ML19250C283
| ML19250C283 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 10/01/1979 |
| From: | Deale V Atomic Safety and Licensing Board Panel |
| To: | |
| Shared Package | |
| ML19250C277 | List: |
| References | |
| NUDOCS 7911230147 | |
| Download: ML19250C283 (7) | |
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PL'GET SOUND PDWER & LIGF.T
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Docket Nos. 50-522
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In Se event the agenda of 2e above sche".uled hearings are
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not completed:within de ti.me allo::ed, the Board an:icipates Se schedul-Ing cr a,,.;:;onal yearings, as may be ne. G:= ry, on.yurscay, r ricay w.
and Saturday, November 3, 9 and 10,1979, and during Se week begin.ning Q
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Monday, November 26, 1979.
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ine coard,s.,ocus on tu.e testimony accu: Geo. logy ad
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Seismology will be on wha: are de answers :o Se below Sree cuestias.
It will also be on answers of Se Board's c.uestions abou: earlier :es:i=cn.v ci te wi= esses. The referenced tree cues:Lons are:
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What is te wors:-case seismic even: having reasonable probability of occurrence affecting Se pro-posed plan: during its lifetime ?
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What is de corresponding ground accelera: ion,
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witnesses on Geo.cgy and cetsmology: otu.erwise, :n.e r e:ca==a::en ::
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The parties are u: on notice &at 10 CFR 3 2. 743(b) is a.c.olt-r cable to the for$ coming hearings win $e exception Sat.i2 res,:ec: to t.he tes:imcay en Geology and Seis= ology for SCA.NP and rCE/CF5? Se
.e requirement of fifteen days of advance no: ice of proposed :esti.ony is reduced to seven days.
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day of October 1979 at Washing on, D. C.
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UNIVERSIT1 OF WASHINGTON c7 :., 1979 SEATU.E. WASHINGTON 98195
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Department of Geological Sciences, AK-20 Cctaber 8, 1979 Roger M. Leed, Esq.
Room 620 1411 Fourth Avenue Seattle, Washington 99101 Dea'r Mr. Leed:
Your announcement that the NRC hearings will commence on 25 October and run inter-mittently through November produces several extermely serious conflicts for me.
Firstly, my teaching schedule: The class I am teaching this quarter meets for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on Tuesday and Thursday afternoons.
Thus, the afternoons of 25 and 30 October, 27 and 29 November, and similar afternoons in December are out.
I am scheduled to teach a class on the morning of 26 October.
I have a speaking engagement in Spokane on 13 November.
The biggest conflict, however is that it is essential for me to attend the Annual Convention of the Geolog.ical Society of Amierca in San Diego from 2-10 November.
On 30 July, I made arrangements at considerable personal expense to attend a pre-convention field trip in southeastern California from 2 to 4 November during which experts will be examining rocks similar to ones that I have been conducting research on in northeastern Washington since 1974.
Several sessions during the convention en the geology and geochemistry of ore deposits, including uranium deposits, are the major sources for updating my teaching and research concepts.
In fact, this is the largest annual convention for researchers of the academic ascects of are deposits. The convention will also have a session on "Ecrthcuake Hazards and Prediction" which will have the utmost relevance to the Skigit, as should various
? apers on tectonics of the Pacific Northwest.
I also have registered for a ctt-conventien field trip from 3 to 10 November examining the unique excesures of the ophiolite complex of the California Coast Range (such rocks are hosts for ore de-posits and are commonly involved in fault zones as serpentinites and silica-carbonate rocks).
In short, this convention and its field trips are of extreme professicnal imcortance to me, and, probably, to many of the other geoscientists involved in the NRC hear-ings.
Furthermore, I have incurred considerable personal excenses already in the form of registration fees.
I must say that I am amazed that the NRC hearings are being scheduled so soon.
Thirty to forth-five days notice has always been given in the past.
When sucn notice did not arrive by 1 October, I confirmed all of the above teaching, speaking, and convention commitments.
Furthermore, I had expected a reasonable amount of time to update my Skagit report.
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ger M. Leed Jctober 8, 1979 Page 2 7
In the past I have always derie my utmost to acccmedate you and the NRC.
I would appreciate some reciprocation this time.
I could barely live with a starting date of 14 November, which is less than 40 days away.
Extremely sincerely,
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Eric S. Cheney ESC /sj
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oEoLcGV ANo EVALU AT!oN ed oME oEPosi?S. REGloNAL EXPLoR A?loN ANo GEOLOGY, ENVIRONMENTAL GEoLoGV Dr. ERIC S. CHENEY & ASSOCIATES CONSULTANTS IN NATURAL RESOURCES October 11, 1979 Mr. Roger M. Leed Esq.
Room 620 1411 Fourth Ave.
Seattle, WA 98101
Dear Mr. Leed,
I understand that =y Interrogatories to the Applicant have been rejected as being untimely. Because I honestly doubt that I could have produced the interrogatories more quickly, let se review the ti=ing involved.
Firstly, the three volu=e report by Bechtel Incorporated (1979) and its sub '
sequent revision arrived in late May and June. The revision is dated 052979.
This is the worst time of the year for all professors. At that time I was engaged in final exams and supervising the completion of two M.S. theses.
I si= ply had no time to devote to the Applicant's report.
Secondly, you will recall that NRC hearings reconvened in the last two weeks of July and that I was a =ajor witness and cross examiner.
I had to prepare prefiled testimony on Alternative Sites and B.C. Coal.
I also prepared testi-many on the significance of the Woodward-Clyde report of alternative sites which the ASL3 rejected, and at the time the Board rejected that testimony I was pre-paring additional prefiled testimony on the gravity of the domestic uranium shortage (no fuel, no plants).
Thus, I could not start to review the three volume work until the hearings ended in the first week of August. Many things could be said about the report (and I tried to ask about them), but all readers will agree that it is lengthy and complex. Many of my Interrogatories inquired -kout apparent discrepancies in various parts of the report.
I spent virtual
-he entire =enth of August try-ing to understand and to critique that repor detail. A lengthy, highly technical, ccmplex report requires considerabi time for a thorough review, and so far, I have not seen any evidence that anybody else has even attempted the task.
Thirdly, you will rece=ber that an excruciating amount of time was involved in obtaining the proprietary Aeromagnetic Figures.
I maintained throughout the su==er, and continue to =sintain, that these Figures cannot be reviewed in the format of the opaque barely legible paper copies that the Applicant provided; they had to be converted to clear overlays so that they could be compared with a variety of geological and geophysical maps at a variety of scales.
Further-more, I had to have custody of such overlays to make the necessary comparisons.
Out of total frustration, I did go to the Applicant's attorneys' office to look at the paper copies to glean what I could.
I did not get custody of the Aero-magnetic Figures until after September 1.
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Mr. Roger M. Leed Esq.
October 11, 1979 Page 2 Finally, I ask how quickly one individual is expected to react? I do not have a staff of geoscientists at my disposal to prepare for hearings and to write interrogatories si=ultaneously. Please communicate to the Chairman of the ASL3 that I devoted most of the summer to the Skagit project to produce Ly testimony and interrogatories as rapidly as time and negotiations over the Aeromagnetic Figures permitted.
I hope you will also communicate to the Chairman the impossible task he now has assigned to me cf producing the seventh revision of my Skagit report by 18 October.
I think it is extremely unfair to ask for an update of a 120 page report on two weeks notice.
Sincerely, Eric S. Cheney ESC:lb
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