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Category:AFFIDAVITS
MONTHYEARML20214C4131986-11-12012 November 1986 Affidavit of DE Gilberts Re Enforcement Action 86-164 & NRC 861022 Order to Show Cause Concerning Use of Radios in Control Rooms ML20205Q7951984-06-29029 June 1984 Affidavit of Lm Richman Re Records & Records Retrieval Rept ML20205Q8011984-06-29029 June 1984 Affidavit of RG Tolson Re Records & Retrieval Rept.Related Info Encl ML20098D1601983-12-13013 December 1983 Affidavit of E Rosolie Re CP Extension.No Need for Facility Exists & Requested Extension Until June 1991 Unreasonable ML20098D0921983-12-13013 December 1983 Affidavit of N Bell Re Discussion W/J Lazar,Research Director of Northwest Conservation Act Coalition,That Power from WPPSS Not Needed ML20133C6411983-11-16016 November 1983 Affidavit of WR Mcafee Re Concerns Over Quality of Const at Plant ML20133C6451983-11-16016 November 1983 Affidavit of Hs Nunn Re Quality of Const at Plant ML20098D0001983-11-11011 November 1983 Affidavit of MD Brincat Re Correctness of Listed Documents ML20133C6321983-11-0909 November 1983 Affidavit of JB Stearns Re Concerns Over Shoddy Workmanship & Retaliation Against Persons Challenging Poor Workmanship at Plant ML20078N7201983-06-20020 June 1983 Affidavit of Ee Kent Re Quality of Welding in Nuclear Power Plants & Inadequate Handling of Allegations by NRC ML20210E6521983-05-27027 May 1983 Affidavit of AD Johnson Re Joint Intervenors 830510 Motion to Reopen Record on Issue of Const Qa.No Items of Noncompliance Represented Major Breakdown of Const Qa/Qc Programs of Licensee & Contractors ML20028B9051982-11-0808 November 1982 Affidavit Re Westinghouse Application for Withholding Proprietary Info Encl in App C to FSAR in TR Tramm 820818 & 0902 Ltrs to NRC Concerning Turbine Missiles ML20023D0341982-07-26026 July 1982 Affidavit of SL Marello Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20023D0351982-07-26026 July 1982 Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20039G7411981-12-0707 December 1981 Affidavit Supporting NRC Motion to Dismiss Ucs & Ny Pirg Petitions for Review of NRC Decision Re Status of Offsite Radiological Emergency Response Plan.Emergency Planning Evaluation Process Incomplete.Related Correspondence ML20098H1231977-12-0505 December 1977 Affidavit of Jd Perko Re Financial Qualifications Update ML20098H1221977-12-0202 December 1977 Affidavit of Dl Renberger Re Mgt Organization & QA ML20098H1241977-11-16016 November 1977 Affidavit of RB Gallup Re Need for Power Update ML20098C7661977-07-13013 July 1977 Affidavit of Jd Perko Re Corrections to Financial Qualifications Testimony ML20098C7591976-08-0202 August 1976 Affidavit of RB Gallup Re Need for Power Update ML20098C6911976-05-14014 May 1976 Affidavit of DW Connor Re Need for Proposed Units.Based on West Group Forecast Projection of Energy Loads & Capacities, Probable Need for Units 3 & 5 Greater than Yr Ago ML20235F0861970-08-0707 August 1970 Affidavit of Ej Walsh Supporting Util Request That Lloyd Harbor Study Group,Inc Motion Seeking Disqualification of Aec,Aslab & ASLB Members Be Denied.Incomplete Statement by Ej Walsh Requesting Motion Be Denied Encl ML20235F0451970-07-28028 July 1970 Affidavit of I Like in Support of Lloyd Harbor Study Group, Inc Motion for Order Seeking Relief Set Forth in Annexed Notice of Motion 1986-11-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20206U0471999-04-20020 April 1999 Council Order 731 Recommending Governors Approval of Amend of Site Certification Agreement for Satsop Power Plant Site ML20206U0291999-04-15015 April 1999 Council Order 731 Recommending Governors Approval of Amend of Site Certification Agreement for Satsop Power Plant Site ML20202C7941999-01-22022 January 1999 Order Revoking Const Permit CPPR-154.Orders That Subj Const Permit Terminated,For Listed Reasons.Order Effective Upon Date of Issuance ML20129D3991996-10-16016 October 1996 Memorandum & Order (Withdrawal of Application).* Grants Applicant Motion for Withdrawal of OL Application & Terminates Proceeding.W/Certificate of Svc.Served on 961016 ML20116N5501996-08-16016 August 1996 Motion for Withdrawal of Application.* Requests Issuance of Order Authorizing Withdrawal of OL Application at Issue & Terminating Proceeding.W/Certificate of Svc & Notice of Appearance ML20011E4861990-02-0707 February 1990 Comment on Proposed Rule 10CFR71 Re Compatibility of Pu Air Transport Regulations W/Iaea Stds.Supports EEI-UWASTE/NUMARC Comments to Be Provided to NRC by 900209 ML20248D2831989-09-28028 September 1989 Notice of Appearance.* Advises That Author Will Enter Appearance in Proceeding on Behalf of Nrc.W/Certificate of Svc ML20247Q2661989-09-26026 September 1989 Establishment of Aslb.* Board Will Comprise of Mb Margulies, Chairman & Oh Paris & Fj Shon,Members.W/Certificate of Svc. Served on 890926 B13367, Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Nrc Made Wise Choice to Not Impose Any Obligation on Private Parties to Include Affirmative Statement in Employment Agreements1989-09-20020 September 1989 Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Nrc Made Wise Choice to Not Impose Any Obligation on Private Parties to Include Affirmative Statement in Employment Agreements ML20248C8751989-09-13013 September 1989 Response to Order Modifying Licenses & Order to Show Cause Why Licenses Should Not Be Revoked.* Requests Hearing on Issues,Including Funds for Equipment.Supporting Info Encl ML20246C7141989-08-18018 August 1989 Order to Show Cause Why CPs CPEP-1 & CPEP-2 Should Not Be Revoked & Requiring Licensee to Notify Commission at Least 30 Days Before Taking Possession of Any Classified Equipment ML20245G0721989-08-0303 August 1989 Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Recommendation on Trust Agreement Wording Be Deleted or NRC Should Grandfather Existing Trusts Such as for Plants ML20248B6201989-08-0202 August 1989 Comments on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. NRC Should Permit Use of Potential Tax Refund as Source of Decommissioning Funds ELV-00674, Comment Opposing Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. 10CFR72.6(c) Should Be Revised to Provide for Storage W/O ISFSI Requirement1989-07-0707 July 1989 Comment Opposing Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. 10CFR72.6(c) Should Be Revised to Provide for Storage W/O ISFSI Requirement ELV-00679, Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Agrees W/Numarc Comments Provided to NRC on 8906261989-07-0505 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Agrees W/Numarc Comments Provided to NRC on 890626 ML20246K4801989-07-0505 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20246D8811989-06-30030 June 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20245D2481989-06-16016 June 1989 Comment on Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. NRC Must Consider Provision in Rule to Permit Indiscriminate Storage of Spent Fuel at Reactors ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20244B3241989-04-10010 April 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20247A2971989-04-0404 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246M2771989-03-20020 March 1989 Decision.* Affirms Board Decision LBP-89-05 Granting CP & OL to Licensee.Certificate of Svc Encl.Served on 890321 ML20236B4641989-03-0808 March 1989 Comments on Proposed Rev 3 to Reg Guide 1.9, Selection, Design,Qualification,Testing & Reliability of Diesel Generator Units Used as Onsite Electric Power Sys at Nuclear Power Plants. Reg Guide Does Not Provide Flexibility B13113, Comment on Proposed Rev 3 to Reg Guide 1.9, Selection, Design,Qualification,Testing & Reliability of Diesel Generator Units.... Util Recommends Rule Be Revised to Incorporate Addl Flexibility in Considering Age of Diesel1989-03-0808 March 1989 Comment on Proposed Rev 3 to Reg Guide 1.9, Selection, Design,Qualification,Testing & Reliability of Diesel Generator Units.... Util Recommends Rule Be Revised to Incorporate Addl Flexibility in Considering Age of Diesel ML20246N9471989-03-0808 March 1989 Comment on Proposed Rev 3 to Reg Guide 1.9 Re Selection Design,Qualification,Testing & Reliability of Diesel Generator Units Used as Onsite Electric Power Sys at Nuclear Power Plants ML20235V8541989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Util Committed to Goal of Achieving Improved Reliability & Safety Through Better Maint ML20235T3581989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Util Endorses Comments Filed by NUMARC & Nuclear Util Backfitting & Reform Group.Rule Fails to Provide Basis for Determining Effective Maint Program JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants B13136, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule on Maint Will Not Improve Maint in Plants Nor Improve Safety or Reliability of Plants.Proposed Rule Much Too Vague1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule on Maint Will Not Improve Maint in Plants Nor Improve Safety or Reliability of Plants.Proposed Rule Much Too Vague ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20235T7391989-02-23023 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235N8531989-02-14014 February 1989 Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices ML20235L5921989-02-0606 February 1989 Comment Supporting Proposed Rule on Chapter 1 Re Proposed Policy Statement Exemptions from Regulatory Control.Extreme Care Will Be Needed in Establishing State Role Both in Developing Rule & in Subsequent Implementation ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F5981988-12-0101 December 1988 Notice of Hearing.* Notifies That Hearing to Be Held in CP Application Proceedings on 881221 Cancelled & Rescheduled to Commence on 890104.Served on 881202 ML20196F5831988-12-0101 December 1988 Memorandum Memoralizing 881129 Telcon.* Applicant & NRC Agreed to Submit Joint Proposed Findings of Fact & Conclusions of Law.Served on 881202 ML20196A5991988-12-0101 December 1988 Transcript of 881201 Hearing in Bethesda,Md.Pp 143-152 ML20206M9181988-11-22022 November 1988 Memorandum Memorializing Telcon of 881121.* Discusses Board 881121 Telcon W/Counsel for Parties Re Prehearing & Scheduling Matters.Served on 881123 ML20206J3701988-11-21021 November 1988 Transcript of 881121 Telcon in Bethesda,Md Re Alchemie. Pp 70-100 ML20206M5321988-11-21021 November 1988 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing JPN-88-063, Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments1988-11-18018 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments ML20195H0111988-11-18018 November 1988 Comment Supporting NUMARC Comments on Proposed Rule 10CFR26 Re NRC Fitness for Duty Program Which Includes Random Drug Testing ML20206C6321988-11-14014 November 1988 Withdrawal of Request of State of Tn to Participate as Interested State,Per 10CFR2.715(c).* Certificate of Svc Encl ML20206C6131988-11-14014 November 1988 Withdrawal of Request of State of Tn to Participate as Interested State,Per 10CFR2.715(c).* Certificate of Svc Encl ML20206C3271988-11-10010 November 1988 Memorandum Memorializing Telcon of 881109.* Licensee Request to DOE to Extend Deadline for Receipt of CPs Until 890131 Not Officially Passed Upon.Further Prehearing Telcon Scheduled for 881121.Served on 881114 ML20206C0851988-11-0909 November 1988 Transcript of ASLB 881109 Telcon in Bethesda,Md.Pp 44-69 ML20206C1081988-11-0404 November 1988 Requests for Renewal or Extension of Exemption from 10CFR50.54(w)(i) Re Property Insurance Regulations ML20205R7111988-11-0404 November 1988 NRC Staff Testimony of Jj Swift Addressing ASLB Inquiries Dtd 881018.* Supporting Info Encl.Related Correspondence 1999-04-20
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. ENCLOSURE A UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
WASHINGTON PUBLIC POWER SUPPLY ) Doclict Nos. STN 50-508
) STN 50-509 SYSTEM
-) -
(WPPSS Nuclear Project Nos. 3 and 5) )
AFFIDAVIT OF DONALD W. CONNOR *-
- I, Donald W.' Connor, being duly sworn do depose and state that:
I am the member of the staff of the Division of, Environmental Impact Studies, V
(formerly Environmental Statement Project) Argonne National Laboratory
! responsible for analyzing the need for the power which the proposed WNP-3 and 5 facility would produce. My duties and professional qualifications are incorporated into the transcript of this proceeding following page 182. In additio[, I submitted prepared testimony entitled Supplemental Testimony Regarding Need for the Proposed Units, which was received into evidence following page 191.
Since the evidentiary hearings of June 24-26, 1975, a number of changes
=. -have occurred in the expectations of the utilities of the Pacific Northwest region. These are reflected in the most recent regional forecast, the West Group Forecast, dated March 1,1976, prepared by the Loads and Resources-
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i 84092{0125840824 PDR
! HEN 84603 ., .
9*
LI Fore-Subc mmittes of the Pacific Northwest Utilities Conference Committee.
~
cast average (energy) loads have been reduced from the 1975 Forecast by about two percent for the middle 1980's when WNP-3 and WNP-6 are expected to begin commercial operation. However, the net schedule slippage of scheduled new generating plants has reduced the projected average (energy) generating capacity to a greater degree so that energy deficits (under worst-case water conditions) are now projected for each operating year through 1986-1987, as shown'on line 10 of the attached Table of the Forecast entitled: " West Group Forecast - Estimated Loads and Resources - July 1976 - June 1987." The changes in projected average loads and generating capacities are shown in the following table:
1 Surplus or (Deficit) of Projected Average Generating Capacity Over Projected' Average Load - Excluding Reserves (Average MWE) 1975 1976 Forecast F_orecast 1980-81 (1562) (1,966)
(2073) (2,0.58) 1981-82 (499) (2,125)
, 1982-83 ,
i 1983-84 388 (685) -
1984-85 1,077 (525) 1985-86 1,634 (31) does not appear 15
'1986 */
As indicated in S 8.2.1 of the NRC Staff's Final Environmental State-ment, the Staff considers the West Group Forecast to be a reasonably accurate projection of energy loads and capacities for the Pacific Northwest . .
i
. 1
. 1 I
I .,
-l
, _~
b
~ With better water conditions, it may be that no actual shortages will occur.
The probability (based on the historical stream flow records) that projected average capacity will be adequate for projected firm loads in each year through 1986-87 is given on line 15 of the attached table. For most of the years prior to the projected 1983-84 operation, the estimated probability is less than 90 percent
' and must be judged to be inadequate. [90 percent would be equivalent to the
- "one loss of load in 10 years" reserve criterion used in most of the U.S. if onl'?'
a brief shortage were likely. However, in the Pacific Northwest a hydro defi-clency is likely to persist for weeks or months so that a reasonable equivalence t
would require 96-98 percent.] ,
- The staff concludes that the probable need for WNP-3 and WNP-5 appears even greater today than it did a year ago. .
\ ETwr idl Ch,%g
- D'aindd W. Connor Subscribed and swo: n before me 5 - this w% day of wm _ . 1976 Q
Ocmdi_ a ~s' .>%}
Nothy Public '
My Commission expires:cir.,i 19%.
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f VEST GROUP FORECAST - ESTIMATED LOADS AND RESOURCES JULY 1976 - JUNE 1987 Sheet I of 2 Figures are meravatts. 1976-77 1977-78 1978-79 1979-80 1980-81 1981-82 1982-83 1983-84 1984-85 1985-86 1986-87 23,136 24,626 26,108 27,476 28,917 30,245 31,658 33,081 34,608 36,200 37,896
- 1. Total Area Peak Load (January) 27,056 28,535 31,788 34,105 35,150 36,314 37,694 41,620 41,769 44,146 45,561
- 2. Total Peak Resources 1/ (2,776) (3,201) (3,655) (4,121) (4 ,627) (5,142) (5,698) (6,285) (6.922) (7.240) (7 .57 9)
- 3. Reserve Requirements 30,523 31,17 2 31,996 35,335 34,847 36,906 37,982 4 Peak Resources 24,280 23,334 28,13,3 29,984 1,144 708 2,025 2,508 1,606 927 338 2,254 239 706 86
- 5. Peak Surplus (over Total Load) 14,953 15,883 16,902 17,722 18,623, 19,418 20,205 21,134 22;027 22,959 23,943
- 6. Total July-June Energy Load 14,666 14,938 15,105 15,859 16,657 17,360 18,140 20,449 21,502 22,928 23,958
- 7. Total Energy Resources 1/
- 8.
- Reserve Requirements (334) (346) (356) (369) (387) (361) (397) (404) (416) (436) (462:
14,332 14,592 14,749 15,490 16,270 16,999 17,743 20,045 21,086 22,492 23,496
- 9. Energy Resources
- 10. Energy Surplus (over Total Load) (621) (1,291) (2,153) (2,232) (2,353) (2,419) (2,522) (1,089) (941) (467) (447:
- Peak 1,054 1,085 1,162 1,213 1 ,2 57 1,219 1,170 1,179 1,189 1,198 1,209
- 11. Area Interruptible Load 1,146 1,181 1,224 1,184 1,131 1,142 1,151 1,161 - 1,172
- Energy 1,019 1,047 (Included in Lines 1 and 6)
- 12. Fossil-Thernal & Miscellaneous Resources - Peak .
554 592 598 592 592 592 592 592 584 584
- Energy 519 (Not Included Above) 2/
Prtbability of Meeting Total Energy Load in All Periods of: 3/ 79.4 82.4 90.2 91.4 88.E
- 13. Year Shown
-% 97.0 87.2 80.2 82.2 77.0 76.6
-% 97.0 84.2 69.4 59.0 45.8 36.8 31.0 27.2 24.6 23.0 21.E 14 Years,1976 Through Year Shown Probability of Meeting Finn Energy Load in All Periods of: 3/ 89.2 91.2 97.6 95.8
-% 100.0 91.4 87.6 89.8 88.4 85.6 9 4 . '.
- 15. Year Shown 74.6 67.2 58.0 54.0 49.2 47.1 46.6 44.8
- 16. Years,1976 Through Year Shown -% 100.0 91.4 81.2
~1/
Resources include hydro; small fossil-fuel plants: Hanford-NPR through October 1977; Centralia; Trojan; West Group portion of Jim Bridger units; Colstrip #1 and #2 (50%), #3 and #4 (70%); WPPSS Nuclear #1, #2, 43, #4, #5; Boardman Coal; Skagit #1 and #2; Pebble Springs #1; and net contractual imports / exports with utilities outside the area. 1tanford is not included as a peak resource. Estimated amounts for scheduled maintenance (energy only), hydro realization factor (peak only) and incremental losses have been deducted. All existing thermal units and future thermal units und'e r 500 megawatts (peak and energy) are included in amounts as submitted by respective project owners. The energy availability of all future thernal units 500 weg'awat ts or larger has been included as 60% the first full year and 757. thereaf ter.
J/ The encrgy renawatts tabulated in line 12 reflect the amounts of energy available from existing fossil and gas turbine installations shic$ may be considered availabic as reserve energy resources. Thesc xwounts are in addition to those included as firm energy resources in line 7.
J/ Based on . r e load and rce.nurce data an other ' tabulations herein, m ent that there is no consideration of energy reserve requirements or realization factor.