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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
[Table view] 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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SEP 14197S >-- 4 Gk UNITED STATES OF AMERICA NUCLEAP, REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL B0 d In the Matter of )
PUGET SOUND POWER & LICLT ) DOCKET NOS. STN 50-522 COMPANY, r.t al., STN 50-523 _
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(Skagit Nuclear Power Proj ect, Augus t 30, 1979 Units 1 and 2) )
n/FIDAVIT OF DAVID STENSBY STATE OF WASHINGTON) ss COUNTY OF K I N G)
I, David Stensby, being first duly sworn, upon oath, depose and state as follows:
Tha: I live at 721 Lake Washington Boulevard South Seattle, hashington 98144 That frem May 1974 to January 1976, I was e= ployed by Engineer-ing Corpar tien of America, which provided engineers to Puget Pcwer on a temporary basis. I reported directly to Puge: Power Management and functioned in the sate nanner as c_ rect employees of that company. 7 was assigned to review the design of the Skagit Nuclear Power Projec:, nore specifically, the nechanical engineering of the Circulating Wa:er and the Slowdown Systems. As reflec:td in Section 9.2.12.2 of the ?SAR, 3echtel criginally designed the 31cwdown System ficw to be 1/11th of the Evaporation ra:e in :he Cooling Tewars. This .ould canse the Circulating Water System to opera:e at 12 cycles of concentration. Tha: is, any minerals found i212 136 7 9102602L 5 3
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i P102 DRl3hl in the =ake-up water from the Skagit River would be 12 times as concentrated in the c. culating water system. I understand that the zoning agree =ent between Puget Power and Skagit Cotmty reflects this limitation.
During the years 1974 and 1975, subsequent to printing of the PSAR and drafting of the zoning agreement, Dames and Moore perfo =ed an extensive water quality study. The results of this _
established that silica in the Skagit F.iver exceeded 10 ppm. Mith the original 12 cycle system, this would bring silica concentration above 120 ppm. This fact, when reviewed against Bechtel's cri-ginal design criteria, proved unacceptable.
I info =ed =y supewisor, who in turn relayed this info =ation to Bechtel's Proj ect Engineering Staff. I was info ced, by was of personal coc:=unication from =y supervisor, that Bechtel had agreed to redesign the system for 7 cycles of concentration.
The new design called fc,: a blowdown flow which is _/6 of the evaporation rate, or an 83". increase over the original design.
Section 9. 2.12.2 of the PSAR gives the =aximum rate of blowdown as 1400 gpm. This being equivalent t.c the original 12 cycle design, does not reflect the planned update.
The end result of the design change, on water discharged n the Skagit River, is an 83" increase in total heat content, and a similar increase in cuantity of chemicals, =ost notably chlorine ?
and residual chlorine.
In late 1375, I became privy to operating data for oil refiner-Les on the Skagit. This data led me to believe that not only 12 cycles of cencantration, but the revised design of 7 cycles of concentracien is unrealistically optomistic. S.ere are 1212 J37
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significant similarities between the cooling systems of the oil refineries and the :ioposed nuclear plant. Although the oil refineries =ake use of nalpful ch ma' additivas, precluded by Puget's above-=entioned zoc'.vg ag- ee=ent, they w v i having trouble operating at 7 cveles ;f co .tcration. Tnis infor=ation I then ec=municated to my superiors.
Shortly after my presenting the above information, .ly employ =ent at Puget Power was ter=in.ted. For this reason, I am not privy to the latest internal developments for design of the Circulating 'Jacer Systes and Slowdown System.
I can state that my recent review of the PSAR, Final Environ-mental != pact State =ent, Safety Evaluation Report, and transcripts of licensing proceedings has disclosed no indication whatsoever of the design change from 12 to 7 cycles of concentration.
In July 1979, I felt it =y duty to ce=municate this infor=ation to SCANP and its attorney, which I did, since I believe it important.
DATEb this 30 day of [k , 1979.
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h- i-DArd STE.NS3? , g s
SU3SCRI3ED and S'40F3 to b fcre = this ,p">Way of
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. NOTA 43Y .UBLIC in and for the
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of 'Jashingten, residing at Adap ,
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005-74 8/24/79 / 'S -
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& VYY$?* 6 UNITED STATES OF AMERICA Q NUCLEAR REGULATORY COMMISSION f ,gg {
BEFORE THE ATCMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
)
PUGET SOUND POWER & LIGHT ) DOCKET NOS. STN 5 0-522 COMPANY, et al., ) 50-523
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(Skagit Nuclear Power Project, )
Units 1 and 2) )
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CERTIFICATE OF SERVICE I tereby certify that copies of:
AFFIDAVIT OF DAVID STENS3Y m
dated Aueust 30, 1979, have been served on the folicwing by dep~ositing the same in the United States mail, pcstage
/2.
. prepaid, on this 6 day of Sectember , 1979.
Valentine B. Deale, Esq. , Chairman Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory
. Commission Commission 1001 Ccnnecticu t Avenue N.W. Washington, D .C. 20555 Washington, D .C. 20036 Richard L. Black, Esq.
, D r. Frank F. Hooper, Member Counsel for NRC Staf f .
Atomic Safety and Licensing Board U.S. Nuclear Regulatory School of Natural Rescurces Commission ,
University of Michigan Office of the Executive Legal :
Ann Arbor, MI . 48104 Director i
- Washington, D, C. 20555 Gustave A. Linenberger, Member Atomic Safety and Licensing Scard Nicholas D. Lewis, Chairman U.S. Nuclear Regulatory Energy F acility S ite Evalu ation Ccmmission Council
/~D Washington, D .C. 20555 820 East Fif th Avenue Olympia, Washington 98504 Certificate - 1 1212 J39
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. ?00R DMG Richard M. Sandvik, Esq., Russel W. Busch Assistant Attorney General Evergreen Legal Services Department of Justice 520 Smith Tower 500 Pacific Building Seattle, Washington 98104 520 S. W. Y amhill Portland, Oregon 97204 Thomas Moser Deputy Prosecuring Attorney Robert Lowenstein, Esq. Skagit County Courthouse Lowens tein, Newman, Reis & M t. Vernon, Washington 98273 Axelrad 1025 Connecticut Avenue, N.W. Warren Hastings Washington, D.C. 20036 Portland General Electric Co. -
121 S.H. Salmon S treet James W. D u rh am, Esq. TB 13 Portland General Electric Co. Portland, Oregon 97204 121 S.W. Salmon S treet TB 17 Portland,' Oregon 97204 CFSP and FOB E. S tachon & L. Marbet 19142 S. Bakers Ferry Road Boring, Oregon 97009 Canadian Consulate General Peter A. van Brakel Vice-Consul 412 Plaza 600 6th and S tewart S treet Seattle, Washington 98101 F. Theodore Thomsen Perkins, Coie, Stone, Olsen
& Willi ams 1900 Washington Building Seattle, Washington 98101 Alan P. O' Kelly Paine, Lowe, Cof fin, Herman
& O' Kelly 1400 Washington Trust Financial .
Center Scokane, Washington 99204 - ,
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