ML20053D429

Info for Antitrust Review of OL Application for Wppss 3.

ML20053D429
Person / Time
Site:	Satsop
Issue date:	05/25/1982
From:	WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
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ML20053D420	List: ML20053D419 ML20053D426 ML20053D429 ML20053D432
References
NUDOCS 8206040423
Download: ML20053D429 (15)

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. l INFORMATION FOR ANTITRUST REVIEW l OF OPERATING LICENSE APPLICATION FOR WASHINGTON PUBLIC POWER SUPPLY SYSTEM'S NUCLEAR PROJECT NO. 3 l

I Pursuant to NRC Regulatory Guide 9.3, the Washington Public Power Supply System herewith submits certain information to the NRC Staff for its antitrust review of the operating license application for our Nuclear Project No.3 ("WNP-3").

The Pacific Northwest is a region which has had and continues to have a high degree of coordination between the various utilities in the generation and transmission of electric power, and the participation in WNP-3 reflects this I coordination. This high degree of coordination has been noted by the Attorney General in his advice letter with respect to WNP-3 dated January 29, 1975, and in his advice letters with respect to Nuclear Projects Nos. 2, 1, 4 and 5

("WNP-2," "WNP-1," "WNP-4," and "WNP-5," respectively.) 1/

There are 103 Participants in WNP-3, of which 28 are municipalities, 26 are public utility districts, 2 are irrigation districts and 47 are cooperatives.

.I All103Participantsarestatutorg)preferencecustomersoftheBonnevilleThe Power Administration ("Bonneville .

sold to the Participants and four investor-owned utility companies.

total capability o The investor-owned companies and co-applicants are Pacific Power & Licht Com-pany (PP&L), Portland General Electric Company (PGE), Puget Sound Power & Light Company (P5P&L), and Washington Water Power Company (WWP). The companies col-lectively own 30% of WNP-3, divided 10, 10, 5 and 5% respectively.

The Supply System is not a utility in the traditional sense of having distri-bution or retail customers. Rather, it functions as a joint operating agency I on a ccit reimbursement (not a rate) basis.

In these circumstances and because of the high level of cooperation and coor-I, dination existing in the region, the Chief Antitrust Counsel for the NRC Staff determined, after discussions with counsel for the Supply System, that certain modifications to the information requested in Regulatory Guide 9.3 were appro-g priate for the WNP-2 operating license antitrust review. Similarily, the in-g formation satriitted herewith follows Regulatory Guide 9.3, as modified by the Staff for this submittal.

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See advice letters (for WNP-1),

WNP-5),

dated February Januaryfor 13, 1975, (24,1972, WNP-4), (for April 19, 1974, andWNP-2)12,1976

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Regulatory Guide 9.3 provides, in part, as follows:

1. To assist the regulatory staff in its review, an applicant for a license t

l to operate a commercial nuclear power plant should consider the following items and any related changes that have occurred or are planned to occur since submission of the construction permit application:

a. Anticipated excess or shortage in generating capacity resources not j cxpected at the construction permit stage. Reasons for the excess or shortage along with data on hort the excess will be allocated, distributed, or otherwise utilized or how the shortage will be obtained.

l I b. New power pools or coordinating groups or changes in structure, activities, policies, practices, or membership of power pools or coordinating groups in which the licensee was, is, or will be a participant,

c. Changes in transmission with respect to (1) the nuclear plant, (2) interconnections, or (3) connections to wholesale customers.

d. Changes in the ownership or contractual allocation of the output of l the nuclear facility. Reasons and basis for such changes should be included,

e. Changes in design, provisions, or conditions of rate schedules and reasons for such changes. Rate increases or decreases are not necessary.

f. List of all (1) new wholesale customers, (2) transfers from one rate schedule to another, including copies of schedules not previously

'I furnished, (3) changes in licensee's service area, and (4) licensee's acquisition or mergers.

g. List of those generating capacity additions committed for operation after the nuclear facility, including ownership rights or power out-put allocations,

h. Summary of requests or indications of interest by other electric power wholesale or retail distributors, and licensee's response, for any type of electric service or cooperative venture or study.

2. Licensees whose construction permits include conditions pertaining to antitrust aspects should list and discuss those actions or policies which have been implemented in accordance with such conditions.

l In response to Paragraph 1.a. In April 1982, Bonneville released a draft of s

its Forecasts of Electricity Consumption which projects regional energy re-g quirements for the Pacific Northwest through the year 2000. The Bonneville I

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forecast was prepared as an interim planning tool pending the April 1983 pub-lication of the Regional Council's regional electric power and conservation plan. The draft forecast projects a baseline average annual 1.7% for the period 1980 through 2000 with a range from 0.8% togrowth rate 2.5% to re-of flect Bonneville's estimate of the reasonable range of uncertainty. The forecast was prepared using consuming sector models that depend upon a large number of assumptions including those which are concerned with the economy, population growth, conservation programs and practices, fuel and electricity prices and technical-engineering factors. Bonneville has provided its fore-cast for review by independent consultants and for public coment. Bonneville expects to consider comments, revise its draft forecast and publish a final forecast during the summer of this year.

A power requirements and resources forecast for the utilities in the Pacific Northwest has been developed annually since 1954 by the PNUCC. The PNUCC 1982 Northwest Regional Forecast of Power Loads and Resources (the "PNUCC 1982 Regional Forecast"), a compilation of the forecasts submitted by, or for, each of the utilities in the region, is expected to be published in mid-May. The draft of the PNUCC 1982 Regional Forecast predicts an average annual increas; in energy requirements of 2.6% per year over the period 1983 through 1993.

The PNUCC forecast has historically provided the basis for long-range regional resource planning by the utilities in the region.

the Washington Energy Research Center for A

thestudy released Washington inLegislature State March 1982 by(the " Legislative Study") predicts an average rate of growth of regional electricity sales of about 1.5% per year for the period 1980 through 2000 with rates ranging from 0.8% to 2.0% resulting from various alternative demand scenarios. Demand growth scenarios in the study B were based on assumptions relating to future regional economic conditions, demographic characteristics, price induced and other conservation, end-use efficiencies, and generation costs. Because of an error in the historical data, a revision to the Legislative Study released in April 1982, indicates a growth rate of slightly over 1.6% per year for the base case. When total regional electricity sales are adjusted to include tiansmission and distribu-tion losses and that electricity produced from cogeneration which was assumed in the study to reduce total requirements, the annual growth rate for the 20-year period is approximately 1.8% per year.

The following table summarizes the estimated electric energy requirements of the region for each of the above mentioned forecast. and the estimated resour-ces available to meet those requirements based on the PNUCC resource forecast.

Resource planning in the region is based on a multi-year critical period for hydroelectric resources, which is the historical water year period that, when augmented with stored water, provides the lowest expected energy production I from the region's hydroelectric resources with respect to system energy re-quirements. During portions of most years substantial secondary energy, re-sulting from more favorable water conditions, is expected to be available.

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REGIONAL ENERGY REQUIREMENTS AND RESOURCES (AverageMegawatts)

[ Estimated Requirements Draft Draft PNUCC

( Year Ending June 30 Bonneville 1982 Regional Legislative Estimated Total

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Forecast (1) Forecast (2) Study Forecast (3) Resources 17,849

[ 1983 1984 17,819 18,702 19,180 18,035 18,237 18,592 18,782 1985 17,964 19,772 18,580 19,517 1986 18,256 20,332 19,076 19,800

[ 1987 18,718 21,030 19,585 20,237 1988 19,258 21,692 20,108 20,325 1989 19,650 22,176 20,611 20,292

[ 1990 1991 20,067 20,445 22,687 23,195 21,154 21,489 21,351 21,878 1992 20,785 23,686 21,836 22,334 1993 21,142 24,176 22,186 22,971 (1) Includes transmission losses. Adjusted to include reserves and exports as projected in the draft PNUCC 1982 Regional Forecast.

(2) Includes transmission losses, reserves and exports. Adjusted to exclude Bonneville's interruptible loads.

(3) Adjusted to include transmission and distribution losses assumed in the Legislative Study at 7.5% of sales in each year, exports and that electricity from cogeneration assumed in the study to reduce total requirements.

(4) Based on the draft PNUCC 1982 Regional Forecast of resources and after deducting reserves under PNUCC planning guidelines. Assumes critical water conditions. Substantial secondary energy is expected to be avail-able under most stream flow conditions. All resources forecasted under these guidelines are licensed for construction except Puget Sound Power &

Light Company's Skagit Nuclear Units Nos. I and 2 and The Washington Water Power Company's Creston Coal Units Nos. 1, 2 and 3.

In response to Paragraph 1.b, this will advise that no new power pools or coordinating groups have been established since completion of the WNP-3 con-struction permit antitrust review. There are four principal organizations in the Pacific Northwest through which the high degree of coordination between the various utilities in the region is maintained. The Northwest Power Pool, a voluntary organization of public, investor-owned, and federal power suppli-ers, was established in 1942, to coordinate power operations in the Pacific Northwest. The Northwest Power Pool is still functioning on an affective basis. .

As the complexities of power supply increased in the region, other groups were formed. The PNUCC, consisting of public and investor-owned utilities in the Pacific Northwest, was formed in the late 1940s, to extend the coordination

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established in the Northwest Power Pool into other areas, including the ad-vanced planning of power resources. In addition, the Public Power Council was formed in the late 1960s, to further the coordination of the public power l groups in their efforts to improve supply in the region. The Public Power l

Council represents over 100 publicly-owned utilities and cooperatives.

There have been no significant changes in structure, activities, policies, or practices of these organizations since completion of the WNP-3 construction permit antitrust review. Of course, membership in these organizations changes occasionally as entities join or withdraw from the organizations. However, membership in these organizations is open and voluntary, to the end that all utilities which desire to participate may do so.

Most recently, the Pacific Northwest Electric Power and Conservation Planning Council ("PNEPCPC") was established and held its first meeting in April 1981.

The PNEPCPC was authorized by the Pacific Northwest Electric Power Planning and Conservation Act (" Regional Power Act") which was enacted in December 1980 (Pub.L.96-501). The PNEPCPC is composed of two representatives from each of the states of Idahc, Oregon, Washington and Montana.

The PNEPCPC is to prepare and adopt a Regional Electric Power and Conservation Plan (" Regional Plan") within two years after it is formed and is to prepare and adopt a program to protect, mitigate and enhance fish and wildlife on the Columbia River and its tributaries. The Regional Plan must set forth a general scheme for implementing conservation measures and developing the resources required by Bonneville to meet its obligations, and must also incorporate the fish and wildlife program. The Regional Plan shall give priority to resources which the PNEPCPC determines to be cost-effective, with priority among cost-effective resources given: first, to conservation; second, to renewable re-sources; third, to generating resources utilizing waste heat or which are of high fuel conversion efficiency; and fourth, to all others. Also, due consi-deration is required to be given to environmental quality; resource compati-bility with the existing regional power system; protection, mitigation and enhancement of fish and wildlife; and other criteria as may be set forth in I the Regional Plan. These same priorities and considerations guide Bonneville's resource acquisition determinations.

l The Regional Power Act substantially changed the power supply program of the I Pacific Northwest utilities, Bonneville and Bonneville's G! rect service in-dustrial cust & ci. The Regional Power Act obligates Bonneville to meet the firm energy requi. lents of all requesting Pacific Northwest utilities, in-cluding the Participants, to the extent these requirements exceed their own resources used in the year prior to December 5, 1980, or subsequently com-mitted to meet their own loads.

Provisions of the Regional Power Act: (i) require Bonneville to offer to sell power to each requesting Pacific Northwest utility, including each Participant, I to meet its firm power loads in the region in excess of such utility's own committed resources; (ii) require Bonneville to offer to exchange power with Pacific Northwest investor-owned utilities for residential and farming uses I ,

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l and to establish rates for such power that are the same as the rates paid by p public bodies, cooperatives and federal agencies, and require such utilities l 1

to pass the cost benefits of any such exchanges through to these consumers; I

l (iii) require Bonneville to offer to sell power to its existing direct service industrial customers under new long-term contracts; (iv) require Bonneville to meet its obligations to provide power through conservation to the extent that I conservation is cost effective; and (v) authorize Bonneville to provide finan- I cial assistance for conservation measures and construction of renewable re-l sources and to borrow from the Federal Treasury to obtain funds for such assistance.

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Pursuant to Net Billing Agreements which the Supply System, Bonneville, and each Participant in WNP-3 have executed, each Participa'it has assigned to I

l Bonneville its share of the capability of WNP-3. In consideration of these assignments, Bonneville will offset or credit the amounts paid by the Partici-pants to the Supply System for WNP-3 against amounts owed Bonneville by the Participants for power and services purchased under contracts with Bonneville.

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In effect, Bonneville has purchased the seventy percent of the capability of WNP-3 in this manner. The power received by Bonneville from WNP-3 will be l integrated into the Bonneville grid for sale at wholesale to its customers.

The Regional Power Act does not dilute or diminish Bonneville's ability to j meet its existing obligations under the Net Billing Agreements or the agree-ments with the Companies for their share of the WNP-3 capability, which remain I as preexisting Bonneville obligations. However, the Regional Power Act in-creases the number of options available to the sponsors of generating resour-ces, and provides mechanisms for the sharing of the risks and costs of new generation on a region-wide basis. In order to meet Bonneville's increased I

power sales obligations outlined above, the Regional Power Act grants it f authority to acquire by purchase the capability of output of electric generat-I ing resources to be constructed by resource sponsors. The Regional Power Act does not give Bonneville authority to own or construct any generating resour-ces. Rather, Bonneville is required to acquire from other entities whatever l

power resources are needed to enable Bonneville to meet its new contractural obligations.

l To the axtent that Pacific Northwest utilities place their requirements on I Bonneville through execution of new net requirements power sales contracts, Bonneville will be required to provide the resources necessary to eliminate forecasted regional power deficits. This means that Bonneville must attempt l

to acquire, on a long-term basis, any qualified power resource (and otherwise, I on a short-term basis, any resource) that is needed by Bonneville to enable it to fulfill its new power sales obligations.

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In January 1981, Bonneville advised its customers, that if they had previously j planned to meet a portion of their load with their own resources and now plan  !

l to place that load requirement on Bonneville, then Bonneville considers it '

reasonable to obtain an option on such resource to enable Bonneville to meet the same load.

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In response to Subparagraph 1.c(1), this will advise that the Supply System does not have a transmission network. The entire output of WNP-3 will be delivered by the Supply System to Bonneville at the Satsop substation, a short distance from WNP-3, on the Project site. This approach as to transmission has not changed since completion of the WNP-3 construction permit antitrust review.

With respect to Subparagraphs 1.c(2) and (3), and Paragraphs 1.e,1.f,1.g, and 1.h, the NRC Staff modified the request for information in view of the unique ownership arrangements of WNP-3 and close relationships of utilities in I the region such that responses are to be provided only for those Participants or owners of WNPn3 which have facilities for transmission to wholesale custom-ers of bulk power at wholesale. The Participants who have such facilities l will be referred to hereinaf ter as " transmission Participants." Of the 103 9 Participants in WNP-3, the Supply System had previously determined that three Participants may be properly characterized as transmission Participants, viz.,

Consumers Power, Inc. (a cooperative), Public Utility District #1 of Gray's I Harbor County, and Public Utility District #1 of Okanogan County.

Additionally the Supply System, in consultation with the BPA, has identified six additional " wheeling" arrangements which have developed, within to provida emergency capabilities or due to new or alternative feed points from the re-gional system. These arrangements indicate even greater levels of regional cooperations, hava no anti-trust verifications and will not be discussed I further herein.

In response to Subparagraphs 1.c(2) and (3), this will advise that there have I been no changes in transmission by these transmission Participants with re-spect to interconnections or connections to wholesale customers since comple-tion of the WNP-3 construction permit antitrust review.

In further response to Subparagraphs 1.c (2) and (3) each of the investor-owned utilities has facilities for transmission to wholesale customers of bulk power at wholesale. The interconnection changes since the construction permit are summarized by utility in Table I. The changes in connections to new wholesale customers are found in Table II.

I In response to Paragraph 1.d, this will advise that there have been no changes in ownership or contractual allocations of the output of WNP-3 since the con-struction permit antitrust review.

Incidentally, this will advise that Public Utility District #1 of Okanogan County became a member of the Supply System in 1976, raising the membership to 23 members, including the cities of Ellensburg, Richland, Seattle, and Tacoma, and 19 public utility districts.

In response to Paragraph 1.e, this will advise that the Supply System is a joint operating agency of the State of Washington which is legally empowered I to acquire, construct, and operate facilities for the gener0 tion and transmis-sion of electric power. It does not sell electricity direct!y to customers, I

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I and does not have rate schedules. Accordingly, there have been no changes in design, provisions or conditions of rate schedules with respect to the Supply System. With respect to the transmission Participants in WNP-3 while there have been changes in rates per se, there have been no substantial changes in design, provisions, or conditio7is of wholesale rate schedules since completion of the construction permit antitrust review.

In response to Paragraph 1.f, this will advise that the transmission Partici-pants in WNP-3 have no new wholesale customers, have made no transfers from one rate schedule to another, and have made no changes in service areas rela-I tive to the status of these considerations at the time of completion of the WNP-3 construction permit antitrust review. This will also advise that neither the Supply System nor any of the transmission Participants in WNP-3 I have acquired or merged with any other entity since completion of the WNP-3 construction permit antitrust review.

In further response to Paragraph 1.f, in the casa of the investor-owned utili-ties, the majority of the changer, are disclosed in response to 1.c.(3). Addi-tionally, the City of Ashland, Oregon, has ceased to be a wholesale customer of Pacific power and now obtains its bulk power supply from the Bonneville I Power Administration. Otherwise, Pacific Power has not transferred any of its wholesale customers from one rate schedule to another; has not experienced any significant changes in its service territory except for minor adiustments with I neighboring utilities to improve efficiency of service and in situations where publicly owned utilities have appropriated portions of Pacific Power's service areas; and has not merged with any other operating utilities. Pacific Power has recently acquired Consumers Lite and Power Company, a small farmer-owned I cooperative located in northwestern Wyoming, which had previously purcnased power from the U.S. Bureau of Reclamation.

I PGE has no new wholesale customers and has made no significant changes in service areas since completion of the WNP-3 construction permit antitrust review. Additionally, PGE has not acquired or merged with any other entity since completion of the WNP-3 construction permit antitrust review.

PSP &L has no new wholesale customers and has made no significant changes in service areas since completion of the WNP-3 construction permit antitrust I review. Additionally, PSP &L has not acquired or merged with any other entity since completion of the WNP-3 construction permit antitrust review.

I WWP has no new wholesale customers and has made no significant changes in service areas since completion of the WNP-3 construction permit antitrust review. Additionally, WWP has not acquired or merged with any other entity since completion of the WNP-3 construction permit antitrust review.

In response to Paragraph 1.g, this will advise that the Supply System has been constructing four additional nuclear power reactors designated WNP-2, WNP-1, I WNP-4 and WNP-5 pursuant to NRC construction permits. WNP-2 is presently scheduled to begin comercial operation in February 1984. There are 94 Participants in WNP-2, consisting of 27 municipalities, 21 public utility 8

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districts, 1 irrigation district, and 45 cooperatives, all of which are F statutory preference customers of Bonneville. Of the total capability of L WNP-2, the municipalities have contracted to purchase 22.6%, the districts have contracted to purchase 56.9%, and the cooperatives have contracted to purchase 20.5%.

Until recently WNP-1 was scheduled to begin commercial operation in June 1986.

The Supply System and the Bonneville Power Adninistration recently decided to

{ implement an extended construction delay on WNP-1. The total capability of WNP-1 has been sold to the Participants and five investor-owned utility com-panies, the same four as for WNP-3 and the Montana Power Company. Of the to-p tal capability of WNP-1, the Participants have contracted to purchase 67.53%

L during the period from July 1,1980, to June 30,1996, and 100% thereaf ter.

The companies have contracted to purchase 32.47% during the period from July 1,1980, to June 30, 1996. As payment for the sale of this portion of WNP-1

{ to Bonneville, Bonneville has agreed to furnish to each such company 80,000 kilowatts of capacity and 68,000 kilowatts of average annual energy.

With respect to WNP-4 and WNP-5, construction has been terminated.

With respect to the transmission Participants in WNP-3, this will advise that Grays Harbor PUD is participating in WNP-2 and WNP-1 in the following percent-( ages of total output: WNP-2 (3.075%) and WNP-1 (1.862% in 1986-1996; 2.758%

thereafter). Consumers Power, Inc. (a cooperative) is participating in WNP-2, WNP-1, WNP-4, and in the Boardman coal plant constructed by Portland General Electric Company, in the following percentage shares: WNP-2 (.453%), WNP-1 (0.721% in 1986-1996; 1.068% thereafter), and Boardman (10%). 2/ Okanogan PUD is participating in WNP-2 and WNP-1 in the following percentage shares: WNP-2 (1.042%) and WNP-1 (0.174% in 1986-1996; 0.257% thereafter). Okanogan also began receiving power from Wells Dam, a 774 megawatt hydroelectric f acility in September 1976. Okanogan's initial share of Wells Dam was 0.6% of capacity (4.64 MW), and its share will increase on a sliding scale to 8% of capacity (61.92 MW) in 1988.

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With respect to the investor owned utility owners, at this time the only future r generating capacity additions committed for operation by Pacific Power & Light L af ter the scheduled comercial operation date for WNP-3 (1986) are Wyodak Unit No. 2 (330 MW coal-fired plant initially scheduled for commercial operation in 1986, but for which commencement of construction has been delayed for an inde-

[ finite period); and Skagit/Hanford Units 1 and 2 (1275 MW nuclear plants sche-duled for completion in 1991 and 1993, respectively). Pacific Power will own 80% of Wyodak Unit No. 2 and 20% of Skagit/Hanford Units 1 and 2.

-2/ The 10% output allocation for the Boardman facility represents the

- Pacific Northwest Generating Company's share of the Boardman plant. This

( 10% share will be divided among the 17 participating cooperatives in the Pacific Northwest Generating Company. Consumers Power, Inc. is partici-pating in the Boardman plant through the Pacific Northwest Generating

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Portland General Electric Company is participating in Skagit/Hanford Nuclear F Plants No. 1 and No. 2 and Pebble Springs Nuclear Plants No. I and No. 2 in L the following percentages of total output: Skagit/Hanford Nuclear Plants No. I and No. 2 (30 percent) and Pebble Springs Nuclear Plants No.1 and No. 2 (47.1 percent).

[ The Puget Sound Power and Light Company has a 25% share in Colstrip Units 3 and 4, a two-unit, 700 MW (net) each coal-fired facility currently under

{ construction at Colstrip, Montana. The Colstrip Project is sponsored by the Montana Power Company. The Puget Sound Power and Light Company, as Project Sponsor, is in the process of obtainirg a construction permit for the two-unit 1275 MW (net) each Skagit/Hanford Nuclear Project at Hanford, Washington. The Company plans to own 40% of the Project. The Puget Sound Power and Light Company also plans to participate with a 25% ownership in the proposed Creston

{ Project which is a four-unit, 500 MW each facility at Creston, Washington.

The Washington Water Power Company has a 15% ownership in Colstrip Units #3 b and #4, a two-unit, 700-MW (net) each coal-fired facility presently under L, construction at Colstrip, Montana. The Colstrip Project is sponsored by The Montana Power Company. The Washington Water Power Company is also building a 40-MW wood-waste fuel facility at Kettle Falls, Washington. The Washington

.[ Water Power Company is presently applying for a siting certificate for a four-unit, 500-MW each facility at Creston, Washington. The Company plans to own 25% of the Creston Project. The Washington Water Power Company has agreed

{ to participate with a 10% ownership in the proposed Skagit/Hanford Project.

In response to Paragraph 1.h, this will advise that because the Supply System has terminated projects WNP-4 and WNP-5 we have received indications of inter-est relative to the projects. Such expressions of interest are best charac-terized as speculative in nature at this time. The Supply System declined the opportunity to participate in the Skagit nuclear plant proposed by Puget Sound Power and Light Company. The Suppl in WNP-3 through the Supply System)y System and the (andowned investor the transmission utilities have Participants participated in certain cooperative generic studies with respect to items of comon interest to utilities in the Pacific Northwest. These studies are of no significance to antitrust considerations. For example, the Supply System participated in a joint study by several utilities in the Pacific Northwest of the 1872 North Cascades earthquake which is of common interest to all utili-

[ ties in the region.

The four investor owned utilities have taken a number of actions toward coop-erative ventures. In particular since completion of the WNP-3 construction E permit antitrust review, Pacific Power & Light Company has been involved in the followin matters relating to cooperative development of generating faci-lities with ther wholesale or retail distributors of electrical service:

(a) In response to an order of the Montana Board of Natural Resources and Conservation, the owners of Colstrip Units 3 and 4 (including Pacific b

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Power) offered ownership interests in those plants to a number of pub-licly owned utilities in Montana. After extensive negotiations, the publicly owned utilities declines to participate.

(b) Pacific Power has been offered, but has declined, an ownership interest in the Creston, Washington, coal-fired generating plant being proposed by the Washington Water Power Company.

(c) Pacific Power & Light Company and Black Hills Power and Light Company have tentatively agreed jointly to construct Wyodak Unit No. 2.

(d) Pacific Power and the three other Pacific Northwest investor-owned utili-ties involved in WNP-3 have formed Northwest Energy Services Company (NESCO) to provide initial planning, siting, and construction management services f or future generating resources in this region.

(e) Pacific is currently involved in five projects which have been submitted to the Bonneville Power Administration as unsolicited research and devel-opment proposals regarding alternative energy sources.

(f) Pacific Power has held various levels of discussions with a number of utilities and private concerns who are interested in building major or minor generating facilities and who wish Pacific Power to join in the development of these projects or purchase output from them. Pacific I Power has not entered into any formal arrangements with these concerns other than those mentioned above to supply power to Pacific Power's customers.

As noted in response to question 1.g, Portland General Electric is participat-ing in Skagit/Hanford Nuclear Plants No.1 and No. 2 with Puget Sound Power &

Light Company, Pebble Springs Nuclear Plants No. I and No. 2 as sponsor, and Colstrip (coal-fired) Plants No. 3 and No. 4 with The Montana Power Company.

Puget Sound Power & Light Company is participating in the Colstrip, Creston and the Skagit/Hanford Nuclear Project.

The Washington Water Power Company is also participating in the Colstrip, Creston and Skagit/Hanford Nuclear Project.

Since completion of the WNP-3 construction permit antitrust review, these investor-owned utilities have participated in other cooperative ventures and I studies which are of no significance to antitrust considerations. They have not received any requests or indications of interest by electric wholesale or retail distributors (utilities) to purchase portions of WNP-3 since completion of the WNP-3 construction permit antitrust review.

With respect to Paragraph 2, since the construction permits for WNP-3 included no conditions pertaining to antitrust aspects, no discussion is necessary, 11

TABLE 1 PACIFIC POWER & LIGilT COMPANY Year in Interconnection Additions Voltage Utility Service Buffalo, Wyo. Gillette, Wyo. 230 KV (C/I 161 KV) Black llills P&L 1975 Jim Bridger Plant, Wyo. to Borah Sub., Idaho 345 KV Idaho Power 1975 Albina-Ilarrison Line Lap, Ore. to llolladay Sub., Ore. 115 KV Port. Gen. Elec. 1975 Jim Bridger Plant, Wyo. to Kinport Sub... Idaho 345 KV Idaho Power 1976 Fry Sub., Ore. to Conser Lap, Ore. 115 KV BPA 1976 USCE Lost Creek Plant, Ore. to Prospect-Lone Pine, Ore. 115 KV US Corp. of Eng. 1976 BPA Alvey-Oakridge Line, Ore, to Pleasant 11111 Sub. ,

Ore. 115 KV BPA 1976 BPA Troutdale Sub., Ore. to Linneman Sub., Ore. 230 KV BPA & PCE 1976 BPA Lion Mr., Mont. to Lion Mt. Sub., Mont. 230 KV BPA 1978 D. J. Plant, Wyo. to Tri-State Difficulty Sub., Wyo. 230 KV Tri-State G.6T. 1978 H D. J. Plant, Wyo. to Basin Electric Laramie River, Wyo. 230 KV WAPA 1978

" 115 KV BPA 1979 Priest River Sub. , Idaho to Albeni Falls Line, Idaho TWWP Co., Idaho to Oden Sub., Idaho 115 KV Wash. Water Pw. 1979 Malin Sub., Ore. to Meridian Sub., Ore. 500 KV (a) 1980 BPA Trumbull Cr., Mont. to Trumbull Cr. Sub., Mont. 230 KV BPA 1980 BPA Redmond, Ore. to Prineville Sub./ilarney Tap (Emerg.) Ore. 115 KV BPA 1981 Riverton Sub., Vyo. to Tri-State Riverton, Wyo. 230 KV Tri-State G.&T. 1981 WAPA to Wagonhound Sw. Sta., Wyo. 115 KV WAPA 1981 Malin Sub., Ore. to Midpoint Sub., Idaho 500 KV (b) 1981 Black Forks Sub., Wyo. to B.V.E.A. Sweetwater Sub.,

Wyo. 230 KV Deseret G&T 1981 Interconnection Reductions l

Sold to the Springfield Utility Board, Ore. in 1975 Springfield Sub., Ore. to Laura St., Sub., Ore. 69 KV Springfield Sub., Ore. to South Bank Middle Fork Willamette River, Ore. 69 KV

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TABLE 1 (Cont'd)

PACIFIC POWER & LIGHT COMPANY Year in Interconnection Reductions Voltage Utility Service Alvey-Springfield 115 KV Line to Jasper Sub., Ore. 115 KV Springfield Sub., Ore, to South Bank, Middle Fork Willamette River, Ore. 115 KV Springfield Sub., Ore. to BPA Springfield Sub.,

Ore. 115 KV Sold to the Northern Wasco County PUD, Ore. in 1976 The Dalles Sub., Ore. to Columbia Hts. Sub., Ore. 115 KV Columbia Hts. Sub., Ore. to BPA Eddy Sub., Ore. 115 KV U The Dalles Sub., Ore. to N-S Section of Mosier Sub. 69 KV The Dalles Sub., Ore. to BPA The Dalles Sub.,

Ore. 115 KV The Dalles Sub., Ore. to BPA Maupin Sub., Ore. 69 KV (a) BPA, PGE, PG and E and USBR (b) BPA. Idaho Power, PGE, PG and E and USBR.

l UAC'4INGTON WATER POWER COMPANY Year in Interconnection Additions Voltage Utility Service Hatwai-Lolo-Hatwai Connection Lewiston, ID 230 KV BPA 1975 Hatwal-Moscow-Hatwai Connection Lewiston, ID 230 KV BPA 1975 l Beacon-Rathdrum Line-Moab Sub Tap Spokane, WA 115 KV Inland Power & Light 1975 Sifford-Orin Line-Matchip Tap Colville, WA 60 KV Metalurgical Chip Co. 1975 Cabinet-Sandpoint Line-Oden Sub Tap Hope, ID 115 KV Pacific Power & Light 1975 Addy-Long Lake Line-BPA Addy Sub Tap Addy, WA 115 KV BPA 1976

W W W M M M M M M M M M M M M M M M M TABLE 1 (Cont'd)

WASHINGTON WATER POWER COMPANY (Cont'd)

Year in Interconnection Additions Voltage Utility Service Lind-Long Lake Line-Gaffnet Tap Sprague, WA 115 KV Lincoln Electric Co-op 1976 Long Lake-Stratford Line-Irby Tap Odessa. WA 115 KV Lincoln Electric Co-op 1977 E. Colfax-Sunset Line-Nangman Tap Spokane, WA 115 KV Inland Power &

Light 1977 E. Colfax-Moscow Line-Armstrong Tap Pullman, WA 115 KV Inland Power &

Light 1978 Albeni-Post Falls Line-Hoodoo Tap Blanchard, ID 115 KV Inland Power &

y, Light 1978 E. Colfax-Lind Line-Rals ton Tap Ralston, WA 115 KV Big Bend Electric NT Co-op 1980 Larson-Stratford Line-Round .

Lake Tap Stratford 115 KV T Grant County PUD 1980 BPA Bell-Colville Line-Loon Washington Water Lake Tap Loon Lake, WA 115 KV Power 1981

TAPIE ll New Wtiolesale rnwer rustrvners since l'875 ractIIC Prwer_ L_Intyt, [cmpany

- Frc IItING NOS.

IrrECTIVE OititR Ptr IILING - ~ lTIttilvT STATE CONTRACT NO. DATE l'NilY SIAIE DATE SClito Stirrt DAlt 20 hills /KM1 - NUN FIRH i

l ~--[f'AsiTTITCI. LO. t ETIER M.Rl[ HINT O'/05/78 Il FASO WYO [6 01/78 138 07/21/78 NtrAASFA PUBtlC 00WER DISTRICI IElitR AcrtEEHINI I?/l.1/19 NrrD s WYO I?/7ft/19 174 01/01/00 SAN DIEGO GAS & fitflRIC CO. t[ LIER K#IEMINI 03/08/79 SIT &t 161 03/On/19 CIIY OF FASADINA lElIIR KRifftNT 03/l?/19 PASADENA 162 03/l?/74 Ci t Y Of Gl t NUM E lElitR FAf f MINT 03/17/19 GitNDAIE 164 03/13/19 CIIT Of RURRAFE LEITER AGRtfftNT 03/12/19 DURPNE 163 03/13/19 PACIfl0 CAS & El.ECTRIC CO. IETIER Ar#EEMENT 03/l?/19 PGEF 167 01/17/19 CITY OF LOS ATCELES tilitR AGRifMENI 03/09/19 L.A. If;6 03/09/10 SOUTHERN CMIFORNin IDISON 00. IEIIER AGREtHINT 01/09/19 S(T 16n 03/09/19 SALT RIVER PROJECT AGRI & IHr., A 00WrR DISIRICT LEITER AGREtHINI 06/1ft/19 170 09/13/19

. MONIANA l'0WER fotFNEY IElitR F#f tHtfli 10/03/19 HPC WYO 11/09/19 til 10/03/19 illCSON GAS & flECTRIC CO. IElitR FAlffftNI 09/28/79 IGP.t C WYO 10/31/19 177 10/01/19 PUGEl 50ffNO POWER & tlGill CO. l.IlitR &#[ifftNI 09/01/19 r$rtl 79 HILLS - NON TIRH Till 51ATECIN.TTR7R5. WYG 29 Hiti S/EMI 04/?S/80 IRI 51Att WYO 05/08/P0 1% 06/16/80 ARl10NA PURtlC SERVICE CO. WYO 29 HitLS/tMI 04/28/90 APS WYG 07/14/P0 100 06/16/n0 SAN DitGO GAS & ELECTRIC C0. CALIF 29 HittS/FWil 04/78/00 SfCLE WYO 07/14/00 194 04/22/80 PACIFIC GAS & ELECTRIC C0. CALIF 29 HIttS/KMI 04/79/00 rGI.t WYO 07/l4/00 180 04/23/80 CIIY Or StannlK CAtlr 29 Hills /EMI 04/23/80 BURPNE WYG 07/11/80 18? 04/73/80

[ IDAHO 00WER CO. IDA 29 HILLS /KMI 04/?R/00 frC WYO 07/14/00 181 06/16/pn MtnRASF A l'ttPLIC POWIR DISTRICT WYO 29 Hills /tMI 05/09/00 NrrD WYG 06/01/00 187 06/16/R0 011Y 0F CLENOALE CALIF 29 Hill S/KMI 04/71/80 CIENDAIE WYO 07/14/PO 1R3 01/73/r0 CilY Or 105 NIGttts CALIF 29 liittSAWil 01/?i/PO L.A. WYO 07/14/80 185 04/7?/80 DLACK lillLS POWER & LIGill 50 29 HillSA MI 04/21/00 B.II. WYo 05/19/nD Inl OS/14/no SOUlitERN CAllFWNI A EDISDN CALIF 29 Hills /FMI 04/72/00 SLE WYO 06/20/fm 195 04/77/B0 HONIANA POWER C0tFANY f10ffi 29 Mitis /FMI 04/73/80 HLtr WYO 06/70/no IP6 06/16/80 IUCS0ti GAS & EIECIRIC CO. WYO 29 Hills /FMI 04/74/00 IGETC WYO 06/?0/80 197 06/16/00 FASADENA WAIER & ROWER DEri. CALIr 29 H! tis /RMI 05/27/n0 WYG 06/20/00 189 04/22/no FIIUllt SERVICE CO. Or NEW HEXICO WYO 29 filitSAWil 06/03/80 Pfm WYO 07/14/no 197 06/16/80 PUBLIC SERVICE CO. OF COLORADO WYO 29 HitLS/EMI 04/29/80 r%C WYO 06/23/80 191 06/16/no SALT RIVER l'ROJECT WYO 29 HitLS/KMI 07/12/00 WYO 01/14/no 193 06/16/80 PLATIE RIVFR POWER AUill0RlIY WYG 29 HILLS /KMI 07/31/80 100 06/16/r0 UIAll 00WER & LIGili C0. WYO 29 Hllt S/FMI On/ID/80 198 06/16/r0 WASillNG10N WAITR 00WFR CD. WAsil 29 HILLSAMI 04/08/80 199 04/II/no SIEPRA PACirlC r0WIR CO. CAIIF 29 Hills /KM1 II/l A/ft0 WYO ?05 17/03/n0 DESERE T UT 29 Hills /KMI 08/16/n1 Ifi SANIA fl ARA ELECTRIC Pf ri. CALIF 79 Hill S/kMI on/IR/ft! I'I'AL WYO 08/31/01 36 HILLS - SilVRT 1EPH FIRH 7ACIrlFCAT F tttCT.-[F CA 36 Hill.S 04/01/RI 04/77/fti 209 04/01/81 50VilftRN CAllIORNIA EDISON CA 368 Hill S 04/01/81 06/79/nl  ?!O 04/01/81 l lDAtU 00WER CO. ID 36e Hill 5 07/01/nl 70n 07/01/fti J BONNEVILLE FUWIR ADMINISIRAll0N OR 36' Mills 09/01/81 SAN DIEGO GAS & ELECTRIC CO, CA 36' Hitl5 09/01/01 715 09/01/81 PAClfl0 GA5 & (LECT. 00. CA 36* Hills 09/01/ft) 716 09/01/ftl TIRRINGTON, TOWtl Or WYG FIPM SAIE 01/3n/76 WYO OR/II/16 17(, 08/75/76 SitrrlEftNI NO. I 10/01/19 I?6 1 11/21/19 Stirritf4Ni No. ? 06/01/nl WYG 04/01/n1 176 7 06/01/RI I T IliR MRf f f 5 N1 04/01/n1 WYO 04/?n/ft1

^

~f\j ') Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 G03-82-529 Docket No: 50-508 May 25, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

NUCLEAR PROJECT 3 - APPLICATION FOR OPERATING LICENSE Pursuant to 10CFR2.101(a) and 50.30, the Washington Public Power Supply System (Supply System) is filing herewith its Application for an Operating License for Nuclear Project 3 (WNP-3). Authorization for the construction of this project is set forth in Construction Permit CPPR-154 issued by the NRC on April 11, 1978.

O In accordance with 10CFR50.30(c)(3), the following Operating License submittals for this Project are enclosed; e Ten (10) copies of the general information required by 10CFt50.33; e Fifteen (15) copies of the Final Safety Analysis Report (FSAR) including the Emergency Preparedness Plan required by 10CFR50.34 and 50.34a; e Twenty (20) copies of the Environmental Report required by 10CFR Part 51.

e Five (5) copies of a document entitled "Information for Antitrust Review of Operating License Application" requested by NRC Requlatory Guide 9.3.

When NRC deems the tendered Application to be acceptable and complete for docketing, we will submit the additional copies of these documents as required by 10CFR50.30.

The antitrust information confirms that there have been no significant changes in our activities subsequent to con:pletion of the construction permit antitrust review of this Project, and confirms the conclusions in the favorable advice letters rendered by the Attorney General at that time.

i

- (~h

HR Denton

! } Page 2 1

May 25, 1982 WNP Application for Operating License 10CFR50.34(t) establishes a requirement for Operating License Applications to include an evaluation of the facility against the Standard Review i

Plan (SRP). At the time this rulemaking was promulgated, the WNP-3

! Application was in the final publication process and it was not feasible to include this information in the documents now being tendered. Discussions with the NRC Licensing Branch have indicated the acceptability of providing the required information in the docket version of the FSAR and subsequent amendments. We see no reason for the absence of this material to be cause for rejection of the Application.

Additionally, per discussions with the NRC staff, three copies of the FSAR are being forwarded under separate cover to EG&G Idaho for their usage in performing the acceptance review.

Sincerely, M b G. D. Bouchey, D uty Director Safety and Security KWC/sm Enclosures cc: WG Albert - NRC 726 w/o NS Reynolds - D&L w/o D Smithpeter - BPA 762 w/o LL Wheeler - NRC w/o l

O Spplirafrbn 5r (d.uf J STATE OF WASHINGTON)

Subject:

doera4QO / /c en.re

, ) ss COUNTY OF BENTON )

I G. D. BOUCHEY, being duly sworn, subscribe to and say that I am the Deputy Director, Safety and Security, for the WASHINGT0?! PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have full at.thority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information and belief the statements ma# in it are true.

DATED A1ay c25 ,1982 V

MDw c4w G. D. BOUCHEY, D ty Director Safety & Securi On this day personally appeared before me G. D. BOUCHEY to me known to be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and purposes therein mentioned.

GIVEN under my hand and seal this cPMday of ///a / 1982.

rett f Notary PubLic in and for the LS State of Washington Residing at NE/r>>2)/cM o

,(

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