Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography EnclML19209B069 |
Person / Time |
---|
Site: |
Skagit |
---|
Issue date: |
07/10/1979 |
---|
From: |
Weber P AFFILIATION NOT ASSIGNED |
---|
To: |
|
---|
Shared Package |
---|
ML19209B067 |
List: |
---|
References |
---|
NUDOCS 7910090101 |
Download: ML19209B069 (8) |
|
|
---|
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
[Table view] |
Text
. < r ' 'f
.- .- \ y 2*-
-- :.eO:m u y y ccCps o -
Environmental Concerns Re: Ranney Collectors .N .g3 ? -
at the Proposed Skagit tiuclear Power Plant Site g *. -y,pel ,,
p - Q grot-gE~ f03 N'l We have had the opportunity to examine a number of documents c'e w to the environmental impact of the proposed Ranney Collectors on the sur-rounding environment and the converse envircnmental constraints on the collector wells.
Several items have not been considered, or have received inadequate consideration in the documents we have seen. These include concerns about effects of operating these collectors and effects related to river cnannel stability.
COLLECTOR OPERATI0t1 The following items concern operation:
- 1) Yield Calculations.
- 2) Water quality, particularly in reference to iron content.
- 3) Effect of possible chlorine flushing.
- 4) Effect on local wells. -
- 5) Effect.on tributary streams.
We do not propose to repeat the previous testimony except where neces-sary to explain our concerns. The items herein are additional concerns not covered in the material to date.
- 1) Yield calculations Mikels has answered concerns of the adequacy of the yield calculation with a question as to whether the flow will be laminar or turbulent. This is not the entire problem. An additional instance where Carcy's law might not be applicable is in the analysis of coarse sands and gravels wnich eg910090h 1115 086
.- .~
might not be able to sustain the groundwater gradient proposed. In this case, the low yield pumping tests are not sufficient to determine the avail-able yield at very high rates. The yield, as can be observed from the calculations presented would decrease proportional to the falling gradient.
The effect of an inability to sustain the proposed gradient would be to cause increased draw of stored groundwater, as well as reducing the total yield.
- 2) Water quality, especially iron content ,
Although the precise proportion of infiltrated river water to stored groundwater cannot be determined, the theoretical consideration presented indicates that it will be high. Nonetheless, additional iron and other minerals over the river water content, can be expected to dissolve as the water filters through the ground. Additional comments presented by Jeffrey Haley indicate that iron bacteria can forn in water with iron con-tents in the range known here.
Mikels noted in his affidavit (p.2) that the 48-hour pumping tests (E, F & G) were used only to " establish the initial chemical characteristics of the relatively stagnant groundwater." Yet the water level in these wells
" responded rapidly and consistently to changes in river stage." These wells were pumped at rates from 913 to 1013 gal / min.
The fluctuating levels indi-cate influx of river water.
He also concludes that for a 6-month test on the 16-inch well "the water pumped during the test was primarily intercepted groundwater flow. . . ."
(p.14). This test was pumped at 1,325 gal / min.
Pumping rates on the 6-month tests are similar to the 48-hour tests and induced filtration can be initiated at these rates. Altnough the groundwater level at the start of the test was .6' above river level (31.4' MSt. vs.
/
1115 087
80.8 tiSL), indicating a gradient toward the river, recharge from both the groundwater and river could be expected.
Iron contents on the 16" well varied from .003 ppm to .57 ppm. Al-though the exhibit notes two high values " appear to be anamalous" they should not be discounted as they are in exhibit E. Lab determinations may not always be reliable but the tendency to discount all high values is det-rimental. We might note that two silica values were discounted elsewhere because they appear high. Other applicable iron values are trace amounts discovered in the drilling program and a comment that a well 200' from the collector site contained objectionably high iron (p.10,325 review board).
Behavior of the 48-hour and 6-month pumping tests indicate that infil-trated river water was pmuped. In addition, although both river and ground-water showed generally low iron contents, they are currently sufficient to sustain iron bacteria. The well 200' off-site indicates that there is sol-uble iron in the vicinity which will likely be mobilized by the pumping operation and further increase the iron content.
- 3) Effect of possible chlorine flushing Both the staff report and Mikels recognize the possibility of iron formation and note that there will be no effect on the environment if chlor-ine flushing is required. We strongly disagree. There is no possibility that the chlorine can be restricted to the laterals. When the pump is not operated the water table will begin to readjust toward natural conditions.
This constitutes a flow of water from the river and the vicinity of the laterals away from the river. Scme of that water will be contaminated with chlorine. The chlorine treatment requires 16 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of standing time after which some of the diffused cnlorine can be recovered and pumped to waste.
Ii15 088 '
Some of the chlorine will migrate away from the site and could con-taminate the tributary creeks to the north and wells in the vicinity.
- 4) Effects on local wells The Environmental Report shows that a large number of the water wells within a three mile radius of the proposed plar were located and data tabu-lated. However, the proposed collector well site is outside that radius and the wells have not been investigated. There are undoubtedly wells in this area and the drastic drawdown contemplated for the collector walls will affect them. Also possible contamination should be considered.
- 5) Effect on tributaty streams.
- Muddy Creek has only been shown to be percned in the secticn (approxi-mately 1/4 mile) frcm Lyman-Hamilton road to its confluence with the Skagit River during low flow conditions (Nov. 2,1978). In terms of salmon-spawning this reach is critical as a dry creek mouth would preclude spawning.
RIVER STABILIZATION Concerns related to river channel stability are poorly defined as the proposed riprapping construction and possible repair have been eliminated.
We are not aware what stabilization measures have been substituted.
Adequate protection for collector - laterals, caissons and lines should be developed. From the analysis by Whitney M. Borland (Appendix L -
River Stabilization Study) it is evident that the current reprapping is in-sufficient in a 30,000 cfs flood. The 100-year flood is 225,000 cfs. Dur-ing the January 1974 flood the central portion of the existing 4,600 lineal feet of riprap failed. Additional weak points are upriver from the Red Cabin Creek (east fork) enters the Skagit at mile 39.5 and at the lower end of the riprap where a slough enters the river channel.
1115 089'
From 1918 to 1958 the channel migrated 1,000' northward. After stabilization work the river has been contained frcm 1958 to the present.
In the intervening twenty years the river has directed its current move severely against the bank and the possiblity of resumed migration has in-creased.
Two undiscussed possibilities are:
- 1) Outflanking of the existing bank and stabilization structures by single flood event entrenching the channel at the prcposed collector site, and 2) A cut-off developing across the meander from mile 38.5 to some point dcwnriver.
' 00CUMEtiTS EXAMIt4ED 1)
, ER (Environmental Report),2.5 Sec
- 2) Hydrology i
3).
ER, Appendix G, Hydrogeologic Study i ER,a)Appendix Jan. 25, 1974 L. River Stabilization St
] b) c)
Feb. 15, 1974 report by Whitney Mudy consisting of Feb. 27, 1974 letter frcm Bechtel t. Borlund
- g 4) report by W.M. Borlundo Borlund Figures 3,4-3, 5 & 6 g
- 5) Cec. 23 Make-up, a)
Water, with attached ng 1977 Applicant's Mem Quality of b)
T 5) Affidavit of Keith E. AndersonAf
~
Marmer, Hydrologic Engineering er, R.A.
ssues. Zussman, and G.J. I11RC Sta 7) j Feb. 22, 1978, Testimony of F C
- 8) May 22, 1978 . . Mikels subject: letter from Puget S
- 9) Wild and Scenic Rivers Cecisionound Power and Light i
Supplemental Testimony of David L
- 10) . Schreiber Rivers DeterminationJune,1978 , subject. letter from flRC to PSP
- 11) Wild and Scenic June 13, 1978Intervenor's Interrogatories and R equest for Production,
- 12) June 12, 1978 information letter in response to ffR C request for additional
- 13) June 16, 1978 PSPL's res Request a) May for Production, 17, 1978 ponse to SCAttP Interrogatories includes and report by F.C b)
Supply System, andand Proposed Design Modification eup Water June 14,
- 14) June 22,1978 1973 letter by F.C. Mikels to Bechtel Problems in Ranney Collectors foreport by Jeffrey Hale
- 15) r Skagit fluclear Power Planty, Po Record of Board Meeting including most of p.
10,762 to 10,967
/
.= . .
PAU'. WEBER & ASSOCIATES f GROUND ENGINEERING PROFESSIONAL QUALIFICATIONS & EXPERIENCE PAUL R. WEBER -
36 years of age Eleven year Seattle resident BSCE, Arizona State University, 1964 Recently completed four full-time quarters as 9.rnduate crudent tn Ceology and Ceetechnical in;ineering. *'niver s it.y >
. Wa s ing to n Registered Engineer, Washine. ton, Oregon and Ccorgia EMPLOWENT EX?ER!.'NCE Southwest Materials Laboratory, Phoenix, June '64 to Jan. '66 -
Dames S Moore, Seattle, Jan. '66 to Nov. '71 Owner of Private Practice, Seattle, Nov. '71 to Present GROUND ENGINEERING Paul Weber & Associates provides Ground Engineering services to Designers and Contractors in the following arens:
Soils , nacerials, and subsurface inves t.4 cations
- Engineering Ceol -
/ Environmental Ceology Investigations for clains, failures and lee,al disputes arising from ground construction and encineering Design and cos: estimating for fcundations, retainir; structures and excavation bracing sys:cm3 ,
- Design, installa: ion and evaluatica of Cectechnical Ins:rument-ation
- Applied research in ground engineering i 115 0'12 O I [
v . '. . [ .e v }4., )
a
ENVIRONMENTAL CE0 LOGY 1969 WEYER!!AUSER READOUARTERS BUILDING - Lake and drainage studies for a man-made lake at the Federal Way of fice conplex.
1969 CITY OF MARYSVILLE WATER SUPPLY - Investigations for expanding and 1:nuroving the Marysville Storage Pond and water supply system.
1974 CHERYL LEE HEICHTS - Subsurface drainage design, 30 acre Maple Valley Subdivision.
1974 TERMINATION POINT LANDSLIDE - 200 foot high by 1200 foot long landslide on IIood Canal, Jefferson County, Washington.
1974 "IG SEAVER LAKE ACCR". CAT" SOURCE - Envirormental geology and aggregate qualit, studies for Kitsap County project.
1975 COLDEN CARDENS LANDSLIDE - 300 foot high by 1500 foo . long landiside in Sea;:le. Stabilization measures following Jailure by City of 3eattic forces.
1975 WOODWAY PARK LANDSLIDE - 300 f oot high by 1300 foot long landslide near ~.dmonds, Washington. Drainage stabilization of landslide for 3u.-lington Northern and local residents.
1976 SAN DIECO RARBOR DREDGINC - Geologic studies of changed conditions in Corps of Engineers contract for dredging San Diego Marbor - for General Construe:1on.
1977 CARKEEK ESTATES - Environmental geology studies for 6.7 acre condem_nium development in Carkeek Park drainage basin, Seattle.
1977 OUEEN ANNE DEVELOPMENT - Environmental geology, foundation and ground engineering studies for 300-acre comprehensive development plan.
1977 SO'?THPARK APA'O'ENT PROJCCT - Environnenta? quo'.ogy and storm drainm': de:.w tu . .nc County standar<.,, s '.x-a c re site, Sou:hpark, Sent: e.
1977 RED DOT MEATER CORP 0'.\ TION "nvironmental Aeolorf and storm drainage dea _zn er _9 acre Creen River 'lalley site, i.e n t .
Washington 1977 yAMTHON CORPOEA,T,IO)], - Enviro = ental geolocy for maj or downtown of.:.ue cc~ .ey. w_r 'ao cwers, one 1.'.-story and the second 20-story, Jellevue, '.'achington.
/
1115 093 e'
r, .e. v .
y \.r de O. . Q.(
.