ML20027B566

Response to First Set of Interrogatories.Certificate of Svc Encl

ML20027B566
Person / Time
Site:	Skagit
Issue date:	09/17/1982
From:	Cavanagh R AFFILIATION NOT ASSIGNED, National Resources Defense Council
To:	PUGET SOUND POWER & LIGHT CO.
References
NUDOCS 8209210292
Download: ML20027B566 (9)

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UNITED STATES OF AMERICA ED NUCLEAR REGULATORY COMMISSION-

-Y Y 20 gj;55 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 2

In the Matter of PUGET SOUND POWER & LIGHT

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COMPANI, et al.

Nos. STN 50-522, 50-523 (Skagit/Hanford Nuclear

).

,'DATE:

September 17, 1982 Project, Units 1 and 2)

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RESPONSE OF THE NATURAL RESOURCES DEFENSE COUNCIL TO APPLICANTS' FIRST SET OF INTERROGATORIES

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The Natural Resources Defense Council (NRDC) submits the following answers to Applicants' first set of interrogatories.

These responses were pre' pared by Ralph Cavanagh, attorney of record for NRDC in this proceeding, who affirms that all represen-tations herein are true and accurate to the best of his knowledge.

l Interrogatory 1

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Most of NRDC's bases for each contention admitted by the Licensing Board are identified in the Supplement to NRDC's Amended Petition for Leave to Intervene, filed with the Licensing Board and served upon Applicants on April 20, 1982 (hereinafter cited as "NRDC Con ntions").

Additional documents, not then available, either now provide or are expected to provide further support for NRDC's contentions.

These include:

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For contention 3, "The Applicants will not be able to market surplus output from the Skagit/Hanford Project outside the Pacific Northwest Region":

(3:1) California Energy Commission, Biennial Report IV (Electricity)' (to be published in January of 1983)

For contention 4, "Appliggnts' Application for Site Certification / Environmental Report does.n'ot adequately discuss reasonable alternatives to the Skagit/Hanford Nuclear Project":

(4 :1) Incorporates, by reference, documents cited above under " Contention 1," nos. 1:2 and 1:3 (4 : 2) Battel'le'Phcific Northwest Laboratories, Assessment of Electric Power Conservation and Supply Resources

~for the Pacific Northwest (sixteen volumes; June 1982)

Interrogatory 2 All bases identified above are documents.

Interrogatory 3 Each document has been cited in full, either in the response each.has been to Interrogatory 1 or in NRDC Contentions, supra; or will be published by the agency or organization specified as the author, and each should be readily available to Applicants.

There follows a brief description of the way each document identifed for the first time in-the response to Interrogatory 1 supports or is expected to support the contention to which it was referred See also NRDC Contentions, supra, for comparable in that response.

descriptions of the documents identified therein.

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(1:4)

BPA's " Role EIS" documents exhaustively the merits of a so-called "one-utility" planning concept, in which loads and resources are balanced on a regional basis, rather than district-by-district.

See, e.g.,

pp. iv-v.ii; and Sections III and IV.

(2:1)

All three of these documents contain, or are expected

. ' o contain, amply documented-estimates of regional demand growth t

that are substantially lower than those of the 'for'ecast's upon which Applicants rely.

(2:2)

This is the latest in a series of long-range forecasts prepared annually by the Pacific Northwest Utilities a body whose membership includes Applicants Conference Committee, and other Northwest utilities (see NRDC contentions, supra pp. 7-11).

At the hearing-stage, NRDC expacts to document both the internal inadequacies of this forecast and its manifest inconsistency with independent analyses that are entitled to greater deference from the NRC (items 1:1, 1:2, and 1:3 above).

(3:1)

The California' Energy Commission's Fourth Biennial Report is now being prepared, as required by Public Resources Code S 25309.

NRDC expects that report, which serves as the cornerstone of California energy planning, to reconfirm that the state does not need electricity from the Skagit/Hanford nuclear project to meet demand growth or reduce oil and gas consumption.

Obviously, as in the case of the Northwest Power Planning Council's plan, final conclusions about the report's implications must await its publication, now scheduled for January of 1983.

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of this response, many but not all volumes had been published; the Council expects to produce the full set by the end of September 1982.

In every volume we have been able to review, the Council's contractors have produced estimates of the potential for alternatives to Skagit/Hanford that substantially exceed those developed by Applicants.

E.g., Vol. I (residential sector conservation patential of4961averageMWinexistingandnewbdildings);Vol.

II' (commercial sector conservation potential of 731 average MW in existing and new buildings); Vol. VI (2610 MW net capacity for geothermal electricity, gqneration) ; Vol. X (potential contribution of wind energy exceeds 2200 MW of capacity and 770 average MW of energy by year 2000, at cost of less than 40 mills /kWh).

Interrogatory 4 Answered, to the extent relevant, under Interrogatory 3, above.

Interrogatory 5 Answered, to the extent relevant, under Interrogatory 3, above.

Interrogatory 6 We do not presently plan to rely on any of the sources specified in Interrogatory 6.

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NRDC reserves the right to call as additional witnesses staff members of the Bonneville Power Administration, the Northwest Power Planning Council, and the California Energy Commission, as well as one or more of the Washington state employees who authored Final Report to the Washington State Legislature:

Independent Review of Washington?Public Power Supply System Nuclear Plants 4 and 5' (March 1982)'.

'It is NRDC'.s position, however, thad the Licensing Board should independently solicit testimony on need for power issues from each.of these bodies, pursuant to the Board's duty to develop a complete record on questions vital to the outcome of this proceeding.

These are not partisan witnesses, but state and federal officials charged by law with assessing the very questions put to the Board by the National Environmental Policy Act and by NRDC's four contentions.

We stand ready to begin discussions with Applicants, NRC staff, the Board, and the other intervenors, aimed at reaching agreement (.1) on suitable BPA, Regional Council, California Energy Commissi>n, and Washington State. witnesses who should be subpoenaed to testify by the Board, and (2) on the appropriate scope of their testimony.

We do not believe that NRDC or any other intervenor should be required to solicit or' underwrite this crucial testimony, but if the Board disagrees, we reserve the right to make the attempt.

Interrogatory 8 NRDC presently intends to offer in evidence all the documents identified above in this response and in NRDC Contentions, E

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DATED:

September 17, 1982 1

Respectfully submitted, M

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Ralph.havanagh.

b Attorney for Natural Resources Defense Council 25 Kearny Street San Francisco CA 94118 Phone: (415)421-6561 l

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h hhED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.

OA920 g 35 BEFORE THE ATOMIC SAFETY AND LICENSING fi$fa RETAk v 0

In the Matter of BRA E6VIC; PUGET SOUND POWER & LIGHT

)

COMPANY, et al.

Nos. S7N 50-522, 50-523 (Skagit/Hanford Nuclear

)

Project, Units 1 and 2)

.)

CERTIFICATE OF SERVICE I hereby certify that the following:

1.

Response of the Natural Resource Defense Council to Applicants' First Set of Interrogatories; 2.

Natural Resources Defense Council's First Set of Interrogatories to Applicants 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 September 17, 1982 with proper:

postage affixed for first class mail.

DATED:

September 17, 1982 a

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Ralph Cavanagh

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Attorney for Natural Resources Defense Council, Inc.

25 Kearny Street San Francisco CA 94108 Phone: (415)421-6561 4

,e SKAGIT/HANFORD SERVICE LIST DATED:

September 17, 1982 COMMISSION Secretary of the Commission Attention Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington DC 20555 LICENSING BOARD l

John F. Wolf, Esq., Chairman 2,

Administrative Jtdge Atomic Safety and Licensing Board Panels 3409 Sheperd Street Chevy Chase MD 20015 Mr. Gustave A.

Linenberger Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington DC 20555 Dr. Frank F.

Hooper Administrative Judge Atomic Safety and Licensing Board Panel School of Natural Resources University of Michigan Ann Arbor MI 48190 NRC STAFF Richard L. Black, Esq.

J U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington DC 20555 i

APPLICANTS F. Theodore Thomsen Perkins,. Coie, Stone, Olsen & Williams 1900 Washington Building Seattle WA 98101 INTERVENORS Eugene Rosolie, Director Coalition for Safe Power Suite 527, Governor Building 408 S.W. Second Avenue Portland OR 97204 y-

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i James B. Hovis Yakima Indian Nation "C/6 Hovis',~Cockrill 5 Ro'y ~

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316 North Third Street P.O.

Box 487 Yakima WA 98909 Terence L. Thatcher, Esq.

National Wildlife Federation 708 Dekum Building 519 S.W.' Third Avenue Portland OR 97204' D

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