ML19276H572

Requests That Certain Witnesses Be Called to Testify:Per R Black 791016 Ltr:Dp Dethier,Jt Whetten,Jp Minard,Hd Gower, C Stepp,B Ryan,T Loveseth,Jc Savage,C Wentworth,Dl Jones, DM Boone & C Blake

ML19276H572
Person / Time
Site:	Skagit
Issue date:	10/25/1979
From:	Leed R LEED, R.M.
To:	Deale V Atomic Safety and Licensing Board Panel
Shared Package
ML19210E129	List: ML19210E128 ML19276H567 ML19276H572 ML19276H575 ML19276H578 ML19276H580 ML19276H583
References
NUDOCS 7911290431
Download: ML19276H572 (3)

Text

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' ' LAW OFFICES ~~

ROGER M.1.EED -

Feurteen Eieven Fcu tn Avenue

.p...+e,: Seeit:e. Wcsne.gten 98101

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Valentine B. Deale, Esq , Chairman Atomic fafety and Licensing Board g A U.S. Nuclear Regulatory Commission (h<?g T 13Cl Connecticut Avenue N.W. 2 ihS

• ias hington , D.C. 20036 ll- 93 si$ #

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Re: Skagit Nuclear Power Proj ect, Units 1 & 2 g, 6 Dockets No. STN 50-522, 50-523 3 ho V"

Dear Chairman Deale:

• 's As indicated in the October 15, 1979 letter of Richard Black, "certain individuals who advised the U.S.G.S. of the field ecrk in the Skagit area . .

. will be available if the Board or the parties so desire." Below is the list of such witnesses whom we request be called to testify:

1. D. P. Dethier U.S.G.S expert on the pleistocene 1107 N.E. 45th St. geology of the Skagit Valley, and Suite 125 co-author of U. S.G. S. Open File Seattle, WA 93105 Report 79-1468

2. J.T. Whetten U.S.G.S expert on bedrock geology llc' N.E. 45 h St. of the Skagit Vallet, and co-Sui:e 125 author of U.S.G.S. Open File Seattle, UA 93105 Report 79-1468

3. J. P. Minard U.S.G.S. expert who studied 1107 N.E. 45th St. deformed lake sediments near Lake Suite 125 Cavanaugh and concluded that they Seattle, WA 98105 were faulted. Apparently he has noted some discrepancies between what he found and what the Applicants later reported to have found.

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Valentine B. Deale, Esq., Chairman Atomic Safety and Licensing Board October 25, 1979 Page Two

4. H. D. Gower Has compiled the first and only U.S. Dept. of Interior neotectonic map of Western Geological Survey Washington (U.S.C.S. Open File Middlefield Road Report 78-426).

Menlo Park, CAL 94025 The following witnesses, although they may not have specifically advised the U.S.G.S. of their field work, have knowledge which is essential to facilitate an adequate understanding of the .

Skagit Valley geology and seismology. Witnesses Stepp, Ryan and Loveseth are not employees of the U.S.G.S., and will require formal subpoenas. As specified in 10 CFR Sec. 2.720(a), a showing of general relevance is included.

1. Carl Stepp Dr. Stepp is the chief geologist Fugro, Inc., Consulting for the advisory report to Seattle Engineers & Geologists City Light on the Copper Creek Dam.

3777 Long Beach Blvd. The relevence of this report is -

Long Beach, CAL outlined in the prefiled testimony of Dr. Cheney. Briefly, the report predicts ground motions of .7g from an event similar to the 1872 earthquake.

2. Dr. Barry Ryan Dr. Ryan has worked on the Canadian Geophysics Department portion of the Straight Creek -

University of British Fraser River Fault Zone. He has Columbia evidence that this fault cuts the Vancouver, B.C. Chilliwack Batholith and may well Canada be active.

3. Timothy Loveseth Mr. Loveseth has evidence that the Narmco, Inc. Devil's Mountain fault is a major 10546 West Sundance fault and that it is connected to Mt. Littleton, Colorado the Leech River fault on Vancouver Island.

4. J.C. Savage Dr. Savage is the authority on the U.S. Dept. of Interior 1946 earthquake. He has information Geological Survey which suggests with a 99% confidence 345 Middlefield Rd. level that surface deformation exists Menlo Park, CAL 94025 as a result of this earthquake.

Compare the U.S.G.S. review team position, that no evidence exists to suggest that the 1946 earthquake is shallow.

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Valentine B. Deale, Esq., Chairman Atomic Safety and Licensing Board October 25, 1979 Page Three

5. C. Wentworth Dr. Wentworth is in charge of U.S. Dept. of Interior neotectonic analysis of Washington.

Geological Survey He is fdmiliar with the standards 345 Middlefield Rd. for neotectonic mapping, standards Menlo Park, CAL 94025 which SCANP contends have not been met.

6. David L. Jones Noted authority on West Coast U.S. Dept. of Interior geology and tectonics.

Geological Survey 345 Middlefield Rd.

Menlo Park, CAL 94025

7. D. M. Boone Seismologist, senior author of U.S. Geological Survey U.S.G.S. Circular 795 that evaluates 345 Middlefield Rd. strong ground motion of earthquakes.

Menlo Park, CAL 94025 He has concluded that 0.35 is commonly exceeded by nearby earth-quakes.

8. C. Blake Ex-branch chief of Western Environ-U.S. Dept. of Interior mental Geology for U.S. Geological Geological Survey Survey. He has expressed grave 345 Middlefield Rd. doubts over the validity of con-Menlo Park, CAL 94025 cluding that 0.35g is an appropriate level for the safe shut-down earth-quake at the Skagit Plant.

Respectfully-

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ROGER M. LEED Counsel for SCANP jk ec. Service List

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