ML20040B969
| ML20040B969 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/13/1982 |
| From: | Salava M SALAVA, M.E., INTERVENOR |
| To: | KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8201270115 | |
| Download: ML20040B969 (7) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIESf6SN M 25 R2 M6 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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K ANSAS GAS & ELECTRIC COMPANY,
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Docket No.30-482 et. al.
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(Wolf Creek Generating Station,
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Unit No.1)
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ANSWER OF INTERVENOR SALAVA TO APPLICANTS' FINANCIAL QU ALIFICATIONS IN TERROG ATORIES.
The intervenor, Mary Ellen Salava, being first duly sworn states under oath as follows: The following are my answers to the applicants' financial quahfications contention interrogatories, numbers FQ-1 to FQ-23, which are dated August 19, 1931.
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FQ-1.
I have not given consideration to matters relating to the financial F.ECEIVED qualifications of the applicants to operate the Wolf Creek facility. ':
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nsuitssym m m I have, thercfore, not developed criteria which relate to the appli-IME 8ltfDtXi tt 7
cants' financial qualifications.
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IG FQ-2.
I have not contended that financial conditions have changed since the issuance of the construction permit for the Wolf Creek facility, and I do not have any opinion about how changes in the financial conditions have affected the cost of operating the Wolf Creek facility.
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FQ-3.
I have not given thought to how the applicants will be able to finance I /[
the,perations of the Wolf Creek facility and have not made any contentions about the app'icants' ability to do so.
8201270115 820113 PDR ADOCK 05000482 0
PDR 1
FQ-4.
I do not have any figures or sources relating to the applicants' estimates of the cost of operating the Wolf Creek facility.
FQ-5.
I have not contended that the applicants' costs for operating the Wolf Creek f acility have increased and are underestirnated. I do not have an opinion about whether such costs have increased or are underestimated.
FQ-6.
I have not contended that the costs of operating the Wolf Creek facility have increased over the applicants' p ojected costs or are underestimated.
I have not studied this rnatter and therefore do not have an opinion about the future operating costs of the facility.
FQ-7.
I have not contended that any work stoppages have increased the cost of operating the Wolf Creek far!!ity. I do not have any information about such work stoppages that relates to how they might have increased operating costs for the facility.
FQ-8.
I have not contended that there are construction problems which have increased the cost of operating the Wolf Creek facility. I do not have any information or opinions about how such construction problems l
l might have affected the operating costs of the facility.
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FQ-9.
I have not contended that iegulatory changes made necessary by Three Mile Island problems have increased the cost of operating the Wolf Creek l
l facility. It is not a matter I have given consideration to and therefo. e do not have an opinion about it.
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FQ-10. I have not contended that there are costs of permanent waste storage which have increased the cost of operating the Wolf Creek facility.
Therefore, I do not have an opinion about the relationship of permanent waste storage and the cost cf operating the Wolf Creek facility.
FQ-i l. I have not contended that there are any potential delays in the construction of the Wolf Creek facihty due to water drought conditions. Therefore, I do not have information as to how any such delay might haw increased the operating costs of the facihty.
FQ-12. I have not contended that there are air and water emissions which have increased the cost of operating the Wolf Creek facility. Therefore, I do not have an opinion or information as to the affect of any such emissions upon the costs of operating the facility.
FQ-13. I do not have an opinion about the relationship between the safe operation of the Wolf Creek facility and increased operating costs described in interrogatories FQ-2 through FQ-12 above. I have not given any considera-tion to these matters.
FQ-14. There is not any information I have relied upon regarding the costs of operating a nuclear power plant.
FQ-15. I have not given any substantial consideration to criteria that can be applied to determine if the applicants are financially qualified to decommission the Wolf Creek facihty. Therefore, I have not developed any set of criteria relating to this matter.
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FQ-16. I have not contended that financial conditions have changed since the issuance of the construction permit for the Wolf Creek facility. There-f ore, I do not have information or an opinion about how such changes will affect the costs of decornmissioning the Wolf Creek facility.
FQ-17. I have not contended that the applicants lack the financial ability to cbcommission the Wolf Creek facility. Therefore, I do not have an opinion or information about their ability to do so.
c FQ-18. I cannot identify any figures or sources which are the basis for the applicants' estimates of the costs of decommissioning the Wolf Creek f acilit y.
FQ-19. I do not contend that the opplicants have underestimated the cost of deco:nmissioning the Wolf Creek facility. Therefore, I cannot state an amount by which the cost of decommissioning may have been under-estimated.
FQ-20. I have not made any contention about the cost of decommissioning the Wolf Creek facility. Therefore, I am not able to respond to the other snatters set forth in this interrogatory.
FQ-21. I have not mntended that the applicants should establish a reserve for the Wolf Creek facility. Therefore, I am not able to describe the extent of any such reserve or how it should be funded.
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FQ-22. I have not given consideration to the cost of decommissioning a nuclear power plant. Therefore, I do not have any information that I rely upon regarding the costs of such decommissioning.
FQ-23. My answers to interrogatories FQ-1 through FQ-22 above are not based on any documents. My answers are not based upon any type of study, calculation, or analysis. My answers are not based upon any research.
My answers are not based upon any conversations, consultations, corre-spondence, or any other type of cornmunication with one or more individuals.
The answers set forth on pages 1 - 5 above are based on the information available to me at this time. If further information becomes available to me,I reserve the right to supplement or amend these answers and to the extent required to do so will supplement or amend these answers.
Signed this /3/4 day of January,1982.
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l Mary en Salava e
l STATE OF KANSAS, COUNTY OF Jchnson On this /3/4 day of _@mnev
,1982, Mary Ellen Salava appeared before me and being first duly sworn made and signed the above answer under oath.
JOHN M.SIMPSOh ttOTARY PUBUC yd' gf L'4 ",WN STATE OF KAIM N
.p e 4-M- 6 s otary Public pg 4
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
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KANSAS GAS & ELECTRIC COMPANY,
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Docket No. 50-482 et. al.
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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 Answer of Intervenor, Mary Ellen Salava, to Applicants' Financial Qualifications Interrogatories in the above captioned proceeding have been served on the following by deposit in the United States mail, first class, on January /f,1982.
James P. Gleason, Esq., Chairman Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Silver Spring, MD 20901 U.S. Nuclear Regulatory Commission Washington, D.C.
20535 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.
20555 Dr. 3. Venn Leeds 10807 Atwell Eric A. Eisen, Esq.
Houston, Texas 77096 Birch, Horton, Bittner & Monroe 1140 Connecticut Avenue, N.W.
Treva 3. 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 Wichita, Kansas 67201 3ay Silberg, Esq.
Shaw, Pittman,Potts & Trowbridge Mary Ellen Salava 1800 M Street, N.W.
Route 1, Box 36 Washington, D.C.
20006 Burlington, Kansas 66839
Wanda Christy Myron Karman
$15 N.1st Street Deputy Assistant Chief Hearing Counsel Burlington, Kansas 66839 Office of the Executive Legal Director Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board U.S. Nuclear Regulatory Commission C. Edward Peterson, Esq.
Washington, D.C.
20555 Assistant General Counsel Kansas Corporation Commission State Office Bldg.
Topeka, KS 66612
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-Jonn M. Simpson 1
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