ML20073J124
| ML20073J124 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 04/14/1983 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| ISSUANCES-CPA, NUDOCS 8304190194 | |
| Download: ML20073J124 (3) | |
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.t 241ATED Conne'Dum UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA 9D
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In the !!atter of )
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WASHIflGT0tl PUBLIC POWER SUPPLY SYSTEtt ) Docket No. 50-460 CPA et. al. ) 'g3 gog y p g (WPPSS Muclear Project No. 1) )
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COALITION FOP SAFE POWER FIRST SET OF INTERROGATORIES TO APPLICANT DATED APRIL 14, 1983 '
The Coalition for Safe Power hereby serves its First Set of Interrogatories on the Washington Public Power Supply System (UPPSS) pursuant to 10 CFR 2.740b and 2.741. Each interrogatory is to be answered fully in writing, under oath or affirmation, by an officer or agent of UPPSS and is to include all pertinent inrormation known to UPPSS. Each answer should clearly indicate the interrogatory to which it is intended to be responsive.
"UPPSS" shall include all agents, employees, attorneys, investiga-tors and all other persons directly or indirectly subject to NPPSS's control in any way.
" Documents" means all written or recorded material of any kind or character known to UPPSS or in its possesssion, custody or control including, without limitation, letters, correspondence, telegrams, memoranda, notes, recorded minutes, contracts, agreements, records or notation of telephone or personal conversations or conferences, inter-office communications, micrnfilm, bulletins, circulars, pamphlets, v35 studies, notices, summaries, reports, books, articles, treatises,
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On teletype messages, invoices, tape recordings, computer printouts g and worksheets.
CD 0;Q If UPPSS cannot answer any portion of the interrogatories in 85 full, after exercising due diligence to do so, so state and answer con.o to the exteat possible, specifying the inability to enswer the renainder t
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i and stating when expects to be able to answer the unanswered portions.
Interrogatory 1: Supply copies of " Net Billing Agreement's" executed between UPPSS and the Bonneville Power Adminstration and " Participants".
Interrogatory 2: Supply copies of the " Exchange Agreement" executed i
between WPPSS, Bonneville Power Adminstration and the " Companies".
Interrogatory 3: Provide all documents used to support the statement made by Applicant that "the BPA recommendation concerning construction deferral at W!!P-1 significantly affects the ability of the Applicant to raise capital needed for continued construction of W!!P-1".
Interrogatory 4: What was the date of'the last issuance of bonds, for WNP-l? Had WPPSS intended to issue bonds for*WNP-1 prior to the BPA recomendation? If yes, supply the date and all documents which show that such a bond sale would have been possible or impossible.
Interrogatory 5: Provide the last date WPPSS issued bonds for any of its proje".s and identify the project.
Interrogatory 6: Provide all documents exchanged between UPPSS, " Parti-cipants" and " Companies" concerning the delaying of UNP-1 construction.
Interrocatory 7: Provide ninutes of all meetings of the IPPSS Executive Board at which the delay of UtlP-1 was discussed.
Interroijatory 8: Provide all documents generated internally by UPPSS concerning the delay of W!!P-1.
Interrocatory 9: Provide documents related to all options considered by 'c!PPSS for W!!P-1 between April 23 and 29,1982.
Interronatory 10: Explain what caused the delay by WPPSS in making an amendment to its Construction Permit Extension request to the I !!P.C . Provide all documents generated internally by WPPSS related to this action.
Signed:
Dated: '/ / Y f $
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Eugepf.Rosolie,firector CoaWtion for S'afe Power
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0t94ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM ) Docket No. 50-460 CPA et. al. )33 [pq 18 0)) :30
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(WPPSS Nuclear Project No. 1) ),
CERTIFICATE OF SENICE,,. I I hereby certify that copies of "C0ALITION FOR SAFE POWER FIRST SET OF INTERROGATORIES TO APPLICANT DATED APRIL 14, 1983" in the above-captioned proceeding have been served on the following by deposit in the U.S. Mail, first class, postage prepaid on this 14th day of April, 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 0. Bright Dr. Jerry Harbour Adminstrative Judge Administrative Judge 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 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 Docketing & Service l U.S. Nuclear Regulatory Comission l Washington D.C. 20555 I
AB Nina Bell, Staff Intervenor j
Coalition for Safe Power