ML20063M624

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First Set of Interrogatories Re Contentions 14,29,30 & 35. Certificate of Svc Encl.Related Correspondence
ML20063M624
Person / Time
Site: Skagit
Issue date: 09/07/1982
From: Bell N
NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:
PUGET SOUND POWER & LIGHT CO.
References
NUDOCS 8209150301
Download: ML20063M624 (10)
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. NNDgym DOCKETED USHRC UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY C0rilSSION BEFORE Tl!E ATOMIC SAFETY AND LICENSING B0/dtD In the Matter of ) CFFICE OF SECRETAR*

PUGET SOUND PO'4ER & LIGHT COMPANY, ) Docket Nos. Sf9C66 [EEYICE et. al. ) STN 50 (Skagit/Hanford Nuclear Project) ) Date: September 7, 1982 C0ALITION FOR SAFE PO'4ER' S INTERROGATORIES TO THE APPLICANT - SET 1 Pursuant to 10 CFR2.740b, the Coalition for Safe Power hereby serves Set 1 of its Interrogatories to the Applicant. Each interrogatory must be answered fully in writing, under oath or affirmation, by an officer of agent of Applicant.

In the requests outlined herein, the words " documents", " studies".

" reports", " evaluations", and " calculations" should be interpreted to mean any of the following materials relied upon or in the passession of the Applicant: correspondence, telegrams, memoranda, notes, records, minutes, contracts, bulletins, summaries, articles, invoices, tape r<cordings, mcps, computer printouts, and work-sheets. ,

Re: CFSP Contention 29

1. Provide S.M. Stoller Corporation data relied upon in determining fuel cost ~. presented in ASC/ER Section 8.2.2.
2. k"nat is the "real escalation" cost mentioned in ASC/ER Section 8.2.2?
3. Provide all information used to justify its use.
4. Provide a copy of ERRI Study PS-120lSR, dated July, 1979.
5. Provide all data and reports used to justify an escalation rate of 8%

per year.

6. Provide all data and reports used to justify a Levilized Fixed Charge Rate of 13.880 and 14.580 in Table 8.2-3 in ASC/ER Section 8.2.
7. In Section 8.2.2 in the ASC/ER it states that "The operations and r.ain'.cnance costs were derived using a one-unit currently operating nuclear 8209150301 820907 plant." Provide the following: PDR ADOCK 05000522 G PDR

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a. Name of unit;
b. Capacity factor on monthly basis from date of commerical operation to present;
c. All monthly operating reports filed with the NRC;
d. Yearly operating and maintenance cost since cor.merical operation; (Provide an itemized list. )
c. Cost per kw (in mills) for each year of commercial operation;
f. Fixed and variable cost for each year of operation;
g. Cost per kw (in mills) for replacement power due to shutdowns of this unit. Explain how these costs are totaled into average cost and how these costs are reflected in Table 8.2-3 of the ASC/EK.
h. Identify all costs including replace = eat power which are related to the following:
1. the repair of any equipment for f ailure to meet NRC Quality Assurance requirements;
2. the repair of any equipment due to improper installation during constructien;
3. changes in NF.C regulations;
4. vendor errors; and
5. contractor errors.
i. Fellowing the format of ASC/ER Table 8.2-2 provide the mills /killo-

.:at-hour on a yearly basis for the operating unit centioned above.

S. In table 8.2-1 of.the ASC/ER, the.avarage site labor pay rate is given

. "f, 1973 dollars., What is the estimated rate in 1984 dollars?

9. Provide justification for using this rate, ih ; Power supply contracts with the Bonneville Power Adminstration
10. Provide copies of power supply contracts signed by Applicants with tha RFA in August, 1982.
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> Re: Pebble Springs Nuclear-Plant, Units 1 and 2

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11. Has the Applicant considered constructing Pebble Springs Unit 1 and the S/RNP Unit 1 at the same site?
12. If so, provide all relevant documents.
13. Has the Applicant considered placement of the Pebble Springs Units 1 and 2 at the S/HNP site?
14. If so, under what circumstances?

, 15. Provide all relevant documents.

Re: Attachment to PLN-263, July 16, 1982

16. What specific factors will the Applicant use to identify "an improved regulatory climate which will introduce certainty into the construction and operation of the Project"?
17. Who will evaluate these f actors?
18. When will such an evaluation be made?
19. How will the specific factors be quantified and weighed in the evaluation?
20. When will a decision be made to proceed with the construction of the S/ ESP?
21. What specific economic, financial and other factors are necessary for an affirmative decision?

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22. What inflation and interest rates will the Applicant require for en affirmative decision?
23. When does the Applicant expect to have a labor agreement necessary for an affirmative decision?
24. How will this agreement differ from t hose currently in ef fect for the construction of the WPPSS Nuclear Project s 1,2 and 4?
25. What are the specific factors requried by the Applicant in a labor agreerent that would be considered satisfactory?

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How will such an agreement prevent " frequent work stoppages, wildcat str ikes and labor dif ficulties"?

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27. What steps has the Applicant taken to resolve the questions it poses 2

l in its Repsonse to Question 4, page 3, Attachment to PLN-263, regarding -

the WPPSS Nuclear Projects 4 and 57

' 28. Why does the Applicant believe resolution of these matters and a decision on the aquisition of UPPSS 4 and 5 must wait for issuance of the Construction Permit for the S/ENP?

29. How does the Applicant assess the probability that economic, labor 4

and financial factors will improve to the required level as stated in the answers to Interrogatories 16 through 28 above?

I Re: CFSP Contention 14 i

! 30. Provide any studies ~and other documentation on the popluation, habitat, breeding characteristics and location of the sandroller (Percopsis transson-l tana).

31. Why.is this species not discussed _in the Applicant's ASC/ER?
32. What effect does the Applicant expect-construction and operation i

i will have upon this species?

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33. Discuss the basis for this conclusion.

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34. Provide all supporting evidence that Applicant relics upon for this j conclusion.
35. Provide any studies Applicant has evaluated that contradict this i

conclusion.

i 35. Does the Applicant concur .with the State of Washington, Department of C:me assumption (stated in comments to DEIS, 6-28-8'2) that " adjacent f -

h bitats [of displace birds) are assumed to be at carrying capacity"?

37. If not, why not? -

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l 33. If yes, does the Applicant agree that wildlife will be lost?

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39. Provide quantified projections of this loss.

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40. Provide any existing documentation of location of raptors' nests, l

perches, feeding and migration stop-over sites within a fifty-mile radius i

of the S/HNP. Quantify and specify to the greatest degree possihic.

41. What ef forts will be taken by contractors and subcontractors to minimize danage of habitat and biota during construction of the S/HNP?
42. Describe and quantify the location, population and propagation habits of Rorippa var. columbiae, Astragalus sclerocarpus, Cryptantha _leucophae and tarragon in the area to be affected by the construction and operation of the S/HNP.
43. Describe and quantify the effect of a major catastrophic accident l

on the population of the terrestrial and aquatic popluations of rare, throatened and endangered species that exist with the fifty mile zone of the S/HNP.

44. What would the overall ef fect be on the worldwide populations of these species.
45. Provide the documentation to support these projections.
46. Provide any studies that the Applicant has evaluated which contradict these conclusions .
47. Explain why the Applicant believes that construction will be confined to a one acre area in the Old Hanford Townsite.
48. What calculations have been dones to arrive at this conclusion?
49. What plans will be implemented to ensure that construction will be confined to a one acre area?
50. Specify and quantify the projected effect of this plan in terms of biota and habitat.
51. What-is the largest are the Applicant believes could be affected by construction in the Old Hanford Townsite without causing irreversible harm to the ecology?
52. What would the anticipated effect on the populations of aquatic and terrrestrial biota and habitat be from this level of construction?
53. Provide calculations to support this conclusion.
54. What is the smallest area the Applicant could utilize for construction -

in the Old Hanford Townsite?

55. What would be the corresponsing impact on biota and habitat?
56. Provide all studies done on the c'cology of the Old Hanford Townsite.
57. Provide all quantitative and qualitative studies relied upon by the Applicant on the swimming and migration habits of salcon along the Hanford Reach.
58. Provide all studies and reports Applicant relies upon on the location of all aquatic species in the area affected by the S/HNP.

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59. How will scheduling of construction minimize the damage to aquatic life?
60. Quantify the projected effect of construction upon aquatic life.
61. Provide the basis for the statement in ASC/ER Section 4.1 that the effects of river construction on salmon is "not expected". .
62. Provide all studies the Applicant relies upon to support this conclusion.
63. Provide any studies that contradict the conclusions and findings of the Applicant and the basis for rejected their inclusion in the evaluation.
64. Provide all studies and calculations on the impingement of ChinookSalmon fry by the intake structure.
65. Provide all studies on the existence, feeding and breeding habits of the giant Columbia River limpet and the great Columbia River Spire Snail.
65. What is the basis for concluding that thermal, chemical and radioactive

'ischarges and constr,uction on the river would not impact negatively upon these species?

G7. Provide docunentation to support this conlusion.

69. Provide any studies that contradict the conclusions and findings of the Applicant and the basis for rejecting their inclusion in the evaluation.
69. Why was this subject no discussed in ASC/ER Section 2.2.2.9? .

70.What incentives does the Applicant propose to offer contractors and cubcontractors to cause them to use every effort to minimize damage to the habitat and biota of the S/HNP construction site?

71. What types of chemical erosion controls might be used by the Applicant?
72. Provide all studies on the effectiveness amd environmental hazards associated with these controls.
73. Provide all available date.and studies on the Oregon Swallowtail butterfly in the Old Hanford Townsite.
74. What is the basis for the statement in Sect'on 4.1.1 of the ASC/ER that the effect on the raptor population.from construction of the S/HNP is " expected to improve" and that the effect on curlews will "probably be not lasting"?
75. Provide all studies and evaluations.that Applicant relics upon for this conclusion.
76. Provide any studies that contradict the conclusions and findings of che Applicant of this issue and the basis for rejecting their inclusion in the evaluation.
77. Provide all studies that discuss the effect of transmission lines upon avifauna that both support and contradict Applicants conclusions.
78. What is the basis for the Applicants conclusion that the operation of transmission lines will not have a significant effect on the avifa' una?
79. Provide any calculations done by the Applicant to support this.

Re: CFSP Contention 30 P0. Provide copies of all studies and other documents used by the Applicant to assess the existing radiological burden on the Hanford area environment, including the Columbia River (and sediment), and respective terrestrial

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and aquatic biota. .

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81. Is it the Applicants position that the existing radiological burden should not be taken into account in assessing the impact of the S/H:iP?
82. Discuss the basis for this answer.
83. Provide copies of all supporting documentation. utilized by the Applicant.
84. Provide any studies and other documents that contradict the conclusionc and findings of the Applicant on this issue and the basis for rejecting their inclusion in the evaluation, f
85. Which theory of dose-effect of ionizing radiation does the Applicant subscribe to: linearity, linearity with threshold, supra-linearity or diminished effects at' low doses?
86. Provde copies of all studies relied upon by the Applicant to support this position.

87.If Applicant does not agree that the number of radiation induced cancers is directly proportional to the does of radiation (linear without threshold), provide copies of all documents that refute reports that conclude that this statement is true.

88. What number of annual fatal and non-f atal cancers does the Applicant predict from the doses (to 0-50 mile population) estimated in ASC/ER Tables 5.2-5, 5.2-6 and 5.2-8?
89. Provide all calculations to support this result.
90. Uhat studies does Applicant rely upon to support this position?

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91. Why does the Applicant not include in utero doses in ASC/ER Table 5.2-4.
92. Provide documentation to support this position.
93. Provide the data relied upon to calculate the cumulative radiation doeues in ASC/ER Table 5.2-8.

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d Re: CFSP Contention 35 .

94. Provide an assessment of the effects of a nuclear accident on the operability of the Fast Flux Test Facility, WPPSS Nuclear Projects Nos.

I and 2.

95. Provide all studies and calculations which Applicant uses to support this assessment.

Respectfully suimitted,

/ r, s ; , _,:'.f..-

Dated this 7th day of Nina Sell Seotember, 1982. Coalitian for Safe Power i

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DOCKETE'D USNRC UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION

'82 SIP 13 P253 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GFFICE OF SECRETAR' DCCKETING & SERVfC'.

Iri the Matter of ) BRANCH

)

PUGET SOUND POWER & LIGHT CO. ) Docket Nos. STN 50-522 et. al. ) STN 50-523

) .

(Skagit/Hanford Nuclear Project) )

CERTIFICATE OF SERVICE I hereby certify that copies of " COALITION FOR SAFE POWER'S INTERROGATORIES TO THE APPLICANT - SET 1" in the above captioned proceedings have been served

-on the= follewing by deposit in the United States mail, first class, postage prepaid on this 10th day of September, 1982.

Srcretary of the Commission Ralph cavanagh, Esq.

Docketing and Service Branch Natural Resources Defense Council U.S. Nuclear Regulatory Corretission 25 Kearny Street F:ashington, D.C. 20555 San Francisco, CA 94108 Tereice L. Thatcher, Esq.

NWF and OEC ,

John F. Wolf, Esq., Chairman 708 Dekum Building

.&.ini str a tive Judge 519 S.W. Third Avenue teric Safety and Licensing Board Portland, OR 97201 24n9 Shepherd Street Mr. Robert C. Lothrop cPevy Chace, MD 20015 Atcorney for Coletbia River Dr. Frank F. Hooper Inter-Tribal Fish Cormission Administrative Judge Saite 320 8383 N.E. Sandy Blvd.

,itemic Safety and Licensing Board Portland, OR 97220 School of Natural Resources University of Michigan Janes B. Hovis nnn t.rbor, MI #190 .

Yakima Indian Nation

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  • I "r. Gustave A. Linenberger "
  • d tinistra t ive Jtr.loe 1.to-ic Saf ety r.nd I'.icensing Deard m W 98907 s 9 Nuclea r Cogulatory Co-.:t.inr. ion

.Nashington, D.C. 20555 P. Theodore Thomsen Perkins, Cole, Stone, t.to- ic Sa f ety and Licensin9 Olsen & Williams A; peal Board 1900 Washington Duilding 9.s. truclear P.equiatory Co iission Seattle, WA 98101

ashiray ton, D.C. 20555

. David G. Powell, Esq.

Wa ch in'J tc.) En!rgy racility Site Lowenctein, Newman, Reis & Axelrad Evaluattr,a Counell 1025 Connecticut Aven.se N.W.

Washington, D.C. 20036 Nicholn* D. Lewis, Chairman Patl Stop n'Y-11 Olyrpia, WA ?R504 Elchard L. D h d., Esq. .,

Ceuusel E r th tiPC Striff .Gna Bell U.S. I:ue!ce;- 5egulatory Comnicsion Coalition for S.fe Pcwer l of f ice of the Dtecutive Legal Direetc.t waahitet t n, *r . . C . 20555

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