ML20023C374

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Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1
ML20023C374
Person / Time
Site: Skagit
Issue date: 05/12/1983
From: Cavanagh R
National Resources Defense Council
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8305170279
Download: ML20023C374 (2)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g, qQ,(V f f

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD hY

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STN 50-523 PUG SOUND POWER & LIGHT COMPANY, DATE:

May 12, 1983 I

(Skagit/Hanford Nuclear Project)

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INTERVENORS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION 1 1.

AS AN INDEPENDENTLY SUFFICIENT MATERIAL FACT, AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD:

The Northwest Power Planning Council has omitted the Skagit/Hanford Nuclear Project from the inventory of electrical energy resources recommended for acquisi-tion in its final Northwest Conservation and Electric Power Plan (April 1983).

2.

AS ADDITIONAL MATERIAL FACTS, AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD:

A.

The regional forecast commis~sioned in 1981 by the Washington Legislature concludes that, under the most likely rate of load growth, the need for new Northwest baseload generation (beyond plants currently under construc-tion) will be deferred beyond the end of this century if moderate levels of conservation savings are supplemented by moderate levels of renewable resource development and more use of combustion turbines and/or imports.

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The " base case" electricity demand projections in the regional forecast released by the Bonneville Power Adminis-tration in July of 1982 are substantially lower than those upon which applicants rely, and the latest available BPA analysis of the region's. resource needs defers new large-scale thermal resources until at least 2001.

C.

The regional forecast prepared in 1982 by the Natural Resources Defense Council concludes that the Northwest needs no new large-scale thermal power plants through the year 2005, even if five partially completed coal and nuclear units are terminated or abandoned.

1 Respectfully submitted, mAAo '

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Ralph w vanagh Attorney for the Natural Resources Defense Council, Inc.

25 Kearny Street San Francisco CA 94108 Telephone:

(415) 421-6561 4

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