6 SONGS is the present position and width of the present plate 7 boundary. The width of a so-called system of plate boundaries is 8

of limited significance.

9 The San Andreas fault zone is the present plate boun

10 dary in southern California, and has been so for about 4 million 11 years. Depending on the latitude where it is measured, the width 12 of the San Andreas fault zone is highly variable. It probably 13 approaches its maximum dimension in the Salton Trough where its 14 width is on the order of 36 miles, including the San Jacinto 15

fault.


17 Do you agree that in a wrench tectonic model there is 18 torquing on the structural blocks?

19 19 If you do not agree, state the basis of your disagree20 ment.


22 Presumably, the question mistakenly used torquing for 23 rotation. Rotation and rotational strain are parts of a wrench 24 tectonic model in any simple shear couple, and part of the de25 formation in a wrench tectonic model is rotational. This rota26 tional strain can be regional or highly local in response to the 27 regional shear couple.

28

37.


2 Do you agree that wrench tectonic systems are charac

terized by en echelon and subparallel faulting, and plastic de

formations?


Again, the unqualified use of terms such as "systems" and "characterized by" makes the question ambiguous. If "wrench

8 tectonic system" means wrench fault system, then the response to 9

the question is affirmative. In this case, "plastic deforma10 tions" means folds, and other forms of aseismic deformation and 11 "faulting" means faults having orientation and senses of slip 12 consistent with wrench faulting.

13 As stated in the response to Interrogatory No. 40, the 14 presence of en echelon and subparallel faults and folds in a 15 region is not singularly diagnostic of wrench faulting. Critical 16 genetic, age and geometric relationships are also required. 17 INTERROGATORY NO. 55

18 Do you think that faulting at great depths on a plate 19 boundary would necessarily cause surface rupture?


21 Yes, depending on the depth, amount and cumulative-slip

22 of faulting events. A single small movement at depth would not 23 necessarily cause surface rupture; but many such events over 24 geologic time spans would contribute strain that would ultimately 25 reach the surface, probably in association with a much larger 26 event. For an active fault the probability of surface rupture 27 accompanying rupture at depth increases with the rate of slip on 28 the fault as manifested by the cumulative displacement for

38.

10 1 periods thousands of years and longer. The historic record of 2 earthquakes in southern California and in similar tectonic

regimes has shown that moderate to large earthquakes of shallow 4

focus (faulting at depth less than 20km) are commonly associated

5 with surface fault rupture.


7 Do you have any data or evidence that would contradict

8 the hypothesis that a single continuous fault in the basement 9 rocks of the Newport-Inglewood Rose Canyon Fault Zone would not

10 necessarily cause surface faulting in the ductile sedimentary

11 deposits near the surface?

12 If so, please provide us with such data and evidence. 13 RESPONSE TO INTERROGATORY NO. 56

14 The question is irrelevant because it says nothing about movement on the "fault in the basement rocks", which

16 movement must actually occur first before any surface manifesta17 tion by earthquakes or rupture can be considered. If the "fault 18 in basement" is not active and displays no evidence of recent 19 movement, whether at the surface or at depth, then there is no 20 reason to expect that it would cause surface faulting. If the 21 "fault" is active, then the circumstances of the response to 22 Interrogatory No. 55 prevail.

23 There is no evidence to support the Interrogatory's 24 presumption of a "single continuous fault in basement rocks", nor 25 the use of the term "Fault Zone" for the Newport-Inglewood to 26 Rose Canyon train of structural features. The deepest evidence 27 I. approaching basement rock depth is that presented in Figure 2E-2 28 (referenced earlier), which clearly shows the absence of "a

39.

1 single continuous fault" and instead displays a broad complex of 2 deformational features that are not properly described as a fault

3 zone.


Do you have any evidence that there is not one contin6 uous fault in.the basement rocks along the Newport-Inglewood-Rose 7

Canyon Zone?

8 RESPONSE TO INTERROGATORY NO. 57 9

Yes. The extensive offshore geophysical profiling 10 performed in 1972 by Western Geophysical provides evidence that

11 faulting in the acoustic basement along the OZD consists of 12 discontinuous folds and faults and an absence of a continuous 13 fault. This position is supported by the USGS in their assess14 ment in the SER of a zone that extends from Santa Monica to the 15 Mexican border, and one "Preliminary Map Showing Recency of 16 Faulting in Southern California (MF-585)", J. I. Ziony et. al., 17 1974.

18 Essentially all studies of the Newport-Inglewood Zone 19 of Deformation support the existence of a zone of en echelon

20 folds and faults which is believed to extend into the basement

21 rocks.


23 Do you agree with the statement, "little strong motion 24 data is available at distances of less than 10 km from the rup25 ture surface. Hence, estimates of ground motion at San Onofre 26 from a major earthquake along the hypothesized zone of deforma27 tion approximately eight km offshore from the site would have 28 significant uncertainty when based on empirical data"?

40.

1 If not, state the basis for your disagreement. 2 RESPONSE TO INTERROGATORY NO. 58

The majority of recorded earthquake strong motions have 4 been obtained at distances greater than approximately 25 km from

the zone of energy release. However, sufficient recordings have 6 been obtained near the distance of 8 to 10 km for well-documented 7

earthquakes to provide statistically and physically meaningful 8 ground motion estimates for the San Onofre site. On that basis 9

Applicants disagree with the statement set forth in Interrogatory 10 No. 58.


12 Do you believe that you have adequate data to predict 13 future seismicity on the Off-Shore Zone of Deformation by anal14 yzing historic records?


16 The historical.seismicity data are not sufficient, so 17 analysis of possible future seismicity has included geologic, 18 geophysical, and tectonic data and analyses. 19 INTERROGATORY NO. 60

20 Describe all vertical offsets or scarps that have been 21 observed offshore from SONGS within a 20-mile radius. 22 RESPONSE TO INTERROGATORY NO. 60

23 Four possible abrupt changes in the elevation of the 24 sea floor (Horizon A), which may be vertical offsets or fault 25 scarps have been observed within a 20-mile radius of SONGS. This 26 is based on continuous-recording fathometer data by Western 27 Geophysical.

28

41.

1* These features lie from 9 to 18 miles southwest of

2 SONGS, at least 5 miles offshore and are no more than 5 miles in 3 length. Resolution of the data is 1-2 fathoms suggesting vert4 ical seafloor offset on the order of 6-12 feet. 5 Comparison of these features with deeper horizons does 6 not suggest a relationship with any significant geologic struc7

ture. 8


How wide do you consider the offshore continental bor10 derlands zone of deformation to be?

11 IRESPONSE TO INTERROGATORY NO. 61 12 Applicants are not able to define the term "offshore 13 continental borderlands zone of deformation." Assuming the ques14 tion to address the Southern California Continental Borderland 15 without the implication of a "zone of deformation", the Southern 16 California Continental Borderland geomorphic province is bordered 17

on its western edge by the Patton Escarpment some 140 miles 18

southwest of SONGS. However, near its northern terminus the 19

province is less than 40 miles wide. 20


21 How far would you estimate to be the extent of ground 22 strains and land deformations associated with the San Andreas 23 Fault System?

24 RESPONSE TO INTERROGATORY NO. 62 25 Applicants consider the influence of the San Andreas 26 plate boundary in Southern California is evidenced with decreas27

ing intensity out to distances of approximately 200 miles. 28

42.

1 Measurements of tectonic activity decrease the further one gets 2 from the plate boundary.

3 INTERROGATORY NO. 63 4

Have you researched the reports referred to by 5

Dr. Wayne Thatcher of the USGC speaking at the opening session of 6 the American Geophysical Union's annual meeting in December 1977. 7


The referenced report, "Horizontal Crustal Deformation 9

From Historic Geodetic Measurements in Southern California" Wayne 10 Thatcher, Journal of Geophysical Research, Vol. 84, No. B-5, May, 11 1979 is one which Applicants are knowledgeable concerning but 12 have not analyzed in the context of this proceeding. 13 INTERROGATORY NO. 64 14

What evidence do you have to disprove the hypothesis 15'

that faults parallel to the San Andreas Fault, such as the San 16 Jacinto, Elsinore and Newport-Inglewood, absorb strain and stress 17 from the seismic nature of the plate boundary? 18 RESPONSE TO INTERROGATORY NO. 64 19 The named faults parallel to the San Andreas respond to 20 the regional stress system associated with the Pacific-North 21 American plate boundary. In this context the parallel faults 22 respond in a fashion particular to each fault and are character23 ized by slip rates, total displacements, and other deformation 24 measures decreasing with distance away from the San Andreas. 25 Use of the term "absorb strain and stress" is non26 scientific and misleading in this context. Such faults are 27 clearly part of the stress release system, but progressively a 28 less significant part farther away from the San Andreas fault.

43.


2 What is the angle and dip of the Offshore Zone of

3 Deformation near San Onofre?


5 The Offshore Zone of Deformation is a zone of discon6 tinuous folds and faults which have various orientations. The 7 OZD is not a planar structural feature and, therefore, cannot be 8 defined by strike and dip as in the case of a fault or fault 9

zone. Geophysical evidence indicates the individual faults in 10 the zone are generally steeply dipping.


12- How deep would you estimate to be the hypocenter of a 13 postulated earthquake on the Offshore Zone of Deformation?


15 Applicants estimate that the large earthquake con16 sidered would have a focal depth of about 12 km. Smaller earth17 quakes might originate somewhat shallower.


19 Explain your analysis of the relationships between the 20 hypocenter, epicenter, surface ruptures, and peak ground accel

21 erations in the San Fernando earthquake?


23 The Applicants and their consultants have not conducted 24 any special analysis restricted to the San Fernando earthquake

25 acceleration data. However, strong motion data for the San 26 Fernando earthquake has been used to assist in estimating ground 27 motion at San Onofre due to a earthquake on the OZD. Distance 28 from the recording station to the point of energy release is

44.

defined as the closest inclined distance from the recording 2 station to a horizontal line on the fault rupture surface that 3

passes through the approximate center of energy release.


Have you or your consultants predicted ground accelera6 tions from an earthquake on the Offshore Zone of Deformation with 7. a magnitude of M7.0?

8 If so, what is said prediction?


10 Yes. In a study outside this docket, Applicants pre

dicted a peak ground acceleration of 0.31g, based on an earth

12 quake with a magnitude of Ms = 6.94 (approximately 7) some 8 km 13 from the recording station.


15 Have you or your consultants predicted ground accelera16 tions from an earthquake on the Offshore Zone of Deformation with 17 a magnitude of M7.5?



20 No.


22 Have you or your consultants predicted ground accelera23 tion from an earthquake on the Offshore Zone of Deformation with 24 a magnitude of M8.0?



27 No.

28 ///

45.


2 Have yoU or your consultants predicted ground accelera

tions from an earthquake on the Offshore Zone of Deformation with 4

a magnitude of M8.5?


RESPONSE TO INTERROGATORY NO. 71 7.

No. 8


9 What is the maximum magnitude earthquake that you pre

10 dict could occur on the Cristianitos Fault?


12 The Cristianitos fault has been evaluated in terms of 13 10 C.F.R., Part 100, Appendix A and determined to be not capable 14

of generating earthquakes.


16 For the maximum credible earthquake on the Cristianitos

17 Fault what would be the expected ground motion at SONGS? 18

RESPONSE TO INTERROGATORY NO. 73 19 Since the Cristianitos fault is not capable of gene20 rating earthquakes (see Interrogatory No. 72), there is no 21 expected ground motion.


23 What do you predict to be the peak ground acceleration 24 at SONGS from the maximum credible earthquake on the Cristianitos? 25 RESPONSE TO INTERROGATORY NO. 74

26 Since the Cristianitos fault is not capable of generat27 ing earthquakes (see Interrogatory No. 72), there is no ground 28 acceleration.

46.


2 Please supply us with your data from the microearth

3 quake survey of the Cristianitos embayment.


5 Applicants object to Interrogatory No. 75 on the ground

6 that said request is not authorized by the Rules of Practice.

Intervenors request for documents must be pursuant to the pro8 cedures set forth in 10 C.F.R. § 2.741(1).


10 Do you agree that it is possible that a rupture propa

11 gating on the Off-Shore Zone of Deformation could be oriented so

12 as to focus energy at the location of the Nuclear Generating Sta

13 tion 2 and 3?


15 Yes.


1 7Considering the maps referred to in question #28, 82 18 and 83, which branch of the Off-Shore Zone of Deformation do you 19 believe connects with the Cristianitos?


21 As discussed in the PSAR, FSAR and SER and shown on the

22 referenced maps, the OZD is not a discrete fault with various

23 branches. Rather it is a zone of deformation with short, discon

24 tinuous, en echelon segments of folds and faults lying at about

25 5 miles offshore.

26 The Cristianitos fault is projected offshore only about .27 10,000 feet, and probably dies out before reaching the OZD, par28 ticularly in the near surface sediments.

47.

1 Although the OZD includes faults which have branches

2 and related folds, it is not correct to refer to all of them as

"branches" of the OZD. Many are, rather, more-or-less individual

elements that collectively constitute an irregular zone of defor

mation.

6 The maps of Figures D-1 and D-2 of the Woodward-Clyde

Consultants' report of June 1979 are modified after Figures 2E-2 8 and 2E-3 contained in Appendix 2E, Amendment No. 11 of the PSAR,

March 1972. Figures 2E-2 and 2E-3 are maps prepared by Western 10 Geophysical Company to describe the distribution and structure of 11 important horizons in the offshore region of southern Cali

12 fornia. The data for these maps were taken.from extensive off13 shore geophysical surveys conducted by the U.S. Geological Survey 14 and by Western Geophysical Company.


16 Do you have any plans to conduct a microearthquake

17 survey of the Cristianitos Fault Zone?

18 If not, why not?


20 A microearthquake survey of the Cristianitos fault was 21 conducted from April through July 1975. The results demonstrated

22 that this area is very inactive, compared to areas along active 23 faults in Southern California. No additional surveys are planned 24 in light of the current ongoing monitoring carried out by the 25 California Institute of Technology.


27 Has the applicant done a class 9 Accident Analysis for 28 SONGS 1?

48.


2 Applicants object to Interrogatory No. 79 and decline

to answer on the ground that it is totally unrelated to the cap

4 tioned proceeding and can have no possible bearing on the issues

before this Board.


7 How many people live within an 80-mile radius of

8 SONGS 1, 2 and 3?


10 Applicants estimated that as of 1976, some 4,710,850

11 persons lived within 50 miles of .the San Onofre site. Further

12 information on Applicants' population projections -are listed in

13 FSAR, Vol. 1, section 2.1.3. Applicants have not prepared

14 information based on an 80-mile radius from the San Onofre site.


16 Has the applicant done a class 9 Accident Analysis for

17 SONGS 2 and 3?


19 Applicants object to Interrogatory No. 81 and decline

20 to respond on the ground it is totally irrelevant and unrelated

21 to any issue in this proceeding and an answer could not lead to

22 discovery of probative evidence.


24 What is the projected population within 20 miles of

25 SONGS during the predicted operating lifetime of SONGS 2 and 3?


27 27 Applicants have projected the population within twenty

28 miles of the site to be 546,847 persons the year 2020.

49.


2 Have you had any consultants do reports or analyses of

3 the apparent structural relationships between the Cristianitos 4 and the OZD as evidenced in the map produced by the U.S. Depart5

ment of the Interior, Bureau of Land Management, Pacific Outer 6

Continental Shelf Office, Proposed OCS Outer Continental Shelf 7

Sale 48 ES, Southern California Offshore Area. 8


The reference maps, Proposed O.C.S. Sale 48ES, do not 10 support any apparent structural relationships between the Cris11

tianitos fault.and the OZD. Nonetheless, analyses have been per12

formed by Western Geophysical, Marine Advisers, Woodward-Clyde 13 Consultants, and Dr. Perry Ehlig concerning the possibility of 14 structural relationships of the OZD with the Cristianitos as well 15

as the Rose Canyon Fault Zone, and the Newport-Inglewood Zone of 16 Deformation.

17 The results of this analysis are presented in PSAR 18

Appendices 2B, 2C and 2E.


20 Have you had any consultants do reports or analyses of

21 the apparent structural relationships between the Cristianitos

22 and the OZD as evidenced in the map produced by the .CDMG 23 (Official State Geology Map).


25 The referenced map (Geologic Map of California; 1977,

26

27

28

50.

1 State of California) does not support any apparent structural

2 relationships between the Cristianitos. fault and the OZD.

3 However, as stated in Interrogatory Nos. 28 and .83, analyses have

4 been performed by various consultants regarding the possibility

5 of structural relationships of the Cristianitos fault and the

6 OZD.

7 DATED: 1979.

8

9 DAVID R. PIGOTT SAMUEL B. CASEY

10 CHICKERING & GREGORY

11 CHARLES R. KOCHER JAMES A. BEOLETTO

12 LINDA THORNTON SOUTHERN CALIFORNIA EDISON COMPANY

13

14 B

17

avid R. PIGOT-T

16 Southern California Edison Company

and San Diego Gas & Electric Company

18

19

20

21

22

23

24

25

26

27

28

51.

1 CERTIFICATE OF SERVICE

2

3 I hereby certify that on.the 3 day of4,

4 1979, a copy of the foregoing "RESPONSE OF SOUTHERN CALIFORNIA 5

EDISON COMPANY AND SAN DIEGO GAS & ELECTRIC COMPANY TO INTERVENOR 6

FOE ET AL. INTERROGATORIES TO SOUTHERN CALIFORNIA EDISON" was 7 served upon each of the following by deposit in the United States 8

mail, first-class postage prepaid, addressed as follows: 9

Ivan W. Smith, Esq. Chairman 10 Atomic Energy Safety and Licensing Board

U.S. Nuclear Regulatory Commission 11 Washington, D.C. 20555

12 Dr. Cadet H. Hand, Jr., Member Director, Bodega Marine Laboratory

13 University of California P.O. Box 247

14 Bodega Bay, California 94923

15 Dr. Emmett A. Luebke Atomic Safety and Licensing Board

16 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

17 Lawrence J. Chandler, Esq.

18 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission

19 Washington, D.C. 20555

20 Janice E. Kerr., Esq. J. Calvin Simpson, Esq.

21 Lawrence 0. Garcia, Esq. 21 California Public Utilities Commission

22 5066 State Building San Francisco, California 94102

23 David W. Gilman

24 Robert G. Lacy San Diego Gas & Electric Company

25 P.O. Box 1831 San Diego, California 92112

26 James H. Drake, Vice President

27 Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue 28 Rosemead, California 91770

John R. Bury, General Counsel 2 Charles R. Kocher, Esq.

James A. Beoletto, Esq.

3 Southern California Edison Company P.O. Box 800

4 2244 Walnut Grove Avenue Rosemead, California 91770

5 Alan R. Watts, Esq.

6 Rourke & Woodruff California First Bank Building

7 10555 North Main Street, Suite 1020 Santa Anta, California 92701

8 Richard J. Wharton, Esq.

9 Wharton and Pogalies 2667 Camino Del Rio South

10 Suite 106 San Diego, California 92108

11 Phyllis M. Gallagher, Esq.

12 1695 W. Crescent Avenue Suite 222

13 Anaheim, California 92801 14 14 Mrs. Lyn Harris Hicks

GUARD

153908 Calle Ariana San Clemente, California 92672

16 16 Mr. Lloyd von Haden

17 2089 Foothill Drive Vista, California 92083

18 James F. Davis

19 State Geologist Division of Mines & Geology

20 1416 Ninth Street Room 1341

21 Sacramento, California 95814

22 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission

23 Washington, D.C. 20555

24 Docketing and Service Section *Office of the Secretary

25 U.S. Nuclear Regula ry Commission Washington, D.C5

26

27 David R.-igott One of Counsel for Applicants

28 Southern California Edison Company and San Diego Gas & Electric Company

2.

1 VERIFICATION

2

DAVID R. PIGOTT, being first duly sworn, deposes and 4 says:

1. That he is a member of the law firm of Chickering &

6 Gregory, San Francisco, California.

7 2. That he is Counsel for Applicants Southern Cali8

fornia Edison Company and San Diego Gas & Electric Company (here9

after "Applicants") in this proceeding.

10 3. That he is authorized by Applicants to execute and 1 verify the foregoing "RESPONSE AND OBJECTIONS OF SOUTHERN CALI

12 FORNIA EDISON COMPANY AND SAN DIEGO GAS & ELECTRIC COMPANY TO 13 INTERROGATORIES FOE, ET AL., SECOND SET OF INTERROGATORIES".

S14 4. That he is informed and believes and upon such 15 information and belief affirms that the foregoing "RESPONSE AND 16 OBJECTIONS OF SOUTHERN CALIFORNIA EDISON COMPANY AND SAN DIEGO 17 GAS & ELECTRIC COMPANY TO INTERROGATORIES FOE, ET AL., SECOND SET 18 OF INTERROGATORIES" is true and correct.

19 DATED: __ , 1979.

20

21

22 David Pigott

23 Subscribed and sworn to before me this ~j day of 3ccepl yr, 1979.

24

V NOTARY PUBLIC 26 In and for the City and County of

San Francisco, State of California Y L p0APDUVAN

27 -j!,ALFR 1 27 ~ ~ NOTARY FU7UC-CALFORNIA

CT ANDUTY OF My Commission Expires: / / 0 . S FRANCISCO

DAVID R. PIODTT

SA'MUL 8. CA-EY CHICKERING- GREGORY Three Embarcadero Center TwentyThird Floor San Francisco, California 94111 Telephone: (415) 393-9000

CHARLES R. KOCHER ' JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1931

Attorneys for Applicants, Southern California Edison Company and San Diego Gas & Electric Company

UNITED STATES OF AMERICA

NUCLEAR REGULATORY 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. (San Onofre. ) STIPULATION EXTENDING TIME Nuclear Generating Station, ) FOR ANSWERS OF INTERVENORS' Units-2 and'3) ) SECOND SET OF INTERROGATORIES

On October 18, 1979, Intervenors Friends of the

Earth, et al. ("FOE et al.") served on Applicant Southern

California Edison Company ("Applicant") their second set of

interrogatories.

It has been mutually agreed between Applicant and

Intervenors FOE et al.. that 14 days is not an adequate time

within which to prepare responses to the interrogatories.

It is hereby stipulated, by and between the

parties hereto that Applicant may have to December 3, 1979,

within which to respond to said interrogatories as required

by 10 C.F.R. 5 2.740b.

Dated / I 7 David R. Pigott Samuel B. Casey Chickering & Gregory

. By

David R. Pigott d One of Counsel for Applicant

Dated / 9 7 Richard J. Wharton Wharton & Pogalies

By

Richard J harton

Attorney Intervenor FOE, et E

CERTIFICATE OF SERVICE

I hereby certify that on the 9th day of November

1979, a copy of the foregoing "STIPULATION EXTENDING TIME

FOR ANSWERS OF INTERVENORS' SECOND SET OF INTERROGATORIES"

was served upon each of the following by deposit in the

United States mail, first-class postage prepaid, addressed

as follows:

Ivan W. Smith, Esq. Atomic Energy Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dr. Cadet H. Hand,.Jr., Member Director, Bodega Marine Laboratory University of California P. 0. Box 247 Bodega Bay, California 9-4923

Dr.. Emmett A. Luebke Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Lawrence J. Chandler, Esq. Office of the Executive Legal Direc 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, California 94102

David W. Gilman Robert G. Lacy San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112

James H. Drake, Vice.President _.Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770

John R. Bury, General Counsel Charles R. Kocher, Esq. James A. Beoletto, Esq. Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770

Alan R. Watts, Esq. Rourke & Woodruff California First Bank Building 10555 North Main Street, Suite 1020 Santa Ana, California 92701

Richard J. Wharton, Esq. Wharton and Pogalies 266.7 Camino Del Rio South Suite 106 San Diego, California 92108

Phyllis M. Gallagher, Esq. 1695 W. Crescent Avenue Suite 222 Anaheim, California 92801

Mrs. Lyn Harris Hicks GUARD 3908 Calle Ariana San Clemente, California 92672

Mr. Lloyd von Haden 2089 Foothill Drive Vista, California 92083

James F. Davis State Geologist Division of Mines & Geology 1416 Ninth Street Room 1341 Sacramento, California 95814

Atomic .Safety .and Licensing Board Panel U.S.. Nuclear Regulatory Commission Washihgton, D.C. 20555

Docketing and Service Section Office of the Secretary U.S. Nuclear Regula ory Commission Washi fgton, .C. 0555

DavidR.. Pgott One of Counsel for Applicants Southern California Edison Company and San Diego Gas & Electric Company

UNITED STATES OF AMELRICA NUCLEAR REGULATORY COMMISSTON

BEFORE THE ATONIC SAFETY AND LICENSING BOARD

In the Matter of ) Docket Nos. 50-250-SP ) 50-251-SP

FLORIDA POWER & LIGHT COMPANY ) ) (Proposed Amendments to

(Turkey Point Nuclear Generating ) Facility Operating License Units Nos. 3 and 4) ) to Permit Steam Generator

) Repair)

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that copies of the attached notion

captioned in the above matter were served on the following by

deposit in the United States mail, first class, properly stamped

and addressed, on the date shown below.

Elizabeth S. Bowers, Esquire Cha irman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

Dr. Emmeth A. Luebke NOV 13 1973 > Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

M4r. Mark P. Oncavage 12:00 S.W. 110 Avenue M1iacmi, FL 33176

Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555

Steven C. Goldberg, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555

Harold F. Reis, Esquire Lowenstein, Newman,. Reis, Axelrad & Toll 1025 Connecticut Avenue, NW Washington, DC 20036

Norman A. Coll, Esquire Steel, Hector & Davis 1400 Southeast First National Bank Building Miami, Florida 33131

Dated: November 9. 197-9 K