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Category:INTERVENTION PETITIONS
MONTHYEARML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate 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 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 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 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 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 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 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 ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20058G4091982-07-30030 July 1982 Response Opposing Columbia River Inter-Tribal Fish Commission 820716 Motion for Admission of Second Suppl to Petition to Intervene & Response to ASLB 820702 Order. Certificate of Svc Encl ML20063H1271982-07-20020 July 1982 Statement Supporting Yakima Indian Nation Petition to Intervene.Many Aspects of Petition Germane Only to Representation by Yakima Indian Nation ML20063H1191982-07-16016 July 1982 Second Suppl to Petition to Intervene,Listing Contentions & Bases for Contentions ML20054L8301982-06-29029 June 1982 Reply to NRC & Applicant Objections to Natl Wildlife Federation & or Environ Council 820521 Amended Contentions. All Amended Contentions Should Be Admitted.Certificate of Svc Encl ML20054F7001982-06-11011 June 1982 Response to Coalition on Safe Power 820524 Revised Contentions.Supports Admission Only of Revised Contentions 1,2,3,4.A-E,29.B,29.G,29.H & 29.I.Certificate of Svc Encl ML20054F3391982-06-11011 June 1982 Answer to Coalition for Safe Power 820525 Revised Contentions.Contentions Should Be Rejected Due to Lack of Adequate Notice of Particular Issues to Be Litigated. Certificate of Svc & DOJ 810715 Opinion Encl ML20053D5751982-06-0202 June 1982 Response to Natl Wildlife Federation/Or Environ Council 820521 Amended Contentions.Balancing Factors Governing Late Contentions Weigh Against Admission.Contentions 3.E & 5.A Objectionable.W/Certificate of Svc ML20051H4581982-05-10010 May 1982 Petition to Intervene in Proceeding.Affidavit of Svc Encl ML20052F3601982-05-0505 May 1982 Petition of Columbia River Inter-Tribal Fish Commission to Intervene in Proceeding ML20052F3641982-05-0505 May 1982 Suppl to Petition to Intervene of Columbia River Inter-Tribal Fish Commission,Listing Contentions to Be Litigated ML20052F5181982-05-0404 May 1982 Answer to Supplemental Petitions to Intervene.Util Does Not Object to NRDC Contentions & to Natl Wildlife Federation/Or Environ Council First Two Contentions.Coalition for Safe Power Contentions Should Be Rejected.W/Certificate of Svc ML20052A3041982-04-20020 April 1982 Suppl to Amended Petition to Intervene,Listing Contentions. Proof of Svc Encl ML20052A3851982-04-20020 April 1982 Amended Petition to Intervene Delineating Nature of Petitioner Interest & Specific Aspects of Proceeding to Which Intervention Is Sought.Certificate of Svc Encl ML20052A3881982-04-20020 April 1982 Suppl to Petition to Intervene,Listing Conditions to Be Litigated.Certificate of Svc Encl ML17276B8071982-04-19019 April 1982 Suppl to Amended Petition to Intervene,Listing Contentions & Basis for Contentions ML20050E2811982-04-0505 April 1982 Amended Petition to Intervene.Exhibits Encl ML20042B4161982-03-22022 March 1982 Answer Opposing Coalition for Safe Power & Forelaws on Board 820306 Request for Hearings & Amended Petition to Intervene.Petitioner Failed to Allege Sufficient Basis for Standing.Certificate of Svc Encl ML20042B7121982-03-19019 March 1982 Answer Opposing NRDC 820304 Petition to Intervene.Petitioner Failed to Allege Sufficient Basis for Standing to Intervene as Matter of Right on Own Behalf or on Behalf of Members. Certificate of Svc Encl ML20042B7291982-03-19019 March 1982 Answer Opposing Natl Wildlife Federation & or Environ Council 820308 Petition to Intervene.Petitioners Failed to Allege Sufficient Basis for Standing to Intervene. Certificate of Svc Encl ML20041F0271982-03-0808 March 1982 Petition to Intervene in Proceeding.Certificate of Svc Encl ML20049J6581982-03-0606 March 1982 Amended Petition to Intervene in Proceeding & Request for Hearing.Affidavits & Certificate of Svc Encl ML20041E5871982-03-0404 March 1982 Petition to Intervene in Proceeding.Notice of Appearance & Proof of Svc Encl 1983-01-31
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate 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 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 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 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 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 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 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 ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20058G4091982-07-30030 July 1982 Response Opposing Columbia River Inter-Tribal Fish Commission 820716 Motion for Admission of Second Suppl to Petition to Intervene & Response to ASLB 820702 Order. Certificate of Svc Encl ML20063H1271982-07-20020 July 1982 Statement Supporting Yakima Indian Nation Petition to Intervene.Many Aspects of Petition Germane Only to Representation by Yakima Indian Nation ML20063H1191982-07-16016 July 1982 Second Suppl to Petition to Intervene,Listing Contentions & Bases for Contentions ML20054L8301982-06-29029 June 1982 Reply to NRC & Applicant Objections to Natl Wildlife Federation & or Environ Council 820521 Amended Contentions. All Amended Contentions Should Be Admitted.Certificate of Svc Encl ML20054F7001982-06-11011 June 1982 Response to Coalition on Safe Power 820524 Revised Contentions.Supports Admission Only of Revised Contentions 1,2,3,4.A-E,29.B,29.G,29.H & 29.I.Certificate of Svc Encl ML20054F3391982-06-11011 June 1982 Answer to Coalition for Safe Power 820525 Revised Contentions.Contentions Should Be Rejected Due to Lack of Adequate Notice of Particular Issues to Be Litigated. Certificate of Svc & DOJ 810715 Opinion Encl ML20053D5751982-06-0202 June 1982 Response to Natl Wildlife Federation/Or Environ Council 820521 Amended Contentions.Balancing Factors Governing Late Contentions Weigh Against Admission.Contentions 3.E & 5.A Objectionable.W/Certificate of Svc ML20051H4581982-05-10010 May 1982 Petition to Intervene in Proceeding.Affidavit of Svc Encl ML20052F3601982-05-0505 May 1982 Petition of Columbia River Inter-Tribal Fish Commission to Intervene in Proceeding ML20052F3641982-05-0505 May 1982 Suppl to Petition to Intervene of Columbia River Inter-Tribal Fish Commission,Listing Contentions to Be Litigated ML20052F5181982-05-0404 May 1982 Answer to Supplemental Petitions to Intervene.Util Does Not Object to NRDC Contentions & to Natl Wildlife Federation/Or Environ Council First Two Contentions.Coalition for Safe Power Contentions Should Be Rejected.W/Certificate of Svc ML20052A3041982-04-20020 April 1982 Suppl to Amended Petition to Intervene,Listing Contentions. Proof of Svc Encl ML20052A3851982-04-20020 April 1982 Amended Petition to Intervene Delineating Nature of Petitioner Interest & Specific Aspects of Proceeding to Which Intervention Is Sought.Certificate of Svc Encl ML20052A3881982-04-20020 April 1982 Suppl to Petition to Intervene,Listing Conditions to Be Litigated.Certificate of Svc Encl ML17276B8071982-04-19019 April 1982 Suppl to Amended Petition to Intervene,Listing Contentions & Basis for Contentions ML20050E2811982-04-0505 April 1982 Amended Petition to Intervene.Exhibits Encl ML20042B4161982-03-22022 March 1982 Answer Opposing Coalition for Safe Power & Forelaws on Board 820306 Request for Hearings & Amended Petition to Intervene.Petitioner Failed to Allege Sufficient Basis for Standing.Certificate of Svc Encl ML20042B7121982-03-19019 March 1982 Answer Opposing NRDC 820304 Petition to Intervene.Petitioner Failed to Allege Sufficient Basis for Standing to Intervene as Matter of Right on Own Behalf or on Behalf of Members. Certificate of Svc Encl ML20042B7291982-03-19019 March 1982 Answer Opposing Natl Wildlife Federation & or Environ Council 820308 Petition to Intervene.Petitioners Failed to Allege Sufficient Basis for Standing to Intervene. Certificate of Svc Encl ML20041F0271982-03-0808 March 1982 Petition to Intervene in Proceeding.Certificate of Svc Encl ML20049J6581982-03-0606 March 1982 Amended Petition to Intervene in Proceeding & Request for Hearing.Affidavits & Certificate of Svc Encl ML20041E5871982-03-0404 March 1982 Petition to Intervene in Proceeding.Notice of Appearance & Proof of Svc Encl 1983-01-31
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding ML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl 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 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 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 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 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 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 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 ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions 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 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 ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc 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 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
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.z In the Matter of )
)
PUGET SOUND POWER & LIGHT CO., ) Docket Nos. STN 50-522 PACIFIC POWER & LIGHT CO., ) STN 50-523 WASHINGTON WATER POWER CO., and ) ~
PORTLAND GENERAL ELECTRIC CO. # "
) / /
) & C' (Skagit/Hanford Nuclear ) T' Project, Units 1 and 2) ) g RECam q REQUEST FOR HEARINGS AND AMENDED PETITTON FO u h 7
LEAVE TO INTER 7ENE C CIcck.Id [ /s7 Introduction O w i
[I io By application dated September 18. 1974, Puget Sound Powe Light Company, acting for itself and as agent for Pacific. Power.i&
Light Company, The Washington Water Power Company, Idaho Power Company, and Washington Public Power Supply System applied for construction permits for two boiling water nuclear reactors de-signated as the Skagit Nuclear Power Project, Units 1 and 2.
The proposed facilities were to be located at a site five miles northeast of Sedro Woolley in Skagit County, Washington. By an agreement dated January 23, 1976, ownership shares in the Skagit project were reallocated. Idaho Power' Company and Washington Pu-blic Power Supply System are no longer co-applicants, and Port-land General Electric was added as a thirty percent owner and co-applicant. The Coalition for Safe Power and Forelaws on Board were admitted as intervenors and parties to the proceedingiby Or-der dated May 26, 1976.
go35 On September 26, 1981, Puget Soun'd Power & Light-Company
/
submitted Amendment #23 to the application which relocates the proposed project to the Department of Energy's Hanford Reserva-tion in Benton County, Washington and changes the name of the 8203190096 820306 PDR ADOCK 05000522 8 PDR
project to Skagit/Hanford Nuclear Project. The proposed facility will be located approximately eight miles west of the Columbia River, seven miles north of the Yakima River at Horn Rapids Dam, and twelve miles northwest of the city of North Richland.
On February 5, 1982, a Notice of Receipt of Amended Applica-tion for Construction Permits and Facility Licenses and Notice of Hearing on Amended Application for Construction Permits was published in the Federal Register in the Matter of Puget Sound Power & Light Co., et al., Skagit/Hanford Nuclear Projects, Units 1 and 2, Docket Nos. STN 50-522 and STN 50-523. The notice set March 8, 1982 as the deadline for requests for hearings and a-mended petitions for leave to intervene. Pursuant to 10 CFR 2.714, the Coalition for Safe Power and its members, and Fore-laws on Board and its members (see affidavit) (hereinafter re-fered to as " Coalition") hereby submits its request for hearing and amended petition for leave to intervene.
Description of Petitioner The Coalition is a non-profit citizens organization, founded in 1969 to work for safe energy. Its work includes research and education. The Coalition, through its office'rs and attorneys, has
! represented its members before the Commission as well as state agencies, on questions of nuclear power safety and. licensing, and electric utility rates. The Coalition has been granted full par-ty status in four proceedings before the Commission including the original application for construction permit for the Skagit Nu-clear Projects, Units 1 and 2, application for eonstrucrion ger-
, mit for Pebble Springs Nuclear Plants, Units 1 and 2, and two li-cense amendments for the Trojan Nuclear Power Plant. The Coali-tion has also filed several Show Cause petitions with the NRC.
1 Status of Petitioner The Coalition asserts a continuing intervenor status derived from its admission as a party in the original Skagit Nuclear Pro-ject proceedings. The Coalition for Safe Power and Forelaws on Board were admitted without regard to the location of the pro-posed site. Thus the change in proposed site in the amended ap-plication for construction permit does not alter the original i
status of the organizations.
Amended Interest of the Petitioner The interests of the Coalition are, in large part, predicated on the interests of its members. The Coalition has at least one member residing within a 20-mile radius of the proposed site 4
(e.g. M. Terry Dana), others who reside within a 60-mile radius (e.g. Garth Orkney) and yet others who live throughout Oregon and Washington . (e.g. Linda Larkin) . Affidavits are attached. Members of the Coalition are ratepayers of Puget Sound Power & Light Co.,
Pacific Power & Light Co. and Portland General Electric Co., three of four applicant utilities. Members of the Coalition work, live, recreate and travel in the environs of the proposed Skagit/Hanford site and eat foodstuffs, both dairy, produce and meat, grown and produced in the vicinity potentially impacted upon by the construc-tion and operation of the project. The organization's work, itself, is in part conducted in Richland, Washington approximately sixteen l miles from the proposed site.
How These Interests May Be Affected The above-stated interests of the members and staf f of the Coalition, and thus the Coalition itself as their representative, may be affected by the proposed construction and operation and on-site storage of spent nuclear fuel, of the Skagit/Hanford Project.
The operation of nuclear power plant at the proposed site may en-danger the health of Coalition members due to several factors, the first of which is the routine and accidental releases of low-level ionizing radiation from the plant which will contaninate the air, food and water sources upon which members depend. The safety and well-being of members may be adversly affected by the possibility of a nuclear accident which may damage or destroy their livelihood, homes, other property and happiness. Recreation may be jeopardized by.the project's impact on the water and aquatic life of the Colum-bia River and the surrounding environment. A nuclear accident at the project may af fect the economy of the region. Insurance l
would not adequately cover losses sustained by members of the Coa-
! lition in case of an accident. The proposed plants will place an exessive economic burden on members who are ratepayers of appli-cant utilities.
An Order granting a construction permit in this matter may subject the Coalition to undue risks to health, life and property interests.
Specific Aspects of Subject Matter The Coalition intends to file contentions on the following aspects of the application for construction permit for the Skagit/
Hanford Nuclear Project:
- 1. Need for Power
- 2. Alternative Sources of Energy
- 3. Financial Ability of Applicant
- 4. Technical Ability of Applicant
- 5. Geology of the Proposed Site
- 6. Safety Hazards of the Project
- 7. Alternative Sites
- 8. Washington Public Power Supply System Units 4 and 5
- 9. National Defense
- 10. Impact of Additional Intake Structures on Columbia River
- 11. Effect of Thermal Impact on Columbia River
- 12. Emergency Planning
- 13. Production and Disposal of Nuclear Wastes from Project
- 14. Effect of Project on Regional Economy and Agriculture
- 15. Somatic and Genetic Impact of Radiation Released from Project
- 16. Cost Benefit Analysis
- 17. NRC Staff Ability to Adequately Evaluate Project
- 18. Architect / Engineer Ability to Construct Project in safe manner
- 19. Applicant and Architect / Engineer ability to conform to NRC Approved QA/QC Proceedure
- 20. Synergistic Effect Both Upon and By the Proposed Project in relation to the construction and operation of other nuclear fhcilities located at the Hanford Nuclear Reservation
- 21. Abili*y to Comply with Safety Requirements of TMI Effect of Intervention The Coalition's participation in previous and on-going re-gulatory proceedings is indicative of its ability to assist in the development of a sound record due to its familiarity with the process and the issues, and its access to expert witnesses. The Coalition's participation, for example, in the Trojan Control Building proceedings resulted in additional safety measures be-ing incorporated into plant modification plans. The Coalition's participation in the on-going construction permit application for the Pebble Springs nuclear plants would bring a thorough and con-
temporary understanding to the Skagit/Hanford application.
Conclusions The Coalition for Safe Power and Forelaws on Board, consoli-dated for purposes of this proceeding, having been previously ad-mitted as a party to the originalxSkagit Nuclear Project case, and having herein established a continuing standing of right un-der the Atomic Energy Act of 1954, as amended, the National En-vironmental Policy Act,of 1969, and Chapter 10, Code.of Federal Regulations, Part 2.714, is entitled to receive the hearing it requests on the Puget Sound Power & Light Co., et al. amended application for construction permit, Skagit/Hanford Nuclear Pro-jects, Units 1 and 2, and an Order granting this amended petition for leave to intervene.
Respectfully submitted,
^^JF D Dated this day, the Euggfe Roso)(e, Director sixth of March, 1982. Coalition for Safe Power
1 STATE OF OREGON )
) ss.
2 County of Multnomah )
3 I, Eugene Rosolie, being first duly sworn, do depose and 4 say as follows:
5 1. That I am the Director of the Coalition for Safe Power 6 and its duly authorized representative; and 7 2. That the foregoing petition was prepared under my super-8 vision and direction and that, to the best of my knowledge and 9 belief, it and the facts contained therein are true and correct.
10 Signed:
11 12
[ff.
Eug ge Rosol)d, Director 13 Coafition for Safe Power 14 SUBSCRIBED AND SWORN to before me this sixth day of March, 15 1982.
16 - 1 (3i 17 -
yh,( 0 d) -
Notary Publ\ic for Ore 18 )
My Commission Expir6[gpnf_5L $'ll_
19 20 21 23 23 24 35 26 Page 1 of 1 - AFFIDAVIT
1 STATE Or OREGON )
) ss.
2 County of Multnomah )
3 I, Lloyd K. Marbet, being first duly sworn, do depose and 4 say as follows:
5 1.) That I am Co-Director of F'relaws o on Board and its duly 6 authorized representative; and 7 2) That for the purposes of the amended application for 8 Construction Permit for the Skagit/flanford Nuclear Projects, 9 Forelaws on Board hereby joins in the amended petition for 10 leave to intervene attached hereto.
11 signed
- L y . Marb ;, CoC rector 14 re aw on ard 15 SUBSCRIBED AND SWORN to before me this fifth day of 16 March , 1982.
17 18 y [.3g Notary Public for Oregon 19 My Commission Expires: 2/s/85 20 21 22 23 j
24 25 26 Page 1 of 1 - AFFIDAVIT
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3 T, ". ! + rr - , beine first dulv 4 <s - rn , clo fiel ose anti say as follows:
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'i "ha? Y am..a r.emier of the Coalition for Cafe Tower:
6 2 ,, " hat I reside at '
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S ti ' hat I herel:y authorize the Coalition for ~afe Teser,
' C.rnuch its officers a n t! attorneys, t o r e t.-r e s e n t my interests i n ' r *'r re the 'Juclear "eculatory Commission on any =atter ver-lI c. i n i r.:. to nuclear units 1,0 or .: of the ',ashincton rullic 12 c. . e r T ut f lv e rster, the S'eacit/Hanford nuclear t ro ierts, 13 _ n i . . I arni a anc' the constructir.in or orcration of anv other l' n'elear roser racilite at the !!an rer<! '*uclea r "ese n a ti on .
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nA077/ . RN W lf, beine fi rst uulv 4 worn, do clerose and say as f ollows : V 5 ' l._! hat T an_.a_ =emi:er o f the Coalition for Safe Tower; 6 2) That I reside at M[ M//9/d+t ,
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S t V' ha tI herely authori re the Coalition for Sa fe Tower, 9 thrnuch its officers and attorneys, to rerresent my int ~ rests 10 Fe' ore the '?uclear "cculatory Commission on any matter rer-11 tai ni nt. to nucle..r units 1,7 or .: of t.he hashing; ton fullic 12 ' owe r c ui riv System, the S'<ac i t/Hanfor d nuclea r rrojects, 13 u n i t s 1 and ' and the construction or areration of anv other 14 nnel ea r rower facility at the Hanford "uclear Reservation.
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2 County of !!ultnomah )
3 I, Linda J. Larkin, being first duly sworn, do depose and 4 say as follows:
5 1. That_I am a member of the Coalition for Safe Power; 6 2. That I reside at -vy.i 9 '. T f i[' W N '
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L 'G li ) ; and 8 3. That I hereby authorize the Coalition for Safe Power, 9 through its officers and attorneys, to represent my interests 10 before the Nuclear Regulatory Commission on any matter per-11 taining to the Trojan Nuclear Poeer Plant, Washington Public 12 Power Supply System Units 1,2,3,4 cnd 5, the Pebble Springs 13 Nuclear Projects, Units 1 and 2,~the 5!agit/Eanford Nuclear 14 Projects, Units 1 and 2 and the constructicn or operation of 15 any other nuclear facility in the states of Oregon and Washing-16 ton. _ _. _ _ _ _ .
17 Si 'ed: 1
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20 SUBSCRIBED AND SWORN to before me this sixth day of March, 21 1982.
22
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. Akbn P !? )
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Notary Public for Oregon My Commission Expires: 2/3/a5*
25 26 Page 1 of 1 - AFFIDAVIT COAUTION FOR SAFE PC'..n SUITE 527 403 5 w : :
PCRTLAND. oEC.y ;:4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS3 ION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' ,
In the Matter of )
PUGET SOUND POWER & LIGHT CO., ) Docket Nos. STN 50-522 PACIFIC POWER & LIGHT CO., ) STN 50-523 WASHINGTON WATER POWER CO., and )
PORTLAND GENERAL ELECTRIC CO. )
)
(Skagit/Hanford Nuclear )
Project, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that on March 6, 1982, the Coalition for Safe Power's REQUEST FOR HEARINGS AND AMENDED PETITION FOR LEAVE TO INTERVENE was served upon the parties listed below by depositing copies thereof in the United States mail with proper first class postage.
Secretary of the Commission U.S. Nuclear Regulatory Commission Washington D.C. 20555 Attn: Docketing & Service Branch Executive Legal Director U.S. Nuclear Regulatory Commission Washington D.C. 20555 Mr. F. Theodore Thomsen Perkins, Coie, Stone, Olsen & Williams 1900 Washington Building Seattle, Washington 98101 Signed:
- . k Dated this day, the Eugerf Rosolife, Director sixth of March, 1982. Coalftion fof Safe Power