ML20080M554
| ML20080M554 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 09/27/1983 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| ISSUANCES-CPA, NUDOCS 8310040200 | |
| Download: ML20080M554 (5) | |
Text
_,
UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION ggg.gg 03y fE BEEQBE_IBE_6IggIC_S$EEIY_6Ng_LICgySIgg 6 In the Matter of )
WASHINGTON PUBLIC POWER SUPPLY SYSTEM Do 8hfhkfMph460CPA et. a1. )
BRANCO %
)
(WPPSS Nuclear Project No. 1) )
INTERVENOR'S UPDATE RESPONSE TO LICENSEE'S SECOND SET OF INIEB8996IQBIgg_6NQ_8Eggg@I_IQ_EBgQggE t _6pgy@I_13t_12@@
IDtstresst9tr_Z State what you believe are the functions of Bonneville Power Adminstration (BPA).
EgsD9gsg '~
Intervenor believes the functions of BPA is to -
distribute electrical energy in the Pacific Northwest and duties as contained in the Pacific Northwest Electric Power Planning and Conservation Act, enacted December 5, 1980.
ID t grrgggtggy_@
State what you believe are the functions of Licensee.
Egsggggg Intervenor believes that Licensee's function is to construct, finance and operate electrical generating facilities.
IDtgrrgggtgry_2 Provide the bases for your response to Interrogatories 7 and 8.
8310040200 830927 m PDR ADOCK 05000460 QQ G PDR
r o 89999092
- 1. Pacific Northwest Electric Power Planning &
Conservation Act, A Summary, Bonneville Power Adminstration (BPA), uncated.
- 2. Pacific Northwest Electric Power Planning &
Conservation Act of 1980, 16 U.S.C. sec.839.
- 3. Net Billing Agreement, November 16, 1972.
- 4. WPPSS Inquiry, Washington State Senato Energy &
Utilities Committee, January 12, 1981.
Igtgggggatgry_;s Identify all documents in your possession obtained from BPA concerning the delay of WNP-1 and state when and from whom you obtained each of these documents.
8gspggsq
- 1. Analysis of Alternatives Related to WNP-3, May 26, 1983, BPh.
- 2. Analysis of Resource Alternatives: Summary and Conclusions, May 2 6,, 1983, BPA.
Intervenor continues to object to the other part of this interrogatory.
IDt9EE999E9EE_2E Identify all documents in your possession obtained from any source other that BPA concerning the delay of WNP-1 and state when and from whom you obtained each of these documents. .
B9me90ee Intervenor has already idenified all documents in its possession in various filings in this proceeding. Except. [
for the documents referred to interrogatory 24 all other documents have been obtained from other than t'he BPA. '\
Intervenor also now has in its possession documents received from Licensee after requesting copies of certain h
(
^*
s *
\
,q 3
-i k.
,,~ - n , , , ,
n,- . , - .
- documento Licenseo made available in response to Intervenor interrogatories. Intervenor assumes that Licensee knows what those documents are so sees no need to list those documents at this time. However if Licensee does not have that last Intervenor will supply a list upon request.
Intervenor also has in its possession the following documents:
- 1. Informal Opening Remarks, Peter T. Johnson, Bonneville Power Adminstrator, Before the Subcommittee on Mining, Forest Management and Bonneville Power Adminstration of the House Committee on Interior and Insular Affairs, Portland, Oregon, June 10, 1983.
- 2. Northwest Power Planning Council, Statement Before the Subcommittee on Mining, Forest Management, and the Bonneville Power Adminstration of the Committee on Interior and Insular Affairs, June 10, 1983.
- 3. Letter with Attachment from D.W. Mazur, Managing Director, WPPSS, to Honorable Jim Weav'~rye Chairman, Subcommittee on Mining, Forest Management, and Bonneville Power Adninistration, dated June 8, 1983.
Respectfully submitted y J Eug e Rosoli , Director Coa ition For Safe Power September 27. 1983.
'k r
ek
~
. , - _ _ - . - _ . ~
_ .y.
STATE OF OREGON )
) ss.
County of Multnoman )
I, Eugene Rosolie, having first been duly sworn, do depose and say as follows:
- 1. That I reoresent the Coalition for Safe Power in the Matter of WASHINGTON PUBLIC POWER SUPPLY SYSTEM (WNP-1),
Docket 50-460C0A; and
- 2. That the responses to " LICENSEE' S SECOND SET OF INTERROGATORIES AND REQUEST TO PROVIDE TO INTERVENOR, DATED AUGUUST 12, 1983," and those responses contained in "INTERVENOR' S UPDATE RESPONSE TO LICENSEE' S SECOND SET OF INTERROGATOHIES AND REQUEST TO PRODUCE," Wuere prepared under my direction and are true and correct to the best of my knowledge except as to matters therein stated on information and belief, and as to that I believe them to be true.
Signed:
Euger Rosoli
(
SUBSCRIBED AND SWORN TO before rne this ahk J _d
__ day of
_________.,4 d&tfdgy/_, 1983.
Not y Public for Oregon M ommissionExpires//)J/8f 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEE 9BE_IHE_6IQ8IC_!6EEIy_8ND_LIQE8@INQ,BQ68Q In the Matter of )
)
WASHINGTON PUBLIC POWER SUPPLY SYSTEM ) Docket No. 50-460CPA et. al. )
)
(WPPSS Nuclear Project No. 1) )
QEBIIEIQ6IE_gE_!E8VIgE I hereby certify that copies of "INTERVENOR'S RESPONSE TO LICENSEE MOTION TO COMPEL," and "INTERVENOR'S UDATED RESPONSE TO LICENSEE'S SECOND SET OF INTERROGATORIES AND REQUEST TO PRODUCE, AUGUST 12,1983," in the above captioned matter have been served on the following by deposit in the U.S. Mail, first class, postage prepaid on this 27TH day of September, 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 l Counsel for NRC Staff Licensing Program Office of Executive Legal Dir. WPPSS 4 Nuclear Regulatory Commission 300 G. Washington Way Washington D.C. 20555 Richland, WA 99352
(
l State of Washington Atomic Safety & Licensing Appeal Energy Facility Site Evaluation Board Panel i Council Mail Stop PY-11 Nuclear Regulatory Commission l Olympia, Washington 98504 Wash 2ngton D.C. 20553 Docketing & Service Nuclear hogulatory Commisuion Washington D.C. 20555 -
i
_____ _____ _[JC9dl_______
Eug e Rosol
! Coe ition fo,/e r Scre Power l
t L-