ML20070T066
| ML20070T066 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 02/04/1983 |
| From: | Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8302080182 | |
| Download: ML20070T066 (15) | |
Text
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00CKETED uvec 13 FEB -7 All 229 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PUGET SOUND POWER & LIGHT
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Docket Nos. STN 50-522 COMPANY, et al.
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STN 50-523
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(Skagit/Hanford Nuclear Project
)
February 4, 1983 Units 1 and 2)
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APPLICANTS' MOTION TO SUSPEND HEALTH AND SAFETY PREHEARING SCHEDULE On January 18, 1983, the Board issued an Order Establishing Schedule that established a schedule for events leading to the evidentiary hearing on health and safety matters in the above proceeding (the Health and Safety Prehearing Schedule).
The Health and Safety Prehearing Schedule was established consistent with the Memorandum Summarizing Joint Prehearing Conference dated January 7, 1983, which was issued jointly by the
't Board and the State of Washington Energy Facility Site Evaluation Council (EFSEC).
Among other things, the joint memorandum established a schedule for events leading to the joint EFSEC-NRC evidentiary hearing on need for power and other environmental issues.
The triggering event for that schedule is issuance of the joint EFSEC-NRC Final Environmental Statement (FES) for the Skagit/Hanford Nuclear Project (S/HNP).
O P
O 2
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4 In furtherance of the January 7 joint memorandum, EFSEC and the NRC Staff established March 15, 1983 as the target date for l
issuance of the FES.
See schedule attached to letter of January 13, 1983 from Mr. Lewis, Cl: airman of EFSEC, to Mr. Muller, of the NRC Staff.
That schedule was based on the assumption that the draft Regional Power Plan being developed by the Regional Power Planning Council would include the S/HNP units amo'ng the resource options that might be needed by the region during the twenty-year period covered by the plan.
This assumption proved to be incorrect.
The Regional Council adopted i
the draft plan on January 26, 1983 and the S/HNP units are not included in the proposed resource portfolio.
Applicants do not agree with the conclusion reached by the Regional Council.
In Applicants' judgment, inclusion of the S/HNP units in the resource option portfolio of the Regional Power Plan would be in the public interest.
Applicants will attempt to persuade the Regional Council of this prior to its adoption of the final plan, which is scheduled for April 28, 1983.
In view of the content of the draft plan, Applicants have concluded that it would be in the best interest of all concerned to defer completion of the FES until after the final plan becomes available.
Accordingly, Applicants have requested EFSEC and the NRC Staff to defer completion and issuance of the FES until after the final Regional Power Plan becomes available.
See attached l,
I letter dated February 4, 1983 from Mr. Myers of Puget Sound Power o
& Light Company to Messrs. Lewis and Muller.
Consistent with Applicants request concerning deferral of the FES and the resulting deferral of the schedule for the joint hearing on need for power and other environmental issues, and to minimize further expenditures in connection with S/HNP pending adoption of the final Regional Power Plan, Applicants believe that it would be in the best interest of all concerned to suspend the Health and Safety Prehearing Schedule for the time being.
Based on the foregoing, Applicants request the Board to issue an order suspending the Health and Safety Prehearing Schedule pending adoption of the final Regional Power Plan and until further order of the Board.
More specifically, and recognizing that schedule event No. 3 (filing new contentions) and probably No. 4 (responses to new contentions) will have occurred before the parties will have responded to and the Board will be in a position to rule on this motion, Applicants respectfully suggest that, if the Board decides to grant this motion, it would be reasonable and must productive to suspend the prehearing. events after event No. 5 (Board ruling on contentions).
DATED:
February 4, 1983.
PERKINS, COIE, STONE, OLSEN & WI AMS By d
A F. Theodore Thomsen Attorneys for Applicants 1900 Washington Building Seattle, Washington 98101 Phone (206) 682-8770 Of Counsel:
David G.
Powell Steven P.
Frantz Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Phone:
(202) 862-8400
> l.
PUGET SOUND POWER & LIGHT COMPANY PUGET POWER BUILDING -(206) 4544363 B ELI.EVU E. WASHINGTON 98009 February 4, 1983 Mr. Nicholas D. Lewis, Chairman Energy Facility Site Evaluation Council Mail Stop PY-ll Olympia, Washington 98504 Mr. Daniel Muller Assistant Director Environmental Technology Division of Engineering U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Puget Sound Power & Light Company Skagit/Hanford Nuclear Project EFSEC Application No. 81-1 NRC Docket Nos. STN 50-522 and STN 50-523 Reference is made to the schedille for completion and issuance of the Final Environmental Statement (FES) for the Skagit/
Hanford Nuclear Project (S/HNP), which was attached to Mr.
Lewis's letter of January 13 to Mr. Muller and calls for the FES to be ready for distribution by March 15.
As was noted by EFSEC in approving this schedule, this schedule was based on the assumption that the draft Regional Power Plan would include the two S/HNP units among the resource options that might be needed by the region during the twenty-year period covered by the plan.
This assumption proved to be incorrect.
The Regional Council adopted the draft plan on January 26 i
and neither S/HNP unit is included in the proposed resource portfolio.
We do not agree with the conclusion reached by the Regional
[
Council.
In our judgment, inclusion of the S/HNP units in the resource option portfolio of the Regional Power Plan would be in the best interest of the region and its ratepayers.
We shall attempt to pursuade the Council of this prior to issuance of the final plan, which is scheduled to be adopted on April 28, 1983.
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PU2ET CCUND POWER & LICHT CLMPANY a
'b Messrs. Lewis & Muller Page Two February 4, 1983 In view of the content of the draft plan, we believe that it would be in the interest of all concerned to defer complet. ion and issuance of the FES until after the final plan becomes available.
Accordingly, please consider this letter as Applicants' formal request that completion and issuanca of the FES for S/HNP be deferred until after the final Regional Power Plan becomes available.
Very ruly yo rs, Robert V. M Vice Presi t
Generation esources cc:
EFSEC Distribution List (1/10/83)
NRC Service List Grant Bailey, URS i
I i
PUGET SOUND POWER & LIGHT COMPANY PUGET POWER BUILDING -(206) 4544363 B ELLEVU E. WASHINGTON 98009 February 4, 1983 Mr. Nicholas D. Lewis, Chairman Energy Facility Site Evaluation Council Mail Stop PY-ll Olympia, Washington 98504
Dear Mr. Lewis:
Puget Sound Power & Light Company Skagit/Hanford Nuclear Project EFSEC Application No. 81-1 Reference is made to my letter of this date to you and Mr. Muller of the NRC requesting that completion and issuance of the Final Environmental Statement for the Skagit/Hanford Nuclear Project (S/HNP) be deferred until after the final Regional Power Plan becomes available.
Consistent with that letter, and to minimize further expenditures in connection with S/HNP pending adoption of the final Regional Power Plan, we believe that it would be in the best interest of all concerned to suspend the S/HNP certification proceeding for the time being.
Accordingly, please consider this letter as Applicant's formal request that the S/HNP certification proceeding and the further processing of our certifica-tion application be suspended pending adoption of the final Regional Power Plan.
Very ly yo s,
Robert V. My Vice Presi Generatio - esources cc:
EFSEC Distribution List (1/10/83)
NRC Service List Grant Bailey, URS
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter 6f
)
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PUGET SOUND POWER & LIGHT COMPANY, )
DOCKET NOS.
et al.
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STN 50-522 (Skagit/Hanford Nuclear Project,
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STN 50-523 Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that the following:
1.
Applicants' Motion to Suspend Health and Safety Pre-hearing Schedule dated February 4, 1983 (NRC).
2.
Letter dated February 4, 1983 from Puget Power (Myers) to EFSEC (Lewis) and NRC (Muller).
3.
Letter dated February 4, 1983 from Puget Power (Myers) to EFSEC (Lewis).
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 February 4, 1983 with proper postage affixed for first class mail.
DATED:
February 4, 1983 j
F. Theodore Thomsen Attorney for Puget Sound Power &
Light Company 1900 Washington Building Seattle, Washington 98101
I NRC Service List COM. MISSION Secretary of tne Commission Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 LICENSING B0sRD John F. Wolf, Esq., Cnairman Administrative Judge Atomic Safety and Licensf79 Board 3409 Snepherd Street Chevy Cnase, MD 20015 Dr. Frank F. Hooper Administrative Judge Atomic Safety and Licensing Boarc School of Natural Resources University of Michigan Ann Arbor, MI 48190 Mr. Gustave A. Linenberger Administrative Judge Atomic Safety and Licensing Boaro U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APPEAL BOARD 5tepnen F. Eilperin, Esq., Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Reginald L. Gotchy t
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Comnission Washington, D.C. 20555 NRC STAFF Lee Scott Dewey, Esq.
l Counsel for the NRC Staff Office of tne Executive Legal Director U.S. Nuclear Regulatory Commission Wasnington, D.C. 20555 l
-2 ItiTERESTED STATES AND COUNTIES wasnington tnergy racility Site Evaluation Council Nicholas D. Lewis, Chairman 4224 6th Avenue, S.E., didg. 1, Rowesix Lacey, WA 98504 Kevin M. Ryan, Esq.
Washington assistant Attorney General Temple of Justice Olp p13, WA 98504 Frank W. Ostrander, Jr., Esq.
Oregon Assistant Attorney General 500 Pacific Building 520 S.W. Yamnill PortIano, OR 97204 Bill Sebero, Chairman Benton County Comissioners P.O. Box 470 Prosser, WA 99350 APPLICANTS F. Tnecdore Thomsen, Esq.
Perkins, Ccie, Stone, Olsen & Williams 1900 Washington Building Seattle, WA 93101 David G. Powell, Esq.
Lowenstein, Newnan, Reis & Axelrad 1025 Cc7necticut Avenue, N.W.
Washington, D.C. 20036 James W. Durham, Esq.
Senior Vice President General Counsel and Secretary Portland General Electric Company 121 S.W. Salmon Street Portland, OR 97204 Warren G. Hastings, Esq.
Associate Corporate Counsel Portlano General Electric Company 121 S.W. Salmon Street Portland, OR 97204
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Ricnara D. 3ach, Esa.
Stoel, Rives, Boley, Fraser & Wyse 2300 Georgia Pacific Building 900 S.W. Fifth Avenue Portland, OR 97204 INTERVENORS Nina Sell Coalition for Safe Power Suite 527, Governor Building 40d S.W. Second Avenue Portland, OR 97204 Ralph Cavanagh, Esq.
Natural Resources Defense Council 25 Kearny Street San Francisco, CA 94108 James 3. Hovis, Esq.
Yakima Indian Nation P.O. Box 487 Yakima, WA 98907 Terence L. Inatcher, Esq.
NWF anc OEC 708 Je<sm Building 519 5.W. Third Avenue Portland, OR 97204 Robert C. Lothrop Colamoia kiver Inter-Trical Fisn Commission Suite 320 8333 d.E. Sandy Boulevara Portland, OR 97220 OTHER Canadian Consulate General Donald Martens, Consul 412 Plaza 600 Sixth and Stewart Streets Seattle, WA 93101
BEFORE THE STATE OF WASHINGTON ENERGY FACILITY SITE EVALUATION COUNCIL In the Matter of the Application of
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PUGET SOUND POWER & LIGHT COMPANY,
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Application No. 81-1 A Washington Corporation
)
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(Skagit/Hanford Nuclear Project)
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CERTIFICATE OF SERVICE
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The undersigned certifies that on Februarv 4.
19R1 he served the enclosed:
1.
Applicants' Motion to Suspend Health and Safety Pre-hearing Schedule dated February 4, 1983 (HRC).
2.
Letter dated February 4, 1983 from Puget Power (Myers) to EFSEC (Lewis) and NRC (Muller).
3.
Letter dated February 4, 1983 from Puget Power (Myers) to EFSEC (Lewis).
by depositing copies thereof in the United States mail, properly stamped and addressed to the persons listed on the EFSEC Distribution List dated 1-10-83.
DATED:
February 4, 1983
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+4
^
F.
Theodore Thomsen Attorney for Applicant PUGET SOUND POWER & LIGHT COMPANY
i,/
'f
- Indicates Revision 1-10-83 DISTRIBUTION *IST PUGET 9OUND POWER & LIGHT COMPANY SKAGIT/HANFORD PROJECT APPLICATION NO. 81-1 APPLICANT COUNCIL (Cont.)
Mr. Mike Stimac, Manager Mr. Merlin Smith Licensing & Regulations Comm. & Economic Development Puget Sound Power & Light Co.
General Administration Bldg.
Puget Power Building Olympia, WA 98504 AX-13 Bellevue, WA 98009 Mr. Fred D. Hahn Mr. Gordon Jacobsen Department of Ecology Vice Pres., Nuclear Projects Olympia, WA 98504 PV-ll Northwest Energy Services Co.
P.O.
Box 1090 Kirkland, WA 98003 Mr. David H. Guier Dept. of Emergency Services 4220 East Martin Way Mr. F. Theodore Thomsen Olymcia, WA 98504 PT-11 Perkinc, Coie, Stone, Olsen & Williams 1900 Washington Bldg.
Mr. John G.
Douglass Seattle, WA 9S101 State Energy Office 400 East Union ORIGINAL AND TWO COPIES TO:
Mr. William L. Fitch Dr. Charles Woelke Executive Secretary Department of Fisheries Energy Facility Site General Administration Bldg.
Evaluation Council Olympia, WA 98504 AX-11 Mail Stop PY-ll Olympia, WA 98504
- Mr. Jack Howerton Department of Game COUNCIL 600 North Capitol Way Olympia, WA 98504 GJ-11 Mr. Nicholas D.
Lewis, Chairman Energy Facility Site Eval.
Council Ms. Nancy Burnett 4224 Sixth Ave. S.E.
Dept. of Natural Resources Olympia, WA 98504 PY-ll Public Lands Bldg.
Olympia, WA 98504 OW-21 Mr. Art Scheunemann Department of Agriculture Mr. Claude E.
Lakewold General Administration Eldg.
Office of Financial Mgmt.
Olympia, WA 98504 AX-41 320 Insurance Bldg.
Olympia, WA 98504 AQ-44
I i
Ne COUNCIL (Cont.)
COUNSEL FOR THE ENVIRONMENT Mr. John A.
Clark Mr. Thomas R. Bjorgen Parks & Recreation Comm.
Assistant Attorney General 7150 Cleanwater Lane Temple of Justice Olympia, WA 98504 KY-ll Olympia, WA 98504 AQ-01
- Mr. Bert Baron ATOMIC SAFETY &
Planning & Comm. Affairs LICENSING BOARD 9th & Columbia Building Olympia, WA 98504 GH-51
- Judge Gustave Linenberger Atomic Safety & Licensing Boar 6 U.S. Nuclear Regulatory Commissior Mr. Sam I. Reed Washington D.C.
20555 9erial & Health Serv.
Olympia, WA 98504 LD-ll Judge Frank Hooper Ecology, Fisheries & Wildlife, Mr. C. Robert Wallis School of Natural Resources Utilities & Transp. Comm.
University of Michigan HighwaysLicenses Building 128 S.T. Dana Building Olympia, WA 98504 PB-02 Ann Arhor, MI 48109 Mr. Joe Bell Judge John F. Wolf, Chairman Dept. of Transportation Atomic Safety & Licensing Bocrd Highway Adr.inistration Bldg.
3409 Shechard Street Olympia, WA 98504 KF-01 Chevey Chase, Mn 20015 COUNSEL FOR THE COUNCIL NRC STAFF Mr. Kevin M.
Ryan Assistant Attorney General
- Mr. Lee Scott Dewey Counsel for NRC Staff Temple of Justice U.S. Nuclear Regulatory Com. mission Olympia, WA 98504 AV-21 Office of Executive Legal Director Washington, D.C.
20555 COUNCIL LEGAL OFFICER Mr. Jan A. Norris Mr. Patrick Biggs Senior Siting Engineer Legal Officer Siting Analysis Branch Energy Facility Site U.S. Nuclear Regulatory Commission Evaluation Council M/S AR-5200 Olympia, WA 98504 Washington, D.C.
20555 PY-11.
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AGENCY PARTIES
- Mr. Frank J. Owens Attorney for the Construction Mr. Spencer W.
Daniels Impact Group Assistant Attorney General Owens, Weaver, Davies & Domir.ick Department of Transportation 926 - 24th Way S.W.
Olympia, WA 98504 KF-01 Olympia, WA. 98502 Mr.
R. C. Schuster District Administrator Department of Transportation P.O. Box 52 Yakima, WA 98907 Mr. Charles Lean Department of Ecology Mail Stop PV-ll Olympia, WA 98504
- Mr. James M. Johnson Sr. Assistant Attorney General Dept. of Fisheriec Olympia, WA 98504 PB-53
- Mr. Paul Majkut Assistant Attornev General Dept. of Game Olympia, WA. 98504 PB-53 COU!:TY MEMBER Commissioner William H. Sebero Board of Benton County ComT.s.
P.O. Box 470 Prosser, WA 99350 INTERVENORS Mr. Robert C. Lothrop Attorney for Columbia River Inter-Tribal Fish Commission Suite 114 2705 East Burnside St.
Portland, OR 97214