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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding ML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl ML20080L9431983-09-28028 September 1983 Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl ML20080G0731983-09-13013 September 1983 Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl ML20071Q7201983-06-0303 June 1983 Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl ML20071M0781983-05-25025 May 1983 Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl ML20023C4571983-05-12012 May 1983 Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl ML20023C6971983-05-12012 May 1983 Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl ML20023C3741983-05-12012 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1 ML20023C3691983-05-12012 May 1983 Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists ML20064N6681983-02-10010 February 1983 Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs ML20071A6671983-02-10010 February 1983 Certifies Svc of Intervenor Motion to Suspend Safety & Health Schedule on 830210 ML20070T0661983-02-0404 February 1983 Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc ML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20083N1991983-01-26026 January 1983 Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl ML20028F1831983-01-25025 January 1983 Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20028E9701983-01-19019 January 1983 Reply to NRC & Applicant Response to Natl Wildlife Federation/Or Environ Council,Columbia River Inter-Tribal Fish Commission & Coalition for Safe Power 821213 Motion to Clarify & Amend Certain Contentions.W/Certificate of Svc ML20072A6731983-01-18018 January 1983 Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl ML20028C9581983-01-0505 January 1983 Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc ML20028C9501983-01-0505 January 1983 Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents ML20028C3221983-01-0303 January 1983 Suppl to DOE 821126 Limited Appearance Statement.Doe Position Is That Hanford Site Is Not Open,Unclaimed Land as Defined in 1855 Treaty W/Yakima Indian Nation,Article Iii. ASLB Is Wrong Forum for Resolving Issue ML20070L5411982-12-27027 December 1982 Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded ML20070L4901982-12-27027 December 1982 Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl ML20079J6021982-12-23023 December 1982 Response Supporting Intervenor 821213 Motion to Clarify & Amend Contentions 7 & 8.Quantification of Environ Impacts Not Practicable Due to Subjective Nature.Certificate of Svc Encl ML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20079H3711982-12-13013 December 1982 Motion to Clarify & Amend Contentions 7 & 8.Contentions Should Be Reorganized to Facilitate Coordinated Evidentiary Presentations for Environ Matters ASLB Set Out as Contentions 4,7 & 8.Certificate of Svc Encl ML20070D1181982-12-10010 December 1982 Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land ML20070C9121982-12-10010 December 1982 Notice of Counsel New Law Firm Affiliation,As of 820901 ML20070C8181982-12-10010 December 1982 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Yakima Indian Nation Contentions 7,8 & 9.Nation Right to Enjoy Reservation Peacefully Given by 1855 Treaty Should Be Protected by ASLB ML20070C7691982-12-10010 December 1982 Certifies Svc of Brief on Admissibility of Reworded Proposed Contention 10,motion for Reconsideration of ASLB 821029 Memorandum & Order,R Jim Affidavit & Notice of Counsel Law Firm Change on 821210 ML20070C7981982-12-10010 December 1982 Brief Supporting Admissibility of Yakima Indian Nation Reworded Proposed Contention 10.Attempt to Terminate Reserved Rights of Yakima Indian Nation Violates Fifth Amend.Land Cannot Be Taken by Inverse Condemnation ML20028B9251982-12-0101 December 1982 Brief Re Admissibility of Yaking Indian Nation Proposed Contention 10.Clarification Needed on Procedural Rule of Commission & Scope of Contention.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20028B2631982-11-26026 November 1982 Limited Appearance Statement.Hanford Site Is Not Part of Yakima Indian Nation Reservation Established by 1855 Treaty. Indian Privilege of Hunting,Gathering Roots & Berries & Grazing Animals Does Not Extend to Hanford Site ML20066K9761982-11-22022 November 1982 Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue ML20066L0101982-11-22022 November 1982 Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20023A8141982-10-14014 October 1982 Response to Yakima Indian Nation 820930 Suppl to Petition to Intervene,Containing List of Contentions.Objects to Contentions 4-10.Certificate of Svc Encl ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20063P4011982-10-0606 October 1982 Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20069F9541982-09-23023 September 1982 Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl ML20069F9491982-09-23023 September 1982 Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20137F8001982-09-17017 September 1982 Amended Subagreement 2 Between State of Wa Energy Facility Site Evaluation Council & NRC Re Protocol for Conduct of Joint Hearings on Facility Project ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5571982-09-15015 September 1982 Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl 1983-09-28
[Table view] Category:TRANSCRIPTS
MONTHYEARML19210E1281979-10-18018 October 1979 Prefiled Testimony.Bechtel 1979 Geology Map Cannot Be Used as Tool for Seismic Evaluation of Area.Supporting Documentation,Prof Qualifications & Certificate of Svc Encl ML19276H5781979-10-18018 October 1979 Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications Encl ML19276H5801979-10-18018 October 1979 Prefiled Testimony.Two east-west Trending Faults Can Be Found Along Plant Site Vicinity ML19276H5831979-10-18018 October 1979 Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments Deformation ML19276H5751979-10-17017 October 1979 Prefiled Testimony.High Frequency Seismic Methods Inadequate to Locate Fault Traces Existing in Area.Interpolation Between Spaced Seismic Lines Is Speculative ML19210C1631979-10-0808 October 1979 Testimony of Nm Newmark Re Conservatism of Seismic Design Criteria & Seismic Design Provisions for Facility.Biography Encl ML19210C1601979-10-0808 October 1979 Testimony of Ba Bolt Re Correlation Between Peak Acceleration & Magnitude & Intensity.Biography,Publication List & Supporting Documentation Encl ML19256E3281979-10-0303 October 1979 Supplemental Testimony of J Kelleher Re NRC Methods Used to Estimate Strong Ground Motion ML20136C5211979-08-30030 August 1979 Transcript of 790830 Hearing in Seattle,Wa. Pp 14,802-15,048 ML20136C5271979-08-27027 August 1979 Transcript of 790827 Hearing in Seattle,Wa. Pp 14,388-14,573.Exhibits 213-15 Encl ML19249E1561979-08-0808 August 1979 Testimony Re Financial Qualifications Submitted by J Lazar on Behalf of Intervenor Skagitonians Concerned About Nuclear Power.Asserts Applicant Will Be Unable to Secure Financing. Certificate of Svc Encl ML19207B4771979-07-12012 July 1979 Supplemental Testimony of Es Cheney Re Alternative Site Comparison,Submitted on Behalf of Skagitonians Concerned About Nuclear Power.Goshen,Hanford & Pebble Springs Are Better Sites than Skagit ML19209B0681979-07-10010 July 1979 Testimony of ML Darland on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Evacuation Planning.Professional Qualifications Encl ML19209B0691979-07-10010 July 1979 Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography Encl ML19209B0721979-07-10010 July 1979 Testimony of J Lazar on Behalf of Intervenors Skagitonians Concerned About Nuclear Power,Re Financial Qualifications. W/Supporting Documentation ML19247B2871979-07-0202 July 1979 Testimony of RB Eastvedt Re Bulk Transmission Sys Requirements Associated W/Alternate Sites ML19207B4841979-06-29029 June 1979 Testimony of JW Ellis Re QA Program.Util Has Implemented QA Program That Fully Complies with All State & Federal Regulations ML19207B4811979-06-29029 June 1979 Testimony of Je Mecca Re Amended License Application & Complete Psar.Verifies Application as Amended Through Amend 4 & PSAR as Amended Through Amend 20 & Suppl 18 ML19207B4851979-06-29029 June 1979 Testimony of Wj Ferguson Re Engineering,Qa & Const Project Organizations.Qa Program Is Autonomous & Objective.Bechtel Has Primary Responsibility for Review of Design & Procurement Documents ML19207B4901979-06-29029 June 1979 Testimony of Ev Padgett Re QA Program.Qa Program Was Developed to Meet Requirements of 10CFR50,App B & ANSI N45.2 as Set Forth in Chapter 17 ML19207B4911979-06-29029 June 1979 Testimony of Rn Hettinger Re QA Program.Describes Current Level of QA Activities.Certificate of Svc Encl ML19246C4681979-06-0101 June 1979 Submits Joint Testimony of Re Olson,Me Coberley,Ls Pack & Jm Coombs.Util Does Not Have Reasonable Assurance of Obtaining Funds for Const & Fuel Cycle Costs.Prof Qualifications & Certificate of Svc Encl ML19242D2021979-06-0101 June 1979 Supplements Testimony Presented at 780217 Proceeding Re Util Use of Piping Test Data to Predict Yield of Proposed Ranney Collector Sys & Drawdown Effects of Ranney Collectors on Nearby Red Cabin & Muddy Creeks ML19241A6171979-06-0101 June 1979 Testimony Re Ranney Collector Sys.Sys Is Sufficient to Provide Plant Water Needs Under Varying Conditions W/Minimal Impact on Water Resources 1979-08-08
[Table view] Category:DEPOSITIONS
MONTHYEARML19210E1281979-10-18018 October 1979 Prefiled Testimony.Bechtel 1979 Geology Map Cannot Be Used as Tool for Seismic Evaluation of Area.Supporting Documentation,Prof Qualifications & Certificate of Svc Encl ML19276H5781979-10-18018 October 1979 Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications Encl ML19276H5801979-10-18018 October 1979 Prefiled Testimony.Two east-west Trending Faults Can Be Found Along Plant Site Vicinity ML19276H5831979-10-18018 October 1979 Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments Deformation ML19276H5751979-10-17017 October 1979 Prefiled Testimony.High Frequency Seismic Methods Inadequate to Locate Fault Traces Existing in Area.Interpolation Between Spaced Seismic Lines Is Speculative ML19210C1631979-10-0808 October 1979 Testimony of Nm Newmark Re Conservatism of Seismic Design Criteria & Seismic Design Provisions for Facility.Biography Encl ML19210C1601979-10-0808 October 1979 Testimony of Ba Bolt Re Correlation Between Peak Acceleration & Magnitude & Intensity.Biography,Publication List & Supporting Documentation Encl ML19256E3281979-10-0303 October 1979 Supplemental Testimony of J Kelleher Re NRC Methods Used to Estimate Strong Ground Motion ML20136C5211979-08-30030 August 1979 Transcript of 790830 Hearing in Seattle,Wa. Pp 14,802-15,048 ML20136C5271979-08-27027 August 1979 Transcript of 790827 Hearing in Seattle,Wa. Pp 14,388-14,573.Exhibits 213-15 Encl ML19249E1561979-08-0808 August 1979 Testimony Re Financial Qualifications Submitted by J Lazar on Behalf of Intervenor Skagitonians Concerned About Nuclear Power.Asserts Applicant Will Be Unable to Secure Financing. Certificate of Svc Encl ML19207B4771979-07-12012 July 1979 Supplemental Testimony of Es Cheney Re Alternative Site Comparison,Submitted on Behalf of Skagitonians Concerned About Nuclear Power.Goshen,Hanford & Pebble Springs Are Better Sites than Skagit ML19209B0681979-07-10010 July 1979 Testimony of ML Darland on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Evacuation Planning.Professional Qualifications Encl ML19209B0691979-07-10010 July 1979 Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography Encl ML19209B0721979-07-10010 July 1979 Testimony of J Lazar on Behalf of Intervenors Skagitonians Concerned About Nuclear Power,Re Financial Qualifications. W/Supporting Documentation ML19247B2871979-07-0202 July 1979 Testimony of RB Eastvedt Re Bulk Transmission Sys Requirements Associated W/Alternate Sites ML19207B4841979-06-29029 June 1979 Testimony of JW Ellis Re QA Program.Util Has Implemented QA Program That Fully Complies with All State & Federal Regulations ML19207B4811979-06-29029 June 1979 Testimony of Je Mecca Re Amended License Application & Complete Psar.Verifies Application as Amended Through Amend 4 & PSAR as Amended Through Amend 20 & Suppl 18 ML19207B4851979-06-29029 June 1979 Testimony of Wj Ferguson Re Engineering,Qa & Const Project Organizations.Qa Program Is Autonomous & Objective.Bechtel Has Primary Responsibility for Review of Design & Procurement Documents ML19207B4901979-06-29029 June 1979 Testimony of Ev Padgett Re QA Program.Qa Program Was Developed to Meet Requirements of 10CFR50,App B & ANSI N45.2 as Set Forth in Chapter 17 ML19207B4911979-06-29029 June 1979 Testimony of Rn Hettinger Re QA Program.Describes Current Level of QA Activities.Certificate of Svc Encl ML19246C4681979-06-0101 June 1979 Submits Joint Testimony of Re Olson,Me Coberley,Ls Pack & Jm Coombs.Util Does Not Have Reasonable Assurance of Obtaining Funds for Const & Fuel Cycle Costs.Prof Qualifications & Certificate of Svc Encl ML19242D2021979-06-0101 June 1979 Supplements Testimony Presented at 780217 Proceeding Re Util Use of Piping Test Data to Predict Yield of Proposed Ranney Collector Sys & Drawdown Effects of Ranney Collectors on Nearby Red Cabin & Muddy Creeks ML19241A6171979-06-0101 June 1979 Testimony Re Ranney Collector Sys.Sys Is Sufficient to Provide Plant Water Needs Under Varying Conditions W/Minimal Impact on Water Resources 1979-08-08
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML19210E1281979-10-18018 October 1979 Prefiled Testimony.Bechtel 1979 Geology Map Cannot Be Used as Tool for Seismic Evaluation of Area.Supporting Documentation,Prof Qualifications & Certificate of Svc Encl ML19276H5781979-10-18018 October 1979 Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications Encl ML19276H5801979-10-18018 October 1979 Prefiled Testimony.Two east-west Trending Faults Can Be Found Along Plant Site Vicinity ML19276H5831979-10-18018 October 1979 Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments Deformation ML19276H5751979-10-17017 October 1979 Prefiled Testimony.High Frequency Seismic Methods Inadequate to Locate Fault Traces Existing in Area.Interpolation Between Spaced Seismic Lines Is Speculative ML19210C1631979-10-0808 October 1979 Testimony of Nm Newmark Re Conservatism of Seismic Design Criteria & Seismic Design Provisions for Facility.Biography Encl ML19210C1601979-10-0808 October 1979 Testimony of Ba Bolt Re Correlation Between Peak Acceleration & Magnitude & Intensity.Biography,Publication List & Supporting Documentation Encl ML19256E3281979-10-0303 October 1979 Supplemental Testimony of J Kelleher Re NRC Methods Used to Estimate Strong Ground Motion ML20136C5211979-08-30030 August 1979 Transcript of 790830 Hearing in Seattle,Wa. Pp 14,802-15,048 ML20136C5271979-08-27027 August 1979 Transcript of 790827 Hearing in Seattle,Wa. Pp 14,388-14,573.Exhibits 213-15 Encl ML19249E1561979-08-0808 August 1979 Testimony Re Financial Qualifications Submitted by J Lazar on Behalf of Intervenor Skagitonians Concerned About Nuclear Power.Asserts Applicant Will Be Unable to Secure Financing. Certificate of Svc Encl ML19207B4771979-07-12012 July 1979 Supplemental Testimony of Es Cheney Re Alternative Site Comparison,Submitted on Behalf of Skagitonians Concerned About Nuclear Power.Goshen,Hanford & Pebble Springs Are Better Sites than Skagit ML19209B0681979-07-10010 July 1979 Testimony of ML Darland on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Evacuation Planning.Professional Qualifications Encl ML19209B0691979-07-10010 July 1979 Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography Encl ML19209B0721979-07-10010 July 1979 Testimony of J Lazar on Behalf of Intervenors Skagitonians Concerned About Nuclear Power,Re Financial Qualifications. W/Supporting Documentation ML19247B2871979-07-0202 July 1979 Testimony of RB Eastvedt Re Bulk Transmission Sys Requirements Associated W/Alternate Sites ML19207B4841979-06-29029 June 1979 Testimony of JW Ellis Re QA Program.Util Has Implemented QA Program That Fully Complies with All State & Federal Regulations ML19207B4811979-06-29029 June 1979 Testimony of Je Mecca Re Amended License Application & Complete Psar.Verifies Application as Amended Through Amend 4 & PSAR as Amended Through Amend 20 & Suppl 18 ML19207B4851979-06-29029 June 1979 Testimony of Wj Ferguson Re Engineering,Qa & Const Project Organizations.Qa Program Is Autonomous & Objective.Bechtel Has Primary Responsibility for Review of Design & Procurement Documents ML19207B4901979-06-29029 June 1979 Testimony of Ev Padgett Re QA Program.Qa Program Was Developed to Meet Requirements of 10CFR50,App B & ANSI N45.2 as Set Forth in Chapter 17 ML19207B4911979-06-29029 June 1979 Testimony of Rn Hettinger Re QA Program.Describes Current Level of QA Activities.Certificate of Svc Encl ML19246C4681979-06-0101 June 1979 Submits Joint Testimony of Re Olson,Me Coberley,Ls Pack & Jm Coombs.Util Does Not Have Reasonable Assurance of Obtaining Funds for Const & Fuel Cycle Costs.Prof Qualifications & Certificate of Svc Encl ML19242D2021979-06-0101 June 1979 Supplements Testimony Presented at 780217 Proceeding Re Util Use of Piping Test Data to Predict Yield of Proposed Ranney Collector Sys & Drawdown Effects of Ranney Collectors on Nearby Red Cabin & Muddy Creeks ML19241A6171979-06-0101 June 1979 Testimony Re Ranney Collector Sys.Sys Is Sufficient to Provide Plant Water Needs Under Varying Conditions W/Minimal Impact on Water Resources 1979-08-08
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%:~ :y INTERVENORS SUPPLEMgx2AL TESTIF.ONY ON ALTERNATIVE SITE COMPARISON E. S. Cheney 12 July 1979 750.530mio cA.em) vs .w.
9
SUMMARY
The applicants have identified six alternative sites for the Skagit nuclear plants. With the exception of the hazard of a nearby oil refinery at Cherry Point, Washington, non-geological f actors do not seem to be critical in choosing between these sites. Preliminary geological analyses indicate that Cherry Point and Skagit should be eliminated because they are adjacent to faults in a region of high seismicity. Goshen is better than Skagit, but because it is in the same region of high se: smicity ar.d may be too close to f aults, it probably is, at best, marginal. Hanford, Pebble Springs, and Ryderwood clearly are superior sites compared to Skagit, but this preliminary study is not sufficient to endorse chose as nuclear power plant sites.
This evaluation dif fers markedly from the evaluations of the applicant's (Bechtel, 1979, p. 50) and the NRC's (Leech, et. al.,
1979, p. 13, 15) which concluded that the Skagit was the superior site in western Washington. The NRC even concluded that no known geological, seismological, or geotechnical reason preclude con-struction of nuclear power plants at any of the six sites (p. 14, 18).
Because detailed geological mapping of bedrock and surfical sediments must still be undertaken before the Skagit area can be evaluated in detail, additional delays may be minimized by moving the proposed Skagit plants to Hanford.
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INTRODUCTION The applicants have identified six alternative sites for the Skagit nuclear plants:
Skagit in Skagit County, Washington Goshan in Whatcom County, Washington Cherry Point in Whatcom County, Washington Hanford, in Benton County, Washington Pebble Springs in Gilliam County, Oregon Ryderwood in Lewis County, Washington Of these, I have only studied Skagit in detail (Cheney, 1978 a); so evaluation of the other five sites is preliminary and, thecefore, comparable, to the screening that might be done in the initial selection of nieas for further evaluation as potential nuclear power sites.
Table 1 compares the six sites. The information contained in the table indicates tnat Cherry Point and Skagit are unacceptacle sites and Goshen is, at b'st, marginal; whereas, Hanf ord, P ebble Springs, and Ryderwood z .e clearly superior to Skagit md Goshen.
bO8393 NON-GEOLOGICAL ACTORS The prefiled testimony of Leech et. al. (1979) indicates that non-geological f actors are not critical in choosing between the six sites (Tab.' ? 1). However, Leech et al. do indicate that on socio-economic grounds, Skagit is less desirable than either Hanford or Pebble Springs.
Transmission costs are not critical in the selection of sites.
Electricity is already transmitted from the hydroelectric plants east of the Cascades to western Oregon and western Washington. The transmission costs from Skagit are obviously minimal for Puget Sound Power and Light because the site is within its service area.
How eve r, the Oregon utilities, which own 50% of the proposed plants, would experience lesser transmission costs if the plants were to be located at Ryderwood. If the plants were located at Hanford or Pebble Springs, the transmission costs to the Oregon utilities probably would be somewhat less than from the Skagit, Goshen or Cherry Point sites which are more distant from the utili-ties service areas. Transmission costs to Washington W:tter Power, which owns 10% of the proposed plants, would be minimal if the plants were in Hanford or Pebble Springs. In summary , although the transmission costs to Puget Sound Power and Light would be least if the plants were at Skagit, when all of the utilities are considered, the transmission costs are probably leeit from Ryderwood, and Hanford and Pebble Springs are even better than Skagit.
N
GEOLOGICAL FACTORS The limiting f actors in choosing between the six sites identi-fied by the applicant are geological. Skagit and Cherry Point are unacceptable because they are in an area of high seismicity and are adjacent to faults. Additionally, Skagit has potential landslide problems and its water intake wells adjacent tc the Skagit river cannot be protected because flood-control structures will not be allowed. Cherry Point may have a potential for liquifaction.
Goshen, about 8 miles northeast of Bellingham, appears to be a marginal site. It is in the same area of high seismicity as the Skagit and Cherry Point sites, but it is more distant from the Bellingham Bay-Lcke Chaplain f ault. The suitability of the site wouln depend critically upon investigation of the age of the Vedder
. Mountain fault which passes within 5 miles of the site.
Ryderwood, Hanford, and Pebble Springs all appear to be good candidate sites. Ryderwood is in the same area in which Woodward-Clyde Consultants (1975) independently identified two good candidate sites.
BOB 3bt CRITIQUE OF THE APPLICANTS' AND THE NRC'S EVALUATION OF SITES The applicants' (Bechtel, 1978) and the NRC's (Leech, et al. , 1978) evaluations of the alternative sites deserve some response. In this section I will note some differences in the geological evaluations in those reports and in Table 1 of this report.
Skagit Although Leech et al. (1979, p. 19) and the applicant (Bechtel, 1978, p. 13) expect no landslides, the report of R. H. Blunden (1978) suggests differently.
Leech and others consider the Shuksan thrust, which is three miles west of the plant site, to be the closest significant fault.
This fault is not significant in that it is not capable. What is significant is that the USGS (Whetten testimony of June, 1978) believes that his is not the easterly dipping Shuksan thrust fault, but a somewhat younger westerly dipping th' ec fault. This contro-versy indicates how poorly known the geology of the Skagit site is.
Leech, et al. 1979 and the applicants (Bechtel, 1978) fail to mention that the Day Creek and Gilligan Creek f aults (noted by Whetten) and the inf erred Hamilton f ault (Cheney, 1978 a) pass within three miles of the plant site.
Although Leech et al. consider the Devil's Mountain f ault 13 miles south of the plant site to be capable (p. 19) they do not consider it a hazard because they assume that an earthquake on it w"uld be less than 6.0 to 6.5 M, p. 20). However, if this assump-808352
tion is wrong and the earthquake is >6.8 M, acceleration at the plant site could exceed 0.35g (C heney , 1978 a, Table 3 ) .
Leech et al. believe that the controlling earthquake at Skagit would be associated with the subduct oceanic plate at a depth of 50 km or more below the site (p. 20) and that attenuation from such a grest depth would cause acceleration to be less than 0.35g. However, this would not be the controlling earthquake. The controlling ,
earthquake would be comparable to the shallow 1946 or 1872 earth-quakes. The 1946 earthquake was 7.3 M, less than 30 km deep, and on a preferred f ault plane solution that was northwesterly and right lateral (Rogers and Hasegawa, 1978). The 1946 earthquake was spatially asscaiated with the Beaufort Range f ault; a neter of historic displacement has been noted on this f ault ( Roge rs , S ep-tember, 1978, personal communication). Furthermore, the 1872 earthquake, which was somewhere in the northern Cascades, probably in the vicinity of Ross Lake (Malone and Bos, 1979), was shallow and about 7.3 M (C heney , 1970 a, Table 5) . Because the causitive structure of this earthquake has not been identified, and because the earthquake is in the same geological province as the Skagit site, according to CFR Part 100, Appendix A, the 1872 earthquake must be assumed to occur at the plant site. A 7.3 M earthquake within 15 miles of the plant site could exceed 0.35g (Cheney 1978 a, Table 3). F urthe rmo.re , because the 1872 and 1946 earthquakes were greater than equal to 7.3 M, the maximum credibl.e earthquake must be correspondingly larger.
The problem of preserving the integrity of the coolant water is not addressed by Leech et al., 1979, or by the applicants (Bechtel, g383b3
1978). Dunne (1979) points out that the bend of the Skagit River where the Ranney wells are planned cannot be stabilized without rip rap. The Wild and Scenic River Act presumably excludes such engineering structures.
Cherrv Point This site is within five miles of what Leech et al. term the Northern San Juan Island Fault, which I considered to be part of the BB-LC (Cheney, 1978 a). The presence of this fault and the presence of this site in the same seismic province as the Skagit suggests that 4
the controlling earthquake for the two sites is the same.
There appears to be considerable disagreement as to the age of the sediments at Cherry Point. This is significant because a till reportedly overlies a silt that dips as high as 7* (Easterbrook, 1963, Bechtel, 1978). Such lash and laterally persistant dips in a silt are surely tectonic as Gower (1978) notes. Bechtel cites Gower (1978) as stating that the silts are pre-Frazer (older than 13,000 to 20,000 years), but Easterbrooa explicitly states that Frazer and older sediments do not crop out in the area. He shows the area around Caerry Point underlain by the Bellingham drif t that has locally been dated at 11,000 to 12,000 years B. P. Thus the defor-mation at Cherry Point would appear to be very youag, def orma tion of such young strata would not be a desirable feature at a nuclear site.
Leech et al. point out that extent and age of the Northern San Juan Island fault have not been de termined and that to do so would be di f ficult, costly, time-consuming, and possibly futile (p. 26).
Although such determinations may be costly they should be relatively 808354
easy. Seismic reflection profiling at low frequencies discovered the f ault in the bedrock, and such surveys could be used again.
Presumably, some experimentation with higher frequencies would be needed to find those that will penetrate the overlying unconsolidatea sediments and still have enough resolution to detect any faulting in these sediments. If the f ault strikes eastward as Leech et al.
imp ly , it might be traced onto land. The overlyina sediments could ,
then be drilled to date them paleontologically or radiometrically.
Even if the fault does not strike landward, seismic reflection profiling might recognize the landward extension of the sediments overlying it, so that the cediments could be sampled by drilling.
The Boulder Creek and Vedder Mountain faults may need to be evaluated for this site. However, evaluation of these' faults is described below in the discussion of the Goshen site.
Goshen Because it is the same seismic province as Skagit, Goshen has many of the came problems as Skagit. The site is, therefore, probably unacceptable. Furthermore, it is only 17 miles distance f rom Northern San Juan Island f ault (the BB-LG).
The southwesterly striking Boulder Creek and Vedder Mountain faults may pass within five miles of the site, and thus they would have to be evaluated. According to Miller and Misch, 1963, the Boulder Creek f ault does not cut the middle Eocene Huntingdon formation, and this relationship should be easy to confirm by geology (contrary to the opinion of Leech e al. , p. 22, 26).
'fhe southwesterly striking Vedder Mountain f ault might be more di f ficult to evaluate because it is covered by Pleistocene sediments.
g[38'.[CU
Howeve r, conventionel seismic reflection profiling across the strike of this f ault should indicate whether it cuts the Miocene and Pleisto-cene sediments in the Bellingham basin.
Ryderwood Numerous small f aults are known in the vicinity of the Ryder-wood site. Leech et al. (p. 24) consider that adequate definition and delineation of these f aults might be possible but time consuming and costly due to the lack of marker units. The presence of Tertiary, Early Pleistocene, and Late Pleistocene strata in this area (Woodward-Clyde Consultants, Table 3) suggests that the faults can be dated.
In f act without such a possibility, the two sites in the area would not have been considered by Woodward-Clyde Consultants (p. 39) . In ,
this respect Ryderwood may be superior to Skagit.
80825G
_g_
DELAYS Changing the Skagit plants to the Hanford or Pebble Springs sites might not result in great-r delay than persisting to insist that they be at Skagit. The applicants have not yet undertaken the detailed geclogical mapping of bedrock and surficial sediments at scales greater than one inch = one mile (1:62,500) that is regarded as necessary by geoscientists f amiliar with the area to evaluate the ,
Skagit area (Cheney, 1978 a, Appendix 2; Cheney, 1978 b). The applicants' apparent reluctance to do such mapping suggests that they would not be able to complete it within a year. P resumably ,
Goshen or Ryderwood would take equally long to map. In contrast, the Hanford Site has already been licensed for WPPSS numbers 1, 2 and 4, suggesting that additional studies at Hanford would be mi ninal. Similarly, geological investigation at Pebble Springs are well advanced.
Therefore, assuming that the costs of delay are important, the applicants might find it advantageous to cite the proposed Skagit plants at Hanf ord. This consideration may be especially important, because absolutely no assurance exists that if the applicants or disinterested third parties were to map the area around Skagit at scales greater than 1:62,500, all geological problems would disappear.
I n f a ct , the reverse is highly likely.
,v
>O'jj SITES FOR FOSSIL FUEL PLANTS Because the hazards caused by the destruction of a plant by earthquakes are not nearly as serious for a fossil fuel plant as for a nuclear power plant, the requirements for siting fossil fuel olr.nts are not nearly as stringent. A preliminary study by Woodward-Clyde Consultants (1975, Figure A-6) shows that most of Puget Lowland, including must of the service area of Puget Sound Power and ,
Light, is suitable for fossil fuel sites. Of the six alternative sites, only the Skagit site was eliminated as a fossil fuel plant site in this study.
SC83b8
REFERENCES:
BECHTEL, INC, 1978: A comparative analysis of geologic and seismologic conditions of the alternative sites to the Skagit Nuclear Power Proj ect. Peport submitted Director of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission in behalf of Puget Sound Power and Light Co. , 55 p.
BLUNDEN, R. H., 1978: Review of bore hole logging for the proposed Skagit Nuclear Power Plant near Sedro Wooley, Washington; Report No. C277/2 prepared for Skagitonians Concerned About Nuclear Plants, 12 p.
CHENEY, E. S., 1978: Interim report on the seismic and the geologic hazards to the propcsed Skagit Nuclear Power Site, Sedro Wooley, Washington (6th revision), submi tted May 1978 as prefiled testimony to the Atomic Safety and Licensing Board, U. S. Nuclear Regulatory Commission, Washington, D. C., 128 p.
CHENEY, DR. ERIC, May 1978: Prefiled testimony on geologic mapping, Puget Sound Power and Light, et al., Docket Nos.
STN 50-522 and STN 50-523, Pg. 11,420 DUNNE, T., 1979: Memo to E. S. Cheney dated 11 June, 1979, 2 p.
EASTERBROOK, D. J., 1975: Geologic map of Western Whatcom County, Washington; U. S. Geol. Surv. Map I-854-3, Scale 1:62,500 EASTVEDT, R. B., 1979: Testimony on bulk transmission system requirements associated with alternative sites for the Skagit Nuclear Generating Facilities; prefiled testimony as Appendix B of Leech, et al., 1979, 2 July 1979, 31 p.
GOWER, H. D., 1978: Tectonic map of the Puget Sound Region, Washington, showing locations of faults, principal folds and large scale Quaternary deformation; U. S. Geol. Surv. Open File Report 78-426, 17 p.; Map Scale 1:250,000.
LEECH, P., DVORAK, A., LEFEVRE, H., WINTERS, T., STULL, E., and EASTVEDT, R., 1979: NRC Staff testimony on alternative site comparison; prefiled testimony before the Atomic Safety and Licensing Board, U. S. Nuclear Regulatory Commission, 2 June 1979, 110 p.
MALONE, S. D., and BOR, S-S, 1979- Seismic attenuation patterns in Washington State from intensity data; Seis. Soc.. Amer.
Bull.,v. 69, in cress.
REFERENCES g',}i/S Page 1
MILLER, G. H., and MISCH, P., 1963: Early Eocene angular unconformity at Western front of Northern Cescades, Whatcom Co.,
Washington; Amer. Assoc. Petroleum Geologists, Bull. 47,
- p. 163-174.
MILNE, U. G., ROGERS, G. C., RIDDIHOUGH, R. P., McMECHAN, G. A.,
and HYNDMAN, R. D., 1978: Seismicity of Western Canada:
Canadian Jour. Earth Sco. v. 15, p. 1170-1193.
ROGERS, G. C., and HASEGAWA, H. S., 1978: A second look at the British Columbia earthquake of 23 June 1946; Seis. Soc Amer.
Bull., v. 68, p. 653-675.
WHETTEN, DR. JOHN H.: TestLmony of May 1978; Puget Siund Power and Loght Co., et al., Docket Nos. STN 50-522 and STN 50-523, Pg. 11,010.
WOODWARD-CLYDE CONSULTANTS, 1975: Executive stimmnry Siting Study; available from Washington Public Power Supply System, Richland, Washington, 57 p.
REFERENCES Page 2 80S M
" PEBBLE CRIIERIA IIARFORD SPRINGS RYDERWOOD 60SilEN SKAGIT CilERRY P0llil Comparable to Terrestial Comparable to Comparable to Frobably similar Ecology Skagit (1) Skagit (1) to Skagit Skdste and Pebble Springs (1)
Aquatic Ecology Comparable to Comparable to Frobably sistler Comparable to and Resources Skagit (2) Skagit (2) to Skagit Skcgit and Febble Springs (2) h Socio-Economic Freferable to Preferable to Frobably stallar Less Destrable to h to Skagit than llanford or g Skagit (3) Skagit (3)
Pebble Springs (3) t p l I Approutmately Twice se Expensive as Approminately one lialf as expensive as llanford or Pebble Springs (4) g g Transmission z Cost Western Washington (4)
Too Close to 011 Other g,gg,,,, (5) t once-thsough Cooling Bad (5) g sestomal in Area of Imv Seismicity (6) In Area of High Low Subarea (6) In Area of High Setssicity (6,11) Within Area of Seismicity (6,11)
Selsetetty liigh Seismicity (6,11)
[i Distance to 10 Miles; 2ts Hiles, not Hany Small Fa.Its 17 Hiles to BB-LC 9 Hilaus to BB-t4 <5 Hiles to BB-LC Faults Probably not Capable (1) to be Investigated at llate rasmage 13 Htles to Devils = Northern San Juan f Capable (7) (9) (10) Htn. Island Fault (10,12)
<5 Hiles from <5 Hiles to Several l L VeJJer Htn. Faulta in Skagit g $q Fault Valley (10)
, ~
Cont rol '. tnil Shallow Earthquake, Frobably >20 Miles Distant and Probably Shallow Earthquake, Frobably <20 Hiles Distant and Earthquake 17.3 to 7.5 H of 1946 and 1872 >7.3 to 7.5 H of 1946 and 1872 l
"otential f3r Hone (13) None (13) Low (13) ' low (11) Possibly Imv (13)
Landslides e Severe (14)
With Resvital Nonet Bednock (13) Honet Bedrock (13) Nonet Bedrock (13) Nonet BcJrock (13) Possiblyson rotential For Liquefaction Worm, None (13) Sediments Unpsutected on Wild d' Vunerability cf and Scenic River Ca Cooling Water Eliminated by Ellatunted by Regional investigitto.. of Not Strict!w Not Strict!) Best CanJigate Eliminated by Se i smic it y W Sites 1.ewie #3 and Regional Culturally impor-
- 7) Woodward-Clyda ? valuated, but Evaluated, but (Figure D4)
I.ewie #2 in Sama Area
'[ }"
, Consultants 1975 Acceptchle Benton Acceptable Benton Seismicity (Figure D4) tant Area of Skagit Valley
'% 4
- 1 to Nearby #1 la Hearby (Figuse pt) _ , _ _ _ _ _ _ , _ _ , _ - _
' H ANK I N* ' s' suits (:ANibillATl' 311FS HARGINAl. ItN it's f ra mi t O
TABLE 1: COMPARISON FO THE SIX ALTERNATIVE SITES:
References:
- 1) Leech, et al., 1979 Table 3
- 2) Leech, et al., 1979 Table 2
- 3) Leech, et al., 1979 Table 5
- 4) Eastvedt, 1979 Page 6
- 5) Leech, et al., 1979 Page 13
- 6) Woodward-Clyde Consultants, 1975 Figure D4
- 7) Leech, et al., 1979 Page 30
- 8) Leech, et al., 1979 Page 28
- 9) Leech, et al., 1979 Page 24 Woodward Clyde Consulc. ants, 1975 Table 3
- 10) Cheney, 1978 Figure 12
- 11) Milne, et al., 1978 Figure 10
- 12) Leech, et cl., 1979 Page 26
- 13) Leech, et al., 1979 Table 1
- 14) Blunden, 1978 Format of Table: Note that boxes are drawn around the criteria under each site that make that site questionable for nuclear power plants.
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