ML20080C724
| ML20080C724 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 08/22/1983 |
| From: | Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CPA, NUDOCS 8308290221 | |
| Download: ML20080C724 (5) | |
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RELATED COttitESPONDENce 00CKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEEgBE_IHE_6IQUIC_@6EEII,$Hg_LICEH@ leg _B9689 In the Matter of
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0FF:CE OF SECRETA-C' 00CKEIING & SERVC'
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B ANCH WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Docket No. 50- 60CPA et. al.
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(WPPSS Nuclear Project No. 1)
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CO.iLITION FOR SAFE POWER MOTION TO COMPEL ANSWERS TO THIRD SET 9E_IMIEBBgg6IgBIE@_Ig_6EELIC6 hit _69@y@I_2@t_19@@_
The Coalition for Safe Power, Intervenor in the above-captioned proceeding, served copies of its third set of l
Interrogatories on Applicant on July 13, 1983. Applicant responded on August 1, 1983.
Intervenor hereby moves for an Order causing Applicant to respond to interrogatories 5, 6,
9, and 16 and to respond more fully to interrogatories 2, 3,
13 and 14 for which inadequate responses were provided.
Applicant's ob ections to interrogatories 5, 9,
14 and 16 3
(or portions thereof) are based on its assertion that any I
Information sought which is related to WNP-3 is outside the scope of this proceeding.
In fact, these interrogatories seek I
l information on the effect of the actions at WNP-3 on the delay of WNP-1, at issue in this proceeding.
The Board has ruled (Memo and Order, August 15, 1983 at 4) that a "very direct connection-OE N$$
has been demonstrated between the restart of WNP-1 and the i
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" fortunes of WNP-3, WNP-4 and WNP-5."
O Eg Interrogatory 5 specifically requesta materiala related to no 00
&c the BPA review of WNP-3 which bears on WNP-1.
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te Interrogatory 9 addresses decisions made by WPPSS on WNP-3 mwo gy
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2-which bear on the completion of WNP-1. to this motion (excerpted from the WNP-3 Decision Document) shows clearly that the seven contingencies provided for " Alternative 2"
(" Reduce WNP-3 to Preservation State as Soon As Possible") affect the continued construction of WNP-1.
This interrogatory seeks to discover which scenario was chosen by WPPSS, in light of the BPA recommendation to halt WNP-3 construction for three years.
Interrogatory 14 seeks information regarding th'e effect of the construction halt on WNP-3 on the schedule for WNP-1.
Applicant replies that the deferral of WNP-3 was not for three years but only until a source of funding is assured.
Intervenor has not yet seen the July 8, 1983 resolution of the WPPSS Executive Board which Applicant refers to for this information.
However, Intervenor was present at a August 17, 1983 preheering conference in the Matter of Washington Public Power Supply System, Operating License, application for WNP-3 where Applicant's counsel s.tated that WNP-3 is in a "one year winddown of construction" and that "the outside limit of deferral is three years."
The BPA, in the " Analysis of Resource Alternatives, MEEEEr_EG _990ciggiggg, May 26, 1983" states that it "would d
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approve an Action by the Executive Board to effect, as soon as possible, transition of WNP-3 to a preservation ~ state for three years..." and that " financing alternatives are currently either unavailable or not prudent."
This appears contrary to Applicant's assertions at page 13 of its August 1, 1983. Response to Intervenor's Third Set of Interrogatories, that "WNP-3 has been deferred until a source of funding for its completion is assured."
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. Interrogatory 16 seeks information regarding the restart of construction of WNP-3.
The restart of WNP-3 has a direct bearing on the restart of WNP-1.
gge page 23 of the WNP-3 Decision Document and Memo and Order, su2rg._ While Licensee has indicated to the NRC that construction deferral is for three to nine months (See e.g.
August 19 letter from G.W.
Knighton, NRC to D.W.
1 Melton, WPPSS, Docket No. 50-508) BPA has stated it should be for three years.
For the purposes of this proceeding all parties should be put on notice as to the expected restart of WNP-1 and all factors bearing on it (including the restart of WNP-3).
Applicant's response to Interrogatory 13, which concerns misallocation of funds on the WNP-1/4 projects, is half-hearted and vague.
The BPA has considered this factor as a risk to F-financing the net-billed pro 3ects and as one of 6 factors affecting its financinal status and thus its ability to finance WPPSS (including WNP-1).
@gg page 19 of the WNP-3 Decialon Document.
Interrogatories 5 and 6 seek material used by the BPA to prepare the WNP-1 and WNP-3 Decision Documents, both of which bear on the continued construction of WNP-1 and which are detailed and'uneful analyses.
Applicant seeks to rely upon the BPA recommendation as the reason for its construction delay stating that BPA hca the ultimate authority over the plant.
The original documents, studies and.so forth used to prepare these
. analyses clearly form the basis for the case being made by the a
Applicant.
However, Applicant is unable or unwilling to provide the a aterials which have been used by those it claims have ultimate authority thus shielding itself and the deciaions from A
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scrutiny. 'WPPSS, as should be required to ensure that there is a full and complete public record.
In the alternative the Board should suspend the current hearings schedule to allow Intervenor to discover, through means of the Freedom of Information Act, 5 U.S.C. 552, as amended, from Bonneville Power Adminstration, a federal agency, the information which should clearly be a part of the record in.
this proceeding.
Interrogatories 2 and 3 request that documents be made available for inspection and copying.
These interrogatories also specifically request that a list be furnished of the documents which will be placed in the Applicant's Richland office.
Applicant has ignored this aspect of the interrogatory which is important to relieve Intervenor of travelling 400 possibly unnecessary miles.
Respectfully submitted, Dated this day, the 22nd Nina Bell j
of August 1989.
Coalition for Safe Power l
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L 00LKETED UNITED STATES OF AMERICA USNPC NUCLEAR REGULATORY COMMISSION Bg[gBg_IHg_6IggIC_S$EEIY_6HQ_LICENN3JGMD M0 :27 3
In the Matter of
)0FFICE OF SECRtia.
-l DOCKE-TING & SERVira WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Dod@ANCWo. 50-460CPA et. al.
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(WPPSS Nuclear Project No. 1)
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J CEBIIEICAIE_gE_SE8 MICE 1'
I hereby certify that copies of COALITION FOR SAFE POWER MOTION TO COMPEL ANSWERS TO THIRD SET OF INTERROGATORIES TO APPLICANT" j
above-captioned matter have been served on the following by in the deposit in the U.S. Mail, first class, postage prepaid on thi's 22nd 4
day of August, 1983:
Herbert Grcssman, Chairman Nicholas Reynolds Atomic Safety & Licensing Board Debevoise & Lieberman Nuclear Regulatory Commission 1200 17th Street, N.W.
r Washington D.C. 20555 Washington D.C.,20036 Glen O.
Bright Dr. Jerry Harbour Adminstrative Judge Adminstrative Judge Atomic Safety & Licensing Board Atomic Safety & Licensing Board I
Nuclear Regulatory Commission Nuclear Regulatory Commission Washington D.C. 20555 Washington D.C.
20555 Mitzi Young Gerald Sorenson, Manager Counsel for NRC Staff Licensing Program Office of Executive Legal Dir.
WPPSS Nuclear Regulatory Commission 300 G.
Washington Way Washington D.C. 20555 Richland, WA 99352 State of Washington Atomic Safety & Licensing Appeal Energy Facility Site Evaluation Board Panel j
Council Mail Stop PY-11 Nuclear Regulatory Commission Olympia, Washington 98504 Washington D.C.
20555 Docketing & Service i
Nuclear Regulatory Commission Washington D.C. 20555 jj m_
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Nina Bell Coalition for Safe Power l
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