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Category:AFFIDAVITS
MONTHYEARML20023C6971983-05-12012 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
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
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
ML20063M2581982-08-27027 August 1982
Affidavit of Rv Myers Supporting Motion for Summary Disposition of Coalition for Safe Power Contention 26. Seismic Category I Electrical Equipment Will Be Qualified Per IEEE 344-1975 & Reg Guide 1.1.W/Certificate of Svc
ML20063H1111982-07-0909 July 1982
Affidavit of L George.Columbia River Inter-Tribal Fish Commission Does Not Represent Columbia River Treaty Tribes
ML19312E9321980-05-23023 May 1980
Affidavit in Support of Applicants' Reply Objecting to Skagitonians Concerned About Nuclear Power 800508 Motion to Dismiss Application.Explains Applicants' Efforts to Locate Suitable Site.Certificate of Svc Encl
ML19250C2921979-10-16016 October 1979
Affidavit Attesting That Time Schedule Re Expert Witness Presentations for Geology & Seismology Issues Is Impossible to Meet.Time Restraints Affect Quality of Preparation. Certificate of Svc Encl
ML19254D7271979-09-21021 September 1979
L Gittleman Affidavit,Correcting Typographical Error in Testimony Re Util Net Income for CY78.Net Income Changed from $26.1 Million to $36.4 Million
ML19254E9321979-09-13013 September 1979
Affidavit of JB Read on 790913 Re Recent A6 Aircraft Crash Experience.Crash Rate Was Conservative.Aircraft Hazards Need to Be Considered as Basis for Design
ML19259D6891979-08-30030 August 1979
Affidavit Attesting That Significant Design Change Must Be Made by Applicant,Contrary to Info Disclosed in Psar,Fes, SER & Hearing Transcripts.Certificate of Svc Encl
ML19224D7871979-07-0202 July 1979
Affidavit of Svc for Amend 14 to Application
1983-05-12
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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
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Text
,
- ': ~ 9/21/79 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PUGET SOUND POWER & LIGHT COMPANY, ) Docket Nos. STN 50-522 .
ET AL. ) STN 50-523
)
(Skagit Nuclear Power Project, )
Units 1 and 2) )
AFFIDAVIT OF LOUIS GITTLEMAN - CORRECTING TESTIMONY STATE OF MARYLAND ) SS CCUNTY OF MONTGOMERY )
I, Louis Gittleman, being duly sworn, depose and state:
I prepared " Supplemental Testimony of Louis Gittleman Regarding Financial Quali-fications" dated August 14, 1979, which was received into evidence in this pro-ceeding (Tr. 14, 625). On page 4 of that testimony, I constructed a chart which sets forth,the financial data for the Applicants in this proceeding for the year ending December '31,1978 which includes, among other factors, the net income of the utilities.
I have determined that the figure given on that chart for the net income of Puget Sound Power & Light Co., $26.1 Million, is incorrect. Due to a typo-graphical error that I did not detect at the time of the hearing, the correct figure of $36.4 Million is not reflected in the chart. The purpose of this affidavit is to correct the error, and to change the net income for Puget Sound Power & Light Co. to $36.4 Million. '
As I indicated, the incorrect figure was merely a typographical error in pre-paring the chart, and was not used in calculating the other figures on the chart.
Accordingly, the return on common equity, pre-tax coverage of long-term interest
$ bWf
'7"
2-charges, etc. are correctly indicated on the chart, and my conclusion regarding the ability of the Applicants to obtain 6 necessary funds to design and con-struct the Skagit facility is unchanged.
I hereby certify that the information in this affidavit is true and correct to the best of my knowledge.
%w~ '-nf f/ f< e e z wA-: : d :< ,
Louis Gittleman Subscribed and sworn to before me this <2/ Aday of September,1979
- l.Mi Notary (Public
, b. M
/ d My Commission Expires:
u I' 'i y [ v 9
. 3 360 t
e
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