ML20072H220
| ML20072H220 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 06/22/1983 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML20072H211 | List: |
| References | |
| ISSUANCES-CPA, NUDOCS 8306290375 | |
| Download: ML20072H220 (5) | |
Text
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NUCLEAR REGULATORY COMMISSION T
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In the Matter of
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Docket No. 5 et. al.
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(WPPSS Nuclear Project No. 1)
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INTERROGATORY 7: What is the complete basis for your statement that licensee's " decision in April, 1982 to ' defer' construction for two to five years, and subsequent cessation of construction at WNP-1 was dilatory."
RESPONSE: " Analysis of Alternatives Related to WNP-3", May 26,1983, Bonneville Power Administration.
"WPPSS studies
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construction halt at plant No.3",
March 24, 1982, Oregonian, Portland, Oregon.
.c INTERROGATORY 8: Please explain fully what you mean by the word " defer" as used in your contention.
RESPONSE: Intervenor has used defer-in its contention to mean "put off".
When Intervenor stated that it believed it means "a permanent halt" Intervenor was referring to the meaning as seen by Licensee and others.
'4 INTERROGATORY 11: Why do you contend that Licensee has failed to establish good cause for en extension of the WNP-1 construction permit?
RESPONSE: See response
_a interrogatory 17 dated May 23, 1983 and the updated response cont'ained herein.
INTERROGATORY 13: What is the basis for your response to interrogetory 12?
RESPONSE: Letter to Harold Denton, Office of NRR/NRC, from G.D. Bouchey, Deputy Director, WPPSS dated April 30, 1982.
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.}D;:,MfA INTERROGATORY 14: Do you contend that the reasons offered by licensee to support a showing of good cause are factually is M J incorrect?
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reasons offerred and the reasons why a deferral was/is being sought by Licensee. This interrogatory we feel Just speaks to the reasons offerred by Licensee to the NRC which to the best of
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our knowledge are contained in the April 30, 1982 letter to Denton, NRC from Bouchey, WPPSS.
- E Intervenor has interrupted that letter as stating that
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WNP-1 was deferred based on a recommendation by the BPA. As stated previously Intervenor does concede that BPA did make a
.A&l recommendation. However, na stated in response to Interrogatory
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17 other reasons exist for the deferral of WNP-1.
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.... $E vn INTERROGATORY 15: What is the basis for your response to interrogatory 14?
se RESPONSE: Filings made in the above captioned proceeding.
See response to interrogatory 18.
INTERRROGATCRY 17: If your response to interrogatory 16 is yes, why do you believe tha.t licensee has (a) sought on extension of its construction permit and (b) deferred construction at WNP-17 RESPONSE: As to why Licensee is seeking an extension of its construction permit Intervenor does not know Intervenor believes that Licensee deferred WNP-1 in part due to the requirement of Washington State Energy Financing Voter Approval Act which became law in July, 1982.
INTERROGATORY 18: What is the basis for your response to interrogatories 16 and 17?
RESPONSE: "Hanford plants should be finished", Jerry
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Pavletich, President, Northwest Steelhead and Salmon Council,
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<rn W April 18, 1982, Tri-City Herald, Pasco, Washington. "No,1 should
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Editorial, April 18, 1982, Tri-City Herald, Pasco,
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Washington. "BPA defends N-plant decision", April 21, 1982,
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..pdi!E Oregon Journal, Portland Oregon. ** Washington State Energy g,ay,g p, trNt*d
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Financing Voter Approval Act: Cost Effectiveness Study of WNP-2 igg
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Bulletin: On Preliminary Cost-Effectiveness Study on Washington
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Pub'lic Power Supply System Plants", November 22, 1982, Secretary
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of State, Washington.
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- i.,1?N E INTERROGATORY 19:'What is the basis for your statement that W
the " modified request for extension of completion date to 1991
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does not constitute a ' reasonable period of time provided for iri f;gh 10 CFR 50.55(b)?"
g{ggyp RESPONSE: " Analysis Of Alternatives Related to WNP-3", Mayk
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INTERROGATORY 23: What is the basis for your response to S
interrogatories 20, 21, and 227
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RESPONSE
Intervenor basis is contained in its basis for f r.
its contention and " Analysis of Alternatives Related to WNP-3",
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BPA. Intervenor is currently reseaching legal cases to provide legal support for its position and will again update its response.
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Respectfully submitted, Eug
.e Roso1.e Com ition For Safe Power dated this day the 22nd of June, 1983.
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' ;d.5!*J Eugene Rosolie, being duly sworn, deposes and says:
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That he is the Director, of the Coalition For Safe Power, 9 JJ"y and that he believes the contents of the foregoing Coalition
%d For Safe Power Updated Responses to Applicant's First Set of If$
Interrogatories Dated May 3, 1983 are true and correct to
~-We the best of his information, knowledge and belief.
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l Sworn to and subsc ibed before me ib this M _ day of u__ _, 1983.
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UNITED STATES OF AMERICA 4
NUCLEAR REGULATORY C0i+ilSSION
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BEFORE THE ATOMIC SAFETY AND LICENSING B0A k
In the Matter of
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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et. al.
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(WPPSS Nuclear Project No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "R 5F Rt5 PUN 5L IU LICENSEE'S MOTION TO COMPEL" and "C0ALITION FOR SAFE POWER UPDATED RESPONSES TO APPLICANT'S FIRST SET OF INTERROGATORIES, DATED MAY 3,1983" in the above captioned matter were served upon the following persons by deposit in the United l
States mail, first class, postage prepaid this 22nd day of June,1983:
Herbert Grossman, Chairman Nicholas Reynolds 1
Atomic Safety & Licensing Board Debevoise & Lieberman U.S. Nuclear Regulatory Comission 1200 17th Street, NW Washington D.C. 20555 Washington D.C. 20036 l
Glen 0. Bright Dr. Jerry Harbour Adminstrative Judge Administrative Judge t
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington D.C. 20555 Washington D.C. 20555 Mitzi Young Gerald Sorenson, Manager l
Counsel for NRC Staff Licensing Program Office of Exec. Legal Director WPPSS U.S. Nuclear Regulatory Comission 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 Comission Olympia, WA 98504 Washington D.C. 20555 i
Docketing & Service U.S. Nuclear Regulatory Comission Washington D.C. 20555 l
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( ~Nina Bell, Staff Intervenor 4
i Coalition for Safe Power I
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