Prefiled Testimony.Applicants' Inference That No Significant Northwesterly Trending Fault Exists Between Lummi Island & Clark & Matia Islands Cannot Be Substantiated.Prof Qualifications EnclML19276H578 |
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Skagit |
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Issue date: |
10/18/1979 |
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From: |
Johnson S WASHINGTON, UNIV. OF, SEATTLE, WA |
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ML19210E129 |
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NUDOCS 7911290442 |
Download: ML19276H578 (9) |
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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] |
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UNITED STATES OF AMERICA .4 O C I 2 9 O Tg )p
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NUCLEAR REGULATORY COMMISSION b, ,, s -
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BEFCRE THE ATOMIC SAFETY AND LICENSING EOA . %y)' j"" S b
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In the Matter of )
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PUGEC SOUND POWER & LIGHT ) DOCKET NOS. STN 50-522 CO MP ANY , e t al. , ) 50-523
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( S k agi t Nuclear Power Project, )
Units ; and 2: )
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.: REFILED TESTIMONY OF S AMUEL Y. JOHNSON Octobe r 18, 1979 2 Would ycu state your name and occupation?
A. Samuel Yorks Johnson, graduate student and teaching ass is tant in the Department of Geology, University of K as hin g t o r..
2 What docurents have you reviewed in preparation for your testimony?
A. I h a ce :ead Section 3.4.1 of Bechtel's three volume investigation entitled " Report of Geologic Investigations in 1978-1979".
2 Khat special qualifications do you have which permit you to comment on this report?
A. I am quite f amiliar with the geology of the North Cascades. I consider sedimentology, sedime ntary petro-logy and pnysical stratigraphy to be my particular fields cf expertise. My research is being conducted 1423 150 7 9112 9 0 (F4 '2_,
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s under the supervision of Dr. John Whetten (supervisor),
Dr. Joseph Vance, Dr. Peter Misch, Dr. Samuel Cowen, and Dr. Richard S tewart, all af filiated with the Department of Geological Sciences, University of Washington.
For the last three years, my research has focused on Mesozoic and Cenozoic sedimentary rocks of N.W. Washing-ton. My initial research concerned the Upper Triassic Naro Formation, the Upper Jurassic and Lower Cretaceous Spreden Formation, and the Upper Cretaceous Hasla Formation (Nanaimo Group) of the northwestern San Juan Islands (my M.S. thesis field area) . While pursuing this research, and while working as a research assistant in an N.S.F. supported research project concerning the geology of the entire San Juan Island archipelago, I became very f amiliar with San Juan Island geology.
I have recently begun Ph.D. research concerning the sedimentology, petrology, stratigraphy, and structure of Upper Cretaceous and Lower Tertiary sedimentary rocks in northwest Washington. My goals are to develop paired sedimentologic and tectonic models for the geologic evolution of this area through rigorous field and lab examination of these rocks.
Q. What conclusions have you reached with respect to this report?
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A. My opinion is that the applicants have not presented enough evidence to determine whether the Nanaimo strata of the northeastern San Juan Islands are correlative <
and/or coextensive with the Chuck anu t Formation of Whatcom County and other portions of Washington. Their inference that no significant northwesterly trending fault exists between Lummi Island on the northea st and Clark and Matia Islands on the southwest cannot be substant ated. That is, until more detailed work is i done, the existence of the so-called " Ward Fault' is a possibility.
The applicants' principal grounds for correlating the strata of northeastern Sucia Island with the Chuck-anut Formation strata on Chuckanut Drive were hand specimen petrology and sedimentology (i.e., the occur-rence of similar sedimentary structures in rocks of both areas).
S edime ntolo gi cally , the units are not as simple to interpret as presented. There is unanimous agreement in the literature and among interested workers regarding the fluvial origin of the Chuckanu t Formation on Chuck-anu t D rive. The nature of the fluvial environment may change upsection f rom deposits more typical of mean-dering streams, to those more characteristic of braided streams. Conversely, there is disagreement concerning
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the origin of the strata of northeastern Sucia Island, Patos Island, and Matia Island. Two detailed studies of the Sucia strata have been pursued (Janby, 1972; Wash. S tate Univ. - M.S . thes is; Pacht, 1979, GSA cord. abstract, pers. comm., and Ohio S tate Univ. Ph.D.
thesis in prep.), and in each the conclusion is that these strata were formed in shallow marine environments.
Therefore, the applicants contention that these strata have a fluvial origin is contradicted by these studies.
The large scale trough cross beds found in each unit are not specif'.c to a single depositional environment and could be associated with either a fluvial or shallow ma'.ine depositional system. I consider the question as to the origin of the Sucia strata open.
I think : have noted in the field two signifi-cant differences between the rocks of these areas.
First, organic matter (ancient logs, leaves, etc.) is ubiquitous and very abundant in channel lags and flood plain deposits in the strata on Chuckanut Drive.
Conversely, only a small amount of organic matter (in contradiction to the applicants' findings) seems to be associated with the rocks of purported similar origin, on Sucia Island. Secondly, the degree and style of interbedding between coarse and fine gravel strata is different. It is rare to pass through more than
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100-200 feet of strata on Chuck anu t D rive without finding fine grained level or f1:od plain deposits. In many strategraphic horizons the proportion of these deposits is quite high. Conversely, on Sucia, there are very few fine grained deposi:s in any pert of the exposed section. It has been suggested several times that the fine-grained strata of the Sucia section has been eroded and are now represen:ed by indentations and coves in the Sucia coastline. This may be the case, bu t it still does no: accrunt for the ancralcus absence of fine grained beds in tne thick sections of exposed strata.
Lithologically, the applicants state tha; each unit is a buff-colored, honeycomt weatherec sandstone, and it is implied that these features are unique to Chuck anut Formation strata. Mcweve r, N anaimo C-roup strata lower in the section (turbidites of the Haslan Formation) are als o buf f-colored, and hone j cctb wea-thered, and are not Chuckanu t F ormation ccr relatives.
In short, there is nothing particularly diagnos tic about the lithology. My own reccllection is that the Sucia sandstones and conglomerates contain more chart f ragments than those of Chuckanu: Drive strata.
I have noted a few problems with the applicants' correlation. However, the main troblem does ct 1423 iSA
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lie with the raterial and data they have included , but rather with what they have f ailed to collect
, report.
and/or Any positive correlation between clastic sedimentary units requires point counts of sands tones (using modern methods and techniques) and pebble counts in congicmerates.
Hard specimen descriptions would not be considered sufficient in anything bu t a very ' broad reconnaissance survey.
If the applicants wish to es tablish lithologic similarity between these two areas, then there is no other way to rigorously approacn the prcblem.
If the units were once part of the same e' n c i e n t ,
non-framented seimentary basin, then their lithology should be nearly identical.
The a,cplicants also need to look at the sedimen-
- ology of the units far more rigorously. Detailed stratigrapnic sections could be reasured and inter-
.O r e t e d . If i is c neluded that the Sucia strata are indeed fluria; in orts.a. *3en an attempt should ce a de tc .ra:ch the 2,000 feet of Sucia strata with an equivalen.. section of Chuckanut Drive strata, both litholcgically and sedimentologically.
Finally, a sedimentary basin and paleocurrent analysis should be conducted in the Chuck anu t Forma tion of Wha:ccm County and on Sucia Island to cetermine the criginal ge, ology of the basin and the di stribe: ion 1AL3
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1 of depositional facies within the basin. This would be very important in the evaluation of proposed later structural disruptions.
In rocks such as these, which can not presently r7 accurately dated, these types of investigations are ab-solutely essential. Until they are conducted, correla-tion between the Sucia and Chuckanut rocks can only be regarded as tentative and questionable. Subsequent in-terpretations, using this correlation as a premise, would ,also be suspect.
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_S_t a teme n t of Qualifications N ame : Samuel Yorks Johnson Born: 8/12/51 Sar Diego, California Education:
B. A. , Earth Sciences, 1975, University of California, Santa Cruz, California, 95060; B.A. with honors in Arts and Crafts and Their Histories, 19 75, Univ. of Cal. , Santa Cruz, Cali-fornia; M.S . in Geological Sciences, University of Washington, Seattle, Washington, 98195; presently pursuing Pn.D. in Department of Geological Sciences, University of Washington.
Work and Research Experience:
1974-1975: Completed Senior Thesis research on "The Chemis-try, Minerology, and Ceramic Properties of Santa Cruz County Clays, Supervisor: Dr. Leo LePorte, U .C. , S anta C ruz ,
California 95060.
4/75-6/75: Scientific crew member on United States Geologi-cal Survey research cruise to the eastern Gulf of Alaska.
S upe rvi c or : Dr. Bruce Molnia, U .S .G .S . , 345 Middlefield Rd., Menlo Park, Ca.
3/76-7/76: Research and lab assistant in study of sediment contamination in the Bay of Naples, I taly . Supervisor: Dr.
Gary Griggs , U .C. , S anta Cruz , California, 95060.
7/76-9/76. Scientific crew member on United S tates Geologi-cal Survey research cruise in the Bering Sea. Superviscr:
Cr. Tracy Vallier.
9/76-6/77: Teaching Asst. in Introductory Geology; Depart-ment of G eology , AK- 20, U .S . , Seattle, Washington 98195.
S upe rviso r: Dr. Larry Hansen 9/77: Teaching Asst. in Introductory Field Geology, Dept.
of Geological Sciences, U.W. , Supervisor: Dr. Randall Giesens.
9/77-12/77: Field Asst. in U.S.G.S. reconnaissance mapping project in the foothills of the North Cascades, Wash.
Supervisor: Dr. John Whetten, U.W. and U .S .G .S . , P uget Sound P roj. , 1107 45th, Seattle, Wn. 98105.
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- 1. 71-3/75 and 9/78-12/78 : Research Asst. in N.S.F. sup-p:::ed research project concerning the geology of the San J u a.- I slands , Wash. Supervisor: Dr. John Whe: ten, U.W.
2, 75-f /75 and 3/79-6/79: T.A. in Geology of the Northwest;
'
Dept. cf Geological Sciences, U.W. Supervisor: Dr. Robert Filson.
1,79-3/79: T.A. in Sedimentary Petrology; Dept. of Geolog-ical S ciences , AK-20, U .W. Supervisor: Dr. J ohn <;he t:on.
6/ 79-5/79: Ph.D. Thesis research concerning upper creta-ce cts and lower tertiary sedimentary rocks of N.h. Gash.
partially supported by U.S.G.S., Puget Sound Project, 1107
':. S . 4 5th, s uite 125, S eattle , 98105. S:pervisor: Dr. Jchr Whetten, i,75-9/79: T.A. in Advanced Field Geology, Dept. of Geolo-gi cal S cier.ces , U.W. ,, Supervisor : Dr. Richard Stewar:.
Theses:
Cchnscn, Samuel Y., 1975, The Chemistry , Minercic gy , and Ce ramic P r:perties of S anta Cruz County Clays, San:a Cruz ,
Califcrnia: Senior Thesis, University of California, Santa Cruz, California 95060.
!c h..s c n , Samuel Y., 1978, Sedimentary, Petrology, & S:ruc-tu re cf Meso:oic Strata in the Northwestern San Juan :slands,
.;a s h i..g t o n: M.S . Thesis, Dept. of Geol. Sci. , AK 2C, Un:cersity of Washington, Seatelo 98195. 114 p.
Fue:ications.
- r s c r. , Samuel Y., 1978, The Geology cf Spieden Islar.d, S ar J u a.- : Slands, Wash: Northwest Science Proceedings A:stract
':: .
G r iggs , G . E . , and Johnson, S.Y., 1978, Sediment C o..tanina-
- or _n the Say of Naples, Italy: Bulle:in of Marir.e Pcilution, Vol. , , pp.
!cnnsen, S amu el Y . , 1979: Submarine ... Deposition ir the Jpper Cretaceous Nanaimo Basin, San Juan Islands, .i a s.. i ng t o r :
'::::nwest Science Proceedings, Abstract No.
2:rts:n, S amuel Y. , 1979, Sedimentology, Petrology and 5:ru::ure cf Meso:cic Strata in the Northwestern Sar Juan
- slands, Washington: G.S.A. Cordillera Abstrac:s wi:t P r :gr ams , Vol. '
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