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 CreeksML19242D202 |
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Skagit |
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Issue date: |
06/01/1979 |
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From: |
Schreiber D PUGET SOUND POWER & LIGHT CO. |
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Shared Package |
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ML19242D197 |
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References |
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NUDOCS 7908140682 |
Download: ML19242D202 (11) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl ML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding 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 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 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 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 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 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 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 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 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 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 ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20069F9491982-09-23023 September 1982 Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl 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 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 ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl 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
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SUPPLEMENTAL TESTIMONY OF DAVID L. SCHREIBER RANNEY COLLECTOR WATER SUPPLY SYSTEM SFAGIT NUCLEAR. POWER PROJECT DOCKET NOS. 50-522 & 50-523 A. Introduction This testimony supplements the testimony submitted by Drs. Marmer, Zussman and myself in this proceeding on February 17, 1978. It addresses the Licensing Board's concerns relative to (1) the applicants' use of pumping test data (set forth in Appendix G to ER) to predict the yield of the proposed Ranney Collector System and (2) the drawdown effects of the Ranney Collectors on nearby Red Cabin and Muddy Creeks.
This testimony also evaluates the effects of the applicants' proposed design changes to the System to meet the mitigation requirements pre-scribed by the Department of Agriculture in its Wild and Scenic Rivers Act determination of April 11,1978.
B. Projected Yield The fundamental concepts of the flow of a liquid through a porous media were put forth by H. Darcy in 1856 and were based upon experimental studies. This early work serves as the foundation for modernday theory of groundwater hydraulics. Darcy's Law states that the rate of flow through a poccus medium is directly procorticnal to the cross-sectional area (through which flow takes place) and to the pressure head (or potential energy) difference between the inlet and outlet of the medium, and is inversely proportional to the flow path length between the inlet and outlet.
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2-The central theme of Mr. Mikels' testimony ( testimony of Frederick C.
Mikels dated February 22,1978, Tr.10, 691) is to demonstrate that Darcy's Law is valid for the Skagit pumping test data and for the predicted collector yields. In order for Darcy's Law to be applicable, the groundwater ficw must be in the laminar, and not turbulent, flow regime (a laminar flow regime is evidenced when lines of equal velocity are roughly parallel). Mikels presented a graph from the groundwater textbook by Todd which shows the relationship between the friction factor and Reynolds number for flow in a porous media. Data obtained by several investigators are plotted on the graph. The point at which the data begin to depart from the straight line is approximately the upper limit of the laminar flow regime. This point is approximately a Reynolds number of 10. Darcy'sLawisnothalidforgroundwaterflowconditionsthatexceed this value.
I have reviewed the data from the Skagit pumping tests. The calculated Reynolds number indicates that the flows in the proposed Ranney Collector Water Supply System are wi thin the laminar flow regime; thus, Darcy's Law is valid for this situation. I concur in Mikel's statement that the Reynolds numbers for the proposed Ranney Collectors are lower than those for the pumping tests and are, therefore, further removed from the turbulent flow regimes. Since Darcy's Law is valid for the Skagit si tuation, it can be used as a basis for estimating water yields from the proposed Ranney Collectors.
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It has been comon practice for many years in groundwater development for municipal, industrial, and agricultural use to base design fisw rates on pumping tests with much lower flow rates. Such extrapolation has proven reliable, as long as Darcy's Law is valid for the particular situation.
I have reviewed the applicant's method, which is based upon Darcy's Law, for estimating the water yield of a Ranney Collector. Data from field pumping tests of a vertical well are used in the method. The method is based upon sound physical principles, and I concur in its use.
The Ranney Corporation has utilized this method for nearly 40 years, and their experience (documented as Attachment C to Mikel's testimony) indicates that it is reliable. Furthermore, the method is documented in a reputable professional publication, International Association of Scientific Hydrology Publications (Attachment A to Mikel's Testimony),
and has been referenced by Hantushb in a chapter on the Hydraulics of Wells in a major textbook on Hydroscience. The applicant's methodology dnd selection of Coefficients are sufficiently Conservative to assure design flow rates, even when such things as interactions between collectors are considered.
I have independently checked the applicant's methodology using the pumping test data provided in Appendix G to the Environmental Report. I calculated estimated yields for the proposed Ranney Collectors that are within a few peraent of the applicant's estimates. Therefore, I concur with the applicant's estimates of water yields to be expected frcm the proposed Ranney Collectors.
- Hantush, M.S., Hydraulics of Wells," Chapter 5, Advances in Hydroscience, Edited by V.T. Chow, Volume 1, Academic Press, N.Y., pp. 397-406, 1974.
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The applicant's estimates indicate an average combined water yield from the four collectors of 104.3 million gallons per day (MGD) and a minimum combined yield of 80.7 MGD. The minimum collector yield occurs during the winter months when plant water use is also low. The winter plant use at maxidum thermal output is estimated to be 49.2 MGD (FES, Table 3.2, p. 3-11).
This indicates a safety margin in excess of 60%. Even when comparing the maximum plant water use, 68.4 MGD, which occurs during the summer months, the plant water needs car still be met with the minimum combined collector yield (winter r.ionths) with a safety margin of 18%.
The estimated minimum and average individual collector yields in MGD are as follows:
Collector Minimum Average 1 32.3 41.9 2 30.1 39.1 3 8.9 11.1 4 9.4 12.2 Thus, for minimum conditions (49.2 MGD plant water use) and average conditions (57.9 MGD plant water use), neither collector 3 or 4 is needed to supply plant water needs. In addition, it appears that any one of the four collectors could be out for maintenance at any time and not jeopardize full plant operations under most circLastances, since the above plant water use values are based on maximum thermal output. Furthermore, maintenance outages on the Ranney Collectors could be scheduled during the periods of time when the plant is down for fuel loading, i
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As a final resort, more laterals could be jacked out from the collector caissons or another collector or two could be added to the system within the collector area (see Fig. 5, FES Supplement, p. 4-2), if additiona!
water supply were deemed necessary. Impact on the water resources of such action is cxpected to be minimal because the collector area contains sufficient additional shoreline.
In the January 24, 1978, Prehearing (Tr. 8411-8413), in the January 27, 1978 letter to the applicant, and in the June 22, 1978 Hearing (Tr.
10,899-10,903), the Board inquired about the possibility of installing and testing one of the proposed Ranney Collectors prior to constructing the remaining collectors. Even though this would allow evaluation of actual data, there would still be uncertainty about the other collectors and their interactions. A test such as proposed would not be proof positive.
I do not believe such a test is necessary.
C. Proposed Changes to Ranney Collector System In a letter dated May 22, 1978, the applicant described changes to the Ranney Well intake system that would meet the mitigation requirements prescribed by the Department of Agriculture (letter dated April 11, 1978 from M. R. Cutler to NRC) pursuant to the Wild & Scenic Rivers Act. To minimize visual effects, the Collector caissons were all moved approximately 50 feet further back from the initially proposed 100 feet from the river's edge. Furthermore, the rcoftops of the pump ncuses were lowered by ,-11 feet
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and the wall thickness increased. As a result of moving the Collector caissons, the horizontal lateral design was revised, increasing lateral lengths in the rivarward direction and decreasing lateral lengths in the landward direction. The criteria imposed for the changes in lateral design were that the centers of pumpage, computec yields, water quality, and effects on the grnundwater table should remain unchanged.
I have reviewed the applicant's proposed design changes, have asked questions concerning the changes, have reviewed responses to the questions (letter dated June 12, 1978 from applicant to NRC), and have reviewed the June 21-22, 1978 Hearing transcripts covering this topic (Tr. 10,675-10,690).
It is my professional cpinion that the proposed changes in the design of the Ranney Collector intake system will not change significantly the centers of pumpage, computed yields, water quality, and effects on the groundwater table.
D. Drawdown Effects on Nearby Streams As stated in the earlier written testimony of February 1975 by Schreiber, Zussman, and Marmer concerning drawdown effects of the Ranney Co' lectors, the influence on Muddy Creek and the East Fork of Red Cabin Creek would be small even assuming the groundwater table is not below the creek beds. Data submitted by the applicant in January 1979 covering the Ics-flow period from early August 1978 through early November 1978 (item 16) confirm thic the ground-water table is isolated from the creek beds. Using the grcund-water level measurement;in existing wells on November 2, 1978 (see Table 1, item 16),
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ground-wat3r table elevation contours were sketched on Figure 1 (item 16).
Creek bed elevations (Table 3, item 16) were also noted on Figure 1, along with Skagit River water surface devations (Figure 1, item 9). As evidenced by this Figure, which now includes groundwater table contours, thecreek-bedelehationsinRedCabinandMuddyCreeksareeverywhere atleastseveralfeetabovetheground-watertableintheSkagitRiYer floodplain. Therefore, the groundwater table drawdown effects of the Ranney Collectors will have no impact on the surface water flowing in either Red Cabin Creek or Muddy Creek.
The applicant noted in item 16 that there is no surface water connection to the southeast between the eastern headwaters of Etach Creek and the Skagit River (Ranney Collector vicinitylduring normal (or lesser) ficw conditions The natural flow of Red Cabin Creek is from north to south with confluence at Etach Creek. Flow then progresses westward through Etach Creek to the Skagit River.
The applicant further notes in item 16 that Etach Creek, east of the cor.-
fluence with Red Cabin Creek, is closed off from Red Cabin Creek (and the downstream reaches of Etach Creek) and is murky, making it not conducive to spawning. The headwaters of Etach Creek fork in the vicinity of Cockrehac Road and Ranney Collector No. 3. The southern fork of the creek has a flow-obstructing log jam at its juncture with the northern fork. In addition, the Cockreham Road culvert over the south fork is blocked by mud
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f, , it ' , ')
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_8-and debris. The existence of the ncrthern fork of Etach Creek could not be ascertained during the observation period or in aerial photographs (item 17 enclosure). The area where this fork of the creek is depicted on Figure 1 (item 16) did nct contain any water, nor were there any indications that water had been there.
As noted by the applicant (item 16), and confirmed by aerial photographs (item 17), Manser Slough (East Fork of Red Cabin Creek), just north of Etach Creek, does not flow and has not been in communication with the main fork of Red Cabin Creek for several years. Local residents have been filling in the western end of the slough for several years.
E. Conclusions The proposed Ranney Collector Water Supply System for the Skagit Plant is sufficient to provide plant water needs under varying conditions with minimal impact on the water resources. This conclusion is based upon my independent assessment of the applicant's methodology (which I believe is conservative) and field pumping test data, upon my review of the pertinent literature, upon the common engineering practice of 9xtrapolating pumping test data to estimate design flow rates, and upon the 40 years of experience by Ranney Corporation in installing such systems throughout the world.
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I APPENDIX
[L s
In preparing this supplemental testimony, I have reviewed the I F
following documents: i
_
Letter dated January 9, 1978, from Samuel W. Jensch, Chairman of
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the Atomic Safety and Licensing Board Panel, to Douglas S. Little, -
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Attorney for applicants;
_
- 2. Prehearing Conference Testimony of January 24, 1978 (Tr. 8389-91,
[
8410-8412); I E
- 3. Letter dated January 27, 1978, from Samuel W. Jensch, Chairman of the Atomic Safety and Liceneing Board Panel, to F. Theodore _
Thocasen, Attorney for applicants;
- 4. Testimony of Frederick C. Mikels, Re: Ranney Collector Water Supply System, dated February 22, 1978;
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_
- 5. The applicant's Environmental Report, Appendix G;
- 6. Letter dated April 11, 1978, from M. Rupert Cutler, Assistant -
Secretary for Conservation, Research, and Education, U. S. Department [
of Agriculture, to Lee V. Gossick, Executive Director for f
Operations, U.S. Nuclear Regulatory Commission;
[
- 7. Letter dated May 17, 1978, from E. E. Goitein, Project Engineer, _
Bechtel Power Ccrocration, to J. R. Fishbaugher, Puget Sound Power '
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r
& Light Company;
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{
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&
b
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- 8. Letter dated May 22, 1978, from J. E. Mecca, Manager, Nuclear Licensing & Safety, Puget Sound Power & Light Company, to W. H. Regan, Chief, Environmental Projects Branch No. 2, U. S.
Nuclear Regulatory Commission;
- 9. Letter dated June 12, 1978, from J. E . Mecca, Manager, Nuclear Licensing & Safety, Puget Sound Power & Light Company, to W. H.
Regan, Chief, Environmental Projects Branch No. 2, U. S. Nuclear Regulatory Commission;
- 10. Letter dated June 14, 1978, from F. C. Mikels, President, Ranney Method Western Corporation, to E. E. Goitein, Project Engineer, Bechtel Power Corporation;
- 11. Respense to Intervenor $CAtIP's Interrogatories and Request for Production, Puget Sound Power & Light Company, June 16, 1978;
- 12. NRC Hearing Transcript, Skagit Nuclear Power Project, Docket Nos.
STN 50-522 and STN 50-523, pp. 10,476-10,718, June 21, 1978;
- 13. NRC Hearing Trar ipt, Skagit Nuclear Power Project, Docket Nos.
STN 50-522 and STN 50-523, pp. 10,719-10-978, June 22, 1978;
- 14. Paper by Jeffrey Haley, " Potential Iron Bacteria Problems in Ranney Collectors for Skagit Nuclear Power Plant," June 22, 1978;
- 15. Letter dated July 13, 1978, from W. J. Miller, Engineer, Nuclear Licensing and Safety, Puget Sound Power & Light Company, to D. L.
Scnreiber.
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,
M
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- 16. Letter dated January 8, 1979, from J. E. Mecca, Manager, Nuclear Licensing & Safety, Puget Sound Power & Light Company, to W. H.
Regan, Chief, Environmental Projects Branch No. 2, U. S. Nuclear Regulatory Commission.
- 17. Letter dated January 3,1978, from M. V. Stimac, Senior Project Engineer, Puget Sound Power & Light Company, to Paul Leech, Senior Project Manager, Ervircreental Projects Branch No. 2, U. S. Nuclear Regulatory Commission.
In addition, I have conducted my own independent analysis of the applicant's pumping test data and evaluations thereof.
As expressed in items 1-3 above, the Board is concerned about the applicant's use of the pumping test data, presented in item 5 above, to predict the yield of the proposed Ranney Collector Water Supply System.
The applicant has addressed these concerns in Mr. Mikels' testimony, item 4 above, and in the hearings on June 21-22, 1978, items 12 & 13 above.
. hkN lb b !
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f Approx. Northern Limit of Skagit Floodplain x 90.8
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- e- s s 80.0 U()95.3 N 90 f t.' 90 0 80 f t.- --O - x s 0 137.o 0 85 f t. 99.3 0 78.3 N s s O x x 86.7 x g@ - 80.5 \< #
xO 103.3 q .0 75 f t. N N N 73 x x x ,oo.g 02 \ '80 f t. 98 l N \
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\ 79.9 \ g
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EX/LANATION k ? /
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$ Water Surface Level in Creek, f t.
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e O cround water tevei i -
in Well, f t.
--- Ground Water Leve!, f t.
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Approx. Southern Limit 4Cf7 of Skagit Floodplain 4/p N
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0 1000 2000 4000 30,00 FEET Figure 1 Surface and Groundwater at Skagit Site [: !; f) < (;
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