ML19256E597
| ML19256E597 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 10/09/1979 |
| From: | Little D, Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7911080122 | |
| Download: ML19256E597 (15) | |
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/g C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOh BEFORE THE ATOMIC SAFETY AND LICEN: 3G BOARD In the Matter of )
PUGET SOUND POWER & LIGHT ) Docket Nos. 50-522 COMPANY, et al. ) 50-523
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(Skagit Nucle Jower Project, ) October 9, 1979 Units 1 and 2) )
APPLICANTS' REPLY TO SCANP'S MOTION FOR RECONSIDERATION DATED SEPTEMBER 27, 1979 On August 21, 1979, SCANP served certain discovery requests on Applicants, seeking information on various aspecto of the plant water systems. Applicants objected to the discovery re-quests as being untimely, as relating to matters on which the record had been closed, and as falling outside the permissible scope of discovery under 10 CFR 2.740(b).
Applicants' written objections were distributed to the Board and parties on August 27, 1.179, which was the first day of the most recent set of evidenti.iry hearings. Two days later, the Board solicited the comments of Applicants and SCANP 1294 293 h'
79 11 080
with respect to the dispute over SCANP's discovery requests.
During that discussion, SCANP's counsel explained that the dis-covery was sought in support of.a motion to reopen the record, which SCANP is considering. He further explained that SCANP would be offering an affidavit containing newly discovered in-formation in support of both its discovery requests and its contemplated motior. to reopen the record. He said that the affidavit would br. filed on August 30, 1979. Tr. 14,587-594.
On August 30, 1979, SCANP's counsel stated that the affida-vit would be circulated not on that day but on the following day, which was August 31, 1979. Tr. 15,043-46. However, 12 more days elapsed without the affidavit being circulated.
Finally, by letter dated September 12, 1979, SCANP served the affidavit of David Stensby (" Af fidavi t") , dated August 30, 1979, on the Board and the parties.
One day after the Stensby affidavit was mailed, the Board issued an order in which, among other things, it sustained Ap-plicants' objections to SCANP's discovery requests dated August 21, 1979. In so ruling, the Board noted that SCANP had twice indicated it would respond to Applicants' objections, but failed to do so.
By its motion dated September 27, 1979, SCANP requested the Board to reconsider its sustaining of Applicants' objections.
SCANP's justification was that the Board's order was issued 1294 294
prior to the Board's receipt of the Stensby affidavit. In this memorandum, Applicants respond to both SCANP's motion for re-consideration and the Stensby affidavit.
The motion for reconsideration should be denied because SCANP was given ample opportunity yet failed to file the Stensby affidavit in a timely fashion. SCANP first promised to file the affidavit on August 30, 1979. Tr. 14,589. That was not done. Next, they promised to file the affidavit on August 31, 1979. Tr. 15,043. That also was not done. The Board postponed issuance of any order on the matter for almost two more weeks, thereby giving SCANP full opportunity to reply to Applicants' obj ections. SCANP has provided no reason why the affidavit was .t filed as promised, even though the af-fidavit was signed on August 30, 1979. Therefore, the Board was fully justified in proceeding to decide the matter as it did.
Nevertheless, Applicants have reviewed the Stenbsy affida-vit and its contentions. The affidavit does not provide a basis for either SCANP's late discove.y request or SCANP's often discussed but unseen motion to reopen the record, which presumedly would relate to the subjects in the Stensby affidavit.
When it was first discussed, the Stensby affidavit was billed as providing " newly learned" and " newly discovered" in-formation. Tr. 14,589, 14,594. Stensby swears trat "in July 1294 295
1979, I felt it my duty to communicate this information to SCANP and its attorney, which I did, since I believed it important." Affidavit, p. 3.
The truth is that the affidavit does not present newly dis-covered information; Stensby's allegations were publicly voiced many months ago. On December 7, 1977, SCANP held a press con-ference to publicize Stensby and his allegations. SCANP's press release 1/ set forth in Attachment A hereto. Stensby made the same charges then that he now repeats in his affida-vit. The newspaper reports of Stensby's press conference in December 1977 are set forth in Attachment B hereto. He al-leged then, as he does nov, that the cooling system was de-signed for 7 cycles of concentration, and not for 12 cycles of concentration as Applicants had represented. Stensby neglected to mention in his affidavit the prior history of his allega-tions. Instead, he would have us believe that it was not until July 1979 that he communicated his "information" on the cycles of concentration to SCANP and its attorney.
The cycles of concentratu 4 question was raised by SCANP c.ven prior to Stensby's December 1977 press conference. More-over, this question has been thoroughly evaluated in this record. In its memorandum to the Department of Agriculture dated June 30, 1977, SCANP alluded to the possibility that a 12 cycle cooling system operation might not be feasible due to 1294 296
higher than expected mineral content in the makeup water. It alleged that the consequences would be an increase in the volume and temperature of the plant ef fluent. SCANP repeated this allegation in a letter dated November 1, 1977, to the As-sistant Secretary of the Department of Agriculture. Applicants replied to SCANP's memorandum and its letter by memoranda dated August 8, 1977, and December 23, 1977. Both the June 30, 1977 memorandum and the November 1, 1977 letter and Applicants' replies thereto were provided to the Board and parties by Ap-plicants at the time.
In response to these assertions by SCANP regarding the makeup water for the plant, the Board requested by its letter dated November 14, 1977, that Applicants and the Staff analyze and comment upon SCANP's assertions. Applicants respon63d by filing affidavits by Frederick C. Mikels and Keith E. Anderson on December 23, 1977. Both affidavits were received into evi-dence at evidentiary hearings held in June 1978, at which both Mikels and Anderson were extensively cross-examined. Follows Tr. 10,688, 10,735. The Staf f responded by filing on Febru-ary 17, 1978, a report by Schreiber, Zussman and Marmer. That report was received into evidence and those three witnesses were cross-examined during hearings held in July 1979. Follows Tr. 12,226.
1294 297
The Ste_sby affidavit raises once again the cycles of con-centration question that has been previously considered.
Stensby alleges that a water quality study by Dames and Moore in 1974 and 1975 established "that silica in the Skagit River exceeded 10 ppm," and as a result of that information, the sys-tem was redesigned f rom 12 to 7 cycles of concentration. Af-fidavit, p. 2. Stensby was referring to water quality data assembled by Dames and Moore f rom a six-month pumping test, which was conducted at the proposed Ranney Collector site between December 1974, and June 1975. The results of that test appear as Attachment B to Applicants' Memorandum dated August 8, 1977, which has previously been referred to. Those results show the mean silica concentration as 12.7 plus or minus 1.9 ppm.1 Stensoy errs, however, in claiming thct this test established silica concentrations for the Skagit River.
As explained by Mr. Mikels, ground water was pumped during the six-month pumping test because the drawdown during the test was not sufficient to overcome the ground water gradient toward the river. Mikels, follows Tr. 10,688, pp. 14, 15. Therefore, the six-month pumping test did not induce a flow of river water and sheds little light on the mineral content of water to be pro-duced by the Ranney Collectors.
1F or comparison, the water quality data collected by the USGS between 1959 and 1970 show that the mean silica concentra-tion for the Skagit River near Mount Vernon was about 6.3 ppm.
Environmental Report, Table 2.5-19.
1294 298 Extensive consideration has been given in this proceeding to the ratio of river water to ground water that the Ranney Collectors will produce. Applicants and Staff have separately determined that the composition of water will be approximately 90% river water and 10% ground water. Mikels, follows Tr.
3041, p. 3; Mikels, follows Tr. 10,688, pp. 2, 12, 13; Schreiber, et al., follows Tr. 12,226, p. 13. Therefore, the water quality of the makeup water should be quite close to that of river water.
Applicants plan to operate at 12 cycles of concentration based upon the conclusion that the makeup water composition will closely resemble that of the river water. Since this con-clusion remains sound, Applicants have made no change in their plans for operation of the Project. Contrary to what Stensby suggests, there has been no redesign for 7 cycles of concentra-tion. Stensby may be confusing the operational plans with the design of the size of the pipes, valves and pumps of the cool-ing water system. The latter have been conservatively over-sized to handle flow rates greater than will be encountered under the projected operating conditions. This is a prudent design practice. The operational plans remain unchanged at 12 cycles of concentration. Moreover, the NPDES permit for the project does not permit operation at less than 12 cycles of concentration. Exh. 57.
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DATED: October 9, 1979.
Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WILLIAMS By? /,j //
F. Theodore Thomsen Douglas S. Little Attorneys for Applicant 1900 Washington Building Seattle, Washington 98101 Phone (206) 682-8770 1294 300
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ATTACHMENT A F'W'Q,SK AGITONI ANS CONCERNEDDOX qP
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( The Skogit Nuclear Project is inadequately designed at present to meet Puget Power's obligations under its rezone ogreement with Skogit County. Specifically, in all of Puget's submissions to State and Federdi outhorities they have steadfastly, maintained that they con operate their Ronney well system and that the amounts of water to be taken and discharged were firm figures. These numbers are based upon the assumption that the cooling water for the reactors con be recycled up to 12 times without cousing scaling and other, problems in their heat exchange equipment. Based upon the following evidence, it appcors that Puget will not be able to concentrate the water more than 5 to 7 times, and this may cause them to eliminate the Ranney well system and take mere water directly from the river in order to meet the outfall temperature limitations.
Information from the local refineries shows that they con operate their cooling systems, which are very similar to Puget's, of only 8 to 9 cycles of concentration, and they use chemicals for treatment which Puget is not allowed to do, and they utilize purer water, both of which minimize the scaling problem. Therefore, on that basis alone it appears that Puget will not be able to use 12 cycles of concentration as planned. -
Additionally, evidence received in August of 1977 detailing several months of water quality collection also shows that the water quality from the Ronney wells will be different from that from the river, and will probably cause considerabic scaling problems at 12 cycles of concentration. This dato, collected by Puget from December 1974 to June 1975 has never been previously submitted in either State or Federal hearings, and the State hearings occupied 1294 301
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o period from early 1975 through early 1976. The only data that Puget has previously submitted is shown in ottoched Table C, which are three grob samples from the Renney wells. It is easy to see wh Puget withheld this information for so long since it shows conclusively that the water quality from the Renney wells has a much higher hardness then the river, increasing the likelihood of scaling problems The fact that this dato existed was brought to our attention by Mr. Stensky, a mechanical engineer whose former job with Puget Power consisted of reviewing the adequacy of the water system for.: ir project. .
To summarize, the data just released from Puget Power now shows that their Ranney well water somptes have hordness and silico contents, etc., roughly double that of the Skogit River itself, which is the sotrce for the Anacortes refineries. The refineries operate on this purer water and utilize some chemical treatment but con achieve only 8 to 9 cycles 6f concentration. Therefore, it is extremely doubtful that Puget will be able to operate at its officially projected 12 cycles of concentra tion. '
This will mean a much larger volume of hot blowdown from the cooling towers, which will raise the temperature of the effluent considerably, probably violating the temperature limitotions set by the' County rezone agreement and raising the possibility of greater fish kills. Puget's alternative is to obondon the Renney well system so they con take purer water directly from the river. However, in that event they would probably be limited to the some figures of concentration as the refineries.
Furthermore, this would mean a massive surface water intake system which would imperil yo fry being drawn into its inlet.
In summary, no matter which method Puget elects to try to solve their problem, it will mean a greater hozord to salmon in the river and will raise the outfall temperature. S.C. A. N. P. has brought these matters to the of tention of the Atomic Safety and Licensing Board, and a special hearin has been requested by Chairman Jensch.
1294 302
Skagit Valley F tid December 7, 1977 ATTACHMENT B Lpid cooObg M.p ~ ~ QpM.;Q Sr,". r.
water coming from these weils would be recirculated 12 times through the cooling fish population.
As a way of alleviating the problem.
dy L .. .Mh}p . h.4 p
I M system before being pumped back into the Carstens said Puget Power ma) drop the Ranney wells from its designs and elect to
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recirculation would result in less water draw its cooling water directly from the E.NM
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Skagit River.
Puget Power, however, has repeatedly '
.' ' 97 ' '$*/?w A 19 It was the recirculation cycle that came ruled out this possiblity.
In a report issued this summer, the
, f. 4', ' under attack yesterday.
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T '* I I." Dave Stensby, a mechanical engineer utility s' aid that SCANP's warning of a
. h formerly employed as a consultant by breakdown in the Ranney wells is " purely
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Puget Power to review the plants designs, said there were serious flaws in the speculative."
" Failure of the wells, however, is purely n%3d
@l. G Ranneywell ystem. speculative and contrary to the history of s'Qjg haw '
. He said Puget Power will not be able to successful operation with Ranney W fs iM- .
recirculate the cooling water 12 times as Collectors," the report states. "Moreover, Site Certification Agreement does not L
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g previously planned. The reason for this, he said, is due to higher concentrations of permit such an intake system (at the (M'.N-_q*\g~J f gQ8.@%i .
- . y minerals in the well water as opposed to Skagit River)...A surface intake is neither
- y. ; the water coming irom the Skagit River. proposed, nor being considered."
, N.' % D. .q/ Q] A table of test samples, taken during a The argument over the Ranney wells N 'O W p' six month period in IM5, indicate that the and the recirculation cycles has pasticular importance on the ruling by the
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~ kl Tjjbp'd c5g mineral content in the Ranney wells is nearly twice as high as the samples Department of Agnculture over whether t af 6y 6 , coming from the river, Stensby explained. the Skagit nuclear project will have r.ny
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,4, W his higher mineral content would mean adverse effect on the inclusion of the Skagit River into the federal Wild and that the plants could only recycle the y* 3.w 9 i r,LJdp hq" M#MM water about 7 times, he said, resulting in a Scenic Rivers System.
- > higher temperature of water being A ruling from the Secretary of dischargedinto the Skagit River. Agriculture is expected before the end of In January IN6, coinciding with his the year. For any construction to begin at RON CARSTENS discoveryof thisinformation,Stensby said the Bacus Hill site, Puget Power must first he was fired by Puget Power. get clearance from the Secretary.
BySPENCER HA'ITON The former diechanical engineer. ,
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StaffWriter however, said he was not aware that Puget _ __d BURLINGTON - Present designs for the cooling system at the proposed Skagit Pow er was withholding this information.
"Dunng my time at Puget Power, ! - hygg%Qh:%
^ py3Qwg nuclear power project will damage the didn't think that there was any cover-up," _
g i water quali;y of the Skagit River. said Stensby, who had worked for the L. y 'l' g g ge n 't4y;g.54 g -]
opponents of the twin-unit plant charged riy w _ f 3, .
Tuesday at a press conference here.
utihty for20 months.
Ron Carstens, former president of e M.;N 4 a
Criticism of the cooling system is SCANP, said that if Puget Power reduces ' @fr i 47. e < . U, -;'. ,
nothing new for Skagitonians Concerned the recirculation cycle, as Stensby Q }'!,N .C ..
About Nuclear Plants (SCANP). The anti- contends the utility will probably have to o /',j .. M 4 .i 1 nuclear group has repeatedly attacked do, the increased temperature of the c f j .
- - l Puget Sound Power and Light Company, discharge water will probably violate x ( i ,
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main sponsor of the nuclear project at temperature limitations set by Skagit [ j .. f N // W C' f( i Bacus Hill near Sedro Woolley, for the County's rezone agreement with Puget M ' k. N%L N M, W.#., t-4y -
utuity's failure to protect the nearby Power. -v' Skag:t River frem possible contamination'. He problem with the Ranney Wells, ', w b ![k ,f g %grg g; 7- g' Puget Power, on the other hand, has however, can be fixed Carstens admitted. >
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defended its plans, saying the cooling system for the 511 billion project falls well "It is fixable, but it creates new cost cycles," he said.
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within federal and county specihcations. Carstens said SCANP has sent the rew f S;n.
s.p. ,* M tJ-[ h g , ",
ne arguments, both pro and con, revolve around the Ranney well collectors table of figures to the Atomic Safety and Licensing Board for review. @'70..~
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eqa p designed for the plant's water cooling -
system.
The licensing board, which rules on all constmetion permits for nuclear power
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rods would be drawn from four Rannev possibility of contamination from the - ,
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well collectors, located about four mile's Ranney Well couectors. gf f above the plant and about 100 feet from the In July, the boaM ordered the Nuclear / w F ,5? I Skagit River. A Ranney well, named for its Regulatory Comn ission to make an in-inventor, is a wide shaft weU with finger depth study of the Ranney weu system. to 4 ' ' L pipes radiating into the w ater table. review specificauy the effects that the dqcq g to $ is r tt e water discharge might have on the river's DAVE STENSBY 1 e 1Mm 1294 303
ATTACHMENT B Post Intelligence-December 7, 1977
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.L See a Threat To the Skagit By Wayne Jacobi Opponents of Puget Sound Power & Light's proposed twin nuclear power plants in the Skagit Valley charged yesterday that " poor design" of the cooling towers will lower the water quality in the Skagit River.
John Ellis, Puget Power president, said the company is in " full compliance" with all laws governing the discharge of water into the river.
Larry Carstens, president of the Skagitonians Concerned About Nuclear Power, accused Puget of withholding water qualjty data for three years because it Nas very damaging."
Carstens and Dave Stensby, a mechanical engi-neer formerly employed by a consultant hired by Puget to review the design, said the original plans called for recirculating hot water through the cooling towers 12 times before discharging it back into the tiver.
That, Stensby said, waa based on the assump.
tion that the water from a system of wells , from which Puget intends to draw water to cool the hot reactor, was of about the same chemical content as the river itself.
It turns out, he added, that the well water has more minerals in it than the river. Minerals form scale and sediment in the cooling sys'em and could not be recirculated 12 tim (s without flush-ing.
Stensby said he brought this to the eneering staff's attention and that there was " verbal agree-ment" that seven cycles might be the maximum.
He contended that would raise the water tempera-ture of the discharge into the river.
Carstens said that v ould violate Puget's zoning agreement with Skagit County, which calls for a maximum pointof-discharge temperature of 73 degrees Fahrenheit.
Both the state and federal government licens-ing agencies have water temperature standards for nuclear power plants, with which Puget must con-form, in addition to the county ordinance.
Neither the state nor the federal Nuclear Regu-latory Commission has granted Puget a license for the project, estimated by Puget to cost $2.1 billion but which SCANP now says may cost $4.1 billion.
1294 304
Everett Herald December 7, 1977 ATTACHMENT B Wplad utility scoWed by foes Carstens said ibat if Puget could not re.
BY JOIIN WOLCOTT tycle its co ling water (used to condense B6slaess Editor steam that turns power generators in the plartt) :rp to 12 times it would be faced BURLINGTON "I don't think there with " expensive measures to change the was a cover up (at Puget Scund Power plant design ... or they might ask per-and Light Co.) ... but I think they should have made the information public," says mission to draw water off the surface of the Skagit River or dump hotter water David Stensby, a mechanical ei.gineer into the river."
fired nearly two years ago by Puget Drawitig water off 'he t - surface could kill Power.
He claims the company has withheld en-
- fish, small hesalmon said, and ruin future harvests of vironmental studies about its planned .
Sedro Woolley nuclear pwer plants. Carstens said the existence of the "with.
Company vice president Warren Fergu* held" information came from Stensby, who discovered it while reviewing the de.
son emphatically denies that charge , sign of the plant's cooling system for Pu-Stensby says his company supervisors did not share his concern that the plant get Power as an employee of Engineering Cep. of America.
would never be able to recycle its cooling water 12 times - as planned - without Ferguson, vice president in charge of clogging pipes with mineral deposits. the Skagit nuclear project for Puget Pow-Stensby talked at a press conference er, said Tuesdan
- There is no basis to Tuesday at First Federal Savings and the charges ... Stensby was let go be Iean in Bur!!ngton. It was called by foes cause he did not measure up to the qual.
of the nuclear plant. if cations we were looking for in He said he told his supervisors in m,d-i permanent engineering positions we were filling at that time."
1975 that tests had discovered twice .as much mineral content in water from test He said the company often hires engi-wells at the nuclear plant site as in Skagit neers under contract for short. term, peak work periods to meet deadlines with tech-River water. -
"Puget was maintaining at that time \ nical studies and other paperwork.
'that the well water they were going to use "He was not fired because of any differ-for cooling had the same amoung of min' ences of opinion on the plant design,"
erals as the river it would be discharged Fergusci said., acknowledging that into. My supervisors discussed my. views Stenst'. 'ad brought the water study to the setentiv . of Puget engineers.
- some of them even decided verbally Sansby, a 1972 gnduate of the Univer-that the water should only be recycled . sity of Washington, agreed that he and the seven times senior engineers looked at the same infor-
"But nothing was done about it and the information was never released to the mation and drew different conclusions. Ferguson said that more Nuclear Regu-regulatory agencies by Puget Power. I lie is now working' as a carpenter in latory Agency licensing board hearings Seattle.
told them in late December that refinertes are due on the plant in January and in Skagit County could not recycle cooling Ferguson said. "I'm confidant the wells March and that the chairman, Samuel water more than eight or nine times, even wtl work and that our riesign will meet Yensch, has said be wants to review the all state and federal and Skagit County re- water recycling issue during one of those using de. scaling chemicals Puget won't be quirements and standards able to use. hearings.
"Ott Jan. 2. I was fired because my files "We have never maintained that the Skagitonians Concerned About Nuclear were not being kept up properly. That's well water was purer than the river water. Power requested the NRC review of the is-what they told me," Stensby said. "The point is, we're committed to meet sue through its attorney, Roger Leed of temperature limits for the warm dis-Skagitonians Concerced About Nuclear charge water from the plant and mineral Seattle. SCANP has an official status as Power called the press conference to re* intervenor in all Skagit plant hearings ant real the " withheld" documents. content levels established by the regu- is represented by legal counsel at all latory agencies.
"We have 25 pages of water studies snat hearings.
se requested from Puget Power, through "That's what we Mll meet. We believe ge*Ve designed the facility to meet those the Nuclear Regulatory Agency. The stud. standards."
tes convince us the nuclesr plant at Sedro Ferguson discounted the suggestion that Woolley is inadequately designed " said Puget Power could have withheld any im-SCANP member ical engineer whoseRonald Carstens, company is baseda in chem- portant -information from regulatory Bellevue, agrncies, particularly on such a signift.
- cant issue as cooling water cycles and mineral content affecting both the plant and the river. i I 35
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PUGET SOUND POWER & LIGHT COMPANY,) DOCKET NOS.
et al. )
{ ) 50-522 (Skagit Nuclear Power Project, ) 50-523 Units 1 and 2) )
)
CERTIFICATE OF SERVICE I hereby certify that the following:
APPLICANTS' REPLY TO SCANP'S MOTION FOR
, RECONSIDERATION DATED SEPTEMBER 27, 1979 in the above-captioned proceeding have been served upon the 1
persons shown on the attached list by depositing copies thereof in the United States mail on October 9, 1979 with proper postage affixed for first class mail.
DATED: October 9, 1979 F.
J ,4 Theodore Thomsen
=um Counsel for Puget Sound Power &
Light Company 1900 Washington Building
, Seattle, Washington 98101 4
1294 306
,' Date: October 9, 1979 Valentine B. Deale, Chairman Robert C. Schofield, Director Atomic Safety and Licensing Board Skagit County Planning Department 1001 Connecticut Avenue, N.W. 218 County Administration Building Washington, D. C. 20036 Mount Vernon, RA 98273 Dr. Frank F. Hooper, Member Richard M. Sandvik, Esq.
Chairman of Resource, Ecology, Assistant Attorney General Fisheries and Wildlife 500 Pacific Building University of Michigan 520 S.W. Yamhill School of Natural Resources Portland, OR 97204 Ann Arbor, MI 48109 Roger M. Leed, Esq.
Gustave A. Linenberger, Member Room 610 Atomic Safety and Licensing Board 1411 Fourth Avenue Building U.S. Nuclear Regulatory Commission Seattle, WA 98101 Washington, D. C. 20555 CFSP and FOB Alan S. Rosenthal, Chairman Eric Stachon Atomic Safety and Licensing 2345 S.E. Yamhill Appeal Board Portland, OR 97214 U.S. . Nuclear Regulatory Commission Washington, D. C. 20555 Robert Lowenstein, Esq.
Lowenstein, Newman, Reis, Dr. John H. Buck, Member Axelrad & Toll Atomic Safety and Licensing 1025 Connecticut Avenue, N.W.
Appeal Board Washington, D. C. 20036 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Warren Hastings, Esq.
Associate Corporate Counsel Michael C. Farrar, Member Portland General Electric Company Atomic Safety and Licensing 121 S.W. Salmon Street Appeal Board Portland, OR 97204 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 James W. Durham Portland General Electric Company Docketing and Service Section 121 S.W. Salmon Street Office of the Secretary Portland, OR 97204 U.S. Nuclear Regulatory Commission s Washington, D. C. 20555 Richard D. Bach, Esq.
(original and 20 copies) Stoel, Rives, Boley, Fraser and Wyse Richard L. Black, Esq. 2300 Georgia Pacific Bldg.
Counsel for NRC Staff 900 S.W. Fifth Avenue U.S. Nuclear Regulatory Commission r an , OR 97204 Office of the Executive Legal Canadian Consulate General Director Donald Martens, Consul hashington, D. C. 20555 412 Plaza 600 6th and Stewart Street Nicholas D. Lewis, Chairman Seattle, WA 981C1 Energy Facility Site Evaluation Council Patrick R. McMullen, Esq.
820 East Fifth Avenue Skagit County Prosecuting Attorney Olympia, WA 98504 Courthouse Annex Thomas F. Carr, Esq.
Assistant Attorney General Temple of Justice Olympia, WA 98504 8/22/79