ML20033A989
| ML20033A989 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 11/20/1981 |
| From: | Woods N CITIZENS ACTION FOR SAFE ENERGY, FELDMAN, HALL, FRANDEN, REED & WOODWARD |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8111300256 | |
| Download: ML20033A989 (2) | |
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M Mice of th S::etr / h UNITED STATES OF AMERICA -
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NUCLEAR REGULATORY COMMISSION
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4 ATOMIC SAFETY AND LICENSING BOARD 45 g
(D Before Administrative Judges
' OY'p-]Ip!/ q Sheldon J. Wolfe, Chairman g
Dr. Paul W. Purdom
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Frederick J.
Shon llOf i
L In the Matter of
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Public Service Company of Oklahoma,
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Associated Electric Cooperative, Inc.
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and
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Western Farmers Electric Cooperative
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STN 50-556CP (Black Fox Units 1 and 2)
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STN 50-557CP INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN i
Intervenors respectfully request that their Motion to j
Reopen the Radiological and Safety Hearings be supplemented with the following materials:
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1.
" Exhibit #1" consisting of a letter dated l
September 8, 1981, from Joseph Gallo re:
I the Touche Ross Report and referred to on page 4 of Intervenors' Motion to Reopen, but through inadvertence and mistake was not attached to said Motion.
2.
" Exhibit #2" consisting of a letter dated November 13, 1981, from Joseph Gallo wherein he states, among other things, that copies
})SO3 of the direct testimony of Wm.
R.
- Stratton, Senior Vice President of Finance of Public Service company of Oklahoma, before the f
Oklahoma Corporation Commission in its recent l /g 8111300256 811120 PDR ADOCK 05000556 0
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rate case have been supplied to the NRC.
Intervenors submit the letter as evidence that the Board has access to Mr. Stratton's
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testimony and Intervenors urge the Board to
-consider this testimony in deciding whether to reopen as to the financial qualifications issue.
As grounds for this request to supplement, Intervenors t
state that the transcript of this testimony was not made avail-able to Intervenors until after its November 5, 1981, deadline for filing its Motion to Reopen.
Intervenors submit that the testimony provides additionTal insight into the financial condition of Applicant, Public Service Company of Oklahoma, and the effect of Black Fox Station on its future financial viability.
Mr. Stratton's final re-marks on page 32 of the transcript provide an. excellent example of the nature of the testimony and the reason Intervenors request its supplemental inclusion:
Finally, in the interest of perception by the financial community as to the future of utility regulation in Oklahoma, particularly in what will be a time of financial stress for PSO whether it goes forward with the Black Fox project or not, an indication of the Commission's view and anticipated treatment of construction investments in the rate-making process.
(Emphasis supplied.)
For all the foregoing reasons, Intervenors submit this Supplement to their Motion to Reopen.
Respectfully submitted, FELDJ
, HALL, FRANDEI WOODARD By
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Qancy L. po6ds 816 Enterprise Building Tulsa, OK 74103 DATED:
November 20, 1981
b xhnD G WI ISHAM, LINCOLN & BEALE COUNSELORS AT LAW [T,KEI[O
'T: E H2 O CON N cCTICUT AvC N U C. N.W.
Sutic 225 WAS HINGTON O. C. 20036 TctcenONc 2o2 esMrsJGV 23 PS :24 CMIC &GC OFreCc ONc FlRST MAreONAL *LAZ A FORTv scCONO FLOOm September 8, 1981 C:::ET' ~. :
CM' Caco.aus Cis =0 02 j :;s S[gOCE TcoteaO N c sia ase TsC o ecocm:a sas.
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Sheldon J. Wolfe, Esquire Mr. Frederick J.
Shon Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U. S. Nuclear Regulatory U.
S.
Nuclear Regulatory Commission Commission Washington, D. C.
20555 Washington, D.
C.
20555 Dr. Paul W. Purdom Administrative Judge U.
S. Nuclear Regulatory Commission c/o Environmental Studies Group Drexel University 32nd and Chestnut Streets Philadelphia, PA 19104 RE:
In The Matter Of Black Fox Station, Units 1 and 2, Docket Nos. STN 50-556 and STN 50-557 Gentlemen:
Consistent with the Applicant's policy of full disclosure, I am enclosing a copy of a report prepared by Touche Ross & Co. for the Oklahoma Corporation Commission in connection with a pending rate case filed by Public Service Company of Oklahoma ("PSO").
The summary of the report's conclusions is set forth on pages 10-13.
One of these judgments suggests that, based on Touche Ross' cost assess-ment and development, the Black Fox Station project should be converted from a nuclear to a coal facility.
All aspects of the report are being carefully evaluated and considered by PSO, and its assessment will be presented to the Oklahoma Corporation Commission.
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Sheldon J. Wolfe, Esquire Mr. Frederick J.
Shon Dr. Paul W.
Purdom September 8, 1981 Page Two Applicant has filed today, under separate cover, Amendment No. 16 to the Preliminary Safety Analysis Report for its construction permit application for the Black Fox Station.
Amerdment No.16 addresses the Nuclear Regulatory Commission's post-TMI regulations concerning emergency planning.
Applicant expects to file Amendment No.17 to the Preliminary Safety Analysis Report by October 5, 1981.
This Amendment will address the NRC's recent amendments to 10 C.F.R. Part 50 which are applicable to all pending near-term construction permit applications like Black Fox Station.
Sincerely, M
Joseph Gallo One of the Attorneys for Public Service Company of Oklahoma Enclosure JG/pm cc:
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Exhibd VA ISHAM, LINCOLN & BEALE COUNSELORS AT LAW
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1130 CONN cCT. CUT AVcNU C. N.W.
Suite 32S W SMINGTON, D. C. 2oO 3.
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=*,,o 46 i.*:n November 13, 1981 roan seco o rtoca
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tcLem:a saae Sheldon J. Wolfe, Esquire Mr. Frederick J.
Shon Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U. S. Nuclear Regulatory U.
S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C.
20555 Dr. Paul W. Purdom Administrative Judge U. S. Nuclear Regulatory Commission c/o Environmental Studies Group Drexel University 32nd and Chestnut Streets Philadelphia, PA 19104 Re:
In the Matter of Black Fox Station, Units 1 and 2, Docket Nos. STN 50-556 and STN 50-557 Gentlemen:
Consistent with the full-disclosure policies of Public Service Company of Oklahoma ("PSO"), I an enclosing copies of certain documents from PSO's pending rate case.
This case is styled as the " Application of Public Service Corporation of Oklahoma, an Oklahoma corporation, For an Adjustment in its Rates and Charges for Electrical Service in the State of Oklahoma," Cause No. 27068.
This application is pending before the Corporation Commission of Oklahoma.
The record is closed, and a decision is expected from the Commission by early January 1982.
The enclosures include two Orders of the Corporation Commission granting interim rate relief, and the direct testimony of Messrs. Brown and Stratton.
The testimony
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Sheldon J. Wolfe, Esquire Mr. Frederick J.
Shon Dr. Paul W.
Purdom November 13, 1981
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Page Two provides updated scheduling and cost information with respect to the Black Fox Station.
I am also enclosing a letter from Mr. W.
R.
Stratton, Senior Vice President, Finance, of PSO, that among other things explains the status of the project's reconsideration by PSO and the other owners, Associated Electric Cooperative, Inc., and Western Farmers Electric Cooperative.
Mr. Stratton's letter is self-explana-tory, and I will not attempt to characterize it further.
Sincerely, h
oseph Gallo Counsel for Public Service Company of Oklahoma
Enclosures:
As Indicated cc:
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