ML19211A088

Reply in Opposition to Intervenor Forelaws on Board/Citizens for Safe Power Findings of Fact Re Alternative Sites & Postulated Accidents.Certificate of Svc Encl

ML19211A088
Person / Time
Site:	Skagit
Issue date:	11/30/1979
From:	Little D, Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19211A089	List: ML19211A088 ML19211A107 ML19211A112
References
NUDOCS 7912170020
Download: ML19211A088 (2)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION W BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

PUGET SOUND POWER & LIGHT ) Docket Nos. 50-522 COMPANY, et al. ) 50-523

)

(Skagit Nuclear Power Project, ) November 30, 1979 Units 1 and 2) )

APPLIC ANTS ' REPLY TO FOB /CFSP PROPOSED FINDINGS Th is is Applicants' reply to Intervenor FOB /CFSP's proposed findings of fact dated October 12, 1979 (FOB /CFSP Proposed Find ing s) .

The POB/CFSP Proposed Findings are confined to two sub-jects: (1) alternative sites and (2) environmental effects of postulated accidents. Both of these subjects are beyond the scope of FOB /CFSP's contentions. Board order dated May 26, 1976. Both of these subjects also lie outside the scope of the interest represented by FOB /CFSP, which is the interest of rate payers of Portland General Electric Company and Pacific Power &

Light Company. Id., pp. 2-3. The interest of a rate payer would encompass certain economic issues whereas the issues relating to alternative sites and the environmental effects of 1595 089 .

7912 170 g cc rcer b

accidents now sought to be addressed by FOB /CFSP are environ-mental issues. Accordingly, the FOB /CFSP prop'o sed findings should be rejected. Northern States Power Co. (Prairie Island Nuclear Generating Plant, Units 1 and 2) 8 AEC 857, 867 (1974).

With respect to the merits of the FOB /CFSP Proposed Find-i ng s , they are without merit, for the reasons stated in the r e levant sections of Applicants ' reply dated November 30, 1979 to the SCANP Proposed Findings. With respect to alternative sites, see Section H, Alternative Sites, of that reply, pp. 86 et seg. With respect to the ef fects of postulated accidents, see Section L, Effects of Postulated Accidents, of that reply, pp. 79 et seg.

DATED: November 30, 1979.

Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WII IAMS By _

F. Theodore Thomsen By 8146d 1 -

ou64as S. Little Attorn ys for Applicant 1900 Washing ton Building Seattle, Washing ton 98101 Phone (206) 682-8770 Of Counsel:

Lowen s te in, Newman, Re is ,

Axelrad & Toll 1595 090 1025 Connecticut Avenue, N.W.

Wa shing ton, D. C. 20036