ML20024E999
| ML20024E999 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 09/06/1983 |
| From: | Reynolds N DEBEVOISE & LIBERMAN, WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | |
| References | |
| ISSUANCES-CPA, NUDOCS 8309080082 | |
| Download: ML20024E999 (6) | |
Text
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00CMETED USNRC 53 SB)-7 A9 :d9 e
UNITED STATES OF A'iERICA GFFICE OF SECREIAH '
NUCLEAR REGULATORY COMMISSION 00CKETitiG & SERVlf!
BRANCH BEFORE THE ATOMIC SAFETY E,'
AND LICENSING BOARD i
In'the Matter of '
)
)
WASHINGTON PUBLIC POWER
)
SUPPLY SYSTEM
) Docket No. 50-460 CPA
)
(WPPSS Nuclear Project No. 1)
)
LICENSEE'S ADDITIONAL RESPONSE TO INTERVENOR'S SECOND SET OF INTERROGATORIES On June 9, 1983, intervenor served the Washington Public Power Supply System (" Licensee") with a second set of interrogatoriec.
Licensee objected to interrogatories 19,'21, 22, 25, 27, 28, 31-35, 38, 42-45 and 47.
Intervonor subsequently moved to compel responses to interrogatories 25; 27, 28, 31, 32, 35, 38 and 42 and to compel a more complete response to interrogatories 26 and 50.
On August 15,.1983, the Licensing Board issued a Memorandum and Order granting the motion to compel answers l
to interrogatories 25, 27, and 28 and to compel a more t
i
'a 3.
-l4 complete response to interrogatory 26.
Applicant hereby y,,
j; provides its responses in accordance with the August 15, S
1983 Memorandum and Order.
INTERROGATORY 25:
Explain the difference, if any, between deferral, mothball and preservation.
8309080082 0
1)503
b
- R'sponse:
The Licensee does not as a matter of e
official policy distinguish between deferral, rothball and preservation.
However, as a matter of common usage,
" deferral" means postponed, " mothballed" means protected against the elements and other environmental conditions, and " preservation" means protecting against any peril or alteration.
INTERROGATORY 26:
To what events is the restart of construction on WNP-1 tied.
Explain fully your answer.
Response
The restart of construction on WNP-1 is tied to the ability of Licensee to finance construction of WNP-1.
As soon as an acceptable means of financing becomes available, construction of WNP-1 will be resumed.
A decision as to whether'such financing is available will be made by the Licensee based on sound business practice.
INTERROGATORY 27:
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.
Response
At the present time it is impossible to predict, and License has not evaluated, what would be the exact effect of default on WNP-4 and 5 on the restart and completion of WNP-1.
Licensee has not prepared any
3-s'enarios and time predictions assessing the
- analyses, c
effects of default on WNP-4 and 5 on the restart and com-pletion of WNP-1.
INTERROGATORY 28:
What is the effect of deferral of construction on WNP-3 on the restart and completion of WNP-l?
Give the basis of your response.
Response
The Licensee has not evaluated and therefore does not know what the ef fect of deferral of construction on WNP-3 would have on the restart and com-pletion of WNP-l.
I Respec f
y submitted, I
Nicholgs 1 Reynolds Sanfor< l L iartman DEBEVplSE
& LIBERMAN 1200 Livel eenth St.,
N. W.
Washington, D.
C.
20036 (202) 857-9817 Counsel for Licenseo September 6, 1983 i
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Telecopy Facsimile STATE F lASHimiTON
)
)
C0lMIT T BENTON
)
A.G.Hasler,beingdulysworn,disposesandsays:
That he is Project Licensing Manager, WNP-1, for the Washington.
PublicPowerSupplySystem,andknowsthecontentsoftheforegoing Licensee's Additional Response to Intervenor's Second Set of Inter-rogatories;thatthesameistrueofhisownknowledgeexcept as to matters therein stated oli infernation and belief, and as tothat,hebelievesthemtobetrue.
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Sworntoandsubscribed foreme 4 ay o 1983.
on this 4 d
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F'NotaryPublic
$!YI' d' bM M352.
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$3 m
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k UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
WASHINGTON PUBLIC POWER
)
Docket No. 50-460-CPA e
SUPPLY SYSTEM
)
)
(WPPSS Nuclear Project No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the ' foregoing
" Licensee's Additional Response.to Intervenor's Second Set of Interrogatories" in the captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid, this 6th day of September, 1983:
Herbert Grossman,-Esq.
Chairman, Atomic Sa fety and Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S.
Nuclear. Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Mitzi A. Young, Esq.
]
Mr. Glenn O.
Bright Office of the Executive Atomic Safety and Licensing Legal Director Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Chairman, Atomic Safety and Dr. Jerry Harbour Licensing Board Panel Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Commission W shington, D.C.
20555 U.S.
Nuclear. Regulatory a
Commission Washington, D.C.
20555
e 4 -
Mr. Gerald C.
Sorensen Nicholas D.
Lewis, Chairman Manager of Licensing Energy Facility Site Washington'Public Power Evaluation Council Supply system State of Washington 3000 George Washington Way Mail Stop PY-11 Richland, Wa shington 99352 Olympia, Washington 98504 Mr. Scott W.
Stucky Mr. Eugene Rosolie Docketing & Service Branch Coalition for Safe Power U.
S.
Nuclear Regulatory Suite 527 Commission 408 South West 2nd Washington, D.
C.
20555 Portland, Oregon 97204 Y
& 89 I ib Sanfpd L.
Hartmah i
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