ML19256F840

Reply to Skagitonians Concerned About Nuclear Power 791109 Proposed Findings on Financial Qualifications.Intervenor Adopted short-term View Rather than long-term Considerations Re Inflation Rates & Market Ratios.Certificate of Svc Encl

ML19256F840
Person / Time
Site:	Skagit
Issue date:	12/05/1979
From:	Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7912260039
Download: ML19256F840 (4)

Text

. *$ ca -

/  %,/

// ,9; Y 'h l${} &# gh >.  :

h"" ' UNITED STATES OF AMERICA Ch ih> NUCLEAR REGULATORY COMMISSION

% T 6 e#

_3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 03 In the Matter of )

)

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

)

(Skagit Nuclear Power Project ) December 5, 1979 Units 1 and 2) )

)

APPLICANTS' REPLY TO SCANP PROPOSED FINDINGS ON FINANCIAL QUALIFICATIONS This is Applicants' reply to the proposed findings on financial qualifications filed by SCANP on November 9, 1979 (SCANP Proposed Findings) .

1. SCANP argues that the construction of Skagit will be delayed and that this will cause the cost of Skagit to exceed Applicants' estimate. SCANP Proposed Findings Nos.

3-5, pp. 2-3. Except for the possible effect of the cur-rent suspension of licensing, the points urged by SCANP were answered in Applicants' proposed findings on finan-cial qualifications filed October 8, 1979 (Applicants Pro-posed Findings).

2. As to the possible effect of the suspension, obviously the construction of Skagit will be delayed. How-ever, neither the extent of the delay nor the cost impact of the delay, if any, can be predicted at this time. The 1619 079 3912260cjf

speculations offered by SCANP on these matters provide no basis for any finding by the Board.

3. The remainder of the findings proposed by SCANP challenge the validity of Applicants' financial projec-tions. SCANP Proposed Findings Nos. 6-11, pp. 4-10.

The principal points urged by SCANP were answered in Applicants' Proposed Findings and in the findings pro-posed by the NRC Staff. However, one point warrants further comment.

4. Throughout its proposed findings, SCANP has taken a short term view, virtually ignoring the fact that the construction of Skagit, and the raising of funds for its construction, will extend over a period of years. For example, in the case of projected inflation rates, interest rates, ratios of market-to-book-value, and return-to-equity rates, SCANP has focused primarily on the present situation or most recent rates in criticizing Applicants' projections. This is an unsound approach, when the purpose is to judge the reasonableness of projections extending 10 or 12 years into the future, as here.

Tr. 14, 660-61; 14,674-75; 14,678-79; 14,922-24; 14,954-55; 14,984-86, 15,005.

DATED: December 5, 1979 1619 080 Respectfully submitted, PERKINS, COI , STONE, OLS & LIAMS

%y / ~ 11-6 1'1/ ,l4W'f '[.

F'. Theodore Thomsen Attorneys for Applicant 1900 Washington Building

,. Seattle, Washington 98101

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In une Matter of J

)

PUGET SOUND POWER & LIGHT COMPANY,) DOCKET NOS.

et al. )

) 50-522 (dxegib tiueleu2 towem rzcjacit  ; P;r?7 Units 1 and 2) )

)

CERTIFICATE OF SERVICE I hereby certify that the following:

APPLICANTS' REPLY TO SCANP PROPOSED FINDINGS ON FINANCIAL QUALIFICATIONS in the above-captioned proceeding have been served upon the persons shown on the attached list by depositing copies thereof in the United States mail on December 5, 1979 with proper postage affixed for first class mail.

DATED: December 5, 1979 R h Il

%f &t%

F. Theodore Thomsen Counsel for Puget Sound Power &

Light Company 1900 Washington Building Seattle, W2shington 98101 1619 081

Date: December 5, 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, WA 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 CFLP and r97 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. ?G55; b.e h -+ t bmenst;in, Una:

Lowenstein, Newman, Reid, Dr. John H. Buck, Member Axelrad & Toll Atomic Safety and Licensing 1025 Connecticut Avenue, N.W.

Appeal Board Washington, D. C. 20036 U.S. Nuc] ear Regulatory Commission Washington, D. C. 20555 Warren Hastings, Esq.

Associate Corporate Counsel Michael C. Farrar, Member Portland General Electric Company Atomic Safety and Licencing 121 S:W, Salmon Stro.ct Appeal Board Cartland, OP 9720s U.S. Nuclear Regulatory Commission Washington, D. C. 20S3$ James W. U d t aa..

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 Richard D. Bach, Esq. ~ '

Washington, D. C. 20555 (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 Port. land, OR 97204 Office of the Executive Legal Canadian Consulate General Director Donald Martens, Consul Washington, D. C. 20555 412 Plaza 600 6th and Stewart Street Nicholas D. Lewis, Chairman Seattle, WA 98101 Energy Facility Site Evaluation Council Patrick R. McMullen, Esq.

820 East Fifth Avenue Skagit County Prosecuting Attorney Ol) .apia , WA 98504 Courthouse Annex Mount Vernon, WA 9827.3 Tho.zas F. Carr, Esq.

Assistant Attorney General Temple of Justice Olympia, WA 98504 1619 082 8/22/79