ML20028B897

Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence

ML20028B897
Person / Time
Site:	Skagit
Issue date:	12/01/1982
From:	Thatcher T NATIONAL WILDLIFE FEDERATION, OREGON ENVIRONMENTAL COUNCIL
To:	PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8212070172
Download: ML20028B897 (10)

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USNRC UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSKQN DEC -6 A10:28

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BEFORE THE ATOMIC SAFETY AND LICENSING B.OARDJ,v;^t

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PUGET SOUND POWER & LIGHT ) Docket Nos. STN 50-522 COMPANY, ET AL. ) STN 50-523

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(Skagit/Hanford Nuclear Power ) December 1, 1982 Project, Units 1 and 2) )

INTERVENORS NATIONAL WILDLIFE FEDERATION AND OREGON ENVIRONMENTAL COUNCIL'S REQUEST FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES Pursuant to Commission Rules, 10 C.F.R. S 2.740b and 10 C.F.R.

S 2.741, intervenors National Wildlife Federation and Oregon Environ-mental Council hereby request that the applicants answer each of the following interrogatories separately and fully in writing under oath and produce the documents as requested. The request for prodaction encompasses all documents in the possession, custody, or control of applicants or their agents or employees, including those performing duties for the applicants under contract.

Documents should be produced at the corporate headquarters of applicant Portland General Electric in Portland, Oregon, at 9:00 AM, on January 5, 1983.

INSTRUCTIONS A. In answering these interrogatories, applicants are requested to furnish all information available to all applicants, however ob-tained, including hearsay, and including information known by or in the possession of applicants' employees, agents and attorneys or appearing in applicants' records.

8212070172 821201 PDR ADOCK 05000322 b

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B. If you cannot answer the following interrogatories in full after exercising due diligence to secure the information necessary to do so, so state and answer to the extent possible, specifying your inability to answer the remainder, stating whatever information or knowledge you have concerning the unanswered portion and des-cribing your efforts to secure the unknown information.

C. Information sought by these interrogatories that you obtain after you serve your answers shall be disclosed to the intervenors by supplementary or amended answers within a reasonable time after you obtain such information, as required by 10 C.F.R. S 2.740(c) .

D. Whenever an interrogatory includes a request for production of a document, the document (s) produced should be marked or otherwise organized in a manner to indicate to which request they are in response.

E. In answering each interrogatory, your answer should identify any documents used in answering the interrogatory.

i F. If any of the information sought in an interrogatory or any l document sought in a request to produce is available in machine-readable form (such as punch cards, paper or magnetic tapes, drums, discs, or core storage), state the form in which it is available and describe the type of computer or other equipment required to read the information. If the information requested is stored in a computer, indicate whether you have an existing program which will print the records in readable form and identify the person (s) familiar with the

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l program. If no program exists, state whether you could develop one l

l or whether an existing program could be modified to print the records in a readable form.

G. As used herein, the term " documents" means all writings of every kind, both originals and copies, including but not limited to correspondence, letters, memoranda, notes, reports, papers, studies, analyses, surveys, test results, books, records, contracts or agreements, telegrams and other communications sent or received, transcripts of meetings, hearings or statements, computer print-outs, maps, charts, graphs, drawings, tables, calculations and computations, and printed or published matter. The term " documents" also includes voice recordingc, films, tapes, photographs and other data compilations from which information can be obtained, including materials used in data processing.

INTERROGATORIES AND REQUESTS FOR PRODUCTION

1. For each year since its commercial operation, provide the yearly " plant capacity factor" for the Trojan Nuclear Project. For purposes of this question, plant capacity factor means the net kilowatt hours generated by the Plant (total generation less amounts needed at the plant itself) divided by the product of the number of hours in the year times the rated capacity of the plant. For each year, indicate the " rated capacity" used in the calculation and explain how it was derived.

2. For each year for which figures are provided in Response to 1

Interrogatory 1, indicate what fraction of total potential plant out-put (rated capacity times the number of hours in each year) , was lost due to each of the following factors: (1) routine maintenance; (2) refueling; (3) plant malfunction or safety related shut-downs or reductions; (4) the displacement of Trojan power production by

other power sources for economic or system-wide operational reasons.

In each case, the answer should be based on equivalent hours of full load operation.

3. Explain in detail the basis for the assumption displayed in the Application for Site certification /Snvironmental Report (ASC/ER) that the Skagit/Hanford Project (S/HP) will operate during its life at a 70% capacity factor.

4. Provide any documents discussing, describing, analyzing, or used in determining the plant capacity factor of S/HP. Documents requested include, but are not limited to, all those which discuss, describe, or analyze all possible S/HP plant capacity factors, not just those which support or form the basis for the prediction of a 70% capacity factor.

5. Applicant Pacific Power and Light has estimated that its share of the Washington Public Power Supply System's Project No. 3 (WNP No. 3) will produce power at a cost of 191.4 mills per kilowatt hour in 1987 dollars. (Letter from James F. ?ienovi to Wm. Kramer, l Oregon Public Utility Commission, December 22, 1981.) Explain in l

detail how and why S/HP is expected to cost less per kilowatt hour than WNP No. 3. At a minimum, itemize the explanation pursuant to the cost break-down found in Table 8.2-2 of the ASC/ER, and explain fully the difference in cost between the two plants for each item.

6. Produce all documents discussing, describing, or analyzing the S/HP cost figures for each item listed in Table 8.2-2 or the ASC/ER.

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7. Explain in detail how and why S/HP is expected to cop,C more or less per kilowatt hour than the cost >of completing and >

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operating Washington Public Power Supply System'd Projects No'.*'r "

4 and 5.(WMP No. 4 and 5). Provide all documents' discussing, describing, or analyzing the comparative costs o$ S/HP and completion and operation of WNP No. 4 and 5.

8. What is the estimated levelized mills per kilowatt hour cost of decommissioning S/HP? Provide all documents discussing, describing, or analyzing S/HP decommissioning costs. _

9. Have the applicants calculated or attempted to calculate the quantifiable environmental costs [as that term is used in the Pacific Northwest Electric Power Planning and Conservation Act, P.L.96-501, S 3 (3) (B)] of construction and operation of S/MP?

If so, what are the calculated quantifiable. environmental costs of construction and operation of S/HP in levelized mills / kilowatt hour? Provide all documents discussing, describing, or analyzing quantifiable environmental costs of S/HP.

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10. Produce all documents which form the basis of the assumed l cost of money (10.67%) in the ASC/ER, Table 8.2-2, or which in any 1

other way discuss, describe, or analyze the assumed cost of money, whether they form the basis of the 10.67% figure or not.

11. Produce all documents which discuss, describe, or analyze the assumed interest rate during construction (9%) set out in Table 8.2-2, ASC/ER or any other potential interest rate. -

12. Provide all documents including, but not limited to,  !

t submissions made to state public utility enmmissions or boards, L

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\ S s listing, describing, dibcussing or analyzing the current and pre-dicted future capital' costs for each applicant, for long-term debt, preferred stock, and common equity'. '

s 13.. What is the predicted capital co'st of the new transmission facilitieu described in S 3.9 of the ASC/ER? (Includes four single circuit 500 KV lines and the BPA'Ashe-Hanford line.Np. 2.) What is

.' the predicted an.ual operatingicost of those facilities?

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14. Under what circumstances will additional bulk transmission

[facilitics need to be constructed to carry S/HP [over to the applicants' service territories? Provide all documents discussing, describing, or analyzing the possible need for additional transmission facilitiestocarrhS/HPpowertotheapplicantshserviceterritories.

15. What transmission losses of power produced by S/HP are anticipated over transmission facilitics to either the Ashe or Hanford substation? Provide all documents discussing, describing, or analyzing anticipated or potential transmission losses over these transmission facilities.

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16. What average transmission losses of power produced by S/HP are anticipated between either'Ashe-o,r Hanford substations and the 1

_ applicants' service territories? Provide all documents discussing, k describing, or anlayzing the anticipated or potential transmission losses between those substations and each applicant's service I territory.

17. How do the applicants desire or anticipate that S/HP will l

be operated in conjunction with the regional power system operated by and through the Bonneville Power Administration, the Pacific l

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Northwest Coordination Agreement, end/or the Northwest Power Pool's " Coordinated Operation Principles and Procedures."

18. Provide all documents discussing, describing, or analyzing how applicants desire or anticipate that S/HP will be operated in conjunction with the regional power system operated by and through the Bonneville Power Administration, the Pacific Northwest Coordination Agreement, and/or the-Northwest Power Pool's

" Coordinated Operation Principles and Procedures." Documents supplied should include, but not be limited to, materials dis-cussing, describing, or analyzing the posnible use of S/HP to serve base loads with peak load served increasingly by hydropower resources.

Respectfully submitted, N -

~~s Terence L. Thatcher 0

DATED this 1 day of December, 1982. .

00LKETED UcNR; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'82 DEC -6 A10:28 BEFORE THE ATOMIC SAFETY-AND LICENSING BOARD ff F R t . Si utiE TAk !

t.ccdLI;NG a 7ERVICL BRANCH In the Matter of )

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PUGET SOUND POWER & LIGHT ) Docket Nos. STN 50-522 COMPANY, ET AL. ) STN 50-523

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(Skagit/Hanford Nuclear Power )

Project, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that the INTERVENORS NATIONAL WILDLIFE FEDERATION AND OREGON ENVIRONMENTAL COUNCIL'S REQUEST FOR PRODUCTION OF DOCUtiENTS AND INTERROGATORIES in the above-captioned proceeding has been served upon the persons shown on the attached list by depositing copies thereof in the United States mail on December 1, 1982 with proper postage affixed for first class mail.

DATED: December 1, 1982.

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Terence L. Thatcher Attorney for National Wildlife Federation and Oregon Environ-mental Council Suite 708, Dekum Building 519 S,W. Third Avenue Portland, OR 97204 (503) 222-1429 l

SKAGIT/HANFORD SERVICE LIST December 1, 1982 Commission Secretary of the Commission.

Attention Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Licensing Board John P. Wolf, Esq., Chairman l Administrative Judge Atomic Safety and Licensing Board Panel 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, D.C. 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 Lee Scott Dewey Office of the Executive Legal Director

. U.S. Nuclear Regulatory Commission l

Washington, D.C. 20555 Applicants F. Theodore Thomsen Perkins, Cole, 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

SKAGIT/HANFORD SERVICE LIST Ralph Cavanagh Natural Resources Defense Council 25 Kearny Street San Francisco, CA 94108 .

James B. Hovis Yakima Indian Nation c/o Hovis, Cockrill, Weaver and Bjur 316 North Third Street P.O. Box 487 Yakima, WA 98909 i

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