ML20083A064

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Statement of Matl Facts as to Which There Is Genuine Issue to Be Heard,In Support of Opposition to NRC & Util 831114 Motions for Summary Disposition
ML20083A064
Person / Time
Site: Washington Public Power Supply System
Issue date: 12/13/1983
From: Bell N
NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20083A047 List:
References
ISSUANCES-CPA, NUDOCS 8312200150
Download: ML20083A064 (3)


Text

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UNITED STATES OF AMERZCA NUCLEAR REGULATORY C0FDfISSION OCc M.h5D BEFORE THE ATOMIC SAFETY AND LICENSING BOARD a g

OEC In the Matter of ) I6

) ((^: c s 37 k'ASHINGTON PUBLIC POWER SUPPLY SYSTEM ) Docket.No~."50-460'CPA

) ct. ; . ,

(WPPSS Suelear Project No. 1) ) 5' MATERIAL FACTS TO k'HICH THERE ARE GENUINE ISSUES TO BE FED - 12/13/83

1. Prior to the Bonneville Power Adminstration (BPA) recommendation of April 19, 1982, the Washington Public Power Supply System (WPPSS)

Executive Board Finance Comittee had considered the option of plant deferral (April 5, 1982 Minutes at 5). That same Committee requested the BPA recommendation on plant financing (Minutes, April 19, 1982 at 5). The BPA made its recommendation for construction deferral on April 19, 1982 and the WPPSS Executive Board and Board of Directors concurred in that recommendation on April 29, 1982. Thus the decision to defer kWP-1 is traceable to the Applicant and was intentional.

2. The Applicant deferred construction on WNP-1 on April 29, 1982 and did not request the pending extension until January 11, 1983 from the NRC.
3. The Applicant had several options to the request for the extension including termination of the project, placing the project in a preser-vation state and to enter into negotiations with the owners of the WNP-3 project for deferral of that project and support for continued construc-tion of WNP-1. Deferral of WNP-1 which was 63% complete at the time compared to approximately 50% completion of WNP-3 was chosen as an option for political, not business prudence, reasons. ,

, 4. The deferral of WNP-1 was estimated to be between 2 to 7 years by BPA nearly one year ago. Analysis of Alternatives On-Line Dates for for k'NP-1 Office of Power Resource Management, BPA, October 2, 1982 at 8312200150 831213 PDR ADOCK 05000460 C Fac

13. BPA is currently considering deferral for up to 12 years. Analysis of Alternatives Related to WP-3, May 26,1983 by BPA. The Northwest Power Planning Council (WPPC) is planning the WP-1 completion date to be 1996. Rosolie Affidavit. . The WPPC has tied the completion of WP-1 to the completion of WP-3 which has been deferred for three years.

Analysis of Alternatives Related to WP-3; Summary and Conclusions, May 26, 1983 by BPA. -The WPPSS Executive Board will not make a decision on the overall. construction delay until October 1984. See Attachments C and D to-Answer.

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5. The BPA decision to mothball WP-3 has a direct impact on the deferral period of WP-1. Analysis of Alternatives Related to WP-3, May 26,1983, Attachment F. Since the decisions to defer both WP-1 and WP-3, the BPA has revised its forecast downward. See Attachment B. The "Model Electric Power & Conservation Plan for the Pacific Northwest", Nove.' tr 1982 by the Northwest Conservation Act Coalition shows the power from WP-1 will not be needed.
6. THe Applicant is currently unable to obtain financing for any of its projects because of its default on bonds for its WNP-4/5 projects.

Bailout plans before Congress have not included funding for WP-1. The Applicant has stated that completion of WP-1 rests on' financing (Licensee Additional Response to INtervenor's.'Second Set of Interrogatories, dated September 16,1983 , No. 26.) but no financing appears to exist for any time in the future. Rosolie Affidavit. The financial condition is more than temporary and thas no valid purpose exists for granting the extension.

7. One reason for the BOA recommendation was the escalating rates caused by the Applicant's construction program. Executive Board Minutes, April 23, 1982 at 5.
8. The Applicant has stated that the length of time of the delay is linked

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to need for power and financing, stating in its January 11, 1983 letter to NRC: "the actual length of delay will depend on regional energy demand considerations." In response to C0alition's interrogatories, the Applicant stated that completion of WNP-1 was tied to the ability to finance the

. plant.

9. The development of electrical demand forecasts is performed not only by BPA and the NWPPC, but also the Pacific Northwest Utilities Conference Committee, the Natural Recources Defense Council arid the Northwest Con-servation Act Coalition.

Respectfully submitted, p ~. f -

vv-~YNina Bell Dated this day, the 13th of December, 1983. Staff Intervenor

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