Answer to Skagitonians Concerned About Nuclear Power 790530 Interrogatories & Document Requests.Responds to Questions Re Financial Matters.Certificate of Svc EnclML19241B500 |
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Skagit |
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06/18/1979 |
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Hastings W PORTLAND GENERAL ELECTRIC CO. |
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NUDOCS 7907180539 |
Download: ML19241B500 (10) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20063M6241982-09-0707 September 1982 First Set of Interrogatories Re Contentions 14,29,30 & 35. Certificate of Svc Encl.Related Correspondence ML20063M3321982-09-0101 September 1982 First Set of Interrogatories.Related Correspondence ML20063M3351982-09-0101 September 1982 First Set of Interrogatories.Related Correspondence ML20063M3391982-09-0101 September 1982 First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML19210E0631979-10-30030 October 1979 Interrogatories Directed to Applicant Re San Juan Islands Seismic Profiles Produced by Western Geophysical in 1971. Related Documents Should Be Presented on 791126.Questions Possible Matl False Statement by Applicant ML19210E0681979-10-30030 October 1979 Interrogatories to NRC Re San Juan Islands Seismic Profiles Produced by Western Geophysical in 1971.Related Documents Should Be Produced & Presented on 791126.Questions Possible Matl False Statement by Applicant.Certificate of Svc Encl ML19254F0561979-09-14014 September 1979 Interrogatories & Requests for Production of Documents, Directed to Applicant Re Bechtel Rept of Geological Investigations in 1978-79. Documents Should Be Delivered on 791001.Certificate of Svc Encl ML19209A7081979-08-21021 August 1979 Interrogatories & Document Requests to Util Submitted by Intervenor Skagitonians Concerned About Nuclear Power. Includes Questions Re Basis for Design of Blowdown Flow & Silica Content of Water.Certificate of Svc Encl ML19209A6991979-08-13013 August 1979 Response to Util Interrogatories & Document Requests.Submits Answers Re Source of Info,Witnesses,Publication of Repts & Availability of Documents.Supporting Documentation & Certificate of Svc Encl ML19261E7591979-06-25025 June 1979 Interrogatories & Document Requests Submitted by Intervenor Skagitonians Against Nuclear Plants to Applicants. Requests Info Re Jointly Owned Independent Subsidiary. Seattle Times 790607 Article & Certificate of Svc Encl ML19246B7931979-06-19019 June 1979 Answers Submitted by Puget Sound Power & Light Co to Skagitonians Concerned About Nuclear Power 790524 Document Requests & Interrogatories.Submits Info Re Bechtel Site Investigation,Financial Matters & Geological Surveys ML19246B8001979-06-19019 June 1979 Answers Submitted by Puget Sound Power & Light Co to Skagitonians Concerned About Nuclear Power 790530 Document Requests & Interrogatories for Pacific Power & Light Co. Certificate of Svc Encl ML19241B5001979-06-18018 June 1979 Answer to Skagitonians Concerned About Nuclear Power 790530 Interrogatories & Document Requests.Responds to Questions Re Financial Matters.Certificate of Svc Encl ML19246B7071979-06-14014 June 1979 Answer to Skagitonians Concerned About Nuclear Power 790530 Interrogatories & Document Requests.Util Has No Documents Containing Info on Min Capacity for Spent Fuel for 1978 ML19241A6301979-05-31031 May 1979 Interrogatories & Document Requests,Submitted for Intervenor Skagitonians Concerned About Nuclear Power by Util.Questions Concern Geological Features,Design & Const of Plant,Names of Witnesses & Emergency Plans.Certificate of Svc Encl ML19246B2921979-05-30030 May 1979 Interrogatories & Document Requests to Pacific Power & Light,Submitted by Skagintonians Concerned About Nuclear Power.Requests Include Info Re Form 10-K for 1978,environ Effects of Plant & Activities of Employees & Consultants ML19246B2961979-05-30030 May 1979 Interrogatories & Document Requests to Portland General Electric,Submitted by Skagitonians Concerned About Nuclear Power.Requests Include Info Re 790227 Prospectus, Coal Contracts,Bank Credit & Activities of Employees ML19276G5781979-05-29029 May 1979 Interrogatories & Document Requests to Nrc,Submitted by Intervenors Skagitonians Concerned About Nuclear Power. Requests Include Info Re Thermal Pollution & Salmonids, Earthquakes & Generic Safety Issues Raised by TMI ML19246B3021979-05-29029 May 1979 Interrogatories & Document Requests to Wa Power Co,Submitted by Intervenors Skagitonians Concerned About Nuclear Power. Requests Include Info Re Const Costs,Operation Costs & Estimated Cost of Power.Certificate of Svc Encl ML19224C8031979-05-29029 May 1979 Interrogatories & Document Requests for Puget Sound Power & Light Co Submitted by Skagitonians Concerned About Nuclear Power.Questions Concern Bechtel Reinvestigation of Site Area & Evacuation Plans ML19259B3081979-01-0909 January 1979 Interrogatories Submitted by Intervenors to Nrc.Queries Concern Info Used in Preparation of Certain Documents,Scope of Instructions to Employees & Acoustical or Seismological Studies.Certificate of Svc Encl ML20150A9071978-10-0202 October 1978 State of Wa Water Power Co Response to Intervenor Scanp 780913 Interrogatories & Request for Production of Documents Re Siting & Costs of Proposed Facility,Cost of Mills,Pkh of Installed Capacity & Identification of Documents 1982-09-07
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl ML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding ML20080L9431983-09-28028 September 1983 Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl ML20080G0731983-09-13013 September 1983 Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl ML20071Q7201983-06-0303 June 1983 Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl ML20071M0781983-05-25025 May 1983 Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl ML20023C4571983-05-12012 May 1983 Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl ML20023C3741983-05-12012 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1 ML20023C3691983-05-12012 May 1983 Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists ML20023C6971983-05-12012 May 1983 Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl ML20064N6681983-02-10010 February 1983 Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs ML20071A6671983-02-10010 February 1983 Certifies Svc of Intervenor Motion to Suspend Safety & Health Schedule on 830210 ML20070T0661983-02-0404 February 1983 Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc ML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20083N1991983-01-26026 January 1983 Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl ML20028F1831983-01-25025 January 1983 Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20028E9701983-01-19019 January 1983 Reply to NRC & Applicant Response to Natl Wildlife Federation/Or Environ Council,Columbia River Inter-Tribal Fish Commission & Coalition for Safe Power 821213 Motion to Clarify & Amend Certain Contentions.W/Certificate of Svc ML20072A6731983-01-18018 January 1983 Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl ML20028C9581983-01-0505 January 1983 Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc ML20028C9501983-01-0505 January 1983 Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents ML20028C3221983-01-0303 January 1983 Suppl to DOE 821126 Limited Appearance Statement.Doe Position Is That Hanford Site Is Not Open,Unclaimed Land as Defined in 1855 Treaty W/Yakima Indian Nation,Article Iii. ASLB Is Wrong Forum for Resolving Issue ML20070L5411982-12-27027 December 1982 Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded ML20070L4901982-12-27027 December 1982 Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl ML20079J6021982-12-23023 December 1982 Response Supporting Intervenor 821213 Motion to Clarify & Amend Contentions 7 & 8.Quantification of Environ Impacts Not Practicable Due to Subjective Nature.Certificate of Svc Encl ML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20079H3711982-12-13013 December 1982 Motion to Clarify & Amend Contentions 7 & 8.Contentions Should Be Reorganized to Facilitate Coordinated Evidentiary Presentations for Environ Matters ASLB Set Out as Contentions 4,7 & 8.Certificate of Svc Encl ML20070D1181982-12-10010 December 1982 Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land ML20070C9121982-12-10010 December 1982 Notice of Counsel New Law Firm Affiliation,As of 820901 ML20070C8181982-12-10010 December 1982 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Yakima Indian Nation Contentions 7,8 & 9.Nation Right to Enjoy Reservation Peacefully Given by 1855 Treaty Should Be Protected by ASLB ML20070C7981982-12-10010 December 1982 Brief Supporting Admissibility of Yakima Indian Nation Reworded Proposed Contention 10.Attempt to Terminate Reserved Rights of Yakima Indian Nation Violates Fifth Amend.Land Cannot Be Taken by Inverse Condemnation ML20070C7691982-12-10010 December 1982 Certifies Svc of Brief on Admissibility of Reworded Proposed Contention 10,motion for Reconsideration of ASLB 821029 Memorandum & Order,R Jim Affidavit & Notice of Counsel Law Firm Change on 821210 ML20028B9251982-12-0101 December 1982 Brief Re Admissibility of Yaking Indian Nation Proposed Contention 10.Clarification Needed on Procedural Rule of Commission & Scope of Contention.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20028B2631982-11-26026 November 1982 Limited Appearance Statement.Hanford Site Is Not Part of Yakima Indian Nation Reservation Established by 1855 Treaty. Indian Privilege of Hunting,Gathering Roots & Berries & Grazing Animals Does Not Extend to Hanford Site ML20066L0101982-11-22022 November 1982 Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl ML20066K9761982-11-22022 November 1982 Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20023A8141982-10-14014 October 1982 Response to Yakima Indian Nation 820930 Suppl to Petition to Intervene,Containing List of Contentions.Objects to Contentions 4-10.Certificate of Svc Encl ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20063P4011982-10-0606 October 1982 Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20069F9491982-09-23023 September 1982 Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl ML20069F9541982-09-23023 September 1982 Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl ML20137F8001982-09-17017 September 1982 Amended Subagreement 2 Between State of Wa Energy Facility Site Evaluation Council & NRC Re Protocol for Conduct of Joint Hearings on Facility Project ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5571982-09-15015 September 1982 Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl 1983-09-28
[Table view] |
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I}F,1.ATER CONO!PONIclNtB UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of f C PUBLIC DOCInmur nooy
)
PUGET SOUND POWER & LIGHT COMPANY, ) Docket Nos. STN 50-522 et al., ) 50-523
)
(Skagit Nuclear Power Project, )
Units 1 and 2) )
ANSWER OF PORTLAND GENERAL ELECTRIC COMPANY TO INTERVENO A SCANP ' S INTERROGATORIES AND REQUESTS FOR PRODUCTION DATED MAY 30, 1979 In accardance with 10 CFR, 52.740B and 10 CFR S2.741, Portland Genercl Electric Company answers SCANPS Interrogatories and responds to its accompanying Requests for Production as follows:
Documents produced will be made available at the offices of Perkins, Coie, Stone, Olsen and Williams, 1900 Washington Building, Seattle, Washington at 9:00 a.m. June 29, 1979, or at such other time and place as may be agreed upon.
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ANSWERS TO SCANP INTERROGATORIES DATED MAY 30, 1979 Interrogatory No. 1 "Troj an 's incremental costs" are these costs incurred for energy produced by the plant over any fixed costs which are incurred whether or not such energy is produced. While Trojan was out of service, its incremental cost of energy would have been approximately 2.6 mils per kilowatt hour, nearly all of which is attributed to fuel consumption.
Interrogatory No. 2 The affect on the Compar~ earnings, cash position, and available capital from the denial of rate relief sought to recover excess power costs due to the Trojan shutdown is already included in the financial staterents included in the prospectus. Increased power costs of approximately $26 million were incurred as a result of the Trojan shutdown. Based on a maximum statutory tax rate of 51.9 percent, PGE estimates that the ef fect on earnings of this additional power cost was about $0.50 / share of common stock. The effect on PGE's cash position was substantially less than $26 million, since replacement power was not all purchased immediately, but rather borrowed for future replacement in some cases. PGE is unable to determine what the term "available capital" in Interrogatory 2 is referring to. It would be pure speculation to attempt to assess the effect of the Trojan shutdown en "available capital" from the myriad sources of funds which make up the capital market.
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Interrogatory No. 3 PGE's "present plans for joint ownership of certain future generating f acilities" are discussed at length beginning on pge 20 of the prospectus under the title " Future Resources".
The specific generating facilities referred to may be found in the table presented on page 20.
Interrogatory No. 4 PGE is able to issue preferred stock on the date hereof. I.e ter in 1979 and beyond the capacity to issue preferred stock will depend upcn power purchase cost, the form of financings selected to raise new capital and the timeliness and amount e --te relief. Other financing alternatives to PGE include the issuance of bonds and common stock, short and intermediate term borrowings, and lease financing.
Interrogatory No. 5 PGE is able to issue additional first mortgage bonds on the date hereof.
Interrogatory No. 6 i'able 2-8 of Applicant's Testimony on Financing Qualifications ,
Note 4, states that Table 2-7 was constructed using a forecasted rate of increase in average sales price of 9.9 percent, which maintains a constant 12.84 percent per year return on common stock equity. This is assumed to be received through future rate relief. Under this forecast, the earnings coverage ratio ,
.for bonds improves through 1990. The coverage ratio for preferred stock would also improve through 1990.
519 003
experience at Troi'" This estimate was put in both a cash ficw format and c PC Account format, both of which are available for review. PGE and Bechtel periodically review and update the estimate. The most recent cost estimate in FPC Account form is available for review.
Information with respect to the Boardman coal plant is based in part on estimates by PGE engineers and Bechtel, but also en actual costs incurred in constructing this plant. The most recent construction cost studies by PGE and Bechtel are available for review.
Information with respect to the Skagit, Colstrip and WPPSS No. 3 projects has been obtained from the respective project sponsors.
The direct construction cost estimates used by the co-owners of any given plant are identical. However each co-owner may choose its own form of presentation for various disclosure documents required by regulatory agencies. The " dis crepan cy" between the cost /kw figure as presented by Puget Sound and PGE is attributable to a) a difference in the capital; ~.ed cost of money which accures on direct construction costs between the two companies, b) a difference in certain overhead cost items, c) the capitalization of property taxes by Puget on its share and the deletion of this by PGE, and
, d) the election by PGE to treat both units of a project separately and the combined treatment by Puget. t 9 004 Interrogatory No. 7 The " future generating units" referred to are those in the table on page 20 of the prospectus. The specific plants subject to partial sale or delay would be selected after consideration of a number of factors, including licensing status, cos t projections, load forecasts, financing capability and other factors. Prospective purchasers of 2 partial interest in a future generating f acility include investor-owned and publicly-owned utilities in the Pacific Northwest and California.
Interrogatory No. 8 PGE has not predicted with assurance that the regional power -
legislation will in fact be passed, and if it does pass , what the form will be. Why the currently prcposed regional power legislation would "give assurance to the Company that the cost of construction and operation of its new thermal plants would be recovered" is explained in paragraph 3 under the heading
" Proposals for Reallocation of Federal Power" on page 18 of the prospectus. The only document relevant to the answer of this interrogatory is the regional power bill itself which is Senate Bill 885 - Pacific Northwest Electric Power Planning and Conservation Act.
Interrogatory No. 9 Cost information in the table on page 20 of the prospectus pertaining to the Pebble Springs Project has been produced by PGE engineers and Bechtel, the engineering firm employed on the construction of Trojan and Pebble Springs. An original estimate was made by Bechtel based on the consey46]LionOboht Interrogatory No. 10 Agreement, dated January 23, 1976, among the four utilities participating in the Skagit and Pebble Springs projects, which has previously been made a part of the record in this proceeding.
Interrogatory No. 11 Puget will supply you a copy of the letter from the U.S.
Geological Survey confirming the adequacy of the Skagit site.
Interrogatory No. 12 The coal contract for Boardman was entered into during 1974 during a market when commercial bargaining position of supplies and users was substantially different than today. Therefore the contract, and any provisions thereof pertaining to prica, are not relevant to any matter in controversy, particularly the ecst of alternate sources of energy such as coal fired generating plants.
Information as to actual current coal prices which is relevant and not confidential proprietary may be found in a number of
~
coal industry per odicals, including Coal Week, published by McGraw-Hill. A copy of prices from this publication is available for review.
The most definitive current railroad tariff for coal transportation tc the Boardman plant has been published by the Burlington
, Northern (copy available for review). The parties are attempting to negotiate lower tariffs. This may be subj<ct th hhnte efore the nterstate Commerce Commission. There is no assurance that the r ablished tariff will not become the actual tariff.
Interrogatory No. 13 a) no b) no c) no Interrogrtory No. 14 PGE's principal lines of credit are under three agreements :
a) The Boardman Power Company Loan Agreement, dated as of November 15, 1977.
b) Credit Agreement, dated July 31, 1978.
c) Revolving Facility, dated July 20, 1978.
The banks participating in such lines of credit and the conditions or circumstances under which such lines of credit may be cancelled, terminated, or reviewed, are stated in the respective agreements.
Respectfully submitted, i,/ )l,
- 1Y.9% 4MD Warren Hasbings Attorney for Applicants Dated at Portland, Oregon this 18th day of June, 1979.
5\ 007 State of Oregon )
) ss County of Multnoman )
I, WARREN HASTINGS, being first duly sworn, depose and say that I am Assistant Secretary and Associate Corporate Counsel of Portland General ) .ectric Company. The foregoing Portland General Electric Company's Answers to SCANP Interrogatories dated May 30, 1979 were prepared under my supervision and direction and are true as I verily believe.
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Warren Hasti,ngs Subscribed and sworn to before me this 18th day of June, 1979.
on o h n&
Nogary Public for Oregon My Commission expires: April 11, 1980 519 008 e- se p Sb
'M 90 %
l' JUN21 1979 > T h w ag gggr i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL B In the Matter of )
)
PUGET SOUND POWER & LIGHT COMPANY, )
et al. Docket Nos. 50-522
)
)
50-523 (Skagit Nuclear Power Proj ect, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that the following:
ANSWER OF PORTLAND GENERAL ELECTRIC COMPANY TO PRODUCTION DATED MAY 1979 30,INTERVENOR SCANP 'S INT in the above-captioned proceeding have been served upon e th persons shown on the attached lis t by depositing copies th ereof in the United States mail on June 18, 1979 with proper postage affixed for first class mail.
Dated: June 18, 1979
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Warren'Hastgngs Attorney for Portland 121 S. W.General Electric Company Salmon Street Portland, Oregon 97204 Si9 009
Valentine B. Deale, Chairman Thomas F. Carr, Esq.
Atomic Jafety and Licensing Board Assistant Attorney General 1001 Connecticut Avenue, N.W. Temple of Justice Washington, D.C. 20036 Olympia, WA 9E504 ,
Dr. Frank F. Hooper, Member Robert C. Schofield, Director Atomic Safety and Licensing Board Skagit County Planning Department School of Natural Resources 218 County Administration Building University of M' Sigan Maunt Vernon, WA 98273 Ann Arbor, MI %.09 Richard M. Sandvik, Esq.
Gustave A. Linenberger, Member Assistant Attorney General Atomic Safety and Licensing Bc?rd 500 Pacific Building U.S. Nuclear Regulatory Commission 520 S. W. Yamhill Washington, D.C. ~7555 Portland, OR 97204 Alan S. Rosenthal, 'hai rman Roger M. Leed, Esq.
Atomic Safety and L censing Room 610 Appeal Board 1411 Fourth Avenue Building U.S. Nuclear Regulatory Commission Seattle, WA 98101 Washington, D.C. 20555 CFSP and FOB Dr. John H. Buck, Member E. Stachon & L. Marbet Atomic Safety and Licensing 19142 S. Bakers Ferry Road Appeal Board Bcring, OR 97009 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert Lowenstein , Esq.
Lowenstein, Newman, Reis, Axelrad Michael C. Farrar, Member & Toll Atomic Safety and Licensing 102 5 Connecticut Avenue , N.W.
Appeal Board Washington, D.C. 20036 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 F. Theodore Thomsen, Esq.
Perkins, Coie, Stone, Olsen &
Docketing and Service Section Williams Office of the Secretary 1900 Washington Building U.S. Nuclear Regulatory Commission Seattle, WA "3101 Washington, D.C. 20555 Richard D. Bach, Esq.
Richard L. Black, Esq. Rives , Bonyhadi, Drummond & Smith Counsel for NRC Staff 1400 Public Service Building U.S. Nuclear Regulatory Commission 920 S. W. 6th Avenue Office of the Executive Legal Portland, OR 97204 Director Washington, D.C. 20555 Canadian Consultate General Donald Martens, Consul Nicholas D. Lewis, Chairman 412 Plaza 600 Energy Facility Site Evaluation 6th and Stewart Street Council Seattle, WA 98101 820 East Fifth Avenue Olympia, WA 98504 519 010