ML19290A006

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Responses to Interrogatories 1-7.Objects to Interrogatories 1 & 6 Because of Untimeliness & Lack of Relevancy.Affidavits of SL Wastler,Ph Leech & IA Peltier Encl
ML19290A006
Person / Time
Site: Skagit
Issue date: 06/18/1979
From:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Shared Package
ML19290A002 List:
References
NUDOCS 7908280370
Download: ML19290A006 (21)


Text

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UNITED STATES OF A5fERICA NUCLEAR REGULATORY COhth!ISSION BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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PUGET SOUND POWER & LIGHT

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Docket Nos. STN 50-522 COMPANY, ET AL.

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STN 50-523

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(Skagit Nuclear Power Project,

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Units 1 and 2)

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NRC STAFF'S RESPONSES TO INTERROGATORIES AND REQUESTS FOR PRODUCTION DATED KfAi 29, 1979 June 18,1979 2043 164

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Interrogatory No. 1 Since Januaryl,1978, has any information concerning research or studies come to the attention of the Staff, or any of its consultants regarding any of the following:

(a)

The synergistic, legal, or sublethal effects of thermal pollution, chlorine, or heavy metals upon salmonids at any stage of their life cycle?

(b)

Whether an attraction phenomenon has been observed with respect to the salmonids, particularly juveniles, and thermal discharges.

If so, please describe such information, study or report in detail, and state whether such information justifies altering any of the conclusions regarding fisheries impacts of the project stated in the EIS, or in the testimony on fisheries presented by the Staff.

Response

The Staff objects to this interrogatory because it is untimely and not relevant to the Skagit matter of any issue outstanding in this proceeding. See 10 CFR S 2.740(a). It is the Staff's understanding that the discovery schedule established at the Prehearing Conference held on April 24, 1979 pertained only to those issues that remained open on the docket (Tr.11,945). Since the issue of aquatic impacts is considered closed, the issue is not subject to further discovery.

2043 165

Interrogatory No.1 - Response con't.

In addition, this interrogatory is overly broad since many articles, reports and documents have been published concerning the subject matter sought and continue to be published every day. In any event, the Staff's review of recent literature has disclosed nothing that would.aodify previous Staff conclusions on this subject.

2043 166 e

./,Interroaatory No. 2:

Please describe in detail and with particularity. ill studies, reports, information, data and other information of any kind which Staff has receihed,otherthaninthisdocket,andwhichpertaininanywayto the Straight Creek Fault and the 1872 earthquake in the State of Washington. You may furnish copies of' documents in lieu of describing them.

Response

The following list of references represents to the best of my knowledge all studies, reports, information, data and other information of any kind whichstaffhasreceihed,otherthaninthisdocket,whichpertainin any way to the Straight Creek Fault and 1872 earthquake in the State of Washington. A copy of report number 6, 19 and 20 is attached.

It is thestaff'sunderstan'dingthattheremaindercfthedocumentslistedhaYe beenmadeahailabletotheinterhenorsunderBoardOrdertoWashington Public Power Supply Systems or by Puget Sound Fower and Light.

200 167 f

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Shannon and Wilson, Inc., 1976, 1872 tarthquake, flew Data trcm Oregon, Po-tland Geraral Electric. Company.

2.

Shannon and Wilson, Inc., 1977, Geologic Investigations Ross Pass Area, Washington, Washington fluclear Project, Units 1 and 4.

3.

Shannon and Wilson, Inc., 1978, Investigation of the Ribbon Cliff Landslide Entiat, Washington, Washington Nuclear Project Units 1 and 4.

4.

Shannon and Wilson, Inc., 1977, Studies of the Hope and Yale Faults in Southern British Columbia, Washington fiuclear Project Units 1 and 4.

5.

Woodward-Clyde Consultants, 1978, Straight Creek Fault Zone Study, United Engineers and Constructors, Inc., Washington Public Power Supply Systen fluclear Project flos. I and 4.

6.

Saannon and Wilson, Inc., 1976, Reconnaissance Invectigations of the Ribbon Cliff Landslide, Latiat, Chelan County Wash,ington, Portland General Electric.

/. Shannon and Wilson, Inc., 1977, Geologic Studies of the Southern Continuation of the Straight Creek Fault, Snoqualmie Area, Washington, Washington Nuclear Project, Units 1 and 4.

, 5. Amendment 23 to Washington Nuclear Project. Units 1 and 4 PSAR, Appendices QR, A, B, C, D, E..

9.

Woodward-Clyde Consultants, December 22, 1976, Review of the Pacific Northwest Earthquake of Decec5er 14,1872, Washington Public Power Supply Syst m

10. Weston Geophysical Resaarch, Inc., 1976, the 1872 Earthquake Significant Data and Conclusions, Washington Public Power Supply System, Inc.

(L Cocmbs, H. A., Milne, W.

G., Nuttli, 0. W. and Slemmons, D.

B.,

1976, Report of the Review Panel on the December 14, 1872 Earthquake.
12. Preliminary Safety Analysis Report for Washington Public Power Supply System, Units 1, 2 and 4

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13. Wescon Geophysical Research, Inc., 1978, British Columbia i

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!!icroEarthquake Survey May through October 1977, Washington vublic Power Supply System.

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14. Weston Geophysical Research, Inc., 1978, Stress Gravity Anomalies and Location of Earthquakes in Washington State - Two Dimensional s,

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Models, Washingten Public Fower Supply System.

15. Westor. M ophysical Research, Inc., 1978,!>agnetic Modeling Molumbia Plateau Area, Washington Pihlic Power Supply System.

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16. Weston Geophysical Research, Inc., 1978, Magnetic Properties of Basalts From the Columbia Plateau Part I and II, Washington

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Public Power Supply System.

17. We: ton Geophysical Rt. search, Inc.,1978, Ground Geophysical S edies rol"mbia Plateau and Adjacent Cascsde Mountains
18. WestonGeophysicalResearch,Inc.,1978,Qualitatihe Aeromagnetic Evaluation of Structures in the Columbia Plateau and Adjacent Cascade Mountain Area, Washington Public Power Supply System.
19. Malone, S. O and S. Bor, Attenuation Patterns in the Pacific Northwest Based on Intensity Data and the Location of the 1872 North Cascades Earthquake, Pre-Print.
20. Foster, R. J., 1960, Tertiary Geology of a Portion of the Central Cascade Mountains,, Washington, GSA Bulletin, Vol. 71, pg.99-126.

Interrocatory No. 4 Please describe specifically all documents, maps, photographs, ard other data or information of any kind which was furnished to you at, or displayed to you, at the conference between Staff, USGS and theApplicant,whichtookplaceinLandoher(Bethesda),Marylandon April 18, 1979.

Response

At the April 18, 1979 meetingthestaffandUSGSreceihedthefollowing:

1) Copiesc7theApplicants'hicwgraphs.
2) Copies of the Applicants' report entitled " Interpretation Report on the Aeromagnetic Coverage of the Skagit Nuclear Power Project" by Exploration Data Consultants, Inc.
3) Copies of a map entitled "AeromagnetM ?@ tour Map and Geologic Map" by Bechtel, Inc., and
4) Copies of a map entitied "Geoi m. / by Bechtel, Inc.

2043 169 s-w.-

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l A copy of the Meeting Summary for the April 18, )?79 meeting, including the Applicants' viewgraphs and a summary of the technical discussion is attached.

It is the staff's understanding that the Applicant have provided the intervenor with the remainder of the documents listed above.

Request for Production No. 2: All work papers, working files, notes, memoranda, including intra-agency memoranda, of your consultants, employees of the U. S. Geological Survey, who have reviewed and who are reviewing the site safety aspects of the Skagit Plant, including Dr. William Hays and Mr. Devine.

Response

To the best of my knowledge, attached are all memoranda, including intra-agency nemoranda, of eoloyees of the U. S. Geological Survey, who have reviewed and who are reviewing the site safety aspects of the Skagit Plant, including Dr. William Hays and Mr. Devine.

In response to your December 13, 1977 request for production, the staff provided the USGS memoranda and intra-agency memoranda received or issued by the staff before January 1, 1978. Therefore, the staff response to the present request for Production is limited to those memoranda and intra-agency memoranda received after January 1, 1978. Copies of those documents not available in the public document room are provided. The remainder of the documents are referenced. The staff has not employed outside consultants, other than the USGS, in the Skagit review. Our response to this Request for Production does not include any handwritten notes or drafts which are specifically exempted from production pursuant to 10 CFR Section 2.790.

References February 23, 1978 memorandum from... W. Coulter, USGS to E. G. Case, NRC.

February 14, 1978 memorandum from J. F. Devine, USGS to J. C. Stepp, NRC.

January 30, 1978 memorandum from J. F. Devine, USGS to E. G. Case, NRC.

20 0 170

Interrogatory No. 3 Please describe all publications and other documents, whether or not publicly disseminated, which pertain to staff and commission review and analysis of the following subjects:

(a) The Three Mile Island accident of 1979.

(b) Actual or potential generic safety questions affecting the design of the type of General Electric reactor which is proposed for the Skagit Plants.

(c) Evacuation plans and emergency planning.

Response

(a) Many documents and reports have been published with regard to the TMI incident. These documents have been catalogued in " Title List, Publicly Available Documents, Three Mile Island Unit 2" (NUREG-0568) which is enclosed.

Also enclosed are two of the more important reports concerning the TMI inci-dent: " Population Dose and Health Impact of the Accident at the Three Mile Island Nuclear Station (NUREG-0558)" and " Staff Report of the Generic Assess-ment of Feedwater Transients in Pressurized Water Rec.ctors Designed by the Babcock and Wilcox Company (NUREG-0560)".

(b) Enclosed are the following documents which pertain to generic safety questions of General Electric reactors:

1) Staff Discussion of 15 Technical Issues Listed in Attach-ment to November 3, 1976 Memo from Director, NRR to NRR Staff (NUREG-0138).
2) Task Action Plans for Generic Activities (NUREG-0371).

3)

Staff Discussion of Twelve Additional Technical Issues Raised by Responses to November 3, 1976 Memorandum from Director, NRR to NRR Staff (NUREG-0153).

4) Generic Task Problem Descriptions (NUREG-0471).

2043 17I

5) NRC Program for the Resolution of Generic Issues Related

./,to Nuclear Power Plants (NUREG-0410).

6) Identification of Unresolved Safety Issues Relating to Nuclear Power Plants (NUREG-0510).
7) Letter to Dr. Stephen Lawroski, Chairman, ACRS from Harold R. Denton, Director, NRR dated December 4, 1978.
8) Status of Generic Items Relating to Light-Water Reactors; Report No. 7, dated March 21, 1979.

(c) Enclosed are the folicwing documents which are the principle docu-ments relied on by the Staff when assessing emergency and evacuation plans:

1)

U.S. Nuclear Regulatory Commission, Standard Review Plan Section 13.3 (NUREG-75/087).

2) Regulatory Guide 1.70, Revision 3.
3) Regulatory Guide 1.101, Emergency Planning for Nuclear Power Plants.

Also relied on to some extent when assessing emergency and evaluation plans is " Evacuation Risks - an Evaluation (EPA-520/6-74-002)". This document is available from the National Technical Information Service.

2043 172

Interrogatory No. 5 HowIrany drafts have been prepared for the PSER and the SER for the Skagit Project, and who has custody of those drafts? Please describe the date of each such drafts, and give the number of pages it contains. Also, please produce each draft for inspection and copying in accordance with' Request for Production No.1 above.

Resoonse Many drafts were prepared for the Skagit SER. However, after publication of the SER, all previous drafts were destroyed. Accordingly, it is impossible to recon-struct the dates of such drafts and the number of pages contained in each one.

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Interrogatory No. 6 Please describe all notes, working papers, calculations, tables, data, and other materials of any kind or nature relied upon by Dr. Jacques Read in connection with the preparation of the testimony which he offered herein. Please produce all such documents for inspection and copying in accordance with Request for Produedon No.1 above.

Response

The Staff objects to this interrogatory because it is untimely and not relevant to the subject matter of any issue outstanding in this proceeding. See 10 CFR 52.740(a). Since the issue of aircraft hazards is considered closed, the issue is not subject to further discovery.

2043 174

Interrogatory No. 7.

Please describe all documents and records, including maps, photographs, memoranda, correspondence, and field notes which pertain in any way to the staff's analysis and review of alternative sites for the Skagit project.

Please produce all such documents for inspection and copy-ing in accordance with Request for Production No.1.

Response. The following is a list of documents, records, etc. which the Staff reviewed in its assessment of alternative sites. Many of these docu-ments have either been previously supplied to SCANP, are in the public docu-ment room, or are in the public domain. Accordingly, the staff is not making these documents available for reproduction at SCANP's office.

If SCANP should identify any document which it believes is in the sole posses-sion of the staff, we will consider making it available for reproduction at a future time.

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Re SCANP Interroaatory No. 7, May 19, 1979 1.

Bechtel report " Site Location and Transmission Study" dated April 1966 (2 volumes).

2.

Bechtel report " Site Location Study" dated October 1966.

3.

Bechtel report " Thermal Power Plant Siting Study" dated September 1970.

(Exhibit 46).

4.

Bechtel report letter dated January 20,1972 (Exhibit 47).

5.

Bechtel " Report of Geological Reconnaissance for Six Potential Power Plant Sites in Western Washington" 1973.

6.

Puget Sound Power & Light Company Environmental Report on the Skagit Nuclear Power Project.

7.

Aerial photograph of Ryderwood site area, scale 1" = 1000', marked 73-3414.

8.

Aerial photograph of Goshen site area, scale 1"= 1500', marked SW1-69.

9.

Letter fron PSP &L to John Stolz, NRC, October 21, 1975, providing cost addition to accommodate 0.35 g acceleration.

10.

Letter to Stanley E. King, PSP &L, from Dames & Moore, March 9,1976, providing water use information on Nooksack River.

11.

Letter to Paul Leech, NRC, from J. E. Mecca, PSP &L, June 27, 1977, enclosed responses to alternate site questions regarding Cherry Point, Goshen and Ryderwood.

12.

Letter to PSP &L from Wm. H. Regan, Jr., NRC, July 7,1978, requesting geologic infomation regarding alternative sites.

13.

Letter to John Stolz, NRC, from PSP &L, August 2.1978, providing geologic reference materials in partial response to NRC's letter of July 7,1978.

14 Letter w Wm. H. Pegan, Jr., NRC, from PSP &L, August 9,1978, with one copy of certain drill logs.

15.

Letter to Wm. H. Regan, Jr., NRC, from PSP &L, September 25, 1978, pro-viding geotechnical infomation on alternative sites.

204$

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16.

Letter to Wm. H. Regan, Jr., NRC, from PSP &L, October 2 7,1978, pro-viding a revised bibliography of alternative sites infomtion.

17.

Letter to Wm. H. Regan, Jr., NRC, from PSP &L, January 4,1979, providing an analysis of geologic and seismic conditions at Skagit, Cherry Point, Goshen and Ryderwood sites.

18. Letter to PSP &L from Wm. H. Regan, Jr., NRC, May 21, 1979, requesting current cost estimates for location of the project at Skagit, Pebble Springs and Hanford areas.

19.

Applicant's testimony relative to alternate sites, per transcripts of the ASLB hearings on the Skagit project.

20.

PSP &L letter to W. H. Regan, Jr., NRC, June 12, 1979 providing cost estimates for relocation of Skagit units to Hanford and Pebble Springs.

21.

Staff's testimony relative to alternative sites, per transcripts of the ASLB hearings on the Skagit Project.

22.

Regulatory Guide 4.2 on Preparation of Environmental Reports, U.S.

Nuclear Regulatory f emission, July 1976.

23.

U.S. Geological Survey Maps of appropriate areas.

24 1970 Population Data, U.S. Census.

25. Wind roses for Bellingham, Washington,1956-8 and May 1973-May 1974
26. Memorandum for Paul Leech, EP-1, NRC from Falk Kantor, Accident Analysis Branch, DSE, NRC March 22, 1979, on populations at alternative sites.
27. Memorandum for Wm. H. Regan, Jr., EP-2, NRC from L. G. Hulman, Hydrology-Meteorolcgy Branch, DSE, NRC March 8,1979, on hydrology aspects of alternate sites.
28. General Considerations and Issues of Significance on the Evaluation of Alternative Sites for Nuclear Power Stations under NEPA, NUREG-0499, Supplement 1, U.S. NRC December 1978.

29.

Bingham, J. W., Landquist, C.

L., and Baltz, E.

H., 1970, Geological Investigations of Faulting in the Hanford Region:

U.S. Geol. Survev, Open File Report.

30. Crandell, D. R.,1976, Preliminary Assessment of Potential Hazards from Future Volcanic Eruptions in Washington:

U.S. Geological Survey Miscellaneous Field Study Map MF-774.

2043 177 31.

Easterbrook, D.

J., 1976(a), Map Showing Slope Stability in Western Whatcomb County, Washington, U.S. Geological Survey, Misc. Inv.,

Map I-854-C.

32.

Easterbrook, D. J.,1976(b), Geologic Map of Western Whatcomb County, Washington, U.S. Geological Survey, Misc. Inv. Map I-854-B.

33. 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. Survey Open-File Report 78-426.
34. Griggs, F. R.,1922, The Valley of 10,000 Smokes (Alaska): The National Geog. Soc., 340 p.
35. Hall, H.

B., and Othberg, R. L.,1974, Thickness of Unconsolidated Sediments, Puget Lowland, Washington: Washington Div. Geology and Earth Resources, Geol. Map GM-12,

36. Henriksen, D. A.,1956, Eocene Stratigraphy of the Lower Cowlitz River, Eastern Hillapa Hills Area, Southwest Washington: Washington Division of Mines and Geology Bulletin No. 43.
37. Huntting, M.

T., et al,1961, Geologic May of Washington: Washington Division of Mines and Geology.

38. Miller, G. M., and Misch, P.,1963, Early Eocene Angular Unconformity at Western Front of Northern Cascades, Whatcomb County, Washington:

Am. Assoc. Petroleum Geologists, V. 47, No.1.

39. Misch, P.,1966, Tectonic Evolution of the Northern Cascades of Washington State: Canadian Inst. Mining and Metallurgy, Sepc. Paper,
v. 8.

40.

Preliminary Geologic Map,1978, WPPSS Nuclear Project Nos.1 and 4, Washington Public Power Supply Systen.

41.

Preliminary Safety Analysis Report (PSAR),1974, Skagit Nuclear Power Project, Puget Sound Power and Light Co.

42.

Preliminary Safety Analysis Report (PSAR),1974, Nuclear Project No. 3, Washington Public Power Supply System (WPPSS),1974 as amended.

43.

Radbuch-Hall, D. H., et al.,1976, ' eliminary Landslide Overview Map of the Conterminous United States

3. Geological S& fey Misc. Field Studies, Map MR-771.

44.

Roberts, A. E.,1958, Geology ar,.

oal Resources of the Toledo-Castle Rock District, Cowlitz and Lewis Counties, Washington:

U.S. Geol.

Survey Bulletin 1062.

2043 178

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45. Tabor, R. W., and Cady, W. M.,1978, Geologic Map of the Olympic Peninsula:

U.S. Geol. Survey Misc. Inv. Map I-994.

46.

U.S. Atoraic Energy Commission,1972, " Safety Evaluation of the Hanford No. 2 Nuclear Power Plant," Docket No. 50-397.

47 U.S. Nuclear Regulatory Commission,1975(a), " Safety Evaluation of the Washington Nuclear Projects 1 and 4," Docket Nos. 50-460 and 50-513, NUREG-75/036.

48.

U.S. Nuclear Regulatory Commission 1975(b), Memorandum of Dec. 5,1975, W. P. Gammill to J. F. Stolz, Evaluation of Cherry Point as an Alter-nate to the Skagit Nuclear Platn Site - Foundation Engineering.

49.

U.S. Nuclear Regulatory Commission,1976(a), " Safety Evaluation Report Related to Construction of Pebble Springs Nuclear Plant, Units 1 and 2,"

Docket Nos. 50-514 and 50-515, NUREG-0013.

50.

U.S. Nuclear Regulatory Commission,1976(b), " Safety Evaluation Report Related to Construction of Washington Public Power Supply System Nuclear Projects No. 3 and No. 5".

Docket Nos. STN 50-508 and 50-509, NUREG-0023.

51.

U.S. Nuclear Regulatory Commission,1976(c), Memorandum of May 5,1976, J. C. Sterp to J. F. Stolz, Evaluation of Puget Sound Power and Light Company's Cherry Point Site as a Geologic and Seismological Alternate to the Proposed Skagit Nulear Power Project site.

52.

U.S. Nuclear Regulatory Commission,1977, Memorandum of Sept. 14, 1977, J. Carl Stepp t John Stolz, Draft Safety Evaluation Report - Geotechnical Engineering.

53. Vonheeder, E. R.,1975, Coal Reserves of Whatcomb County, Washington:

Washington Division Geology and Earth Resources, Open cile Report

' 0F-75-9.

54. Waitt, R. B., Jr.,1979, Late Cenozoic Deposits, Landforms, Stratigraphy, and Tectonism in Kittitas Valley, Washington:

U.S. Geol. Survey Prof.

Paper 1127.

55. Weigel, J. M., and Foxworthy, B. L.,1962, Geology and Ground-Water Resources of West-Central Lewis County, Washington: Washington Division Water Resources, Water Supply Bulletin No.17.

56.

Coastal Zone Atlas of Washington,1977; State of Washington, Dept. of Ecology, v.1, Whatcomb Co., Publication No. DOE 77-21-1.

57.

Data Sources Index Map,1978, WPPSS Nuclear Project Nos.1 and 4 Washington Public Power Supply System.

2043 179

58.

Reinhart, W. H.,1969, Compilation of Geologic Mapping in Washington Through 1968; Washington Dept. of Natural Resources Open File Report.

59.

" Water Resource Data for Washington, Water Year 1977, Volume 2.

Eastern Washington", U.S. Geological Survey, Water-Date Report WA-77-2, 1978.

60.

" Final Environmental Statement Related to Construction of Pebble Springs Nuclear Plant Units 1 and 2".

Portland General Electric Company. USNRC Docket Nos. 50-514 and 50-515.

Ap ril,1975.

61.

" Final Environmental Statement Related to the Proposed Hanford Number Two Nuclear Power Plant", Washington Public Power Supply System. USNRC Docket No. 50-397 December 1972.

62.

" Final Environmental Statement Related to the Construction of Washington Public Power Supply System Nuclear Projects 1 and 4".

Washington Public Power Supply System, Docket Nos. 50-460 and 50-513.

63.

" Environmental Report, Hanford Number Two" Washington Public Power Supply System, August 16, 1972.

64.

" Environmental Report - Operating License Stage WPPSS Nuclear Project No.

2", Washington Public Power Supply System.

USNRC Docket 50-397, March 21, 1977.

65.

" Environmental Report, WPPSS Nuclear Project No.1, Relocated Stie, Amendment 1", Washington Public Power Supply System, July 1974.

66. Terrestrial Ecology Studies in the Vicinity,

Washington Public Power Supply System Nuclear Power Stations 1 and 4", Progress Report for the Period July 1974 to June 1975, Battelle Pacific Northwest Laboratories, Richland, Washington, Nov. 1976.

67.

" Terrestrial Ecology Studies in the Vicinity of Washington Public Power Supply System Nuclear Power Stations 1 and 4", Progress Report for 1976, Battelle Pacific Northwest Laaoratories, Richland, Washington, June 1977.

68.

J. F. Franklin and C. T. Dryness, Natural Vecetation of Orecon and Washington, USDA Forest Service Gen. Tech. Rept. PNW-8,1973, pp. 29-32, 209-229, 231-233, 69.

R. Daubenmire, " Steppe Vegetation of Washington", Washington Agric altural Exper. Stn., Tech. Bull. 62, 1970, pp. 1-16.

70.

"Environnental Report, Pebble Springs Nuclear Plant, Construction Permit Phase".

Portland General Electric Co.

2043 180

. 71,1, Beak Consultants, Inc., " Pre-construction Ecological Studies for the Pebble Springs Site," Final Report Prepared for Portland General Electric, Portland, Oregon.

1978.

72.

Final Environmental Statement relative to construction of Washington Public Power Supplj System Projects 3 and 5, USNRC, 'une 1975, Docket Nos. STN 50-508 and 50-509.

73.

Regulatcry Guide 4.7, p. 4 7-9.

74.

Resolution 6279, Skeg'i. Coi:aty Zoard of County Commissioners, Certificate, Aoril 19,1974, p. 3.

75.

U.S. Dept. of Agriculture, Pacific Northwest Region Forest Service, "The Skagit: A Proposal for Classification under Wild and Scenic Rivers Act",

1977, p. 1.

76.

Pacific Northwest River Basin Commission, Columbia North Pacific Reaion Comprehensive Framework Study of Water and Related Lands, Accendix XIV, Fish and Wildlife, November 1971, 77.

Puget Sound Task Force, Pacific Northwest River Basins Commission, Appendix XI, March 1970.

78. Power plant and Industrial Fuel Use Act of 1978, Title VI.

Section 601.

79.

Indian Voice, "Skagit System Unites Three Tribes," June 1977, p. 4.

80. Andy Fernando, Akwesane Notes, Vol.11, No.1, February 1979.

81.

Indian Voice, "25 Tribes Pass Six Resolutions," and " Fishing Issues,"

Vol. 7, No. 3, March 1977, pp.1-11.

82. Letter from.M. Rupert Cutler, Assistant Secretary, Department of Agri-culture, to Lee V. Gossick, Executive Director of Operations, Nuclear Regulatory Commission, April 11, 1978.
83. Letter from Bob Bergland, Secretary, Department of Agriculture to Voss A.

Moore, NRC, May 2,1979 regarding mitigation of possible adverse effects on the Skagit River.

2043 181

,y UNITED STATES OF AMERICA

~

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

)

Docket Nos. STN 50-522 CP

)

50-523 CP Puget Sound Power and Light Company -

)

U. S. Nuclear Regulatory Commission

) Response to Intervenors (Skagit Nuclear Power Plant,

)

Interrogatories of May 29, 1979 Units Nos. 1 and 2)

')

AFFIDAVIT OF SANDRA L. WASTLER Sandra L. Wastler deposes and says under oath a: follows:

1.

I am a geologist attached to the Geology & Seismology Section of the Geosciences Branch, Division of Systems Safety, Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission.

For the past four years I have been involved in the review of Applicant's Preliminary Safety Analysis Reports and responsible for elements of the geology portion of the safety review.

2.

I have prepared the staff responses to Interrogatories No. 2, 4 and Request for Production No. 2.

I certify that the answers given are true and accurate to the best of my knowledge.

k LkRL<. e

.!). rt a Sandra L. Wastler Subscribed and sworn to and before me this,'r day of June,1979.

) 'i..r: D b. b.J/

hot.ary Fuolic gp My Commission Expires 47 f P r

V c/

2043 182

UNITED STATES OF A'.IERICA NUCLEAR REGULATORY COLE 11SSION BEFORE THE ATOhiIC SAFETY AND LICENSING BOARD In the Matter of

)

)

PUGET SOUND PO'.ER L LIGHT

)

Docket Nos. STN 50-522 COhiPANY, ET AL.

)

STN 50-523

)

(Skagit Nuclear Power Project,

)

Units 1 and 2)

)

AFFIDAVIT OF PAUL H. LEECH Paul H. Leech depeses and says under oath as follows:

1.

I am an Environmental Project hianager in the Environmental Projects Section of.he Nuclear Regulatory Commission and I am assigned to the review of the Skagit Power Plant application.

2.

I have prepared the Staff responses to Interrogatory No. 7 and a part of Request for Production No.1. I certify that the answers given are true and accurate to the best of my knowledge.

0 Ycua N.

h. 314,-

c Paul H. Leech Subscribed and sworn to and before me this W Aday of June,1979 Y lr. /., e

'.Lla.$tJ Notary Public,,'

My Commission expires:

tu-

), )77M

/

/

2043 183

UNITED STATES OF A.1 ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Natter of

)

)

PUGET SOUND POWER & LIGHT

)

Docket Nos. STN 50-522 COMPANY, ET AL.

)

STN 50-523

)

(Skagit Nuclear Power Project,

)

Units 1 and 2)

)

AFFIDAVIT OF IRVING A. PELTIER Irving A. Peltier deposes and says under oath as follows:

1.

I am a Licensing Project Manager in the Light Water Reactors Section of the Division of Project Management of the Nuclear Regulatory Com-mission and am assigned to the review of the Skagit Nuclear Power Plant application.

2.

Staff responses to Interrogatories No. 3, 5, and a part of Request for Production No. I have either been prepared by me or under my control and supervision. I certify that the answers given are true and accurate to the best of my knowledge.

Irving A. Peltier Subscribed and sworn to and before me this day of June,1979 Notary Public My Commission expires:

.