ML19312E932

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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
ML19312E932
Person / Time
Site: Skagit
Issue date: 05/23/1980
From: Mecca J
PUGET SOUND POWER & LIGHT CO.
To:
Shared Package
ML19312E930 List:
References
NUDOCS 8006180185
Download: ML19312E932 (6)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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,

)

May 23, 1980 Units 1 and 2)

)

AFFIDAVIT OF JAMES E. MECCA STATE OF WASHINGTON)

)

ss.

COUNTY OF KING

)

I, James E. Mecca, being first duly sworn, on oath depose and say:

1.

I am Manager of Nuclear Licensing and Safety for Puget Sound Power & Light Company.

I have held this position since October 1, 1975.

I have testified in this proceeding on several occasions.

My most recent testimony was given on July 19, 1979 (follows Tr.12,362) and on July 30, 1979 (Tr.

13,917-933).

As Manager of Nuclear Licensing and Sarety, I have personal knowledge of all matters referred to in this 8006180\\t5 g

affidavit, including the efforts of Applicants to locate a suitable site for the Skagit Project on the Hanford Reservation in the State of Washington.

I am submitting this affidavit in support of Applicants' Reply In Opposition to SCANP's Motion to Dismiss the Application.

2.

APE licants have to date expended more than $250 million on the Skagit Project.

Since the ASLB conference of January 22, 1980, Applicants efforts with respect to the Skagit site have included Puget's letter of February 15, 1980 to the NRC Staff seeking clarification from the Staff of the requests for additional information that accompanied the Staff's letter of January 8, 1980, and several discussions of the these matters with the Staff.

Additional discussions are anticipated prior to issuance of any Staff response.

Our efforts also include the preparation by Dr. Dobrin, who has testified in these proceedings on behalf of Applicants on several occasions on geophysical matters, and whose reports appear in the PSAR, of a new report evaluating once again all seismic profile lines in the Northern San Juan Islands.

This report is expected to

)

shed further light on the Staff's requests.

Additionally, our geologists are field checking various features in the vicinity of the Skagit site to aid us in responding to the Staff's requests. -.

3.

As stated in Applicants' status report of April 14, 1980 to the Board, in parallel with our efforts with respect to the Skagit site, Applicants are considering the possiblity of amending their application in this proceeding to change the proposed site of the Skagit Project to a site on the Hanford Reservation in the State of Washington.

In fact, since January 1, 1980, Applicants have expended approximately $1.8 million in their efforts to locate a suitable site for the Skagit Project on the Hanford Reservation.

These efforts have included substantial field work by our geology consultants and our geophysical consultants.

This field work has involved considerable drilling, as well as magnetic and gravity mapping and seismic profiling.

(The ash from the eruption of Mount St.

Helens has brought this field work to a temporary halt.)

Additionally, our work to locate a suitable site at Hanford has included a review of the pertinent data assembled by others, not only with respect to geology and seismology, but also with respect to other site suitability and environmental subjects.

4.

We had hoped to complete our present program and be in a position to identify a suitable site for the Skagit Project on the Hanford Reservation by the end of May 1980, so as to permit a decision to be made on the question of amending the application to change sites.

It now appears t6at a few more l -

o n

weeks will be required to complete this effort, which is being pursued as vigorously as possible under the present circumstances, r > /E44 L.,

L'(A JAMES E. MECCA SUBSCRIBED AND SWORN to before me this jj day of May, 1980.

0 f

~ &.

4 Notary rablic in and for the Sgge of Washington, residing at M_ M m_ 1

! l

mn UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFOI.3 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:

1.

APPLICANTS' REPLY IN OPPOSITION TO SCANP'S MOTION TO DISMISS THE APPLICATION 2.

AFFIDAVIT OF JAMES E. MECCA 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 5/23/80 with proper postage affd.,ed for first class mail.

DATED:

May 23, 1980

)

dJff=

F. Theodore Thomsen Counsel for Puget Sound Power &

Light Company 1900 Washington Building Seattle, Washington 98101

Datas 5/23/80 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 W shington, 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 A':bar, 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.

Ealmon 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, C.

C.

20555 Richard D. Bach, Esq.

(original and 20 copies)

Stoel, Rives, Boley, Fraser and Wyse Richard L.

Black, Esq.

2300 Jeorgia Pacific Bldg.

Counsel for NRC Staff 900 S.W. Fifth Avenue r

an, OR 97204 U.S. Nuclear Regulatory Commission 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 Olympia, WA L98504 Courthouse Annex M3unt Vernon, WA 98273

-Kevin M.

Ryan, Esq.

Atsistant Attorney General Temple of Justice Olympia, WA 93504 12/6/79