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Supplemental Request for Hearing & Petition to Intervene by San Luis Obispo Mothers for Peace, Avila Valley Advisory Council

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Supplemental Request for Hearing & Petition to Intervene by San Luis Obispo Mothers for Peace, Avila Valley Advisory Council UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket # 72-26 Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant Unit Nos. 1 and 2 Independent Spent Fuel Storage Installation July 18, 2002 SUPPLEMENTAL REQUEST FOR HEARING AND PETITION TO INTERVENE BY SAN LUIS OBISPO MOTHERS FOR PEACE, AVILA VALLEY ADVISORY COUNCIL, PEG PINARD, CAMBRIA LEGAL DEFENSE FUND CENTRAL COAST PEACE AND ENVIRONMENTAL COUNCIL ENVIRONMENTAL CENTER OF SAN LUIS OBISPO, NUCLEAR AGE PEACE FOUNDATION, SAN LUIS OBISPO CHAPTER OF GRANDMOTHERS FOR PEACE INTERNATIONAL, SAN LUIS OBISPO CANCER ACTION NOW, SANTA MARGARITA AREA RESIDENTS TOGETHER, SANTA LUCIA CHAPTER OF THE SIERRA CLUB, AND VENTURA COUNTY CHAPTER OF THE SURFRIDER FOUNDATION In accordance with the Nuclear Regulatory Commission's ("NRC's" or "Commission's") "Rules of Practice for Domestic Licensing Proceedings" in 10 CFR Part 2, and the Atomic Safety and Licensing Board's ("ASLB's) Initial Prehearing Conference Order of June 6, 2002, the San Luis Obispo Mothers for Peace (SLOMFP), Avila Valley Advisory Council ("AVAC"), Peg Pinard, Cambria Legal Defense Fund, Central Coast Peace And Environmental Council, Environmental Center Of San Luis Obispo, Nuclear Age Peace Foundation, San Luis Obispo Chapter of Grandmothers For Peace International, San Luis Obispo Cancer Action Now, Santa Lucia Chapter of the Sierra Club, and Ventura County Chapter of the Surfrider Foundation, hereby submit contentions challenging the adequacy of Pacific Gas & Electric Company's ("PG&E's") December 21, 2001, application for a license for an independent spent fuel storage 2 installation (ISFSI) at the Diablo Canyon Nuclear Power Plant. SLOMFP will act as a lead intervenor with respect to all of these contentions. As demonstrated below, the contentions satisfy the NRC's admissibility requirements in 10 C.F.R. § 2.714(b). CONTENTIONS TECHNICAL CONTENTIONS TC-1 Inadequate Seismic Analysis Contention: In Section 2.6 of the SAR, PG&E claims to satisfy Appendix A of 10 C.F.R. Part 100 and 10 C.F.R. § 72.102, which provide criteria for seismic design of nuclear facilities and ISFSIs. However, the seismic analysis presented by PG&E does not consider a number of significant seismic features in the area of the Diablo Canyon plant. As a result, the design basis earthquake for the proposed ISFSI cannot be considered reasonable or conservative for purposes of protecting public health and safety against the effects of earthquakes.' Basis: There are a number of serious shortcomings in the evaluation of seismic issues and design considerations that are presented in the Safety Analysis Report (SAR) and Environmental Report (ER) for the ISFSI at Diablo Canyon. The foremost problem with PG&E's seismic analysis is its failure to consider the threat posed by large reverse or thrust fault earthquakes in the vicinity of the Diablo Canyon site. While PG&E correctly considers the Hosgri fault zone to constitute the constraining seismic source for the facility, PG&E incorrectly and nonconservatively assumes that it is a purely strike-slip fault (SAR p.2.6-33). The nonconservatism is increased by the fact that PG&E also assumes that the fault is a vertical fault 1 This contention is supported by the Declaration of Dr. Mark R. Legg, attached as Exhibit 1 3 (SAR p. 2.6-30), rather than east dipping. Finally, using this nonconservative fault geometry, PG&E places the fault in a nonconservative location. Incorrect Assumption of strike-slip faulting. PG&E assumes the Hosgri fault is a strike-slip fault rather than an oblique-reverse or thrust fault (SAR p. 2.6-33). As a result, the ground motions calculated by PG&E are lower than they should be. To assume that only strike slip faulting on a vertical Hosgri fault represents the most severe seismic threat to the Diablo Canyon site understates the hazard. One must also consider the oblique fault character, with thrust or reverse slip in combination with the right-slip. The oblique fault character of the Hosgri fault zone is demonstrated by three decades or more of geological and seismological investigation in the vicinity of Diablo Canyon. A list of references that describe the fault character of the Hosgri fault and tectonic style of the region is listed at the end of the contention. This list is incomplete, providing only a sampling of the relevant investigations. These investigations have yielded ample data to show the character and locations of the major active fault systems that pose serious earthquake threats to the DCPP and ISFSI. PG&E provides much of this important data from its Long Term Seismic Program (LTSP; SAR Figs. 2.6-40, 41, 42). These data show that the south-central California coastal zone is an area dominated by oblique-shortening. A combination of right-slip, as expressed by the San Andreas fault system, in concert with northeast-directed compression, due to as yet poorly understood tectonic plate boundary processes, has controlled the earthquake and geologic deformation of the region for the past 3-6 Million years (Page, 1981; Nicholson and Crouch, 1989; Sorlien, 1994). This deformation is expressed in the regional geology by the widespread thrust and reverse faulting as well as the major geologic folding (Crouch and others, 1986; 4 Namson and Davis, 1990; Clark and others, 1991; Nicholson and others, 1992). Most likely the parallel trends of faults and fold axes are directly related to the oblique character of this deformation, that is due to the combined interaction of the strike-slip associated with the Pacific North America transform fault plate boundary and the northeast-directed compression. Geologists use the word transpression to describe this tectonic style. The credibility of the proposed large oblique-reverse earthquake scenario is amply demonstrated in the existing geological and seismological data acquired over the past decades of research in the south-central California coastal region. First, the overall transpressional character (combination of strike-slip and compression) of the region has been described in numerous published and unpublished technical papers. The earthquake history and active seismicity show this character in the focal mechanisms and the broad distribution of microseismicity, without well-defined vertical fault planes over much of the region, are consistent with the complex patterns of faulting expected in such a transpressional environment (SAR Figs. 2.6-40,4 1). The seismic reflection data, including the high-quality, deep penetration, multichannel seismic profiles show this complexity, although the deeper structure (below about 3-4 km where large earthquakes initiate) is poorly imaged (Ewing and Talwani, 1991; Clark and others, 1991; McIntosh and others, 1991; Meltzer and Levander, 1991; Nicholson and others, 1992; Sorlien, 1994). The complexity of the geological structure is one of the main reasons why the data quality of the seismic reflection profiles deteriorates with depth in this and other active tectonic areas. Last, the geology as mapped at the surface on land, inferred from seismic profiles and well logs offshore, and inferred into the subsurface by geological methods is consistent with this overall structural and tectonic style (Page, 1981; Crouch and others, 1986; Namson and Davis, 5 1990; Guptil and others 1991; Sorlien, 1994). Consequently, PG&E must carefully re-evaluate the seismic hazard at the Diablo Canyon nuclear facilities to include the real potential for large oblique-reverse earthquake ruptures in close proximity to the subject site before the NRC can consider licensing the ISFSI. Assumption of vertical faulting. An important effect of considering an oblique-reverse character for major earthquakes along the Hosgri fault zone is to realize that the fault is not vertical, but instead has an east to northeast dip. Seismic reflection profiles in the area, from the EDGE and PG&E multichannel seismic work (Ewing and Talwani, 1991; Clark and others, 1991; Meltzer and Levander, 1991; McIntosh and others, 1991; Trehu, 1991) as well as proprietary petroleum exploration industry data (Crouch and others, 1986; Namson and Davis, 1990) show numerous east-dipping reverse or thrust faults in the region, including faults within the mapped Hosgri fault zone. Some scientists suggested more than a decade ago that the Hosgri fault is listric in character, going from a steep fault at the surface into a shallow east-dipping thrust fault at depth and merging into a regional d6collement or detachment fault (Crouch and others, 1986; Namson and Davis, 1990). Such regional detachment fault systems have now been identified throughout the southern California region (e.g., Rivero and others, 2000), and shallow dipping blind faults that cut upwards into the shallow crust above these detachments are the source of recent damaging "blind thrust" earthquakes. California examples include the 1983 Coalinga, 1987 Whittier-Narrows, and 1994 Northridge earthquakes. An excellent example of a blind-thrust earthquake associated with a well-known right-slip (assumed vertical strike-slip) fault is the 1989 Loma Prieta earthquake along the Santa Cruz Mountains segment of the San Andreas fault. Thus, it is reasonable and prudent to consider such earthquake sources along the 6 Hosgri fault zone in proximity to the Diablo Canyon site. With an east to north-east dip, the closest distance of the fault surface to the DCPP and ISFSI is significantly closer than (4.5 km SAR p. 2.6-32) used in the design ground motion evaluations, and the epicenter of such an earthquake could lie directly beneath the subject site (epicentral distance equals zero). This is significant for the Diablo Canyon seismic analysis, because strong ground motion (shaking) from moderate to large reverse or thrust earthquakes tends to be greater at a specified source-to-site distance and source magnitude than for pure strike-slip earthquakes (Abrahamson and Silva, 1997; Boore and others, 1997).
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