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Intervenors' Request for Documents and Records from Pacific Gas and Electric Company Relating to Geology and Seismicity

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Intervenors' Request for Documents and Records from Pacific Gas and Electric Company Relating to Geology and Seismicity A ~ QQEQMPONDENGE ~ UNXTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) I ) Docket Nos. 50-275 0 — PACIFIC GAS AND ELECTRIC COMPANY ) 5 23 O.L. ) (Diablo Canyon Nuclear Power Plant, ) Units Nos. 1 and 2) \ ~gg) ~ INTERVENORS'EQUEST FOR DOCUMENTS uS~t,C gq V ~ AND RECORDS FROM PACIFIC GAS AND QE s~, )g ~ ol+~S ELECTRIC COMPANY RELATING TO GEOLOGY AND SEISMICITY Intervenors SCENIC SHORELINE PRESERVATION CONFERENCE, SAN LUIS OBISPO MOTHERS FOR PEACE, ECOLOGY ACTION CLUB, SANDRA SILVER and JOHN J. FORSTER hereby request pursuant to 10 C.F.R. 52.744 and the Freedom of Information Act (5 USC 5552) that all t documents and records relating to the geology and seismicity of the vicinity of the Diablo Canyon Nuclear Generating Station, site in the possession of the Nuclear Regulatory Commission be produced for inspection by Intervenors'ttorneys and/or technical consultants. This request for documents and records relating to the general category of geology and seismicity includes, but is not limited to, the following sub-categories: J ~ 1 1) All0maps,. reports, geological. ~survey records,. correspondence, inter-office communications and other writings F and records relating to faults or any geological formations related to faults within a 20 mile radius of the Diablo Canyon plant site. 2) All maps, reports, geological survey records, correspondence and other writings and. records relating in any way to =the total length of geologic faults and fault systems that pass through and extend beyond the 20 mile radius around the Diablo Canyon nulcear plant. This document request does not include 'any portion of'the Final Safety Analysis Report for the Diablo Canyon Nuclear Generating Station This document request encompasses documents relevant to, the several contentions in the Diablo Canyon operating P license safety proceedings which encompass issues of geology and seismology of the plant site and the seismic design of plant and reactor structures. DATED:. 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 Attorneys for Intervenors Scenic Shoreline Preservation Conf. San Luis Obispo Mothers for Peace Ecology Action Club Sandra Silver John J. Forster lfl ~ ~TED C(Bg~pOqg~~ . v -+o vo~P '.. ~ g~/ CERTIFICATE OF SERVICE BY MAIL The foregoing d6cuments entitled INTERVENORS'EQUEST .'FOR DOCUMENTS AND RECORDS FROM THE NUCLEAR REGULATORY. COMMISSION 1 RELATING TO 'GEOLOGY AND SEISMICITY and XNTERVENORS'EQUEST FOR DOCUMENTS AND RECORDS FROM PACIFIC GAS AND ELECTRIC COMPANY. RELATING TO GEOLOGY AND SEXSMXCXTY have. been served today, November 24, 1976,*by deposit in the United States'mail, properly * stamped "and addressed: Mrs., Elizabeth E. Apfelberg , Mr. John J. Forster 1415 Ca adero c/o Mr. Gordon Silver San Luis Obi;spo, CA 93401 5055 Radford Av nun North Hollywood, CA 91607 James R. Tourtellotte, Esp. Office of E"ecutive Legal -'irector L'icensing ' Division of Reactor BETH 042 U.S. Nuclear Regulatory Co.m'n. " U.S. Nuclear Regulatory Comm'n. Pa hington, D.C. 20555 'washington, D.C. 20555 Eli"abeth S.. Bo~rers,.Esp. Chairman Chairman Atomic Safety & Lic nsing Bo rd Atomic Safety 6 Licensing Panel Board. U,S. Nuclear Regulatory Comm'n. ~ U.S. Nuclear Regulatory Comm'n. Washington, D.C. 20555 Landosr 'Building — Room 1209 Nashington', D.C. 20555 Dr. Hilliam E. Mar"in Mr. Glenn O.. Bright Atomic Safety 6 Licen ing Board Atomic Safety 6 Licensing Board .Senior Ecologis U;S. Nuclear. Regulatory Comm'n. Battelle Memorial Institute " Lando~z Building — Room 1209 Columbus, Ohio 43201 washington, D.C. 20555 Alan S., Ro enthal, Esp.. Mr.. Hilliam P. Cornwell Chairman P.O. Bo.. 453 .*. Atomic Safety 6 Lic nsing App:.'-a- Morro Bay,'CA 93442 'anel. U.S..Nuclear Regulatory Comm'n. Mr. Frederick Eissler Landov Buildi'ng '- Room,: 1209 Scenic Shoreline Preservation Nashington,- D.C. 20555 Conference, Inc-. 4623 Morc Mesa Drive Secretary Santa Barbara, CA, 93110 U.S. Nuclear Regulatory Comm'n. 7',ashington, D.C. 20555 Ms. Ray@ Fleming Attn: Docketing and Serv'ce 1746 Chorro Street Section San Luis Obispo,, CA 93401 Mrs. Sandr .'. Silver 5055 Radford Avenue North. Hollywood,, CA 91607 ~ Andrew.Skaff, Esq. Yale X. Jones, Esq. Counsel, Public Utilities 100 Van Ness. Avenue — 19th Floor Commission of the State San Francisco, CA 94102 of California 5066 State Building John C. Yorrissey San Francisco, CA 94102 Phillip A. Crane, Jr. Bruce R. Worthington Paul C. Valentine, Esq. Pacific Gas & Electric Company 400 Charming Avenue 77 Beale Street Palo Alto, CZ 94302 San Fr"ncisco, CA 94106 Arthur C. Gehr Bruce Norton SNHLL''& PZLHER 3100 Valley Center Phoenix, Ariz. 85073 Dated: November 24, 1976 n M. Wailer ~ ~ 0 V TED COMESPOZDENGE ,C 0 -:-- b gsHRc' UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION OEc~~7~ —. s ~glott '.. ~ ~ '"a S.~<c «gayacloll™ j BEFORE THE ATOMIC SAFETY AND TICENSING BOARD sgcl~ In the Matter of ~ ~ ~ .-. ..- - .....;„, . ";;,;,', ':: ),'ocket Nos .. 50-275 O.L.. .., PACIFIC GAS, AND ELECTRIC. COMPANY":-"-:-;. , "):.'.";,.:,... ...,50-,323 0 L 4 (Diablo Canyon Nuclear Power-P3.ant,-'=;.'„=- ) '- Units Nos-. '1 and. 2'j .;,.;-':--'..'."-,=",,.:",) ..... -;.".:.'.; . T XNTERVENORS'. REQUEST POR DOCUMENTS'ND RECORDS PROM THE. NUCLEAR.REGULATORY ;—.';... *l.';.';-„" COMMISSION RELATING TO GEOLOGY.AND- 'l SEISMICITY V 3 P: r E Intervenors SCENIC SHORELINE PRESERVATION CONFERENCE, ~ ",-, SAN LUIS OBISPO MOTHERS FOR PEACE,.=.ECOLOGY. ACTION CLUB, SANDRA""„: SXLVER and JOHN 'J. PORSTER hereby request pursuant to 10 C.F.R.....- . 52;744 and the Freedom of Information-'Act (5', USC 5552)"'that all documents and records relating to the geology and seismicity " I'- of the vicinity of the Diablo Canyon Nuclear Generating Station I .'site in the possession of. the Nuclear Regulatory Commission be produced for inspection'y Intervenors'ttorneys and/or ~,. 6,, technical consultants. - This request-for documents=,and -records C relating to the general category of"geology and seismicity' but is not limited to, the C'ncludes,.following. sub-categories:. 0 1) All maps, reports, geological survey records, and other writings and I'orrespondence, records relating to faults or any geological formations related to faults within a 20 mile radius of the Diablo Canyon plant site. 2) All maps, reports, geological survey records, " ~ correspondence and other writings and records relating. in any way to the total length of geologic faults and,fault systems -\ that pass through and extend beyond the 20 mil'e radius around 0 ~ the Diablo Canyon nulcear plant. This document request, does not include any portion of''= the. Final Safety Analysis Report for the Diablo Canyon Nuclear Generating Station. This document request encompasses documents relevant to the several contentions in the Diablo Canyon operating license safety proceedings which encompass issues of geology and seismology of the plant site and the seismic design of plant and reactor- structures. DATED: Respectfully submitted, BRENT N. RUSHFORTH JAMES GEOCARIS Center for Law in the Public Interest. 10203 Santa Monica Boulevaxd Los Angeles, California 90067 (21'3) 879-5588 Attorneys for Intervenors Scenic Shoreline Preservati:on Conf. San Luis Obispo Mothers for Peace Ecology Action Club Sandra Silver John J. Forster 0.
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