ML20023B450
| ML20023B450 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 05/04/1983 |
| From: | Wagner M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| References | |
| ISSUANCES-CPA, NUDOCS 8305050082 | |
| Download: ML20023B450 (8) | |
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May 4, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM Docket No. 50-460 CPA (WPPSS Nuclear Project No.11
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NRC STAFF'S FIRST SET OF INTERROGATORIES AND FIRST DOCUMENT PRODUCTION REQUEST TO COALITION FOR SAFE POWER In accordance with 10 CFR Sections 2.740, 2.740b and 2.741, the NRC Staff hereby serves the Coalition for Safe Power (CFSP), as an intervenor in the above-captioned proceeding, with the following interrogatories and request for production of documents. These interrogatories and document request relate to CFSP Amended Contention No. 2, as admitted in the Licensing Board's Memorandum and Order (Admitting Intervenor and Contentions) dated March 25, 1983.
Each interrogatory shall be answered separately and fully in writing under oath or affinnation, and shall include all pertinent information available to CFSP, its officers, directors, members, employees, advisors, or counsel, based upon the personal knowledge of the person answering. Answers to these interrogatories are required to be served upon all parties to the proceeding within 14 days after service of the interrogatories. By each request for production of documents, the NRC Staff seeks to inspect and copy pertinent documents g
which are in the possession, custody or control of CFSP, its officers, directors, members, employees, advisors or counsel.
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As used herein, the term " documents" shall include any writings, drawings, graphs, charts, and schedules, however produced; photographs or other pictorial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
Each interrogatory should be answered in six parts as follows:
(1) Answer the direct question asked or provide the information requested.
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(2) Identify fully any documents (a) used as the basis for the answer to the interrogatory or (b) related to the subject of j
the interrogatory upon which you intend to rely in establishing the contention.
(3) Give the name, address, occupation and employer of the person or persons (a) answering each interrogatory, or (b) who have served, presently serve, or it is anticipated will serve as consultants or advisors to CFSP on the subject matter of the interrogatory.
(4) Identify each person whom you expect to call as a witness to testify at the hearing as to the issue addressed in the pertinent interrogatory. As to each such person, please state (a) the subject matter of his or her testimony and (b) the substance L
of the testimony and (c) the witness' professional or other qualifications to testify on the subject matter on which the witness expects to testify.
(5) Is the answer based on a calculation? If so, describe (a) the calculation, (b) identify any documents setting forth such calculation, (c) identify the person who performed each calculation, (d) when it was performed, (e) each parameter used in such calculation, each value assigned to the paramete.'s, and the source of your data, (f) the results of each calculation, and (g) how each calculation provides basis for the answers.
(6) Is the answer based on conversations, consultations, correspondence or any other type of communications with one or more individuals? If so, (a) identify each such individual by name and address, (b) state the educational and professional background of each such individual, (c) describe the information received from such individual and its relation to your direct answer (d) identify each writing or record related to each such conversation, consultation, correspondence or other communication with such individual.
Lam 3-In addition, CFSP is requested, pursuant to 10 CFR Section 2.740(e),
to supplement its responses as necessary with respect to the identity of each person expected to be called as an expert witness at the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance of such testimony. Similarly, CFSP is requested to amend its responses if CFSP subsequently learns that any response made to the interrogatories herein was incorrect when made, or that the response though correct when made is no longer correct.
INTERROGATORIES Interrogatory 1 Explain fully the relationship between your statement that the decision to defer construction of WNP-1 for a two-to-five year period was "made upon reviewing the recommendations of the Bonneville Power Administration (BPA), reviewing alternative proposals and taking public comment" and your contention that Permittee's decision to defer construction was " dilatory" and without " good cause."
Interrogatory 2 (a) Is it your position that the Permittee was " dilatory" in not notifying the NRC on or about April 29, 1982 that it was modifying its request for a completion date from 1986 to 1991?
(b) If your answer to Interrogatory No. 2(a) is in the affirmative, explain fully the basis for that statement.
Interrogatory 3 (a) Is it your position that BPA support is not necessary to the financing of WNP-17 (b) If ycur answer to Interrogatory No. 3(a) is in the affirmative, identify and give full details with respect to all information upon which you base that statement.
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. D (c) If your answer to Interrogatory No. 3(a) is in the affimative, explain fully how the financing of WNP-1 could be accomplished if BPA were to disapprove any further financing of WNP-1 construction.
Interrogatory 4 Is it your contention that the financial support or lack of financial support by BPA for WNP-1 would have no effect on the financing costs of WNP-17 Interrogatory 5 Is it your contention that the opinion of BPA on the PNYCC as to l
when WNP-1 should go into commercial operation, would have no effect on the financing costs of WNP-1?
Interrogatory 6 (a) Is it your statement that BPA does not have the authority to disapprove any further financing of WNP-1 construction?
(b) If your answer to Interrogatory No. 6(a) is in the affirmative, explain fully the factual basis for that statement.
Interrogatory 7 Is it your contention that there has not been a slowing in growth rate of electric power requirements in the Pacific Northwest?
Interrogatory 8 l
Is it your contention that the growth rate of electric power requirements in the Pacific Northwest has stopped or will stop completely before 1991?
Interrogatory 9 Is it your contention that the growth rate of electrical power requirements has no business relationship as to when WNP-1 should go into commercial operation?
Interrogatory 10 (a) Is it your statement that the January 11, 1983 letter to H. Denton, Director, NRR, NRC, from G.D. Bouchey, WPPSS, does not support
Permittee's assertion that a deferred need for power constitutes " good cause" for deferring construction?
(b) If your answer to Interrogatory No.10(a) is in the affirmative, set forth and explain fully the factual basis or legal authority for your statement.
Interrogatory 11 (a) Do you contend that s deferred need for power cannot as a matter of lawconstitute"goodcause"under10CFRl50.55(b)?
(b) If your answer to Interrogatory No.11(a) is in the affirmative, set forth and explain fully the factual basis or legal authority for this contention.
Interrogatory 12 (a) Do you claim that the actual deferral in the need for power in the Northwest United States does not justify deferring construction of WNP-1?
(b) Explain fully your answer to Interrogatory No.12(a).
(c) If your answer to Interrogatory No.12(a) is in the affirmative, state the relevance of your statement that " Petitioner... does not believe the power from WNP-1 will ever be needed?" to your claim that need for power in the Northwest United States does not justify deferring construction of WNP-1.
Interrogatory 13 l
i What is factual basis for your statement that " Petitioner... does not believe the power from WNP-1 will ever be needed"?
Interrogatory 14 Is it your contention that if and when WNP-1 is completed and ready to operate, it will not be operated because there would be no need for the power?
I Interrogatory 15 What factors do you contend are relevant in assessing whether power from WNP-1 will ever be needed?
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l Interrogatory 16 that "[ plain the factual basis and/or legal authority for your statement Ex s]ix to nine years cannot have been contemplated as a ' reasonable period of time' by the writers of 10 CFR 50.55(b)."
Interrogatory 17 What do you contend would be a reasonable period of time for extension of the construction completion date for WNP-17 Interrogatory 18 (a) Identify any and all " requirements of any regulations" promulgated since the date of docketing of the WNP-1 operating license application from which WNP-1 would otherwise be grandfathered by virtue of its date of docketing.
(b) Explain full how each of the requirements identified in response to Interrogatory No.18(y) will delay completion of the plant beyond the a
requested completion date of 1991. Give full details as to the extent of delay attributable to each such requirement.
REQUEST FOR DOCUMENTS Pursuant to 10 CFR Section 2.741, the NRC Staff requests you to make available for inspection and copying at a time and location to be designated any and all documents, nf whate>er description, identified in the responses to the above Staff interrogatories, including, but not limited to:
(1) any written record of any oral communication between or among Intervenor, its advisors, consultants, agents, attorneys, and/or any other persons, including but not limited to the Permittee, and its advisors, consultants, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letters, memoranda, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.
If CFSP maintains that some documents should not be made available for inspection, it should specify the documents and explain why such are not
being made available. This request extends to any such document, described above, in the possession of CFSP, its advisors, consultants, agents, or attorneys.
Respectfully submitted,
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MaryE[ Wagner I CounseY for NRC Staff Dated at Bethesda, Maryland this 4th day of May, 1983 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of WASHINGTON PUBLIC POWER SUPPLY SYSTEM Docket No. 50-460 CPA (WPPSS Nuclear Project No.1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST SET OF INTERROGATORIES AND FIRST. DOCUMENT PRODUCTION REQUEST TO COALITION FOR SAFE POWER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 4th day of May, 1983:
- Herbert Grossman, Chairman Gerald C. Sorensen Administrative Judge Manager, Licensing Programs Atomic Safety and Licensing Board Washington Public Power Supply System U.S. Nuclear Regulatory Comission 3000 George Washington Way Washington, DC 20555 Richland, Washington 99352
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- Mr. Glenn 0. Bright
- Atomic Safety and Licensing Administrative Judge Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 i
Washington, DC 20555
- Atomic Safety and Licensing Appeal
- Dr. Jerry Harbour Board Panel Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Comission Washington, DC 20555
- Docketing & Service Section U.S. Nuclear Regulatory Comission Nicholas S. Reynolds Washington, DC 20555 Debevoise & Liberman 1200 Seventeenth Street, NW Nicholas D. Lewis, Chairman Washington, DC 20036 State of Washington Energy Facility Site Evaluation Eugene Rosolie Council Coalition for Safe Power Mail Stop PY-11 Suite 527 Olympia, Washington 98504 408 South West Second Street Portland, Oregon 97204 f;h, YAD i
Mary E 4fagner
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Couns for NRC Staff
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