ML19209A699
| ML19209A699 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 08/13/1979 |
| From: | Leed R LEED, R.M., SKAGITONIANS CONCERNED ABOUT NUCLEAR POWER (SCANP) |
| To: | PUGET SOUND POWER & LIGHT CO. |
| References | |
| NUDOCS 7910050237 | |
| Download: ML19209A699 (17) | |
Text
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gTED CORRESPO gg
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UNITED 'TATES OF AMERICA g .
NUCLEAR REo0LATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
)
PUGET SOUND POWER & LIGHT ) DOCK ET 'JOS. STN 50-522 COMPANY, et al., ) 50-523
)
)
(Gkagi t Nuclear Power Project, ) August .s5, 1979 Units 1 and 2) )
)
)
INTERVENOR SCANP 'S RESPONSE TO APPLICANT'S IRTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Interrogatory No. 1. Our sole sources c' information are available tnrcugh the University of Washington Geophysics Program.
We would recommend contacting Prof essors Smith, Malone, on C ros son.
The details requested are presumably available from these sources.
We do not presently have them.
Interrogatory No. 2.
a) McC lery , J . , Dohrenwend, J . , Cluff, L., at.d H anson, K.,
April, 1978, Straight Creek Fault Zone Study, piepared by Woodward-Clyde Consultants (San Francisco, Cal.) as a part of the 1872 Earthquaka S tudies for WPPSS Nuclear Project Nos. 1 and 4.
b) M cCleary , J .R. , Dohrenwend, J .C. , and Risdley, A.P.,
1979, Geol. Soc. Amer. Abs tracts with Programs , p. 90-91. The authers are employed by Woodward-Clyde Consultants, San Francisco, California.
_1_
79100D"537 1106 0;/
l c) Seattle City Light is currently studying the geological feasibility of the Copper Creex damsite, and such investigation may provide additional information about the Straight Creek Fault.
This information can e; obtained by the Applicants through Dr.
H.A. Coombs.
Interrogatory No. 3. ,
a) Whetten, , J .T. , et al., 1978 M Howell, D .G. , and M cD ou ga ll, eds. , Pacific Section Soc. Econ. Paleontologists and Mineralocists: Pacific Coas t Paleontology Sy::posium 2, p. 117-132.
F b) Rogers, G.C., and Hasegawa, H.S., 1978, Seis. Soc. Amer.
Bull., v. 68, p. 653-675.
c) M iln e. W.G . , et al., 1978, Canadian Jour. Earth S ci. ,
- v. 15, p. 1170-1193.
d) Gower, H.D., 197 8, U .S . G eol . Sury. Open File Report 78-426, 17 p.
e) Crosson, R.S., and Nosson, L.J., 1978, Wash. Div. Geol.
and Earth Resources Info. Cire. 64, 12 p.
f) C ros son, R.S., and Noson, L.J., 1978, Wash. Div. Geol, and Earth Resources Info. Cire. 65, 13 p.
Interrogatory No. 4. None Interrogatory No. 5. See Attachment A by Prof essor Thomas Dunn, Department of Geological Sciences, University of Washington, dated 11 June 1979 concerning bank erosion studies of the Skagit River. Also see the series of reports prepared by Dr. E. Cheney, previously made available to you, and previous studies discussed f-t l } (.) b hb
by Mr. Roy Blunden. Also see the attached letter report of Mr.
Blunden. ( Attachment B) .
Interrogatory No. 6. Our witnesses of fered their presenta-tion on this subject at the last hearing.
Interrogatory No. 7. Our witness, Dr. Er ic Cheney, has com-pleted his presentation, which answered the qu:estions raised.
Interrogatory No. 8. The information requested is not yet available to us.
Interrogatory No. 9. Prefiled testimony con evacuation plan-ning was distributed to all parties on July 20., 1979, and responds to this question.
Interrogatory No. 10. The testimony of Jim L azar has been distributed to all parties - nd responds to this question.
Interrogatory No. 11. To the extent such information is now available, it has already be en furnished.
Request for Produciton No. 1.
a) The reports listed under Interrogator:ies No. 2 and 3 can be obtaired from the referenced sources.
b) Dunne 's Memorandum ( Attachment A desc ribed in Answer to Interrogatory No. 5) and the Blunden report dated June 29, 1979 are enclosed. ( Attachment B ) .
Request for Production No. 2. See Attachtments C through P.
DATE7 this day of August, 1979.
Respect fully sutomi tted, RCGER M. LEED Counsel for Inteervenor SCANP 1411 Fourth Ave nue Bldg.
Seattle, Washinigton 98101 i
1106 019
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DTED C0ARE.SPONDF.NCE Q UNITED STATES OF AMERICA o,***
NUCLEAR REGULATORY COMMISSION b y BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
)
PUGET SOUND POWER & LIGHT ) DOCKET NOS. STN 5 0- 522 COMPANY, et al., ) 50-523
)
)
(Skagit Nuclear Power Project, )
Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE ,
I hereby certify that copies of- . Intervenor Scano's Response To Applicant's Interrogatories and Recuests For Production of Documents dated Aug"st 13, 1979, have been served on the folicwi.ng by depositing the same in the United States mail, postage prepaid, on this 16 day of August , 1979.
Valentine B. Deale, Esq., Chairman Alan S. Rosenthal., Chiirman Atomic Safety'and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Commissi 1001 Connecticut Avenue N.W. Washington, D .C. 20055 Washington, D.C. 20036 Dr. John H. B u ck , Member Dr. Frank F. Hooper, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board School of Natural Resources U.S. Nuclear Regulatory Commissi University of Michigan Washington, D .C. 20555 Ann Arbor, MI. 48104 Michael C. Farrar, Member Gustave A. Linenberger, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commiss; Commission Washington, D.C. 20555 Washington, D.C. 20555 Certificate - 1
.\
1 106 020
?00R OR M Docketing and Service Section .
Of fice of the Secretary Canadian Consulate General U.S. Nuclear Regulatory Peter A. van Prakel Commission Vice-Consul Washington, D.C. 20555 412 Plaza 600 6th and Stewart S treet Richard L. Black, Esq. Seattle, Washington 98101 Counsel for NRC Staff U.S. Nuclear Regulatory F. Theodore Thomsen Commission Perkins, Coie, S tone, . Olsen Office of the Executive Legal & 'tilli ams Director 1900 Washing wn Building Washington, D, C. 20555 Seattle, Washington 98101 Nicholas D. Lewis, Chairman Alan P. O 'KeIly Energy Facility Site Evaluation Paine, Lowe, Coffin, Herman Council & onge11y 820 East Fifth A y nue 1400 Washington Trust Financial Olympia, Washington 98504 Center Spokane, Washington 99204 Robert C. Schofield, Director Skagi t County Planning Depart- Russel W. Busch ment Everg reen Legal Services 120 West Kincaid Street 520 Snith Tower M t. Ve rnon , Washington 98273 Seattle, Washington 98104 Richard M. Sandvik, Esq., Thoma, Moser Assistant Attorney General Deputi Prosecuting Attorney Department of Justice Skagi t County Courthouse 500 Pacific Building Mt. Vernon, Washington 98273 520 S. W. Yamhill Portland, Or'gon 97204 Robert Lowenstein, Esq.
Lowens tei n, Newman, Reis &
Axelrad 1025 Connecticut Avenue, N.W.
Washignton, D.C. 20036 H. H. Phillips, Esq.
Vice President and Corporate Counsel Portland General Electric Company 121 S.W. Salmon S tree. DATED: August 16, 1979 Portland, Oregon 97204 ROGER M. LEED CFSP and FOB E. Stachon & L. Marbet !
19'42 S. Bakers Ferry Roaa, Boring, Oregon 97009 Bypj/ /w,,, , . l. k / , g.f_g Certificate - 2 l}()6 O2}
i University of Wsshington Correspondence ALL
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GEOLOGICAL SCIENCES gmrq June 11, 19 .
To: Eric Cheney , 2 W"' Y gp FROM: Tom Dunne ~ /C2?f ,
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I looked over the aerial photos and the consultant's report on bank %IIs em e in the Skagit.
Bechtel hired a good consultant, Sorland, who is experienced in and has published good papers on the engineering of large rivers. He has told then, correctly, that they have a real problem most places on that river.
The Skagit moves). rapidly around its floodplain. However, they have chosen a relatively stable and predictable bend, which was shif ting at an average rate of 25 f t/yr before its outer bank was prote:ted by a rip-rap that he judges to be inadequate. Recent failure of the rip-rap at the proposed v '.1 site in a modest flood (2-3-yr recurrence interval) confirms this. Thy failure occurred because the point bar (the opposite, convex bank) continued to grow after the rip-rap was installed, and it forced the main velocity thread against the outer bank, increasing the shear stress, and.
brobabably) undermining the protective wall by scouring out its toe.
In spite of this experience, Borland believes that the bank can be stabilized, stating (p. 3, line 4 ff)
"It has been proven on many rivers that if the concave (sic) or outside of a bend can be stabilized aad held rigid by structures, the bedload cf the river will be transported through the bend and the point bar en the convex (sic) or inside of the bend will also be stabili=ad, no icnger growing in size."
The statement is true, but its most important centent is the work "if." The Skagit is a big, steep river that exceeded 200,000 cfs at Sedro h*oolley at least four times in the century 1815-1923, according to U.S. Geological Survey Water Supply Paper 1527. The authors of that report estimated that such a flood was the 20-year flood (i.e., had a 5 percent c hance of being ecualled or exceeded in any one year). Borland (p. 3), presumably on the basis of more recent information about the effect of dams on flood peaks (check?), indicates that 225,00 cf s has only a ene-percent chance of being exceeded in any year. This is still an important probablility for an event which is 2.8 times larger than the 1974 flood that caused failure and would rise about 8 feet higher (according to USGS Water Supply Paper 1527, p. 52).
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I do not wish to 1: ply that Borland is wrong. I suspect that he is c o rre c t , particularly if the maintenance that he refers to (p. 3), is f aithfully carried out. But I would ask him to strengthen his centention by pointing to other cases where a rip-rap of the kind proposed in Figure 2 of his report has repeatedly withstood the magnitude of stress and the degree of basal scour that will be imposed in the Skagit during a major flood. I do net know the details of the topography and proposed land usa below the potential failure site, so I cannot suggest how bit a flood should be considered. In any case the recurrence interval to be considered is a planning and politic . decision, rather than a hyorological one.
If the proposed protection is emplaced, I suggest that one important detail be thoroughly checked beforehand. On Fig. 2, Mr. Borland proposes that the toc of the rip-rap be extended to a depth of three feet below the Thalweg.
It is my feeling that en a river the size of the Skagit, this is too shallow for safety. The sketch indicates that the rf ver channel is 8 to 25 feet deep. The depth of scour is almost certainly greater than 3 feet in a big flood, particulaFly on the outside of a bend where the flow will be partly confined by some future growth of the point bar. The sketch suggests a minimum of 3 feet. I suggest that the problem be addressed more thoroughly by field ceasurements and the use of empirical scour formulae before a final decisien is made. The question of rock size in the rip-rap should a.so be Icoked at is more detail. The sketch suggests "24-inch maxi =um" f or :he rock size. I would like to know what the mean size would be,, and how muca of the smaller sizes will be included. I would also judge on the b. asis of 'ocal field observation what size of rock can be moved in that rea ch, es v.ll as on the basis of cautious use.of handbock values. I assume Mr. Borla:3 did this, but that u a big, steep river.
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File No. C337.79 P)BR M K Mr. Crci>c Martin, President, S.C.A.M.P.,
P.O. Box 137, Burlington, Wa. 98233
Dear Sir:
_R e,: 1978-1979 Geological Investigations for proposed Skagit Nuclear Power Project.
,Upon the ins.tuctions of Mr. Roger Leed, Attorney, I have reviewed reports by Bechtel Inc. for Puget Sound Power & Light Company, in his office between June 6th and 8th, 1979. I also held a general discussion of the investigation data with Dr. Eric Cheney and with Dr. Fred Pessl, Jr. of the U.S. Geological Survey.
The reports studied were contained in the Report of Geologic Investigations in 197 8-197 9 con-cerning investigation of deformed Pleistocene sediments.
Included was a report by Dr. Don J. Easterbrook, dated April 3rd. As the actual investigation findings appeared not to have been fully included in that report, a further report of Bechtel Inc. dated Decer.ber 29 th, 1978 was also studied.
- Two specific areas of deformed Pleistccene sedi-r.ents were considered in the reports, neither of which have been studied in the field by the writer. Of the two areas referred to in the Bechtel Inc. reports only the Cavanauc h Road exposures were subjected to sub-surf ace 1106 ON i
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investigation and are here considered in the following analysis. This analysis is concerned with the expect-ations, findings and interpretation of the investigation findings by Dr. Easterbrook and Bechtel Inc.
REVIEW OF LAKE CAVANAUGH ROAD AUGER-HOLE INVESTIGATION The purpose of the sub-surface b;vestigation con-ducted by Bechtel Inc. was to determino the causes of the deformation of Pleistocene sediments observable in read cuts along Lake Cavanaugh Road. These deformed sediments occur along the southern projection of a regional lineation postulated by Dr. John Whetten as beine a fault-line. This postulated fault-line, the Gilligan Creek fault, has been studied by the U.S. Geo-logical Survey (U.S.G.S.) who presumably located and reported thc occurrence of the leformed materials.
A description of the area of investigation by the U.S.G.S. and by Dr. Easterbrook indicate the presence of a till morainal ridge to the west, and transverse to the road, backed to the east by lacustrine deposits folded into anticline-syncline deformations. Along the inner flank of the western anticline multiple faults were observed. In addition flame structures were present in the syncline and inner flank of the eastern anticline.
An auger hole investigation conducted by the U.S.G.S .
suggested there might be a displacemenr of L. derlying glacial deposits in the order of some seven metres.
The apparent intent of the Bechtel Inc. investigation, as suggested by the data presented, was to determine the con-tinuity of the -sub-surface glacial deposits and by inference the presence or absence of faulting essociated with the Gilligan Creek lineation.
Dr. Easterbrook ascribes the surf ace morainal ridge a Vashon age and the lacustrine deposits as being of similar recessional Vashon age. In the same report, however, Dr. Easterbrook identifies two sub-surface clacial sequences encountered in auger holes, the lower-most of which he also ascribes of contemporary Vashen age without citing additional supporting evid'ence.
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Page 3 1978-1979 Geological Investigations for proposed Skagit Nuclear Power Project June 29, 1979 Within the auger hole logs of Bechtel 'nc.
(report dated December 29th, 1978), the lowerwost till of Dr. Easterbrook was visually recognized and generally described as "Till: blue-gray diamicton, dense to very dense." Standard penetration tests results indicate that af ter an initial penetration of six inches, hammet blows required to drive the split spr.-9n sampler a further twelve inches (N-value) varied bet, 3en 2
N = 21 & 100' The mean N-value was 62 blows per foot which tends to confirm the field attribution.
In contrast, Dr. Easterbrook also identified an upper till which in no instance is reported to have been recognized as such in the field. Dr. Easterbrook would appear to have established the existence of the upper till cecording to the jumping action of the auger bit when gravel and boulders were encountered at an approxi-mately common depth within a bedded silty sand sequence.
General auger hole log descriptions for this ' upper till' are ' Silty Sand: blue-gray, variously sorted, scattered gravel and cobbles throughout occasional.ly with bedded materials. Logged drilling indications (i.e. the jumping action of the rods) for the same horizon range from small gravel to small boulders. Reported standard penetration values fall between N = 9 & 97 The mean a-value was 27 b]cws per foot, less than half that of the recognized lower till. The two highest N-values, viz: N = 80 (AH #19) and N = 97 (AH #12) are reported from gravel zones and therefore spuriously high.
Dr. Easterbrook in his analysis of the sub-surface conditions places considerable stress upon the existence of the " upper till" to demonstrate that tectonic faulting was not the cause of the soil deformations. The auger-hole logs in contrast would suggest that rather than an irregular till horizon up to three metres in thickness, the " upper till" is the fortuitous assemblage of gravel seams and small boulders in a bedded silty sand assemblage.
Unless Dr. Easterbrook based his identification of the
" upper till" upon data not reported in the quoted sources, it must be concluded that the existance of the " upper till" is an unproven product of his imacination.
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Page 4 1978-1979 Geological Investigations for proposed Skagit Nuclear Power Project June 29, 1979 ,
The continuity of the basal till horizon wou'.d appear to have been confirmed within the limitations of the investigations. From the data presented it must be concluded that any single, large displacement of this horizon, st ggested by the U.S .G.S . , has been shewn to be nonexistant. In contrast, however, the assertion by Dr. Easterbrook that the faulted and deformed sediments do not persist to significant depths below road level due to the presence of the " upper till" cannot be substant-iated from the investigation findings.
The sub-surface investigation also has neither proven nor disproven the existance of recent post-glacia( faulting within the Lake Cavanaugh Road investigation area. 'Bo th D r . Easterbrook and Bechtel Inc. would appear to have assumed that any recent fault activity would involvn the glacial deposits in easily identifiable vertical dis-locations, as originally suggested by the U.S.G.S. Such reasoning would by implication mean that the absense of dramatic evidence of recognizable dislocation would nullify any postulated recent faulting along the Gilligan Creek 1.neation. The form and method of the investigation confirms that only such dramatic evidence was sought, indeed using the augering methods adopted, was the only evidence that could have been identified.
Quaternary faulting repcrted near Lake Cushman, Washington (Wilson et al 1979) do of fer the dramatic upli'f ts of up to eight metres. Examination of he pub-lished photographs of test trenches excavated .ross these faults reveals that had they been investigated using c c:. e drilling they would probably not have been recognized.
In the photograph (Fig. 2, A p.237, loc . ci t) an apprcxi-mately 3-1/2 metre faulted uplift, had that been core drilled, would have yielded a log:
0.7 m+ Till 3.2 m Cataclastic rock 0.2 m+ Till 1.1 m Vitric tuff With coring breaks, even had the lower till been recovered, the most probable interpretation of such a loc would have been a regular till deposit, containing large boulders, overlying a pluckered rock surface. In a soil formation composed of silty sands and tills, such as along Lake Cavanaugh Road, such alternating materials would not be J .1 .ALJ.n ,
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Page 5 1978-1979 Geological Investigations for proposed Skagit Nuclear Power Project ,
June 29, 1979 ,
identified as evidence of faulting.
In contrast slip faulting with surf ace rupturing associated with the Californian Galway Lake earthquake (Hill & Beeby, 1977) yielded shear planes which would be unrecognizable in any augering investigation. Sim-ilarly even using advanced soil sampling techniques, in a drilling investigation such shear planes would, in the absence of other information, be interpre*.ed as soil fissures probably as a result of dessication.
A critical review of the investigation reports of Bechtel .Tnc. for the Lake Cavanaugh Road Auger-hole study of deformed Pleistocene sediments has neither con-firmed nor disproved a tectonic origin for the features observed. The crudity of the augering process adopted would be unlikely to yield unequivocable evidence of even dramatic faulting. Similarly the anger-hole investigation has yielded insuf ficient evidence to confirm or disprove alternative origins for the features observed.
Respectfully subinit ted ,
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June 29, 1979 References Hill, R. L. & D. J. Beeby, 1977, Surface faulting, associated with the 5.2 magnitude Galway Lake earthquake of May 31, 1975: Mojave Desert, San Bernadino County, California.
Bull. Geol. Soc. Amer., vol. 88, Pp 1378 - 1384.
Wilson, J. R., M. J. Bartholomew & R. J. Carson (1979),
Late Quaternary f aults and their relation-F ship to tectonism in the Olympic Peninsula, Washington, Geology, Geol. Soc. Amer.
Vol. 7, No. 5, Pp 235-239.
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UNIVERSITY OF WASHINGTON SEATTLE, WASillNGTON 93193 Deprtment of GeologicalSciences yes7aary 2, 19yg Dr. R. W. Couch School of Oceanography Oregon State University ULH tshhh h!(;h udig h Corvallis, Oregon 97331 '
Dear Dick:
I would appreciate a copy of the following report:
Couch, R. *,'. , Victor, L. , and Keeling, K.., 1974 Coastalpand offshore earthquakes cf the Paciff e C
Northwest between 39 :: and 49 10 'n Latitude a=.d 123 and 131 W Longitude, 67 p.
You pay for ceuld copy.
a Xerex either tell me where I can get a copy, or ! would be happy to My colleague Darrell Ccwan tells ce that you have recently published a ec:pilation so=ewhat larger of the area.geophysical studies and tectonics of =he sa=e or He said the report was for ::0AA or the USGS. How do I get a copy of this new report?
Sincerely, a
Eric S. Cheney Assoc:iate Professor ESC:ck e
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? PHONE (503) 229-55 k January 12, 1979 s
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Dr. Eric Cheney Departnent of Geological S Univ Seat $ersity of '.7ashington ciences le, Washington 98195
Dear Dr. Cheney:
i" Thank ycu for the opport and analysis of unity to review your the geology of the Sed compilation
, Thank you in particular f ro Wooley site and region.
so long. or your patience in lettin g us keep it 1
We found the informati on tKe iacue as on useful in gaining a pero relates to similar pective Mental retention
- all concerns in Oregon.
and we =ay choose to the material, of cours e, is imponsible as the need arises. contact you and others fro:a time to time Sincerely, v& l/h .
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JDB:lk Encl. John D. Beaulieu
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LCl3 Consultants
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AAAm,A F Energy Mines and Gnergie, Mines et E
B $. Resources Canada Ressources Canada Science and Technology Science et Technologie March 1, 1978.
Dr. Eric Cheney, m ,, _
Department of Geological Sciences, University of Washington, % .,_,
Seattle, Washington, 98195, U.S.A.
2
Dear Dr. Cheney,
p Enclosed is a preprint of a paper entitled "A second look at the British Colu=bia earthquske of 23 June 1946" which has been accepted for publication in the June 1978 issue of the Bulletin of the Seismological Society of America. This represents ury current thinking on the 1946 earthquake and I think will answer the questions in your letter of Feb. 8. .
My collegue, Dr. Hasegawa has indicated to me I:n the last week that there chy be an error in t.he section he has written on ground deformation. This would affect only that section and Figures 8 and 9. If there is a revision I will mail you the corrections.
Sincerely, C(*M o
TM G.C. Rogers, Division of Seisz= ology & Geot'.emal Studies.
GCR:dc a
P.S. Please note the change of name and new address of our organization.
c.c. W.G. Milne.
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, ?'Y Pacific Geoscience Centre Centre gsoscientifique du Pacifique 9S60 West Saanicn Road 9860. cnemin Saanich ouest e i P.O Box 6000 Sidney. B C.
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