ML19246B793
| ML19246B793 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 06/19/1979 |
| From: | Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN |
| To: | |
| References | |
| NUDOCS 7907180619 | |
| Download: ML19246B793 (13) | |
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p Fr I q cecuns N UNITED STATES OF AMERICA * *C NUCLEAR REGULATORY COMMISSION -
8- jut 0221979 ) }L
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BEFORE THE ATOMIC SA7ETY AND LICENSING M RD w wqy y ""iLa 2 In the Matter of NRO PUByC DOCUMEXT RCOM g s=
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PUGET' SOUND POWER & LIGHT ) Docket Ncs. 50-522 COMPANY, et al., ) 50-523
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(Skagit Nuclear Power Project ) June 19, 1979 Units 1 and 2) )
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PUGET SOUND POWER & LIGHT COMPANY'S RESPONSE TO INTERVENOR SCANP'S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO APPLICANTS OF MAY 24, 1979 GEOUEST POR PRODUCTION NO. 1. The le tter of March 29, 1979 from J. E. Mecca to John F. Stolz dascribes on oace 2 an extensive reinvestication of the site area conducted hv Pechtel. Please oroduce all fiald macoinc and field notes made in connection with this extensive reinvestication.
ANSWER. The requested materials are available for inspec-tion in the offices of attorneys for Applicants.
344 16'4 PEOUFST P?R PRODUCTION NO. 2. In cenrection with the extensive reinvestica tion unde rtaken by echtel referred to in Recuest for P roduction No. 1, please oroduce all aero-macnetic surveys and intercretations thereof.
ANSWER. The aeromagnetic surveys requested are presented as proprietary figures in the Edcon report, which is Appendix A to the Report of Geologic Investigations in 1978-1979 by Bechtel Incorporated. These proprietary surveys (magnetic contour maps)
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have previously been made available for inspection by SCANP.
Applicants have offered to provide SCANP with a set of the proprietary surveys pntsuant to a protective agreement. The interpretations of the aeromagnetic surveys are presented in the Edcon report, which has been given to SCANP.
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D.FO U FST F) R P RCDUCTION No . 3 . In connection with the ex-tensive reinvestigation ref erenced in Recuast for Production Mo.1, please oroduce a]1 da ta and interpretations produced throuch reinvectication of the site area involvina magnetics.
ANSWER. Appendix B to the Report of Geologic Investigations in 1978-1979 by Bechtel contains magnetic data and interpretations which are in addition to the aercmagnetic data and interpretations that were the subject of the preceding request ir production.
This additional magnetic data involves ground magnetometer lines, the location of which are shown on figures B-1 of Appendix B of the Bechtel report. The magnetic profiles of many of those lines are reproduced in Appendix B. The other profile lines are avail-able for inspection in the offices of attorneys for Applicants.
IMTEDPOGATO?Y NO. 1. In connection with the reinvestica-tion referenced in Recuest for P rCdu ction No. 1, Claas e de s-cribe all other investicative crocrams endertakan en Gillican and Day Creeks in resnonse to the NRC's cuestions.
ANSWER: The other investigative programs undertaken on Gilligan .',nd Day Creeks are described in the Bechtel report.
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REQUEST FOR PFODUCTION NO. 4 dith restect to the rein-vestication referenced in Pecuest for Production No. 1, clease oroduce all data and interpretations obtained in re-review of imacerv studias.
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ANSWER. The data are identified and the interpretations are presented in the Bechtel report. The imagery that was used includes (1) side looking airborne radar, which is available from the U.S. Corps of Engineers in Seattle, (2) Black and white and color aerial photographs (1: 24,000 and 1: 6,000 scales), which are available from the Resource Inventory Section of the Washington State Department of Natural Resources in Olympia, and (3) imagery which has been discussed previously in hearings and in responses to prior discovery requests.
REQUEST PDR PRCDUCTION MO. 5. Please produce any data, interoretations, or other written materials oroduced or assessed in connection with these other investicative procrams
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referenced in I nterrona torv No. 1 above.
ANSWER. The requested materials are provided in the Bechtel report and in the report entitled " Subsurface Investigation of Disturbed Glacial Deposits on Lake Cavanaugh Road" dated 29 December 1978 by Bechtel. Applicants have previously givsn both reports to SCANP.
INTEPROGATORY NO. 2. In connecticn with the reinvastica-tion referenced in Recuest for P roduction No. 1, please describe the information from seismic prof _iles which have been _ reviewed to define if a structure as hyr.othesized by D r. H ay s -e xi s es.
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ANSWER: See Dr. Dobrin's latter report dated May 15, 1969 in Appendix 0 of the Bechtel report and his other reports in Appendix 2G of the PSAR for the requested description.
PFOUFST FOP PPODUCTIOM NO. 6. P .l. e a s e croduce all of the information described in Interroca torv No. 2 above.
ANSWER. There are four sets of seismic reflection data that are referenced in Dr. Dobrin's reports. The Mobil Oil Co.
data, the 1976 USGS data, and the BBN dEta have previously been made available to SCANP. The 1978 USGS profiles data are avail-able from the USGS, from whom Applicants obtained it. A copy of the 1978 USGS data can be inspected in the offices of attorneys for Applicants.
INTEPROG ATCPY 90. 3. Please describe any factual con-conclusions which Auplicants reached based ucon the extensive reinvestication undertaken by Becatel considerina the hypo-thesized "P & B Fault", including a discussion of how this re-investication succorts those conclusions. .
ANSWER: The factual conclusions are described in Section 3.4.1 of the Bechtel report.
REQUEST P3F PPCDUCTICN NO. 7. Please produce any nin-u tes , memo randa, or notes taken or oroduced in connection with the discussions with Dr. Havs and other reviewers referenced on caces 1 and 2 of the letter referred to in Recuest #or Production No. I .,
ANSWER. The requested material is available for inspection in the offices of attorneys for Applicants.
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nFOU FST FO R PRODUCTION NO. 9. Please produce the aero-macnetic data referenced in the letter dated Februars 23, 1079 fron J. E. Mecca to John F. Stolz, Please produce also anv aeromacnetic data acquired f o r P uc e t P ow e r bv I. .K . B . Resources, Inc. and..Aero Services, which has not been submi tted to the NRC staf f or USGS. Please submit also all written evalua-tions of this data, inclu.ine the factual conclusions, if any, which aco'ic ..ts have reached in connection with this data and the basis thereof.
ANSWER. The aeromagnetic data referenced in the letter dated February 21, 1979 frcm J. E. Mecca to John F. Stolz are the same data that were acquired for Puget Power by .<..B. Resources Inc.
and Aeroservices. These data are presented on the proprietarv aeromagnetic cor. tour maps, which were discussed above in the response to Request No. 2. 'ne methods for collecting, processing, and
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presenting this aero nagnetic data are described in Appendices 3 and 4 to the Edcon report. The evaluations of and conclusions regarding the data is presented in the Bechtel report, particularly in Appendix A (the Edcon report).
INTERPCG ATORY NO. 4. Please describe che location, quantity, and tyces of gravel which applicants intend to use for construction of the Skacit Nuclear Pcwer Project. Please state whether any studies have been undertaken to assess the environmental and other imoacts of cravel removal, includinc ircacts on fisheries. If anv such studies have been' undertaken, clease produce all documents, includinc notes, =roduced in con-nection with such studies.
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OBJECTION: Applicants object to this interrogatory on the ground that the information sought falls outside the permissable scope of discovery under 10 CFR 2.740(b) in that it neither relates to any matter in controversy in this proceeding nor is reasonably. calculated to lead to the discovery of admissable evidence.
INTERROGATORY NO. 5. Please state whether applicants have reevaluated or amended their evacuation clan in lich t of 1) the orcocsed use of the Northern S ta te Hospital Site, and 2' the 3-Mile Island Accident.
Please croduce documents oroduced in connection with any such reevaluation.
ANSWER. Not yet.
RFOUEST FOR PRODUCTION NO. 9. With reference to the meetinc of February 23, 1979, between the NRC staf f, USGS, and Pucet Sound Power & L ich t Comnanv , held in nethesda, M a ry l and , clease croduce all materials presented by Pucet at that meetinc, tecether with any and all notes taken by P uge t representatives at that r.e e t i n c .
ANSWER. The materials presented at that meeting included material by Edcon and by Bechtel. Edcon's material is contained in the Edcon report, which has previously been made available to SCAN?. Copies of the 3echtel material and the notes by Puget representatives are avail:.b2' . the offices of attorneys for Applicants.
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INTEFFOGATORY NO. 6. On March 8 ,, 1979, the weshincton
,cilities and Transoortation Commission issued a Second cucolemental Order in Cause No. U-78-21. The Commission in that order au thorized Pucet to file tari f f revi sions, includina revenues for construction work in crocress ( C WI P ) .
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Please state the annual dollar amount of CWIP rates which Pucet has soucht or will seek in its revised filina. Please state the annual dollar amount of CWIP rates which are attributed to the Skagit Nuclear Pcwer Project, and please itemize all amounts thereunder. Please include in vour
N answer the amount for the next year and eve ry year there-af ter included in the revised tariff filing.
ANSWER: The annual dollar amount of revenue attributable to
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CWIP, which is shown below, is based on the 1977 test year. The percentages shown represent the percent of gross revenue derived from the inclusion of CWIP - Major Projects in rate case. These percentages will remain unchanged in subsequent years until such time as the second Supplemental Order Cause U-78-21, is superceded.
Plant Revenue % of Revenue Skagit 1,743,065 0.65%
WPPS #3 128,595 0.05 Pebble Springs 1,090,584 0.41 Colstrip 3 & 4 441,076 0.17 INTERROGATORY NO. 7. With respect to the croceedina referenced in the immediately precedina interrogatory, please answer all cuestions in that Interrocatory with rescect to the tariff filing which was rejected in the Commission's Second Succlemental O rder.
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ANSWER:
Plant Revenue % of Revenue Skagit 4,420,296 1.60 WPPS #3 573,491 0.21 Pebble Springs 2,479,248 0.90 Colstrip 3 & 4 1,349,911 0.49
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REOUFST FOR PRODUCTION NO. 10. Produce all notes, memo-randa, correscondence, studies, recorts and other documents of any kind relating in any way to the procosed WWP coal-fired plant in Eastern Washington, including all such materials in the hands of engineers and consultants.
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ANSWER. See The Washington Water Power Company's separately filed response and objection dated June 13, 1979.
INTERROGATORY NO. 8. With resoect to the .nroposed WWF coal-fired clants in Eastern Washington:
a) Nhat sources for coal have been considered?
b) Describe all information WWF has recardino avail-abili ty , sucolv , price, and transportation cost for such coal.
c) who will 1) design, 2) build, and 3) operate the plant?,
d) When did design work begin?
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e) Have any ourchases been made to date relating to such plant, and if so, when, by whom, from whom, of what, and in what amou nt ?
f) Is such clant yet reflected in any formal or in-f o rma l, in-hcuse, or public forecast of resources? -
c) When is cons truction to becin? ~
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ANSWER: See The Washington Water Power Company's separately filed answer dated June 13, 1979.
INTERFOG ATORY NO. 9. Please describe all geolocic, seis-molocic, and geoohysica'. studies, recocts, or investications,
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certainino to the Skacit site or any location in the S tate of Washincton, unde rtaken by , commissioned by, or received by vou since January 1, 1978.
ANSWER: The studies pertaining to the Skagit site are in the Bechtel report. Information on the alternative sites of Goshen, Cherry Point and Ryderwood is presented in the document entitled "A Comparative Analysis of Geologic and Seismologic Conditions of the Alternative Sites to the Skagit Nuclear Power Project", by Bechtel (December 1978) . This document was pre-viously distributed to SCANP.
Since January 1, 1978, Puget has received the following geologic reports from WPPSS, (all . of which are publicly available through WPPSS). The documents are listed according to their title, author and date.
- 1. Magnetic Properties of Basalts from the Columbia Plateau--
Part I by Weston Geophysical (March 1978).
- 2. Magnetic Properties of Basalts frcm the Columbia Plateau--
Part II by Weston Geophysical (March 1978).
- 3. Stress, Gravity Anomalies, and the Location of Earth-quakes in Washington State -- Two-Dimensional Models by
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Weston Geophysical (March 1978) .
- 4. Magnetic Modelling -- Columbia plateau area by Weston Geochysical (March 1978).
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- 5. British Columbia Microearthquake Survey -- May through October 1977 by Weston Geophysical (March 1978) .
- 6. Ground Geophysical Studies -- Columbia Plateau and Adjacent Cascade Mountains by Weston Geophysical (March 1978).
- 7. Qualitative Aeromagnetic Evaluation of Structures in the Columbia Plateau and Adjac-7t Cascade Mountain Area by Weston Geophysical (March 1978) .
- 8. Investigation of the Ribbon Cliff Landslide, Entiat, Washington by Shannon & Wilson (February 1978).
- 9. Straight Creek rault Zone Study by Woodward-Clyde Consultants (April 1978) .
- 10. Geologic Reconnaissance of the Cle-Elum-Wallula lineament and Related Structures by Shannon and Wilson (June 1978).
- 11. Geologic Studies of the Southern Continuation of the Straight Creek Fault, Snoqualmie area, Washington by Shannon and Wilson (December 1977) .
- 12. Studies of the Hope and Yale Faults in Southern British Columbia by Shannon and Wilson (December 1977) .
- 13. Earthquake Monitoring of the Hanford Region, Eastern Washington including Quarterly Technical Report 78-B by the Geophysical Program of the University of Washington (August 1978).
- 14. Quarterly Technical Report 78-A, by the Geophysics Program of the University of Washington (April 1973) .
- 15. Paleomagnetism and Age Dating, WPPSS 1 cnd 4 (July 1978).
- 16. Microearthquake Studies, WPPSS 1 and 4 by Woodward-Clyde Consultants (July 1978) .
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INTERRCG ATORY NO. 10. Please cive all available in-formation recardinc eve ry detectible earthouake which has oc-curred within 25 miles of the plant site since 1976. You should furnish the location of eoicenters, maanitude, and fault plane solutions, if available. Also state where vou obtained the information which you are furnishina in answer to this interrocatory, and whether you know of anv source of information which ysu did not consult. Also state whether, to your knowledge, any person is analyzina such data to determine possible correlations between such events, and if so who.
ANSWER: Please see the PSAR and answers to Interrogatory No. 1 of December 16, 1977 and Interrogatory No. 10 of January 20, 1978. The requested data, (to the extent not contained in the PSAR and the interrogatory answers) are available from the Geophysics Department at the University of Washington. Their network of seismographs, with which they monitor seismicity in the region, is considered to produce the most reliable data.
Additional sources of information are the U. S. Geological Survey and the Dominion Observatory in Victoria, B. C. Also, Puget has since July 1975 maintained a strong-motion accelerometer at the site and another one in the valley near the site. Neither instrument has been triggered by seismic events since it was installed. Both are set to be triggered by a ground acceleration of 1/2 of 1% of acceleration due to gravity. ,
To our knowledge, no one is analyzing the data requested.
As indicated in the PSAR, Bechtel and its consultants have analyzed data on earthquakes in the plant site region.
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INTERFOGATORY NO. 11. Have you at any time requested or commissioned a study to attempt to correlate the fault plane solutions for any earthcuakes which have occurred, since
- 1973, in the Skacit Valley? If so, please state when you commissioned such study, who is conducting such study, and identify'"all documents which reflect the fact of such study, and its results. Also, please provide a list showing all available data regardina every known earthquake which has occurred in the Skacit Valley since 1973.
ANSWER: Puget commissioned Dr. Stewart Smith of the University of Washington to study the December 1974 earthquake and its aftershocks. Dr. Smith's report is in the PSAR. As indicated in the answer to the preceding interrogatory, Bechtel and its consultants have analyzed data on earthquakes in the plant site region. Also see the preceding answer regarding a list
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of earthquakes.
DATED: June 19, 1979 Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WILLIAMS
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By- /J/[ " r $'m- -l { ';- ~ M wz
F. Thecdore Thomsen Attorneys for Applicant 1900 Washington Building Seattle, Washington 98101 Phone (206) 682-8770 Of Counsel: -
Lcwenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue N.W. 344 175 Washington D. C. 20036 Phone (202) 862-8400
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STATE OF WASHINGTON)
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COUNTY OF KING )
JAMES E. MECCA, being duly sworn, on oath deposes and says: That he is Manager - Nuclear Licensing and Safety of PUGET SOUND POWER & LIGHT COMPANY: that he has read the foregoing Puget Sound Power & Light Company's Response to Intervenor SCANP'S Interrogatories anc Requests for Produc-tion to Applicants of May 24, 1979, and is informed and believes that the answers stated therein are true.
[J h es E. Mecca
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\ k SUBSCRIBED AND SWOR. .o before me this [h day of June, 1979.
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i NotTry @ublic in'and for the State of Washington, residing at Seattle 344 176
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