ML19350D064

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Response Supporting Kansans for Sensible Energy 810330 Amended Petition to Intervene.Petitioner Should Be Admitted as Intervenor W/Participation Limited to Contention on Financial Qualification.Certificate of Svc Encl
ML19350D064
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 04/09/1981
From: Karman M
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8104130229
Download: ML19350D064 (4)


Text

04/09/81

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f~

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-2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ',3 h 198fg 1 t

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KANSAS GAS AND ELECTRIC COMPANY &

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KANSAS CITY POWER AND LIGHT COMPANY )

Docket No. 50-482 (Wolf Creek Generating Station, Unit No. 1)

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hRC STAFF RESPONSE TO AMENDED PETITION FOR LEAVE TO INTERVENE OF KANSANS FOR SENSIBLE ENERGY:

On March 30, 1981, Kansans For Sensible Energy (KASE) filed an amended petition for leave to intervene in the above captioned proceeding.

In its Memorandum and Order, served on March 16, 1981 the Atomic Safety and Licensing Board (Board) stated that KASE's earlier petition lacked a statement that any of its signatories had "a cognizable interest that might be affected adversely by this proceeding." The amended petition lists six members of KASE and an allegation that these members have an " interest" in the proceeding as defined by Commission rules and decisions. Two of the signatories to the petition Arthur Thompson and Anne Browing state that they either live or own property within the geographical zone that might be affected by normal (or accidental) release of fission products.

The Staff believes these statements, together with their authorization for KASE to represent them satifies the standing requirement of 10 CFR g 2.714.

I The Staff perceives KASE's contention submission as raising one issue for any licensing hearing to determine. The Contention is the viability of i

the applicant to finance, the operation and decomissioning of the Wolf Creek i

Generating Station, Unit 1.

This is a sufficient contention for litigation of this proceeding.

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'For the reasons stated above, the Board should find that petitioner has-

'i satisfied the requirements of 10 CFR S 2.714, and should be admitted as an intervenor in this proceeding. The intervention should be limited to the Contention relating to financial qualification.

Respectfully submitted w,W h M:* fL Myro Karman Deputy Assistant Chief Hearing Counsel Dated at Bethesda,flaryland this 9th day of April, 1981.

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A UNITED STATES OF A*4 ERICA NUCLEAR REGULATORY C0" MISSION BEFORE THE ATOMIC SAFETY AND LICEflSING BOARD In the Matter of

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KANSAS GAS AND ELECTRIC COMPANY &

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Docket No. 50-482 KANSAS CITY POWER & LIGHT COMPANY

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(Wolf Creek Generating Station,

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Unit No. 1)

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, CERTIFICATE OF SERVICE I hereby certify that copies of flRC STAFF RESP 0f!SE TO AMErlDED PETITI0ft FOR LEAVE TO INTERVEf!E OF KANSANS FOR SENSIBLE ENERGY in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 9th day of April, 1981.

James P. Gleason, Esq., Chairman Atonic Safety and Licensing 513 Gilmoure Drive Board Panel Silver Spring, MD 20901 U.S. Nuclear Regulatory Comiission Washington, D.C.

20555

  • Dr. George C. Anderson Department of Oceanography Docketing and Service Section University of Washington Office of the Secretary Seattle, Washington 98195 U.S. Nuclear Regulatory Commission Washington, D.C.

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  • Dr. J. Venn Leeds 10807 Atwell Floyd Mathews, Eso.

Houston, Texas 77096 Birch, Horton, Bittner & Monroe 1140 Connecticut Avenue, N.W.

Treva J. Hearne, Esq.

Washington, D.C.

20036 Assistant General Counsel P.O. Box 360 Kansans for Sensible Energy Jefferson City, Mo. 65102 P.O. Box 3192 Michita, Kansas 67201 Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge Mary Ellen Salava 1800 M Street, N.W.

Route 1, Box 56 Washington, D.C.

20006 Burlington, Kansas 66839 Wanda Christy 515 N. 1st Street Burlington, Kansas 66839 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555

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-2 Mr. L.F. Drbl Missouri-Kansas Section:

American fluclear Society 15114 flavaho Olathe, KS 66062 Francis Blaufuss k'estphalia, Kansas 66093 9/ 0~

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Myron Karman Deputy Assistant Chief Haaring Counsel

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