ML20062B752
| ML20062B752 | |
| Person / Time | |
|---|---|
| Site: | 05000484 |
| Issue date: | 10/13/1978 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 7811010080 | |
| Download: ML20062B752 (18) | |
Text
. . .. , we u u v . .. . . aw" Octob::r 13, 1978
. h . .
I el 4 tC's UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION -
se N
7h [
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ( gh . -y {
c'Q// a In the Matter of )
)
. ,g , ~
NORTHERN STATES POWER COMPANY, )
ET AL. ) Docket No. STN 50-484
)
(Tyrone Energy Park, Unit 1) ) [
p/ -[,./ ,s
/
PERMITTEES' ANSWER TO THE MOTION BY NORTHERN THUNDER, INC., TO COMPEL DISCOVERY On September 18, 1978, Permittees filed responses to intervenor Northern Thunder's discovery requests of August 25, 1978. Pursuant to 10 C.F.R. S 2.740 (f) , Northern Thunder on September 28, 1978, filed with the Atomic Safety,and Licensing Board a motion to compel discovery of Permittees. Permittees herein submit their answer in opposition to the motion. ,
Northern Thunder's motion, at the outset, seeks an order compelling Permittees to respond to certain interrogatories and requests for the production of documents propounded by Northern Thunder. The motion concludes, however, by requesting an order directing Permittees to respond to all interrogatories propounded by Northern Thunder. Section 2.740 (f) provides that a motion to compel discovery ". . . shall set forth the nature of the questions or the request, the response or objection of the party upon whom the request was served, and arguments in support of the motion." In view of this requirement, Per-mittees have construed Northern Thunder's motion to be limited i
t I,* *
]
v
e.
1 to those interrogatories which are at least identified in the body of the motion.-1/
In Paragraph 1 of its motion, Northern Thunder asserts as the ground for its motion to compel discovery with respect to twenty interrogatories the fact that Permittees did not move l the Board for a protective order pursuant to 10 C.F.R. S 2.740 (c) .
t
- As a consequence, Northern Thunder argues, Permittees are obli-gated to respond to the identified interrogatoires. As to six of the twenty interrogatories listed (i.e., interrogatories 6,
! 20, 21, 27, 34 and 38), this is the only argument presented in support of Northern Thunder's motion to compel discovery.
Northern Thunder, however, misreads the Commission's Rules of Practice. Those rules contemplate two categories of satisfactory responses to discovery requests such as those propounded by Northern Thunder. In the case of interrogatories, each interrogatory may be objected to or answered. See 10 C.F.R.
i S 2.740b (b) . In the case of requests for the production of documents, each request may be objected to or met with a re-sponse stating that the documents will be produced. See 10 C.F.R. S 2.741(d) . The rules do not countenance silence or an evasive or incomplete answer or response. Objections, l
however, clearly constitute an adequate threshold response I It is then up to the requesting party, if a
- to discovery.
ruling on the objections is desired, to seek a motion to compel discovery.
1/ Consequently, Permittees will not address here Northern Thunder's interrogatories 1-5, 7-9, 11, 12, 15, 19, 26, 30, I 31, and 35-37.
^
- O
This procedure has been followed with respect to l Northern Thunder's discovery requests. Northern Thunder has stumbled, however, over the following language in 10 C.F.R.
S 2.740 (f):
For purposes of this paragraph, an evasive or incomplete answer or response shall Failure be treated as a failure to answer or respond.
to answer or respond shall not be excused on the ground that the discovery sought is ob-jectionable unless the person or party failing to answer or respond has applied for a protective order pursuant to paragraph (c) of this section.
These provisions mean that a party may not respond to a dis-covery request with silence or with an evasive or incomplete answer, and then, in response to a motion to compel discovery, raise for the first time an objection to the request -- unless In other words, except a protective order has been sought.
where a protective order has been applied for, a responding e party is required to state any objections to the discovery requests in its initial response, rather than prolonging and confusing the discovery process by withholding objections until a motion to compel has been filed. These provisions of section 2.740 (f) do not require, as Northern Thunder seems to assert, that objections must be accompanied by a motion for a protective order.
This same scheme is embodied in the Federal Rules of P. 33(a), 34 (b) and 37 (d) .-2/
Civil Procedure. See Fed. R. Civ.
2/ Rule 37 (d) may be clearer on this point than the Commission's rules. It provides that a " failure to act" may not be excused on
. the ground that the discovery sought is objectionable unless the A failure i
party failing to act has applied-for a protective order.(footnote continued) m
-4_
Professor Moore has sc=marized the appropriate procedure as 4
fo'. lows:
The general pattern of procedure under the dis-covery rules as amended in 1970 is first the service of a request for discovery, in the form of a notice to take a deposition, interrogatories, a request to produce documents or other tangible things or to enter upon land or other property, or a request to admit or deny the genuineness of documents or the truth of statements of fact or fact related opinien, followed by a response either complying with the request or indicating intention to comply, or setting forth ob-jections together with the reasons therefor. After the discovering party receives these responses, he must make the decision whether to accept the response or to move the court to compel. discovery. . . . In such a system, designed to operate insofar as possible without judicial intervention, it is crucial, of course, that the initial request be answered and such objections as the party may have be set forth. If it were neces-sary to seek a court order requiring a response, fol-lowed by a response setting up objections, followed by a second motion to resolve the objections and order discovery, the possibility for delay and abuse would be apparent. Rule 37 (d) makes it explicit that a party properly served has an absolute duty to respond, that is, to present himself for the taking of his deposition, or serve answers or objections to inter-rogatories served upon him, or serve a response to requests for discovery under Rule 34, as the case may be, und that the court in which the action is
' pending may enforce this duty by imposing sanctions for its violation. Rule 37 (d) deals, then, with failure to make the initial response required by the Rules. . .. (Footnote omitted. )
4A MOORE'S FEDERAL PRACTICE 137.05.
In short, the entering of objections to discovery re-q'uests, without a contemporaneous application for a protective 2/ (footnote cont'd) to act includes a failure "to serve answers or objections to inter-rogatories" and "to serve a written response to a request for inspection." Rule 37 (a) (3) also treats an evasive.or incomplete answer as a failure to answer. The entry of a written objection, i
' then, does not constitute a failure to act under Rule 37 (d) .
l
=am., e
- =
- order, is appropriate under the Commission's Rules of Practice.-3/
The fact that Permittees did not seek such a protective order, then, will not by itself support a motion to compel discovery.
Consequently, the argument presented in Paragraph 1 of Northern Thunder's motion to compel discovery is without merit.
Permittees now turn to the particular interrogatories which are the subject of Northern Thunder's motion. In ea,ch case, the text of the discovery request will be reprinted for the Board's convenience.
- 6. INTERROGATORY:
Wi*h respect to each individual identified in response to the foregoing paragraph 5, specify name, age, business and residential addresses, all prior employers, and all prior experience (in terms of duration and function) with the design, construction, or operation of nuclear reactors.
Also indicate the responsibilities of each such individual with respect to TEP.
Permittees objected only to that portion of Interroga-I
' tory 6 which seeks the residential a'ddresses of NSP employees.
Eusiness addresses, along with the other information requested, were provided. We submit that information of such a personal nature is irrelevant to the question of NSP's technical quali-The only fications to design and construct Tyrone Energy Park.
argument presented by Northern Thunder in support of its motion to compel discovery as to this interrogatory is the generic 3/ The Board, under 10 C.F.R. S 2.740 ('f) (3) , may make such a protective ';; der, in ruling on a motion to compel discovery, as it is' authorized to make on a motion made pursuant to section 2.740 (c) .
I i
= + * - **w
question of Permittees' failure to seek a protective order, which we have already addressed.-4/
- 10. INTERROGATORY: With respect to each Permittee, supply a source of funds projection and a source of funds assumptions setting forth for each of the years 1978 through 1985, the expenditures expected to be incurred by each Permittee in connection with design and construction of TEP. Such source of funds projections and source of funds assumptions shall1978 be as contemplated by the Permittees after the February 24, decision ofSuch the Wisconsin source of Public Service Commission funds projections in of and source Docket funds CA-5447.
assumptions shall follow the format of pages A-13 through A-17 attached to the Request for Amendment to Construction Permit No. CPPR-157 dated March 21, 1978.
- 13. INTERROGATORY: Identify every instance of communication between a Permittee and any person in the financial community from January 1, 1970 through the current date, with respect to the obtaining of funds by each Permittee (whether internally or externally generated) for use.in designing and constructing TEP. The term " financial community" means the group of persons who are the potential source of funds for the design and con-struction of TEP, and the persons who might effect the acquisi-tion by, or the transfer to, the Permittees of such funds) in-cluding, but not limited to, individual investors, banks,-
investment bankers, brokers and advisors, the Rural Electrifi-cation Administration, Nuclear Regulatory Commission and other governmental agencies, and bond rating agencies.
- 14. INTEPROGATORY: Identify every instance of communication between one Permittee and another Permittee with respect to the obtaining by any Permittee of the funds (whether externally or internally generated) necessary to design and construct TEP.
- 16. INTERROGATORY: Identify every instance of communication between individuals employed by DPC with respect to the ob-taining by DPC of the funds necessary to design and construct TEP.
- 17. INTERROGATORY: Identify every instance of communication between individuals employed by LSDP with respect to the obtaining by LSDP of the funds necessary to design and con-struct TEP.
4/ Permittees also note that Northern Thunder did not move to compel disccvery in response to an identical objection entered to a portion of Interrogatories 1 and 8.
i
. W
- 18. INTERROGATORY:
Identify every instance of communication between individuals employed by CPA with respect to the ob-taining by CPA of the funds necessary to design and construct TEP.
Permittees objected to Interrogatories 16-18 and to portions of Interrogatories 10, 13 and 14 because they seek information with respect to the financial qualifications of perrittees Cooperative Power Association, Dairyland Power The Cooperative and Lake Superior District Power Company.
financial qualifications of these three permittees, whose ownership percentages of Tyrone Energy Park are unchanged since the Licensing Board's initial decision on this issue in LBP-77-30, 5 N.R.C. 1197, 1239-1245 (1977), are not affected by the withdrawal of Northern States Power Company (Minnesota) as a permittee. The 31.3 percent interest of NSP-MN will be assumed only by NSP-WI, increasing the latter's interest An -
the plant from 36.3 to 67.6 percent.-5/ Permittees therefo're insofar as they seek objected to these discovery requests, information from CPA, DPC and LSDP, as irrelevant to the sub-ject matter of this remanded proceeding.
As the Licensing Board already has observed, in its
" Memorandum and Order Concerning Northern Thunder's Contentions I on Remanded Matters," July 28, 1978, at 2, "[t]he Appeal Board clearly intends for us to consider only those aspects of the permittees' financial and technical qualifications which flow 5/ See Request for Amendment to the Construction Permit, in this Karicwicz, Jr.,
docket, March 21, 1978, Affidavit of Michael L.
NRC Staff, May 15, 1978, at 2.
e* a
6/
from the changes in the legal relationships of the co-applicants."-
l Recognizing that the change in legal relationships of the co- ,
l l
applicants, as it applies to financial qualifications, relates l cnly to the two NSP companies, the Licensing Board rejected Northern Thunder's proposed Contentions 2.A through 2.G because, among other things, the contentions are directed at LSDP and are' irrelevant to the remanded issues. Memorandum and Order, July 28, 1978, at 5. Northern. Thunder, in its proposed contentions of June 16, 1978, did not even attempt to raise any issues with respect to the financial qualifications of CPA and DPC.
Now attempting through the discovery process again to inject LSDP and for the first time to inject CPA and DPC, Northern Thunder argues the language of the Board Contention in support of its motion to compel discovery as to these inter-rogatories. The Board has explained that it adopted its wn contention on the financial qualifications issue because it was unable to extract from the data available to it, with cny l
precision or certainty, the effect of NSP-MN's withdrawal.
Memorandum and Order, July 28, 1978, at 9, 10. Consequently, the Board fashioned the following contention:
Because of the withdrawal of NSP-M as a direct owner of Tyrone, the permittees do not have the financial qualifications to design and construct Tyrone Energy Park Unit 1 in that:
- 1. NSP-M will be unable to transfer funds to NSP-W, or
'i See, in this proceeding, ALAB-464, 7 N.R.C. 372 (1978).
j 6,/
I
- 2. The surviving permittees will not be able to raise the necessary funds from other sources to replace those lost by the with-drawal of NSP-M, or
- 3. A combination of these circumstances will prevail.
As we stated earlier, NSP-WI has assumed the entirety of the 31.3 percent of the Tyrone plant previously owned by NSP-MN, and the financial responsibilities of CPA, DPC and LSDP are un-changed. Consequently, the only surviving permittee which is relevant to Paragraph 2 of the Board Contention is NSP-WI. In I other words , that contention appropriately should be read to state i
l that NSP-WI will not be able to raise the necessary funds from other sources to replace those lost by the withdrawal of NSP-MN.
To assist in so clarifying the issue in controversy Permittees voluntarily adm-t and stipulate for the purposes i here, '
}
l' of this proceeding that they will not rely in any way on; sur-viving permittees Cooperative Power Association, Dairyland Power
. Cooperative or Lake Superior District Power Company, to raise
- the necessary funds from other sources to replace those lost by the withdrawal of Northern States Power Company (Minnesota).
The Board and the parties may rely upon this representation as the admission of the truth of a specified relevant matter of fact, just as if the admission had been raquested pursuant to 10 C.F.R. S 2.742.
The financial qualifications issue i.- this remand being limited to the two NSP companies, Permittees submit that it is l
f
~ ~
T!T
palpable that the information sought by Interrogatories 16 through 18, and the portions of Interrogatories 10, 13 and 14 objected to, can have no possible bearing on the issue in controversy.
- 20. INTERROGATORY: Identify every instance of communication from January 1, 1973 to the current date between NSP-MN and any state or federal agency with jurisdiction over retail or whole-sale electricity rates.
- 21. INTERROGATORY: Identify every instance of communication from January 1, 1973 to the current date between NSP-WI and any state or federal agency with jurisdiction over retail or wholesale electricity rates.
The only argument presented by Northern Thunder. in support of its motion to compel discovery as to Interrogatories 20 and 21 is the generic question of Permittees' failure to seek a protective order, which we have already addressed. As a re-sult the motion fails, as to these two interrogatories, to: meet e
the requirements of 10 C.F.R. S 2.740 (f) , in that Northern Thunder has not addressed the merits of Permittees' objections or pra-sented specific argument in support of the motion.
Nevertheless, as an aid to the Board in its ruling, Permittees will expand upon and explain further the grounds for the objection to Interrogatories 20 and 21. Permittees objected to these requests for the identification and production of documents because they are vague, overly broad, oppressive and burdensome, and irrelevant to the scope of this proceeding on remand.
These interrogatories would have NSP identify every state and federal agency with jurisdiction over its retail and 8 l r
b
wholesale electricity rates, and with respect to each such agency specify the date and place of, and the parties to, and produce for inspection and copying, every instance of communication be-tween NSP and the agency from January 1, 1973, to the present. !:.
First, while the requests identify a class of reasonably }
ll
'~
identifiable correspondents, they encompass a period of nearly c
six years and no limitation on the subject matter of the com- F munications sought. The Commission's regulations, at 10 C.F.R.
l I
~
S 2.741(a) (1) , like Fed. R. Civ. P. 34, require that requested documents be designated. While the courts are continually !
called upon to determine whether documents have been designated with an acceptable degree of specificity, it is generally l
. t accepted that a request must at least designate the documents ,
by sufficiently defined categories. As to the subject matter .
'of the communications sought, Northern Thunder's Interrogatories t 20 and 21 fail to designate adequately the documents sought.
Second, the requests are burdensome and oppressive.
4 As a regulated public utility, NSP has a tremendous number of .
communications, on a wide variety of subjects, with the agencies d
which have jurisdiction over its rates. For example, the files of the NSP-MN Law Department alone-7/ include, for the time period i designated, the files of three electric and three gas rate cases ,
before the Minnesota Public Service Commission (which was created '
7/ Similarly7 if not more, voluminous files are in such departments as Rates, Rate Research, Power Supply Planning, Energy Forecasting and many others.
~
4 t
r oea . 9 m
only in 1975), one rate case in North Dakota, one rate case in South Dakota, and ,two rate cases before the Federal Energy Regu-latory Commission (formerly the FPC). Each such case file includes direct testimony alone which amounts to one foot of paper. The total file space occupied by these files is estimated to be a minimum of 15 feet. One FERC antitrust case file occupies two file drawers. NSP-WI, during this period, had three electric ;
rate cases and one gas rate case with the Public Service Commission of Wisconsin, and two FERC rate cases. In addition, of course, there are facility licensing cases and generic rulemaking, pro-ceedings. In addition to case files, there are hundreds of reports which NSP routinely must file with these agencies on a variety of topics, as well as a very large volume of corre-spondence. In short, the task of identifying and producing, the documents requested is barely short of impossible.
Finally, the information requested is irrelevant to the subject matter of this proceeding, even if one assum s that Northern Thunder was attempting to seek only communications which address electric rates. The Board ruled ac follows in its Memorandum and Order of July 28, 1978, at 3.
Contentions 1.A. through 1.D., each predict that NSP-W will face financial difficulty in one form or another because power sales will be less than forecasted, operating costs will be greater than anticipated, and rate increases will be denied by the regulatory agencies. The proximate cause of the alleged financial weaknesses is in each instance attributable to forces other than the cha'nge in the legal relationships of the per-mittees. Therefore, these contentions are rejected.
e ea .e. , ,
13 - -
- 22. INTERROGATORY: Identify every instance of communication from January 1, 1973 to the current date between CPA and any state or federal agency with jurisdiction over retail or wholesale electricity rates.
- 23. INTERROGATORY: Identify each instance of communication from January 1, 1973 to the current date between LSDP and any state or federal agency.with jurisdiction over retail or wholesale electricity rates.
- 24. INTERROGATORY: Identify every instance of communication from January 1, 19.73 to the current date between DPC and any state or federal agency with jurisdiction over retail or wholesale electricity rates.
In response to the motion to compel discovery with respect to Interrogatories 22-24, Permittees refer the Board to, and incorporate by reference, the arguments presented above with respect to Interrogatories 10, 13, 14, 16-18, and with respect to Interrogatories 20 and 21.
- 25. INTERROGATORY: Produce for inspection and copying all written title opinions which have been prepared from January 1, 1973 through the current date, by any person on behalf of any Permittee, or actual or potential creditor of any Permittee, with respect to the status of the legal title to any real estate heretofore acquired or purportedly acquired, or to be acquired in the future, for use in connection with the con-struction of TEP.
Permittees objected to this interrogatory as irre-levant to the subject matter of this proceeding. Northern Thunder argues, in Paragraph 3 of its motion to compel dis-covery, that title opinions as to real estate acquired.in connection with the plant are relevant because the adequacy of title will influence the ability of NSP-WI to borrow money.
4 i
g meg = 4 46, ,h 6 *- M
,, elm
l l . .
e .
l l l
First, the Board has already addressed the question of NSP's ownership of the Tyrone site lands, in response to a contention raised by other intervenors, and decided the i
matter in favor of the applicants. See LBP-77-30, 5 N.R.C.
1197, 1238-1239 (1977). Second, the issue, like other conten-tions pressed by Northern Thunder and rejected by the Board, is unrelated to the withdrawal of NSP-MN as a permittee.
Finally, even if the adequacy of title were within the Board's
- purview to judge, the connection with NSP-WI's financial quali-fications is too speculative to warrant inquiry here.
, 27. INTERROGATORY: Identify every federal and state govern-mental agency or commission which.has an obligation to review or approve any transfer of funds, howsoever effected, between NSP-MN
, and NSP-WI or NSP-MN and LSDP. With respect to each such agency or commission so identified, specify tna statute, regulation or rule governing such review or approval, and produce for in-spection and copying all written communications (and summaries of all oral communications) between NSP-MN, NSP-WI,and LSDP, on the one hand, and such agency or commission, on the other >
hand. .
The only argument presented by Northern Thunder in support of its motion to compel discovery as to Interrogatory 27 is the generic question of Permittees failure to seek a protective order, which we'have already addressed.
Permittees objected to this interrogatory because it would have Permittees perform legal research for Northern Thunder.
- '
- f In addition, insofar as the request _ seek.s information with re-spect to Lake Superior District Power Company, the Board is referred to our argument above as to Interrogatories 10, 13, 14 6
D e
~
. . _ _ , _ , , , , ,w.,.y -.
y-, .
v.
- 15.-
and 16-18. Finally, as a request for the production of documents, the interrogatory suffers from the same infirmities described above in our argument as to Interrogatories 20 and 21. In this case, however, the designation is even more defective in that no time period is specified.
- 28. INTERROGATORY: Produce for inspection and copying all writings prepared by any person relating to the application of the Public Utility Holding Company Act of 1935 to the design, construction, ownership and operation of TEP, and the acqui-sition by NSP-MN of shares of stock of LSDP.
- 29. INTERROGATORY: Produce for inspection and copying all agreements between NSP-MN and LSDP relating to the acquisition of NSP-MN of shares of stock of LSDP.
Permittees objected to Interrogatories 28 and 29 because they seek information which is irrelevant to the subject matter of this remanded proceeding. The relevancy of NSP's propoded
- t
=erger with LSDP has been clearly settled by the Board in its holding rejecting Northern Thunder's proposed contentiens 1.E, 2.E and 2.F. See Memorandum and Order, July 28, 1978, at 3-5.
- 32. INTERROGATORY: Produce for inspection and copying all ninutes of meetings of the board of directors of each Permittee held between January 1, 1973 and the current date, insofar as such minutes relate to the design, financing, ownership, and operation of TEP.
- 33. INTERRROGATORY: Identify every instance of communication between any person and the board of directors of each Permittee from January 1, 1973 through the current date, relating to the design, construction, financing ownership and operation Of TEP.
Permittees objected to Interrogatories 32 and 33 insofar as they apply to CPA~, DPC and LSDP. Permittees refer the Board to, and incorporate by reference, the arguments
. r .
presented above with respect to' Interrogatories 10, 13, 14 and 16-18.
- 34. INTERROGATORY: Identify every instance of communication between NSP-MN and LSDP, and persons acting on their behalf, relating to the integration of the generation and distribution systems of USP-MN and LSDP, and the purchase by NSP-MN of shares of stock of LSDP.
The only argument presented by Northern Thunder in support of its motion to compel discovery as to Interrogatory 34 is the generic question of Permittees failure to seek a protective order, which we have already addressed.
In addition, Permittees refer the Board to, and incorporate by reference, the arguments presented above with respect to Interrogatories 28 and 29.
3 J
- 38. INTERROGATORY: What is Wiley I. Beavers' middle name?
The only argument presented by Northern Thunder in support of its motion to compel discovery as to Interrog'atory 38 is the generic question of Permittees failure to seek a protective order, which we have already addressed.
Respectfully submitted, SEAW, PITTMAN, POTTS & TROWBRIDGE
- k. 0_?_
Thomas A. Baxter Counsel for'Permittees 1800 M Street, N.W. :
Washington, D.C. 20036 (202) 331-4100 Dated: October 13, 1978 (IDO f
- _ .p
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the M,atter of )
) i NORTHERN STATES POWER COMPANY, ) l ET AL. ) Docket No. STN 50-484 l
}
(Tyrone Energy Park, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Permittees' Answer to the Motion by Northern Thunder, Inc.,
to Compel Discovery," dated October 13, 1978, were served by deposit in the United States mail, first class, postage pre-paid, this 12th day of October, 1978, to all those on the i
1 attached Service List. r*
l k. a.l[! .,_
Thomas A. Baxter Dated: October 13, 1978 S
. 4, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
NORTHERN STATES POWER COMPANY, )
ET AL. ) Docket No. STN 50-484
)
(Tyrone Energy Park, Unit 1) )
SERVICE LIST Ivan W. Smith, Esquire, Cbaien Jocelyn Furtwangler Olson, Escnnre Atcmic Safety and Licensing Board Special Assistant Attorney General
' S.
. Nuclear Regulatory Ccuntission Minnesota Pollution Centrol Agency I .ashington, D.C. 20555 1935 W. Country Pcad 32 Ibseville, Minnesota 55113 Dr. George C. Anderson Oceanography Departrent, h3-10 Richard Ihrig,-Escuire University of Washington 400 Exchange B h ing Seattle, Washington 98195 4th and Center Winona, Minnesota 55987 Mr. Iester Fornblith, Jr.
Atcmic Safety and Licensing Board Michael J. Cain, Es W e U.S.' Nuclear Pegulatory Cca nssion Bureau of Legal Services' Washington, D.C. 20555 Depart: rent of Natural Rescurces Box 7921 Stephen H. Icais, Esquire Madison, Wisconsin 53707 Office of the Executive Legal Director U.S. Nuclear Regulatory Cc mission Steven M. Schur, Esquire Washington, D.C. 20555 Chief Counsel Public Ser/ ice Ccr=ission of Wisconsin Docketing and Service Section Hill Farms State Office Building Office of the Secretary 4802 Shebcrfgan Avenue U.S. Nuclear Regulatory Ccumissicn Madison, Wisconsin 53702 Washington, D.C. 20555 Mr. Stanley Cider James P. Alt:nn, Esquire c/o Durand Postraster Assistant Attorney General Tyrone, Wisconsin 54736 Depart =ent of Justice
- State Capitol -
Madison, Wisconsin 53702 Mr. Thcnus Gala::en Route 2, Box 64 Turtle Lake, Wiscensin 54889 4
e
_ _ _ _ _ _