ML19262A992
| ML19262A992 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/23/1979 |
| From: | Hearne T, Phillips P MISSOURI, STATE OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 7912110393 | |
| Download: ML19262A992 (6) | |
Text
{{#Wiki_filter:* /g . - --..: : r.:. c. ..:....,4._.. /y ......a. 61lIN UNITED STATES OF AMERICA Y 'h ...... ;T; ; T = - EDrivat REGULATORT COMMISSION // gfs' -+-- . =.. 4 h \\$1g y . ' + _ IsE*.7.16TahlE...=2n.3?.E. E4 % $ ^ Q Ob L..# g: .:.==a N= a.::= - ~:==. ><- ~ - -.=, =i s @;~~h 5S ii # J~sl E.G E '~ % w - =
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m..mww...:: - ..w-G G5Eansas.4as'-E Electric Company and ) 4 Wh=:-V:_%2'.- ;~~ % +.=._w. ) m-. :s.m.-.-----: fiKansas! City Tower-E.2.ight Company;) Docket No. STN50-482 ) (1.2pg} y=*]~ ' %...ft ?E= = posed -Insuance of -Amendment to ) 'Tro Mt ) D 'Y,...:ch-~=::=- :is&=.2=:^:CcNiIi5bicI:b5@ Fbii[iN ..~ " ' ' ) hO D =...ms /d 0 In L ~:.. =.. TETITION FOR LEAVE TO INTERVENE AS REPRESENTATIVE OF STATI PURSUANT TO TITLE 10 SECTION 2.715(C) CODE OF FEDERAL REGULATIONS (CFR) Comes now the Public Service. Commission of Missouri by and through its General Counsel to file this petition _pur-suant to 10 CFR Section 2.715 (C) Code of Federal Regulations (CFR) to intervene in the above captioned proceeding. 2. All processed documents, motions and other papers can be served on the Public Service Commission by addressing same to: Paul..W. Phillips, General Counsel or Treva.J. Hearne, Assistant General Counsel, Public Service Commission, P. O. Box 360, Jefferson City, Missouri 65102. 3. The Missouri Public Service Comnission, hereinaf ter referred to as the PSC, is empowered to regulate investor-owned public utilities that serve custoners in the State of Missouri pursuant to the authority granted to it by the General Assembly of the State of Missouri in Chapters 386 through and including 1529 146 791"110 3 8 3
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oc a n 393, Revised Statutes of Missouri 1978 (all statutory references are to 'EsHo.1978 unless otherwise specified). __.;~~~., 4 ..y=:-.-fR& -= i f cf.. -4.'.,. -Zansas City Tower & Light Company, a Missouri cor- ?i F ' ".~51. E. .nk--1.".6 2.t M.. ~ ~ ~ ~ 7.poration7 hereinafter' referred to as the Company, is an operating =nsy:=n jiy~f - +=gg;&=.-7 utility? engaged -principally in the business of furnishing electric gi@guc-;:-{L.,e I-- s.V3 Js_ ;. to the jurisdiction -!.servica :in Eastern Missouri and thus is subject ~ of the PSC.
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The PSC has ?. specific regulatory jurisdiction over the 5E-Company's share of its Wolf Creek Plant. See Section 386.250(5)- and' 39.1.130. Anticipating the eventual inclusion of the Wolf Creek lant into rate base by the Company, the Commission acting under its broad statutory authority to approve rates carefully monitors costs cf naintenance and operation of the Company's electric plant. 6. In volune 44, Federal Register No. 186,.p. 55071 of Monday, September 24, 1979, the United States Nuclear Regulatory Commission published a notice that it was considering the issuance of an Amendment to Construction. Permit CPPR-147 issued to Kansas Gas & Electric' Company and Kansas City Power & Light Company on May 17, 1977 for construction of the Wolf Creek Generating Station Unit No. 1. 7. The amendment would add the Kansas Electric Power Cooperative Incorporated as a co-owner assuming 171 interest in the Wolf Creek facility. Such a change in portion of owner-ship of the Company under the PSC's jurisdiction would have direct effect upon the PSC's eventual determination of the 1529-447 _2
g- . om-a ..\\ J w w Ju o Ju .m appropriate allocation of costs of construction of the plant between jurisdictions when the Company proposes the inclusion of the Wolf Creek Plant into its rate base. 8. The PSC has jurisdiction over the sale or transfer of any part of the Coapany's works or systems that is necessary or ueeful in the performance of its duties to the public. See Section 393.190(1). The PSC has a specific interest in the proceeding as noted in the aforementioned Federal Register. 9. The PSC is an interested agency of the state of Missouri. The Nuclear Regulatory Commission is obliged by Section ' 2. 715 (c) to afford the representative of that state or agency a reasonable opportunity to. participate and to intro-duce evidence, interrogate witnesses and advise the Commission-without requiring the representative to take a position with resp ec': to the issue. 10. The PSC's participation pursuant to the aforementioned section will not tend to unnecessarily hinder or delay the pro-caedings before the Nuclear Regulatory Commission in this matter,, but rather ensure that the PSC fulfills its statutory obligation to carefully monitor the con *struction or sale of plant and the appropriate allocation of costs betveen jurisdictions. WHEREFORE, the PSC respectfully requests that the Nuclear Regulatory Commission grant its request to participate as an intervenor in this proceeding with respect to the issuance of the 1529 148 g amendment, the Construction Permit CPPR-147 iesued to Kansas Cas & Electric Company and Kansas City Power & Light company for construction of the Wolf Creek Generating Station Unit Ko. 1. ~ E ectfully submitted, b' r I Paul W. Phillips General Counsel Treva J. Hearne Assistant General Counsel Attorneys for Public Service Commission of the State of Missouri P. O. Box 360 Jefferson City, Missouri 65102 4 i 4 e e 1529 149.
AFFIDAVIT I hereby swear that I have signed the foregoing document in a representative capacity as attorney for the Mi'ssouri Public Service Commission, with full authority in that capacity; that I have read said document and am familiar with its contents; and, that to the best of my knowledge, information and belief 'the statements made in it are true. Y Y'Ax Treva J. earne Assista General Counsel Subscribed and sworn before me this d L j day of October, 1979. ~ An n+x ' $/ A?) Not%ry P4blic My Commission expires mAa7 Pusuc STATE CW alssout s y m iss, m r n, m,,,,, g. O O D sp7 s \\S29 \\SD
CERTIFICATE OF SERVICE I, Treva J. Hearne, certify that a copy of the foregoing Rotice of Appearance and Petition for Leave to Intervene was s'erved on the Executive Legak Director, a member of the General Counsel of the Nuclear Regulatory Commission, at the United
- States Nuclear Regulatory Commission, Washington, D.
C.
- 20555, and on Olan D. Parr, Division of Proj ect Management. Office of Nuclear Reactor Regulation United States Nuclear Regulatory.
Commission, Washington, D. C. 20555, and on Gerald Charnoff, Esq., Shaw, Pittman, Potts & Trowbridge, 1800 M Street N.W., Washington,. D. C. 20036, by deposit of such copies in the United Statts Mail properly stamped and addressed on the _ MMw 23,19ff. Dated [rh J 3 19]f. = hAAM2 M-TrevaJ.yearne Assistant General Counsel for the Missouri Public Service Commission [', h 5 h
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