ML20050C440
| ML20050C440 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/01/1982 |
| From: | Silberg J KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | SALAVA, M.E., INTERVENOR |
| Shared Package | |
| ML20050C442 | List: |
| References | |
| NUDOCS 8204080505 | |
| Download: ML20050C440 (4) | |
Text
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'82 IN -2 100 T UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION tr BEFORE THE ATOMIC SAFETY AND LICENSING BOAR ORRESPOND Wrpi In the Matter of
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KANSAS GAS & ELECTRIC COMPANY g al.
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Docket No. S
_ 482
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b (Wolf Creek Generating Station,
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s Unit No. 1)
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APPLICANTS' SECOND REQUEST C
iw M* g TO INTERVENOR SALAVA L,
FOR THE PRODUCTION OF DOCUMENTS r
e i This request for production of documents is filed pursuant to 10 C.F.R.
S 2.741, which requires that Intervenor produce and either furnish copies of or permit Applicants to inspect and copy all documents responsive to the request and which are s
in the possession, custody or control of Intervenor.
This request for production of documents is continuing in nature, like the accompanying " Applicants' Second Set of Interrogatories to Intervenor Salava," and Intervenor must produce immediately any additional documents they obtain which are responsive to the request for production.
Applicants request that Intervenor Mary Ellen S'alava respond in writing to the following request for prod htion of documents and produce the original or best copy of each of the
- twmwam, of PDR u
4 documento requested b low at the office of Richcrd Terrill, j
Esq., Kansas Gas and Electric Company, or at a place mutually convenient to the respective parties.
" Documents" means all writings and records of every type in the possession, control or custody of Intervenor, including but not limited to memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, transcripts and all other records, written, electrical, i
i
.nechan cal or otherw se.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of Intervenor.
Applicants request that Intervenor produce each and every document identified or described in the answers to " Applicants' Second Set of Interrogatories to Intervenor Salava."
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By A
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[u Jhy E) Silberg, P.C.g] ~
Defis Ridgway (ouns,,sa A.
el for Applicants 1800 M Street, N.W.
Washing ton, D.C.
20036 (202) 822-1000 Dated:
April 1, 1982 _ _. _
April 1, 1982 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 et al.
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Docket No. STN 50-482
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(Wolf Creek Generating Station,
)
Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of 1.
Applicants' Second Set of Interrogatories to Intervenor Christy 2.
Applicants' Second Set of Interrogatories to Intervenor Salava 3.
Applicants' Second Request to Interveror Christy for the Production of Documents 4.
Applicants' Second Request to Intervenor Salava for the Production of Documents were served upon those persons on the attached Service List by deposit in the United States mail, first class postage prepaid, l
this 1st day of April, 1982.
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May S'ilberg C.
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J Dated:
April 1, 1982
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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KANSAS GAS AND ELECTRIC COMPANY, et al. ) Docket No. STN 50-482
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(Wolf Creek Generating Station,
)
Unit No. 1)
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SERVICE LIST James P.
Gleason, Esquire Kent M.
Ragsdale Chairman General Counsel 513 Gilmoure Drive Missouri Public Service Silver Spring, Maryland 20901 Commission P.O. Box 360 Dr. George C. Anderson Jefferson City, Missouri 65102 Department of Oceanography University of Washington A.
Scott Cauger, Esquire Seattle, Washington 98195 Assistant General Counsel Missouri Public Service Dr. J. Venn Leeds Commission 10807 Atwell P.O. Box 360 Houston, Texas 77096 Jefferson City, Missouri 65102 Myron Karman, Esquire Eric A. Eisen, Esquire Deputy Assistant Chief Birch, Horton, Bittner & Monroe Hearing Counsel 1140 Connecticut Avenue, N.W.
Office of the Executive Washington, D. C.
20036 Legal Director U. S. Nuclear Regulatory Commission C. Edward Peterson, Esquire Washington, D.
C.
20555 Assistant General Counsel Kansas Corporation Commission Atomic Safety and Licensing Board State Office Building - 4th Floor U.
S. Nuclear Regulatory Commission Topeka, Kansas 66612 Washington, D.
C.
20555 John M.
Simpson, Esquire Atomic Safety and Licensing 4400 Johnson Drive Suite 110 Appeal Board Shawnee Mission, Kansas 66205 U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section office of the Secretary U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555