ML20080D260
| ML20080D260 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 08/26/1983 |
| From: | Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| ISSUANCES-CPA, NUDOCS 8308300283 | |
| Download: ML20080D260 (8) | |
Text
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HELATED COBRESPONDENU#
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UNITED STATES OF AMERICA SOCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC S..AFETY AND LICENSING BOARD In the Matter of
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Docket No.
et. al.
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BRANCH
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(WPPSS Nuclear Project No. 1)
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- 1. State the full name, address, occupation and employer of each person answering the interrogatory and designate the interrogatory or the part thereof he or she answered.
RESPONSE: Nina Bell, Staff Intervenor, and Eugene Rosolie, Director of the Coalition for Safe Power, 410 Governor Building, 408 S.W. 2nd, Portland, Oregon are Jointly respon-sible for the responses provided herein.
2.
Identify each and every person you are considering calling as a witness in the event a hearing is held in this proceeding and with respect to each of these witnesses:
a.
State the substance of the facts and opinions to which the witness is expected to testify;
- b. Give a summary of the grounds for each opinion; and
- c. Describe the witness's educational and professional backround.
RESPONSE: Intervenor will provide this information as an
~s updated response to Interrogatory 2 of Applicant's First Set of Interrogatories.
- 3. In response to Interrogatory 17 of Licensee's First Set of Interrogatories, you set forth a number of reasons why
,you believe WNP-1 was deferred.
Are they the only r'easons
- you contend that WNP-1 was deferred?
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RESPONSE: No.
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4.
If your response to Interrogatory 3 is no, state all other reasons you contend that WNP-1 was deferred.
RESPONSE
Cost of power produced by WNP-1 is uneconomical;
-- )i financing of ENP-1 is unavailable and imprudent; and the
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I construction of WNP-1 has been mismanaged.
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- 5. Of the reasons identified in Interrogatory 4, state which (if any) of those reasons were the principle respons why you contend that WNP-1 was deferred.
RESPONSE
Intervonor has no belief as to which reasons were principle.
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- 6. What are the bases for your responses to Interrogatories 3,
4, and 57 RESPONSE: " Northwest Conservation and Electric Power Plan",
Volume I, April 27, 1983 by the Northwest Power Planning Ccuncil; the " Analysis of Alternatives Related to WNP-3",
May 26, 1983 by the Bonneville Power Adminstration; the
- . c "Model Electric Power and Conservation Plan for the Pacific Northwest", November 1982 by the Northwest Conservation Act Coalition; " Analysis of Resource Alternatives" April 19, 1982 by the Bonneville Powar Adminstration; " Analysis of Resource Alternatives: Summary and Conclusions", May 26, s
1983 by the Bonneville Power Adminstration; conversations with Jim Lazar, eccnomist: testimony at the Hearing held June 10, 1983 Before the Subcommittee on Mining, Forest Management and Bonneville Power-Adminstration of the House
[ Committee on Interior and Insular Affairs; House Report No.
3 96-1452, " Evaluating Nuclear Utilities' Performance: Nuclear
Regulatory. Commission Overaight," October 2, 1980; Washing-ton State Senate Energy and Utilities Committee "WPPSS In-quiry" a report to the Washington State Senate and the 47th Legislature, March 1, 1981.
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- 7. State what you believe are the functions of the Bonne-ville Power Adminstration ("BPA").
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RESPONSE: Intervenor objects to this interrogatory because the scope of the requested information is overly broad;
- b answering such an interrogatory would be burdensome to the intervenor as the functions of the BPA are wide and varied, and of no relevance to the instant proceeding.
8.
State what you believe are the functions of the Licensee.
RESPONSE: Intervenor ob ects to this interrogatory for the J
reasons provided in the rcaponse to interrogatory 7 above.
- 9. Provide the bases for your response to Interrogatories 7 and 8.
RESPONSE: No response is required.
- 10. Stste what you believe is the extent, if any, to which 3
'BPA oversees and/or approves development and implementation of Liegn.see's construction oudget for WNP-1.
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RESPONSE: None.
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11.
State what you believe is the extent, if any, to which j
BPA oversees and/or approves development and implementation j
of Licensee's construction activities for WNP-1.
RESPONSE: None.
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- 12. Do you contend that Licensee should have continued the construction of WNP-1, notwithstanding the BPA recommen-l E::
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4-4 dation to, defer its construction for an additional two to five years?
t RESPONSE: Yes.
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- 13. If the answer to Interrogatory 12 is yes, explain fully 1
what sources of funding you believe were available to sup-
.c port continued construction.
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RESPONSE
At the time of the deferral of construction of 1
n, WNP-1, the Bonneville Power Adminstration was continuing to f[$
- *j fund the construction of WNP-3, thus this was a source of V "Oh4 i'" /
funding.
Moreover, the Net-Billing Agreements provide that the participants in the project will continue, to finance
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.y construction in any event (the so-called " hell-or-high-water
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',,; I clause").
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- 14. If the answer to Interrogatory 12 is no, explain whether j
in your opinion Licensee had a valid business purpose in deferring construction.
RESPONSE: There is no valid business purpose to deferring
'.i.f construction as the power from the plant is not, and will not be, needed and its cost will be too great; the plant
,f should be terminated.
- 15. Prov,ide the complete basis for your responses to Inter-rogatories 12, 13, and 14.
s RESPONSE: " Northwest Conservation and Electric Power Plan",
Volume I, April 27, 1983 by the Northwest Power Planning Council; the " Analysis of Alternatives Related to WNP-3",
May 26, 1983 by the Bonneville Power Adminstration; the
- /'Model Electric Power and Conservation Plan for the Pacific Northwest", November 1982 by the Northwest Conservation Act S
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Coalition; " Analysis of Resource Alternatives" April 19,
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1982 by the Bonneville Power Adminstration; " Analysis of
,j ll Resource Alternatives: Summary and Conclusions", May 26, i
1983 by the Bonneville Power Adminstration; conversations
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with Jim Lazar, economist; testimony at the Hearing held
- yj June 10, 1983 Before the Subcommittee on Mining, Forest e4 Management and Bonneville Power Adminstration of the House Committee on Interior and Insular Affairs.
- 16. In response to Interrogatories 20, 21 and 22 of Lican-7^
see's First Set of Interrogatories you stated what you meant by the term " reasonable period of time," what factors should be considered when determining if a requested construction permit is for a " reasonable period of time" and what would constitute a " reasonable period of time" in the case of WNP-1.
On June 22, 1983 you set forth in your Repsonse to Licensee's Motion to Compel the basis for your responses to those interrogatories and stated that you would again update your response.
Provide that updated response.
7 RESPONSE: The update will be provided in the next update.
- 17. Identify what obstacles exist in your opinion to fi-nancing WNP-1, the time needed for each obstacle to be over-come, and what must occur for each obstacle to be overcome.
RESPONSE: Insthe opinion of Intervenor the following ob-stacles exist to the financing of WNP-1: default on WNP-4/5; WPPSS mismanagement; no need for the power from the plant; and opposition to financing from the private utilities of
,the Northwest region.
Intervenor has not conducted'an independant study of the time needed to overcome each of
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.. i these obstacles nor what,must occur for thic to happen.
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- 18. Provide the complete basis for your response to Inter-rogatory 17.
RESPONSE: See response to Interrogatory 15.
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- 19. Do you contend that Licensee must demonstrate that WNP-1 will in fact be completed within the period provided for in the two to five year extension of its construction?
RESPONSE: Yes.
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- 20. Provide the complete basis for your response to Inter-rogatory 19.
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RESPONSE
Licensee represents that the plane will be com-
.1 plate within that time period; for the Licensing Board to
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. -$..h test the veracity of the claim, Applicant must attempt to 9
'A; demonstrate the plar.t will be completed by the date esta-j, blished.
A showing of this is also required to demonstrate
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' T, that the extension is for a "roaaonable period of time".
'l The Atomic Energy Act and 10 CFR SO.55(b) do not provide for extensions in the plural.
There is a safety and environ-mental significance to the provision of the Act which re-quires there to be a beginning and ending date for construc-tion. Numerous extensions, if granted, would challenge the
.s validity of the construction permit and the cost-benefit analyses under the National Environmental Protection Act.
There is a safety significance to building the plant in a timely manner thereby avoiding. material degredation etc.
- 21. Do you contend there has been a misallocation of funds on the WNP-1 and 4 projects such that funds will have to be 9
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repaid by,the WNP-1 project to the WNP-4 pro]ect?
RESPONSE: No.
22.
If the answer to Interrogatory 21 is yes, state the amount of the misellocation and identify the effect, if any, it would have on the construction of WNP-1.
RESPONSE: A response is not required.
23.
Provide the complete basis for your response to Inter-rogatories 21 and 22.
RESPONSE: A response to this interrogatory is not required.
24.
Identify all documents in your possessi'on obtained'from BPA concerning the delay of WNP-1 and state when and from whom you obtained each of these documents.
- 25. Identify all documents in your possession obtained from any source other than BPA concerning the delay of WNP-1 and state when and from whom you obtained each of these docu-ments.
RESPONSE: These documents will be identified, and made available for inspection and copying, on September 16, 1983.
1 Intervenor objects to the portion of interrogatories 23 and 24 which requests information on when and from whom these documents were received.
Such a request is burdensome, if not impossible, and has no relevance to this proceeding.
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s Respectfully submitted,
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2 Dated this day, the 26th ina Bell of August, 1983.
Coalition for Safe Power h
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.. J UNITED STATES OF AMERICA gfhhhfD NUCLEAR REGULATORY COMMISSION B E _FO_ _R E _T_ H E _ A T_O_ _M _I C_ _S_ A _F E_T_ Y _ A N D_ L _I C_ E_ N S_ _I N G_ _ B O_ A In the Matter of
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- 3 h
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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Docket p
CPA' et. al.
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BRANCH 7-
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(WPPSS Nuclear Project No. 1)
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CEBIIEICAIE_OE_SgBVICE
'l I hereby certify that copies of
" MOTION TO AMEND REQUEST FOR HEARING AND PETITION FOR LEAVE TO INTERVENE FILED BY INTERVENOR COA *ITION FOR SAFE POWER" and " COALITION FOR SAFE POWER RESPONSES TO APPLICANT'S SECOND SET OF INTERROGATORIES" in the above-l captioned matter have been served on the following by deposit in the U.S. Mail, first class, postage prepaid on this 26nd day of August, 1983:
Herbert Grossman, Chairman Nicholas Reynolds Atomic Safety & Licensing Board Debevoise & Lieberman Nuclear Regulatory Commission 1200 17th Street, N.W.
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 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 Nuclea_r.Roguletory Commission 300 G.
Washington Way Washington D.C.
20555 Richland, WA 99352 State of Was ington Atomic Safety & Licensing Appeal Energy Facility Site Evaluation Board Panel Council Mail Stop PY-11 Nuclear Regulatory Commission Olympia, Washington 98504 Washington D.C.
20555 Docketing & Service Nuclear Regulatory Commission Washington D.C. 20555 Abm _
P Nina Bell Coalition for Safe Power a
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