ML20072P910
| ML20072P910 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/30/1983 |
| From: | Simpson J CHRISTY, W., SALAVA, M.E., INTERVENOR, SIMPSON, J.M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8304040413 | |
| Download: ML20072P910 (3) | |
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.g3 APR -1 P2:46 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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SRANCH Before the Atomic Safety and Licensing Board in the Matter of
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KANSAS GAS AND ELECTRIC COMPANY, et. al.
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Docket No. 50-482
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(Wolf Creek Generating Station,
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Unit No.1)
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OBJECTION TO PREHEARING CONFERENCE ORDER l.
The intervenors, Wanda Christy and Mary Ellen Salava, object to the Prehearing Conference Order made in this matter on March 18,1983,and ask that the order be modified as specified in paragraph 4 below.
2.
In support of their objection, the intervenors believe that the order should reflect an agreement among the parties regarding amendments to the stipulation of contentions which the intervenors will prepare and file.
The parties agreed that the stipulations may be amended by the intervenors if (a) there is a significant change in the NRC rules and regulations that would cause the intervenors to want to amend the stipulations;(b) the FEMA recommendations or findings present findings or information that would cause i
the intervenors to want to amend the stipulations; or (c) the State of Kansas Coffey County, or Kansas Gas and Electric Company Emergency Preparedness Plan is significantly changed. The prehearing conference record reflects that this agreement was made by the parties.
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3.
Additionally, the intervenors ask that the list of witnesses to be called by them be amended by adding the following: Employees of the Kansas Department of Transportation and Employees of the Kansas Highway Patrol. These employees have significant respmsibilities under the State Plap, but were not listed as witnesses at the Prehearing Conference because the intervenors did not receive the draft of that plan until March 9,1983, and had not had time to review the state plan.
4.
Therefore, the intervenors ask that the Board accept the objection and request for amendment stated above and that the Prehearing Conference Order be amended to reflect the intervenors' objection and request made in paragraphs 2 and 3.
$ )/2. A um
' John M. Simpson~
Attorney for Intervenors Mary Elen Salava and Wanda Christy 4350 Johnson Drive, Suite 120 Shawnee Mission, KS 66205 (913) 384-9144 Dated: March JB,1983.
CERTIFICATE OF SERVICE This is to certify that a copy of this " Objection to Prehearing Conference l
Order" has been served on the following by deposit in the U.S. Mail, first l
class on h7ho Jo
,1983.
l James A. Laurenson, Chairman Kent M. Ragsdale Atomic Safety and Licensing General Counsel Board Panel Missouri Public Service Commission U.S. Nuclear Regulatory Commission P.O. Box 360 Washington, DC 20555 Jefferson City, MO 65102 l
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Dr. George C. Anderson Eric A. Eisen, Esquire Department of Oceanography Birch, Horton, Bittner & Monroe University of Washington 1140 Connecticut Avenue, N.W.
Seattle, WA 98195 Washington, DC 20036 Myron Karman, Esquire A. Scott Cauger, Esquire Deputy Assistant Chief Hearing Assistant, General Counsel Counsel Missouri Public Service Commission Office of the Executive Legal Director P.O. Box 360 U.S. Nuclear Regulatory Commission Jefferson City, MO 65102 Washington, DC 20555 Hugh C. Paxton Atomic Safety and Licensing Board 1229 West 41st St.
U.S. Nuclear Regulatory Commission Los Alamos, NM 87544 Washington, DC 20006 Jay Silberg, Esquire Docketing and Service Section Shaw, Pittman, Potts, & Trowbridge Office of the Secretary 1800 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20006 Washington, DC 20555 C. Edward Peterson, Esquire Brian P. Cassidy Assistant General Counsel Regional Counsel Kansas Corporation Commissim Federal Emergency Management Agency State Office Building - 4th Floor Region 1 Topeka, KS 66612 J.W. McCormack POCH Boston, MA 02109 Wanda Christy Mary Ellen Salava 515 N. First Street Route 1, Box 56 Burlington, KS 66839 Burlington, KS 66839 Kansans for Sensible Energy Atomic Safety and Licensing Appeal Board P.O. Box 3192 U.S. Nuclear Regulatory Commission Wichita, KS 67201 Washington, DC 20555 M A1. A w-
%n M. Simpson 3
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