ML20071G727
| ML20071G727 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 05/18/1983 |
| From: | Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CPA, NUDOCS 8305240347 | |
| Download: ML20071G727 (5) | |
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Docket No.,do,.,
et. al.
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(WPPSS Nuclear Pro]ect NoI 1)
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99661II9N_E98_SoEE_EQWEB_HgIlgN_Ig_gg5EE(6_BEgEgNgEg_IQ EIB@I_gEI_gE_IMIEBBgG6IgBIEg_Ig_6EE6196HI The Coalition For Safe Power (CFSP), pursuant to 10 CFR 2.740(f),
hereby moves that the Atomic Safety and Licensing Board in the above captioned proceeding order the Washington Public Power Supply System (WPPSS) to respond fully to CFSP interrogatories 6,7,8 and 9 filed on April 14, 1983.
4 E09E9899ED On April 14, 1983 CFSP filed its first set of e
interrogatories on WPPSS.
WPPSS served its responses on May 3,
1983.
In its response WPPSS objected to interrogetories 6,7,8 and 9.
HAIMBE_gE_IggUEg All four interrogatories request documents concerning the delay of WNP-1:
Interrogatory 6:
Provide all documents exchanged between WPPSS
" participants" and
" Companies" concerning the delay of WNP-1.
Interrogatory 7:
Provide minutes of all meetings of the WPPSS Executive Board at which the delay of WNP-1 was discussed.
Interrrogatory 8: Provide all documents generated internally by WPPSS concerning the delay of WNP-1.
Interrogatory 9:
Provide all docume,nts related to all options considered by WPPSS, for WNP-1 between April 23 and 29, 1983.
8305240347 830518 PDR ADOCK 05000460 0
WeeSS_gg2EGIlgd WPPSS objects to all four interrogatories in general, stating:
"These interrogatories request documents which are clearly beyond the scope of this proceeding and are irrelevant and unnecessarily burdensome."
WPPSS states that documents would have to be produced which address every.
aspect of the construction delay at WNP-1 and that such documents " bear on health and safety."
6EQUEMEHI_IE_SMEEgBI_QE_UgIlgd Intervener submits that the refusal by WPPSS to answer interrogatories 6,7,8, and 9 is without foundation. WPPSS is simply attempting to withhold information which has a direct relction to the issues in this proceeding. These issues are:
the deferral of WNP-1; was such deferral dilatory; and as the requested extension a reasonable period of time.
The interrogatories in, question seek information concerning actions by WPPSS on the deferral of WNP-1 and whether or not good cause existed for such actions.
For
- example, interrogatory 9 requests all options considered by the WPPSS Executive Board between April 23 and 29, 1982, the period of time during which the decision to defer WNP-1 was made.
Clearly there were a variety of options considered, some of which did not call for the deferral of WNP-1;the consideration of these options has a bearing on the final decision and thus is relevant to this proceeding.
The same is true for interrogatory 7,
which requests the minutes of Executive Board meetings at which the deferral of WNP-1 was discussed. The Executive Board is the
s group that made the decision to defer WN?-1.
(See Letter to H.R.
Denton, Director, Office of NRR, NRC from G.D.
- Bouchy, Deputy
- Director, W??SS dated April 30, 1992)
Thus the Intervenor should be entitled to review these minutes.
The other two interrogatories seek documents exchanged between WP?SS, the Bonneville Power Admininstration (BPA) and other participents in UN?-l which contein information directly relevant to this proceeding.
WP?SS relies upon
- udgement of the the BPA to support its contention that good cause existed for deferral.
Intervenor requests to view documents exchanged by WP?SS and B?A on that very subject.
Regarding the other part:cipants in WN?-1, WP?SS rust have inferned them Of its intentions either prior tr deferral or after.
The pcrties in this case have s.right to know what W??SS told those participants.
Furthermore the participants may have forwarded information which WPPSS used in its decision; if so, the parties have a right to know about that information WP?SS clso expresses the concern that it would have to supply docunents concerning ramp-down actions which have been proposed or teken to prevent possible site or facility degradstion during the deferrel.
While it may be true that such documents bear on heslth and safety" they are also relevsnt to the issues in this proceeding. Issues do not have to be mutually exclusive: c hypothetical exsmple would be if e
letter had been written stating that because of questions about the geology of the
- site, WP?SS was considering. the deferral of WNP-1.
The documents requested
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d would shed light on whether or not UFPSS' actions were dilstory and the extension dstes reasonsble. For instance, WPPSS could have been planning a deferral of construction prior to BPA's suggestion to do so. The only way intervenor could discover that fact would be to have an opportunity to view those documents.
Information regarding the level of the work force also has a
direct bearing on when construction can restert and thus a
bearing on the conpletion dste for WNP-1.
(See Letter to ASL3 ' rom N.
5.
- Reynolds, March 7,
1983)
The scre is true for the changes in
" contractual obligstions" which UPPSS states have no relevsnce to the issues of this proceeding.
9939b25193 WPPSS clains that the documents reguested deel with every aspect of the, construction delay at UN?-l and that such a
request is beyond the scope of this proceeding.
Intervenor submits, as outlined above, that such claims are without basis and that the Board should order WPPSS to respond fully to Interrogatories 6,7,8, and 9.
Respectfully submitted
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Dsted this day, the Nins Bell 18th of May, 1983.
Staff Intervenor e
UNITED STATES OF AMERICA f:UCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Docket No. 50-460 CPA
-et. al.
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(WPPSS Nuclear Project No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "C0ALITION FOR SAFE POWER MOTION TO COMPELL RESPONSES TO FIRST SET OF INTERROGATORIES TO APPLICANT" in the above-captioned proceeding have been served on the following by deposit in the U.S. Mail, first class, postage prepaid on t'his 18th day of May, 1983.
Herbert Grossman, Chairman Nicholas Reynolds Atomic Safety & Licensing Board Debevoise & Lieberman U.S. Nuclear Regulatory Commission 1200 17th Street, NW Washington D.C. 20555 Washington D.C. 20036 Glen O. Bright Dr. Jerry Harbour Adminstrative Judge Administrative Judge Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington D.C. 20555 Washington D.C. 20555 Mitzi Young Gerald Sorenson, Manager Counsel for NRC Staff Licensing Program Office of Exec. Legal Director WPPSS U.S. Nuclear Regulatory Commission 300 G. Washington Way Washington D.C. 20555 Richland, WA 99352 State of Washington Atomic Safety & Licensing Energy Facility Site Evaluation Appeal Board Panel Council Mail Stop PY-ll U.S. Nuclear Regulatory Commission Olympia, WA 98504 Washington D.C. 20555 Docketing & Service U.S. Nuclear Regulatory Commission Washington D.C. 20555 M
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Nina Bell, Staff Intervenor Coalition for Safe Power
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