Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments DeformationML19276H583 |
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Skagit |
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Issue date: |
10/18/1979 |
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Blunden R AFFILIATION NOT ASSIGNED |
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ML19210E129 |
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NUDOCS 7911290450 |
Download: ML19276H583 (7) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding ML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl ML20080L9431983-09-28028 September 1983 Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl ML20080G0731983-09-13013 September 1983 Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl ML20071Q7201983-06-0303 June 1983 Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl ML20071M0781983-05-25025 May 1983 Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl ML20023C4571983-05-12012 May 1983 Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl ML20023C6971983-05-12012 May 1983 Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl ML20023C3741983-05-12012 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1 ML20023C3691983-05-12012 May 1983 Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists ML20064N6681983-02-10010 February 1983 Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs ML20071A6671983-02-10010 February 1983 Certifies Svc of Intervenor Motion to Suspend Safety & Health Schedule on 830210 ML20070T0661983-02-0404 February 1983 Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc ML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20083N1991983-01-26026 January 1983 Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl ML20028F1831983-01-25025 January 1983 Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20028E9701983-01-19019 January 1983 Reply to NRC & Applicant Response to Natl Wildlife Federation/Or Environ Council,Columbia River Inter-Tribal Fish Commission & Coalition for Safe Power 821213 Motion to Clarify & Amend Certain Contentions.W/Certificate of Svc ML20072A6731983-01-18018 January 1983 Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl ML20028C9581983-01-0505 January 1983 Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc ML20028C9501983-01-0505 January 1983 Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents ML20028C3221983-01-0303 January 1983 Suppl to DOE 821126 Limited Appearance Statement.Doe Position Is That Hanford Site Is Not Open,Unclaimed Land as Defined in 1855 Treaty W/Yakima Indian Nation,Article Iii. ASLB Is Wrong Forum for Resolving Issue ML20070L5411982-12-27027 December 1982 Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded ML20070L4901982-12-27027 December 1982 Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl ML20079J6021982-12-23023 December 1982 Response Supporting Intervenor 821213 Motion to Clarify & Amend Contentions 7 & 8.Quantification of Environ Impacts Not Practicable Due to Subjective Nature.Certificate of Svc Encl ML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20079H3711982-12-13013 December 1982 Motion to Clarify & Amend Contentions 7 & 8.Contentions Should Be Reorganized to Facilitate Coordinated Evidentiary Presentations for Environ Matters ASLB Set Out as Contentions 4,7 & 8.Certificate of Svc Encl ML20070D1181982-12-10010 December 1982 Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land ML20070C9121982-12-10010 December 1982 Notice of Counsel New Law Firm Affiliation,As of 820901 ML20070C8181982-12-10010 December 1982 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Yakima Indian Nation Contentions 7,8 & 9.Nation Right to Enjoy Reservation Peacefully Given by 1855 Treaty Should Be Protected by ASLB ML20070C7691982-12-10010 December 1982 Certifies Svc of Brief on Admissibility of Reworded Proposed Contention 10,motion for Reconsideration of ASLB 821029 Memorandum & Order,R Jim Affidavit & Notice of Counsel Law Firm Change on 821210 ML20070C7981982-12-10010 December 1982 Brief Supporting Admissibility of Yakima Indian Nation Reworded Proposed Contention 10.Attempt to Terminate Reserved Rights of Yakima Indian Nation Violates Fifth Amend.Land Cannot Be Taken by Inverse Condemnation ML20028B9251982-12-0101 December 1982 Brief Re Admissibility of Yaking Indian Nation Proposed Contention 10.Clarification Needed on Procedural Rule of Commission & Scope of Contention.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20028B2631982-11-26026 November 1982 Limited Appearance Statement.Hanford Site Is Not Part of Yakima Indian Nation Reservation Established by 1855 Treaty. Indian Privilege of Hunting,Gathering Roots & Berries & Grazing Animals Does Not Extend to Hanford Site ML20066K9761982-11-22022 November 1982 Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue ML20066L0101982-11-22022 November 1982 Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20023A8141982-10-14014 October 1982 Response to Yakima Indian Nation 820930 Suppl to Petition to Intervene,Containing List of Contentions.Objects to Contentions 4-10.Certificate of Svc Encl ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20063P4011982-10-0606 October 1982 Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20069F9541982-09-23023 September 1982 Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl ML20069F9491982-09-23023 September 1982 Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20137F8001982-09-17017 September 1982 Amended Subagreement 2 Between State of Wa Energy Facility Site Evaluation Council & NRC Re Protocol for Conduct of Joint Hearings on Facility Project ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5571982-09-15015 September 1982 Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl 1983-09-28
[Table view] Category:TRANSCRIPTS
MONTHYEARML19210E1281979-10-18018 October 1979 Prefiled Testimony.Bechtel 1979 Geology Map Cannot Be Used as Tool for Seismic Evaluation of Area.Supporting Documentation,Prof Qualifications & Certificate of Svc Encl ML19276H5781979-10-18018 October 1979 Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications Encl ML19276H5801979-10-18018 October 1979 Prefiled Testimony.Two east-west Trending Faults Can Be Found Along Plant Site Vicinity ML19276H5831979-10-18018 October 1979 Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments Deformation ML19276H5751979-10-17017 October 1979 Prefiled Testimony.High Frequency Seismic Methods Inadequate to Locate Fault Traces Existing in Area.Interpolation Between Spaced Seismic Lines Is Speculative ML19210C1631979-10-0808 October 1979 Testimony of Nm Newmark Re Conservatism of Seismic Design Criteria & Seismic Design Provisions for Facility.Biography Encl ML19210C1601979-10-0808 October 1979 Testimony of Ba Bolt Re Correlation Between Peak Acceleration & Magnitude & Intensity.Biography,Publication List & Supporting Documentation Encl ML19256E3281979-10-0303 October 1979 Supplemental Testimony of J Kelleher Re NRC Methods Used to Estimate Strong Ground Motion ML20136C5211979-08-30030 August 1979 Transcript of 790830 Hearing in Seattle,Wa. Pp 14,802-15,048 ML20136C5271979-08-27027 August 1979 Transcript of 790827 Hearing in Seattle,Wa. Pp 14,388-14,573.Exhibits 213-15 Encl ML19249E1561979-08-0808 August 1979 Testimony Re Financial Qualifications Submitted by J Lazar on Behalf of Intervenor Skagitonians Concerned About Nuclear Power.Asserts Applicant Will Be Unable to Secure Financing. Certificate of Svc Encl ML19207B4771979-07-12012 July 1979 Supplemental Testimony of Es Cheney Re Alternative Site Comparison,Submitted on Behalf of Skagitonians Concerned About Nuclear Power.Goshen,Hanford & Pebble Springs Are Better Sites than Skagit ML19209B0681979-07-10010 July 1979 Testimony of ML Darland on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Evacuation Planning.Professional Qualifications Encl ML19209B0691979-07-10010 July 1979 Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography Encl ML19209B0721979-07-10010 July 1979 Testimony of J Lazar on Behalf of Intervenors Skagitonians Concerned About Nuclear Power,Re Financial Qualifications. W/Supporting Documentation ML19247B2871979-07-0202 July 1979 Testimony of RB Eastvedt Re Bulk Transmission Sys Requirements Associated W/Alternate Sites ML19207B4841979-06-29029 June 1979 Testimony of JW Ellis Re QA Program.Util Has Implemented QA Program That Fully Complies with All State & Federal Regulations ML19207B4811979-06-29029 June 1979 Testimony of Je Mecca Re Amended License Application & Complete Psar.Verifies Application as Amended Through Amend 4 & PSAR as Amended Through Amend 20 & Suppl 18 ML19207B4851979-06-29029 June 1979 Testimony of Wj Ferguson Re Engineering,Qa & Const Project Organizations.Qa Program Is Autonomous & Objective.Bechtel Has Primary Responsibility for Review of Design & Procurement Documents ML19207B4901979-06-29029 June 1979 Testimony of Ev Padgett Re QA Program.Qa Program Was Developed to Meet Requirements of 10CFR50,App B & ANSI N45.2 as Set Forth in Chapter 17 ML19207B4911979-06-29029 June 1979 Testimony of Rn Hettinger Re QA Program.Describes Current Level of QA Activities.Certificate of Svc Encl ML19246C4681979-06-0101 June 1979 Submits Joint Testimony of Re Olson,Me Coberley,Ls Pack & Jm Coombs.Util Does Not Have Reasonable Assurance of Obtaining Funds for Const & Fuel Cycle Costs.Prof Qualifications & Certificate of Svc Encl ML19242D2021979-06-0101 June 1979 Supplements Testimony Presented at 780217 Proceeding Re Util Use of Piping Test Data to Predict Yield of Proposed Ranney Collector Sys & Drawdown Effects of Ranney Collectors on Nearby Red Cabin & Muddy Creeks ML19241A6171979-06-0101 June 1979 Testimony Re Ranney Collector Sys.Sys Is Sufficient to Provide Plant Water Needs Under Varying Conditions W/Minimal Impact on Water Resources 1979-08-08
[Table view] Category:DEPOSITIONS
MONTHYEARML19210E1281979-10-18018 October 1979 Prefiled Testimony.Bechtel 1979 Geology Map Cannot Be Used as Tool for Seismic Evaluation of Area.Supporting Documentation,Prof Qualifications & Certificate of Svc Encl ML19276H5781979-10-18018 October 1979 Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications Encl ML19276H5801979-10-18018 October 1979 Prefiled Testimony.Two east-west Trending Faults Can Be Found Along Plant Site Vicinity ML19276H5831979-10-18018 October 1979 Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments Deformation ML19276H5751979-10-17017 October 1979 Prefiled Testimony.High Frequency Seismic Methods Inadequate to Locate Fault Traces Existing in Area.Interpolation Between Spaced Seismic Lines Is Speculative ML19210C1631979-10-0808 October 1979 Testimony of Nm Newmark Re Conservatism of Seismic Design Criteria & Seismic Design Provisions for Facility.Biography Encl ML19210C1601979-10-0808 October 1979 Testimony of Ba Bolt Re Correlation Between Peak Acceleration & Magnitude & Intensity.Biography,Publication List & Supporting Documentation Encl ML19256E3281979-10-0303 October 1979 Supplemental Testimony of J Kelleher Re NRC Methods Used to Estimate Strong Ground Motion ML20136C5211979-08-30030 August 1979 Transcript of 790830 Hearing in Seattle,Wa. Pp 14,802-15,048 ML20136C5271979-08-27027 August 1979 Transcript of 790827 Hearing in Seattle,Wa. Pp 14,388-14,573.Exhibits 213-15 Encl ML19249E1561979-08-0808 August 1979 Testimony Re Financial Qualifications Submitted by J Lazar on Behalf of Intervenor Skagitonians Concerned About Nuclear Power.Asserts Applicant Will Be Unable to Secure Financing. Certificate of Svc Encl ML19207B4771979-07-12012 July 1979 Supplemental Testimony of Es Cheney Re Alternative Site Comparison,Submitted on Behalf of Skagitonians Concerned About Nuclear Power.Goshen,Hanford & Pebble Springs Are Better Sites than Skagit ML19209B0681979-07-10010 July 1979 Testimony of ML Darland on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Evacuation Planning.Professional Qualifications Encl ML19209B0691979-07-10010 July 1979 Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography Encl ML19209B0721979-07-10010 July 1979 Testimony of J Lazar on Behalf of Intervenors Skagitonians Concerned About Nuclear Power,Re Financial Qualifications. W/Supporting Documentation ML19247B2871979-07-0202 July 1979 Testimony of RB Eastvedt Re Bulk Transmission Sys Requirements Associated W/Alternate Sites ML19207B4841979-06-29029 June 1979 Testimony of JW Ellis Re QA Program.Util Has Implemented QA Program That Fully Complies with All State & Federal Regulations ML19207B4811979-06-29029 June 1979 Testimony of Je Mecca Re Amended License Application & Complete Psar.Verifies Application as Amended Through Amend 4 & PSAR as Amended Through Amend 20 & Suppl 18 ML19207B4851979-06-29029 June 1979 Testimony of Wj Ferguson Re Engineering,Qa & Const Project Organizations.Qa Program Is Autonomous & Objective.Bechtel Has Primary Responsibility for Review of Design & Procurement Documents ML19207B4901979-06-29029 June 1979 Testimony of Ev Padgett Re QA Program.Qa Program Was Developed to Meet Requirements of 10CFR50,App B & ANSI N45.2 as Set Forth in Chapter 17 ML19207B4911979-06-29029 June 1979 Testimony of Rn Hettinger Re QA Program.Describes Current Level of QA Activities.Certificate of Svc Encl ML19246C4681979-06-0101 June 1979 Submits Joint Testimony of Re Olson,Me Coberley,Ls Pack & Jm Coombs.Util Does Not Have Reasonable Assurance of Obtaining Funds for Const & Fuel Cycle Costs.Prof Qualifications & Certificate of Svc Encl ML19242D2021979-06-0101 June 1979 Supplements Testimony Presented at 780217 Proceeding Re Util Use of Piping Test Data to Predict Yield of Proposed Ranney Collector Sys & Drawdown Effects of Ranney Collectors on Nearby Red Cabin & Muddy Creeks ML19241A6171979-06-0101 June 1979 Testimony Re Ranney Collector Sys.Sys Is Sufficient to Provide Plant Water Needs Under Varying Conditions W/Minimal Impact on Water Resources 1979-08-08
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML19210E1281979-10-18018 October 1979 Prefiled Testimony.Bechtel 1979 Geology Map Cannot Be Used as Tool for Seismic Evaluation of Area.Supporting Documentation,Prof Qualifications & Certificate of Svc Encl ML19276H5781979-10-18018 October 1979 Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications Encl ML19276H5801979-10-18018 October 1979 Prefiled Testimony.Two east-west Trending Faults Can Be Found Along Plant Site Vicinity ML19276H5831979-10-18018 October 1979 Prefiled testimony.Auger-Hole Investigation Conducted by Bechtel Did Not Provide Sufficient Evidence Approving or Disapproving Origins of Sediments Deformation ML19276H5751979-10-17017 October 1979 Prefiled Testimony.High Frequency Seismic Methods Inadequate to Locate Fault Traces Existing in Area.Interpolation Between Spaced Seismic Lines Is Speculative ML19210C1631979-10-0808 October 1979 Testimony of Nm Newmark Re Conservatism of Seismic Design Criteria & Seismic Design Provisions for Facility.Biography Encl ML19210C1601979-10-0808 October 1979 Testimony of Ba Bolt Re Correlation Between Peak Acceleration & Magnitude & Intensity.Biography,Publication List & Supporting Documentation Encl ML19256E3281979-10-0303 October 1979 Supplemental Testimony of J Kelleher Re NRC Methods Used to Estimate Strong Ground Motion ML20136C5211979-08-30030 August 1979 Transcript of 790830 Hearing in Seattle,Wa. Pp 14,802-15,048 ML20136C5271979-08-27027 August 1979 Transcript of 790827 Hearing in Seattle,Wa. Pp 14,388-14,573.Exhibits 213-15 Encl ML19249E1561979-08-0808 August 1979 Testimony Re Financial Qualifications Submitted by J Lazar on Behalf of Intervenor Skagitonians Concerned About Nuclear Power.Asserts Applicant Will Be Unable to Secure Financing. Certificate of Svc Encl ML19207B4771979-07-12012 July 1979 Supplemental Testimony of Es Cheney Re Alternative Site Comparison,Submitted on Behalf of Skagitonians Concerned About Nuclear Power.Goshen,Hanford & Pebble Springs Are Better Sites than Skagit ML19209B0681979-07-10010 July 1979 Testimony of ML Darland on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Evacuation Planning.Professional Qualifications Encl ML19209B0691979-07-10010 July 1979 Testimony of Pr Weber on Behalf of Intervenor Skagitonians Concerned About Nuclear Power,Re Ranney Wells.Prof Qualifications & Bibliography Encl ML19209B0721979-07-10010 July 1979 Testimony of J Lazar on Behalf of Intervenors Skagitonians Concerned About Nuclear Power,Re Financial Qualifications. W/Supporting Documentation ML19247B2871979-07-0202 July 1979 Testimony of RB Eastvedt Re Bulk Transmission Sys Requirements Associated W/Alternate Sites ML19207B4841979-06-29029 June 1979 Testimony of JW Ellis Re QA Program.Util Has Implemented QA Program That Fully Complies with All State & Federal Regulations ML19207B4811979-06-29029 June 1979 Testimony of Je Mecca Re Amended License Application & Complete Psar.Verifies Application as Amended Through Amend 4 & PSAR as Amended Through Amend 20 & Suppl 18 ML19207B4851979-06-29029 June 1979 Testimony of Wj Ferguson Re Engineering,Qa & Const Project Organizations.Qa Program Is Autonomous & Objective.Bechtel Has Primary Responsibility for Review of Design & Procurement Documents ML19207B4901979-06-29029 June 1979 Testimony of Ev Padgett Re QA Program.Qa Program Was Developed to Meet Requirements of 10CFR50,App B & ANSI N45.2 as Set Forth in Chapter 17 ML19207B4911979-06-29029 June 1979 Testimony of Rn Hettinger Re QA Program.Describes Current Level of QA Activities.Certificate of Svc Encl ML19246C4681979-06-0101 June 1979 Submits Joint Testimony of Re Olson,Me Coberley,Ls Pack & Jm Coombs.Util Does Not Have Reasonable Assurance of Obtaining Funds for Const & Fuel Cycle Costs.Prof Qualifications & Certificate of Svc Encl ML19242D2021979-06-0101 June 1979 Supplements Testimony Presented at 780217 Proceeding Re Util Use of Piping Test Data to Predict Yield of Proposed Ranney Collector Sys & Drawdown Effects of Ranney Collectors on Nearby Red Cabin & Muddy Creeks ML19241A6171979-06-0101 June 1979 Testimony Re Ranney Collector Sys.Sys Is Sufficient to Provide Plant Water Needs Under Varying Conditions W/Minimal Impact on Water Resources 1979-08-08
[Table view] |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICET3ING BOARD In the Matter of )
)
PUGET SOUND POWER & LIGHT ) DOCKET NOS. STN 50-522 COMPANY, et al., ) 50-523
)
)
(Skagit Nucinar Power Project, )
Units 1 and 2) )
)
)
PREFILED TESTIMONY OF ROY BLUNDON October 18, 1979 Q. Would you state your name, address, and occupation, please.
A. Roy H. Blunden, Geologist Urban Environmental Engineering of Coastal Geology 2045 E. Broadway Vancouver, B.C.
Canada 75NIWG My statement of qualifications is on record in :his proceeding.
Q. What documents have you reviewed in preparation f or your testimony?
A. I have reviewed the reports contained in the Report of Geologic Investications in 1978-1979 concerning investi-gation of deformed Pleistocene sediments. Included was a report by Dr. Don T. Easterbrook, dated April 3, 1979.
I have also had a general discussion with Dr. Fred-Pessl, Jr. of the U.S. Geological Survey.
'} \b\
7 9112 0 0 ef fICC)
C. What conclusions have ycu reached?
Tyo specific areas of deformed Pleistocene sediments were considered in the reports, neither cf which have been studied in the field by the writer- Of the two areas referred to in the Bechtel Inc. reports only :he Cavanaugh Road exposures were subjected to sub-surf a:2 investigation and are here considered in the fcilevinc. a..a l.e s i s . This ana_ysis is concernec witn ne expec ations, :in:Ings anc interpretation of th.e i..ve s t ig a t i e r findings cy Ir. Easterbrcok and Sech tel Inc.
Review Of Lake Cavanau:h Ecad Auger-Hele Iny=stiga-ion
.ne purpose o., ene suo-surr ace ;r.ve s tiga: o- Ocnau: ec
.e ...
.__.e, r
.nc. .. . a s *. o 2. .. . e .. 4 . . e . .. . c a ._. _. ...
. co.ec . ..a _
tior cf Pleistocene sediments observable i. road cuts along
, d "..e _e a_ =_ _" s a d_ _i _ =. . . . .= o - ~. . . _='.
_ a r. :,
_ _ . = . _= ". = n au c. h. R o a . d =_ _" c ._
_.,...._e.. . . .g o.... . .c . o ,d a. c .i . . o .# a- -.=. c. .i .
. . . _3 '_ ....=..-.d... .
- . a- ~ u _ a- . a. d
.. . . , . . 0 .. r. ...- =. ~u . o . . m= _= _ s_ _' .=
. . #c.= _' _...i..=..
.. .' _= .. =
_c _e _ . _ _.4._,
. *..g o. c i .l i i - = .- C .- c. s. k. .#au_ , .5 = _= _- s a. .- . . "' ' . . e d - ;-
the ".3. Geological Survey ( U.3.G . 5 . who presunably le:ated and reported the occurrence of the deformed materials.
A description of the area of in ze s ti g a t ie r by the L.5.3.5. and by Dr. Easter br oc< indirates the presence of a
-ill orainal ridge t: :he west, ar.d transterse -0 the road, cacked to the east'by lacustrine dep: sits folded into T 'M
~
D "
3423 162
anticline-syncline deformations. Along the inner flank of
- ne western anticline, cultiple faults were observed. In addition, flame structures were present in the syncline and inner flar- of the eastern anticline. An auger hole investi-ga tion confu cted by the U .S .G .S . suggested there might be a displacement of underlying glacial deposits on the order of s: e seven re res.
The app aren; intent of the Bechtel Inc. investigation, as suggestad by the data presented, was to determine the cen-inuity cf the sub-surface glacial deposits and, by inference, the presence or absence of faulting associated wi:- the Gi;; iga.- C reek lineation.
Dr. Eis :erbrock ascribes the surface morainal ridge a 7asnon a e and the lacustrine deposits as being of cirilar r e cessiona; .* ashen age . In the same report, howeve r , D r.
Eas:erbr:c' identifies two sub-surf ace glacial sequences en:: ntered . . - auge r holes , the lowermost of which he also as: ices :: ce Of conterporary Vashon age without citing ad diticnal suppor-ing evidence.
- ithi. he anger hele logs of Bechtel Inc. (report dated Dece.-ber 29, 1978), the lowermost till of Dr. Easterbr0ok was sual;y re
- c;nized and generally described as "Till
t' . . -g ray distict:n, dense to ve ry dense. " S tandard pene: ratio. :es: results indicate that after an initial pene: ratio. cf six ' inches, hamme r blows required to drive l $
T423 \63
the split spoon sampler a further twelve inches (N-value) varied be tween 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 according to the jumping action of the auger bit when gravel and boulders were encountered at an approximately com.on depth within a bedded silty sand sequence. General auger hole log descrip-tions for this ' upper till' are "Siltv Sand: blue-gray, varicusly sorted, scattered gravel and cobbles throughout" occasionally with bedded materials. Logged drilling indica-tions (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= 8& 97 The =can N-value was 27 blows per foot, less than half that of the recognized lower till. The two highest V-values, vi:: N= 80 (AH #19) and N = 97 (AH #12) are reported from gravel zones and are therefore spuriously high.
Dr. Easterbook in his analysis of the sub-surface conditions places considerable stress upon the existence of
.1423 16 4
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 hcrizon e to three me ters in thickness, the " upper till" is the fortuitous assemblage of gravel seams and small bouloers in a bedded silty sand assemblage. Unless Dr. Easterbrook based his identification of the " upper till" upon data not reported ir the quoted sources, it must be concluded that the enistence ci the " upper till" is unproven.
, The continuity of the basal till horizon would appear
- c have been confirmed within the limitations of the investi-ga tions. From the data presented, it mu s t be concluded that any single, large displacement of this horizon, suggested by the U.S.G.S., has been shown to be nonexistent. In contras t,
'.cweve r , the assertion by Dr. Easterbrook that the faulted and defor:ned sediments do not persist to significant dep ths belcw road level due to the presence of the " upper till" cannot be substantiated from the investigation findings.
The sub-surf ace investigation also has neither proven nor disproven the existence of recent post-glacial f aulting within the Lake Cavanaugh Road investigation area. Both Dr.
Easterbrook and Bechtel Inc. would appear to have assumed
- nat any recent f ault activity would involve the glacial deposics ir easily identifiable vertical dislocations, as cr:ginally suggested by the U.S.G.S. Such reasoning would
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imply that the absence of dramatic evidence of recog-nizaele disiccatien would nullify any postulated recent faulting along the 3illigan Creek lineation. The form and method of the inves-igatien confirms that only dramatic evidence was sougr.t. Indeed, using the augering methods ado.o t ed , this was the oniv. evidence that could have been identified.
Quaternary f aulting reported near Lake Cushman, Washi..; ton 3.ilson et al. 1979) do offer the dramatic uplif ts of ug to eigh: metres. Examination of the publishec phot: graphs cf test trenches excavated across those f aul s r eve als that had they been investigated using core drilling they would p::bably not have been reccgnized. In the phot ogr aph 'Tigure 2, A p. 237, loc. cit.) an approximately 3-1/2 metre f aul:ed uplif t, had that been core drilled, would . ave yielded i log:
. . - _- A 1 .3 .,
1.1 - Cataclasti: rock
. . . _ .,31 1.'*
_ Vitric tuff
.;i:P coring breaks, aten had the lower till seen recovered, the ost probable i..terpretation of such a log would have been a regular till deposit, containing large boulders, overl. ing a puckered rock su rf ace. In a soil formation compcsed of silty sands and tills, s u c.7 as along Lake C ava..a;gh F. ca d , su :P alternating materials would not be iden:ified asevidenceoffaulting.
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t t I .- centrast, slip f aulting with surf ace rupturing associated with the California Galway Lake earthqua:-:e (Hill
- E se by , 1977) yielded shear planes which would ce unrecog-izable in any augering investigation. Similarly, in the ab-sence
- f information other than the results of drilling in-testigations, such shear planes would be interpreted as soil fissures resulting from dessication, even if advanced sang-1:n? :+chnicues were used.
A critical review of the investigation reports of 3ecnte; :nc. for the Lake Cavanaugh Road Auger-hole study of def orrsd Pleistocene sediments has neither confirned nor fispr:ted a tec enic origin for the features observed. The
- rudi:. cf the augering process adopted would be u.-li'<el; to
,* ield ;nequivocable evidence of even dramatic f aulting.
Similarly, the auger-hole investigation has yieldef insuffi-
- ien: ei;dence to confirm or disprove alternative origins it: :ne features observed.
L
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