ML20080R247
| ML20080R247 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/09/1984 |
| From: | Andrea Johnson NUCLEAR AWARENESS NETWORK |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| 81-453-03-OL, 81-453-3-OL, ISSUANCES-OL, NUDOCS 8402280201 | |
| Download: ML20080R247 (5) | |
Text
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DOCKETED USti?.C 14 RB 24 M0:51 crnct or 33:ur,
CGCKETjNG & sdic;.,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Sheldon J.
Wolfe, Chairman Dr. George C.
Anderson Dr. Hugh C.
Paxton In the Matter of
)
) ASLBP Docket No. 81-453-03 OL KANSAS GAS & ELECTRIC CO.,
) (NRC Docket No. 50-482)
(Wolf Creek Generating Station,
)
Unit No. 1)
) February 9, 1984 MOTION FOR ADDITIONAL TIME WITHIN WHICH TO RESPOND COMES NOW the Nuclear Awareness Network, Inc. (Petitioner) and moves the Atomic Safety and Licensing Board for an additional fifteen (15) days within which to file its reply and affidavits as directed by the A.S.L.B. 's order dated February 9, 1984, in i
the captioned case.
l In support of its motion Petitioner would show the A.S. L.B:
1 That the lengthy response of Applicant with ten attached exhibits require detailed analysis and that fifteen additional days would provide sufficient time within which to respond; and That Petitioner has dilligently reviewed documents located at Emporia, Kansas, Which are relevant to its petition to inter-vene and the response filed herein by applicants; and 8402280201 840209 h)
PDR ADOCK 05000482 O
+
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That Petitioner's request for fifteen additional days within which to respond is made in good faith and for good.cause shown; and That additional information relative to Petitioner's conten-tions regarding the adequacy of applicant's quality assurance /
quality control procedures at Wolf Creek have been received by Petitioner in the last ten days; and That the public interest would be served by allowing Petitioner additional necessary time to respond to Applicant's and Staff's responses filed herein.
Respectfully submitted, A.
RODMAN JOHNSON 820 Quincy, suite 418 Topeka, Kansas (913) 232-6933 Attorney for Petitioner Nuclear Awareness Network Dated:
February 21, 1984
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EEEkhEhit UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TdE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
KANSAS GAS & ELECTRIC CO.,
~ ~ ~ ~
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Docket No. STN 50-482 (Wolf Creek Generating Station,
)
Unit No. 1)
)
NOTICE OF APPEARANCE The undersigned, being an attorney at law in good standing admitted to practice before the Supreme Court of Kansas, the United States District Court for the District of Kansas and the U.S. Tenth Circuit Court of Appeals hereby enters his appearance as counsel on behalf of petiticner, Nuclear Awareness Network, Inc. in proceedings related to the above-captioned matter.
Respectfully submitted, A.
RODMAN JOHKSON 820 Quincy, Suite 418 Topeka, Kansas (913) 232-6933 Attorney for Petitioner Nuclear Awareness Network
e
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)
[p CERTIFICATE OF SERVICE Y %y 40O/
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I hereby certify that copies of " Petitioner's"
- n..Fo r Additional Time Within Which to Respond with and Notice if*
Appearance of A.
Rodman Johnson was served this 21st day of February, 1984, by deposit in the U.S.
mail, first class, postage prepaid, to the following parties:
. The United States Nuclear Regulatory The Execu tive Legal Director Commission U.S.
Nuclear Regulatory Commission Washington, D.C.,
20555 Wa shington, D. C. 20555 Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board. Panel U.S.
Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Wa shington, DC 20555 Washington, DC 205555 Dr. George C.
Anderson Dod<eting and Service Section Department of Oceanography Office of the Secretary University of Washington U.S.
Nuclear Regulatory Commission Seattle, Washington 98195 Wa shington, DC 20555 C.
Edward Peterson, Esquire Kent M. Ragsdale Assistant General Counsel General Counsel Kansas Corporation Commission Missouri Public Service Commission State Office Building - 4th Floor P.O.
Box 360 Topeka, Kansas 66612 Jefferson City, Missouri 65102 Dr. Hugh C.
Paxton Atomic Safety and Licensing Board
-1229 - 41st Street U.S.
Nuclear Regulatory Commission Los Alamos, New Mexico 87544 Wa shington, DC 20555 Myron Karman, Esquire A.
Scott Cauger, Esquire Deputy Assistant Chief Assistant General Counsel Hearing Counsel Missouri PUblic Service Commi~ssion Office of the Executive P.O.
Box 360 Legal Director Jefferson City, Missouri 65102 U.S.
Nuclear Regulatory Commission Wa shington, DC 20555 Eric A.
Eisen, Esquire Jay E.
Silberg Birch, Horton, Bittner & Monroe Shaw, Pit tna n, Potts & Tro4 bridge 1140 Connecticut Avenue, N.W.
1800 M Street, N. W.
Washington, DC 20036 Wa shingt on, DC - 20006
Alan S.
Rosenthal, Esquire Dr. John H.
Buck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Brian P.
Cassidy, Esquire Thomas S.
Moore, Esquire Federal Emergency Management Agency Atomic Safety and Licensing Region I Appeal Board Nuclear Regul' tory Commission J.W.
McCormack POCH U.S.
a Boston, Massachusetts 02109 Washington, DC 20555 I
I A.---
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A.
Rodman John 6on
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