ML20024A028
| ML20024A028 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 06/09/1983 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-CPA, NUDOCS 8306150302 | |
| Download: ML20024A028 (5) | |
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ATE.D COmuf.woNDED UNITED STATES OF AMERICA 00CKEJ,E0 NUCLEAR REGULATORY COMMISSION BEEQBE_IBE_6IQBIC_g6EgIY_6NQ_LICEN@INQ_@Q6BD 3 Ju:113 P3:37 In the Matter of
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y WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Docket No. 50-460CPA et. al.
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(WPPSS Nuclear Project No. 1)
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QQ6LIIIQ8_EQB_g6Eg_BQWEB_EIB@I_gEI_QE_INIEBBQQ6IQBIE3 19_EBC_gI6Ert_gggg_gz_Ig833 INTERROGATORY 1: Stato the full name, address, occupation and employer of each person answering the interrogatories and designate the interrogatory or the part thereof he or she answered.
INTERROGATORY 2: Identify each and every person you are considering calling as a witness in the event a hearing is held in this proceeding and with respect to each of these witnesses:
a.
State the substance of the facts and opinions to which the witness is expected to testify:
b.
Give a summary of.the grounds for each opinion; and' c.
Describe the witnesses' educational and professional background.
INTERROGATORY 3: What is the complete basis for your position that Licensee's decision in April,1982 to ' defer" construction for two to five years, and subsequent cessation of construction at WNP-1 was not " dilatory."
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INTERROGATORY 4: Please explain fully what you mean by the word " defer" INTERROGATORY 5: Please explain fully what you mean by the word " dilatory" l
INTERROGATORY 6: What is the basis for your response to interrogatories 4 and 5?
l INTERROGATORY 7: Why do you contend that Licensee has l
estcblished good cause for an extension of the WNP-1 l
construction permit?
Explain your answer fully.
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INTERROGATORY 8: What are the reasons Licensee offered to NRC in support of a showing of " good cause" as required
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INTERROGATORY 9: Is it your position that the reasons l
offered by Licensee to support a showing of good cause are
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in fact'the only reasons why Licensee had requested an extension of its construction permit?
INTERROGATORY 10: If your response to Interrogatory 9 is no, state all other reasons.
INTERROGATORY 11 : What is the basis for your response to interrogatories 9 and 10?
INTERROGATORY 12: Please explain fully what you mean by a " reasonable period of time" INTERROGATORY 13: What factors do you contend should be condidered when determining if a requested construction permit extension is for a " reasonable period of time"?
INTERROGATORY 14: What do you contend would constitute a
" reasonable period of time" in the case of WNP-1?
INTERROGATORY 15: (a) Is it your position that BPA support is necessary to the financing of WNP-17 (b) if your answer to Interrogatory No. 15(a) is in the affirmative, identify and giv e full details with respect to all information upon which you base that statement.
INTERROGATORY 16: Is it your position that the financial support or lack of financial support by BPA for WNP-1 would have an effect on the financing costs of WNP-17 INTERROGATORY 17: Is it your position that the opinion of BPA as to when WNP-1 should go into commerical operation would have an effect on the financing costs of WNP-17 INTERROGATORY 18: (a) Is it your belief that BPA has the authority to disapprove any further financing of WNP construction?
(b) If your answer to Interrogatory No. 18(a) is in the affirmative, explain fully the factual basis for that statement.
INTERROGATORY 19: Is it your position that the growth rate of electric power requirements has a business relationship as to when WNP-1 should go into commercial operation?
INTERROGATORY 20: (a) Is it your position that the January 11, 1983 letter to H, Denton, Director, NRR, NRC from G.D.
Bouchy, WPPSS, supports Permittee's assertion that a deferred need for power constitutes " good casue" for deferring construction?
(b) If your answer to Interrogatory No. 2O(a) is in the affirmative, set forth and explain fully the factual basis or legal authority for your position.
INTERROGATORY 21: (a) Is it your position that a lack of need for power can, as a matter of law, constitute "scod
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cause" under 10 CFR 50.55(b)?
(b) if your answer to Interrrogatory No. 21(a) is in the affirmative, set forth and explain fully the factual basis or legal authority for this position.
INTERROGATORY 22: (a) Does the lack of need for power in the Northwest justify deferring construction of WNP-17 (b) Explain fully your answer to Interrogatory No.
22(a).
INTERROGATORY 23: Explain the factual basis and/or legal authority which supports tha position that six to nine years is a ' reasonable period of time' under 10 CFR 50.55(b).
INTERROGATORY 24: What do you believe would be a (maximum) reasonable period of time for extension of the construction completion date for WNP-17 INTERROGATORY 25: (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 fully how each of the requirements identified in response to Interrogatory No. 25(a) will delay completion of the plant beyond the requested completion date of 1991.
Give full details as to the extend to delay attributable to each such requirement.
INTERROGATORY 26:
Explain the difference, if any, between deferral, mothball and preservation.
INTERROGATORY 27:
To what events is the restart of construction on WNP-1 tied. Explain fully your answer.
INTERROGATORY 28: What would be the effect of default on WNP-4 and 5 on the restart and completion of WNP 1?
Provide all probability analyses, scenarios and time predictions.
INTERROGATORY 29:
What is the effect of deferral of construction on WNP-3 on the restart and completion of WNP-1? Give the basis for your response.
INTERROGATORY 30:
What is the effect of bond ratings on WPPSS ability to finance WNP-1. Explain fully and provide the basis for your response.
i INTERROGATORY 31:
If a bond rating service refused to rate WPPSS bonds would WPPSS be able to finance the constru'etion of WNP-17 Explain your answer.
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INTERROGATORY 32: Is it your position that the Atonic l
Safety and Licensing Board Initial Decision (LBP-75-72, 2 NRC 922) for the Construction Permit found that the i
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Bonneville Power Adminstration had the power to approve or disapprove'the issuance of bonds by WPPSS. If yes give the reasons in detail for approval and/or disapproval.
INTERROGATORY 33: Is it your position the ASLB Initial y
Decision (LBP-75-72, 2 NRC 922) found that BPA could cor. trol the construction of WNP-1? If yes,.in what manner? Explain
.in detail the basis for your answer.
INTERROGATORY 34: Is it your position that the original finding by the ASLB in its Initial Decision (LBP-75-72, 2 NRC 922) on WPPSS financing ability remains valid?
Explain the basis for your answer in detail.
INTERROGATORY 35: Is it your position that the original finding by the ASLB in its Initial Decision (LBP-75-72, 2 NRC 922) on the need for WNP-1 remains valid?
Explain the
. basis for your answer in detail.
INTERROGATORY 36: Is it your position that the only reason the ASLB found WPPSS financially qualified is because of BPA financial backing?
(a) If yes, explain the basis in detail.
(b) If no, cite all the reasons you believe the finding of financial qualification.
INTERROGATORY 37: What constitutes " good business sense" in decisions on nuclear plant deferal?
INTERROGATORY 38: What constitutes "BPA support"?
INTERROGATORY 39: How is "BPA support" recognized in the Initial Decision (LBP-75-72, 2 NRC 922) on the Construction Permit for WNP-1?
INTERROGATORY 40: Is cost of financing an issue in this proceeding?
If so, why?
l INTERROGATORY 41: Is need for power an issue in this proceeding?
If so, what are the issues which should be litigated with regard to need for power ?
l TNTERROGATORY 42: What is the legal basis for your I
answer to Interrogatory 41?
INTERROGATORY 43: What, besides the Applicant's representation on the need for WNP-1, does the Staff rely upon for it position on the need for the plant?
INTERROGATORY 44: Was the construction of WNP-3 (Satsop) halted because of no need for its power?
(a) If so, how does this affect the five-year deferral of WNP-1?
(b)
If not, what were the reasons and how will they affect the deferral of WNP-1?
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INTERROGATORY 45: Is the ultimate cost of power fros WNP-1 a factor in the needefor the plant?
Should it be a factor in the business decisions affecting continued construction?
INTERROGATORY 46: What is the Staff's position on the relationship between time and the deterioration of partially constracted facilities and equipment?
Provide the basis for this position.
J INTERROGATORY 47: What is the difference between BPA withholding approval for financing and BPA disapproving of financing?
INTERROGATORY 48: What level of staffing is necessary at WNP-1 to maintain the construction site and equipment without deterioration ?
INTERROGATORY 49: Is it your position that the only obstacle to financing of the WNP-1 was/is the BPA recommendation?
INTERROGATORY 50: Do you agree that the passage of Washington Initiative 395 affected the ability of WPPSS to issue bonds?
Explain your answer fully giving the basis and identify all documents relied upon.
Respectfully submitted, C
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Dated this day, the 9th Rosol'ie, Director of June, 1983.
e e Coal tion ('or Safe Power