ML20076E956
| ML20076E956 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 05/24/1983 |
| From: | Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-CPA, NUDOCS 8306010364 | |
| Download: ML20076E956 (7) | |
Text
r P.EL.GED ConnE3PONDENC3 COMETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION m? "" 7 BEEQ8E_IHE_6IQ3IC_q6EEIY_6ND_LIQEHgIHQ_BQ6B p j g 'a In the Matter of
)
)
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
)
Docket No.SO-460CPA et. al.
)
)
(WPPSS Nuclear Project No. 1)
)
INIEByENg8ig_BEgEgNEEg_IQ_NBC_gI6EEig_EIBgI_gEI_QE IMIEB89Q6IQBIED The following interrogatories were answered by Et.' gene Rosolie and Nina Bell, Director and Staff Intervenor of the Coalition for Safe Power respectively.
The answers to these do not identify any new documents not already a part of the record.
Intervenor has not yet consulted with any advisors nor identified any potential witnesses.
INTERROGATORY 1: Explain fully the relationship between your statement that the decision to defer construction of WNP-1 for a two-to-five year period was "made upon reviewing the recommendations of the Bonneville Power Adminstration (BPA), reviewing alternative proposals and taking public comment" and your contention that Permittee's decision to i
defer construction was " dilatory" and without " good cause."
RESPONSE
" Dilatory",
in this instance means intentional.
The statement referred to in the interrogatory shows that, in fact, the decision to defer construction was intentional.
(
INTERROGATORY 2:
(a)
Is it your position that the
{
Permittee was
" dilatory" in not notifying the NRC on or about April 29, 1982 that it was modifying its request for a completion date from 1986 to 1991?
(b)
If your answer to Interrogatory No. 2(a) is in the affirnative, explain fully the basis for that statement.
RESPON;E: (a) Yes.
(b) Permittee's response to CFSP Interrogatory No. 10.
Q3 w
B306010364 830524 9
N~ J )>
PDR ADOCK 05000460 O
e a
INTERROGATORY 3:
(a)
Is it your position that BPA support is not necessary to the financing of WNP-1?
(b)
If your answer to Interrogatory No. 3(a) is in the affirmative, identify and give full details with respect to all information upon which you base that statement.
(c)
If your answer to Interrogatory No. 3(a) is in the affirmative, explain fully how the financing of WNP-1 could be accomplished if BPA were to disapprove any further financing of WNP-1 construction.
RESPONSE
It is not clear what the Staff means by "BPA support" in this interrogatory; upon clarification Intervenor will readily answer.
INTERROGATORY 4:
Is it your contention that the financial support or lack of financial support by BPA for WNP-1 would have no effect on the financing costs of WNP-1?
RESPONSE
Intervenor objects to this interrogatory.
The cost of financing is not an issue in this proceeding as it has not been raised by any party.
At no time did the Intervenor contend or set forth as a basis the cost of financing for WNP-1.
INTERROGATORY 5: Is it your contention that the opinion of BPA on the PNVCC (sic) as to when WNP-1 should go into commerical operation, would have no effect on the financing costs of WNP-1?
RESPONSE
Intervenor does not understand this interrogatory but assuming an error in the wording, we object for the reasons outlined in the response to Interrogatory 4, above.
l INTERROGATORY 6: (a) Is it your statement that BPA does not have the authority to disapprove any further financing of WNP-1 construction?
(b)
If your answer to Interrogatory No. 6(a) is in the affirmative, explain fully the factual basis for that statement.
l
{
RESPONSE: (a) Yes.
(b)
The BPA has no legal authority to approve or diapprove the sale of bonda for WNP-1.
See page 2 of the basis for Inturvenor's revised contention No.
2.
INTERROGATORY 7: Is it your contention that there has not been a
slowing in growth rate of electric power requirements in the Pacific Northwest?
RESPONSE
Intervenor objects to Interrogatory No. 7 because need for power is not an lasue in this proceeding.
However, it is clear that the answer la Nc.
INTERROGATORY 8: Is it your contention that the growth rate of electric power requirements in the Pacific Northwest has stopped or will stop completely before 19917
RESPONSE
Intervernor obaccts to this interrogatory; see response to Interrogatory 7.
INTERROGATORY 9: Is it your contation that the growth rate of electric power requirements has no business relationship as to when WNP-1 should go into commercial operation?
RESPONSE
Intervenor objects to this interrogatory because it relates to the operation of WNP-1 not the completion of construction of the actual construction of the project.
INTERROGATORY 10:
(a)
Is it your statement that the January 11, 1983 letter to H.
Denton, Director, NRR, NRC from G.D.
- Bouchy, WPPSS, does not support Permittee's assertion that a deferred need for power constitutes " good cause" for deferring construction?
(b) If your.snswer to Interrogatory No. 10(a) is in the affirmative, set forth and explain fully the factual basis or legal authority for your statement.
RESPONSE: (a) Yes.
(b)
The plant was determined to be needed in the construction permit proceeding; the NRC has recognized that
I need for power la not to be relitigated after the construction permit is granted.
INTERROGATORY 11:
(a)
Do you contend that a deferred need for power cannot as a matter of law constitute " good cause" under 10 CFR 50.55(b)?
(b) If your answer to Interrogatory No. 11(a) is in the affirmative, set forth and explain fully the factual basis or legal authority for this contention.
RESPONSE: (a) Yes.
(b) See response to Interrogatory No. 10.
INTERROGATORY 12:
(a)
Do you claim that the actual deferral in the need for power in the Northwest United States does not Justify deferring construction of WNP-17 (b)
Explain fully your answer to Interrogatory No.
12(a).
(c) If your answer to Interrogatory No. 12(a) is in the affirmative, state the relevance of your statement that
" Petitioner...does not believe the power from WNP-1 will ever be needed?"
to your claim that need for power in the Northwest United States does not Justify deferring construction of WNP-1.
RESPONSE
Intervenor does not understand wh0at
" deferral in the need for power" means but will answer upon clarification.
INTERROGATORY 13:
What is the factual basis for your statement that " Petitioner...does not believe the power from WNP-1 will ever be needed"?
RESPONSE
Intervenor ob ects to this interrogatory for J
)
the reasons outlined in the response to interrogatories Nos.
7 and 10 above.
INTERROGATORY 14:
Is it your contention that if and when the WNP-1 is completed and ready to operate, it will not be operated because there would be no need for the power?
RESPONSE
Intervenor objects to this interrogatry as the subject is not an issue in the proceeding.
o INTERROGATORY 15:
What factors do you contend are relevant in assessing whether power from WNP-1 will ever be needed?
RESPONSE: Intervenor objects to this interrogatory; see response to No. 7 above.
INTERROGATORY 16:
Explain the factual basis and/or legal authority for your statement that "[s31x to nine years cannot have been contemplated as a ' reasonable period of time' by the writers of 10 CFR 50.55(b)."
RESPONSE
Intervenor has no factual or legal basis for this statement.
INTERROGATORY 17:
What do you contend would be a reasonable period of time for extension of the construction completion date for WNP-17 RESPONSE: See response to Permittee's Interrogatory No.
20.
INTERROGATORY 18:
(a)
Identify any and all
" requirements of any regulations" promulgated since the date of docketing of the WNP-1 operating license application from which WNP-1 would otherwise be grandfathered by virtue of its date of docketing.
(b)
Explain fully how each of the requirements identified in response to Interrogatory No. 18(a) will delay completion of the plant beyond the requested completion date of 1991.
Give full details es to the extend to delay attributable to each such requirement.
RESPONSE: Intervenor ob ects to this interrogatory. The J
information which is sought is beyond the scope of the admitted contention.
The referenced quotation is part of a committment made by the Permittee to the NRC Staff; they are the parties who are in a position to identify the existence and impact of any future regulations promulgated beween the date of docketing of the application for an operating license and the resumption of construction.
Intervenor does
not have access to the records necessary and the expertise required to make auch a Judgement.
Moreover, Intervenor cannot anticipate what regulations will be promulgated in the next five years.
Respectfully submitted, Dated this day the 24th ina B of May, 1983.
Coalition for Safe Power l
i I
t
.~
UNITED STATES OF AMERICA CE-I5JKO NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 33 pl.3 31 P1 :34 In the Matter of
)
)
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
) Docket No. 50-460 CPA
-et. al.
)
)
(WPPSS Nuclear Project No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "INTERVEN0R'S RESPONSES TO NRC STAFF'S FIRST SET OF INTERROGATORIES" in the above captioned proceeding have been served, by deposit in the U.S. Mail, first class postage prepaid on this 24th day of May, 1983, on the following:
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 C:mmission 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 A
Nina Bell, Staff Intervenor Coalition for Safe Power
_- -