ML20092A453
| ML20092A453 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/15/1984 |
| From: | Silberg J KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8406190226 | |
| Download: ML20092A453 (9) | |
Text
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June 15, 1984
'84 JT118 P3:14 UNITED STATES OF AMERICNhif;hfgfgf NUCLEAR REGULATORY COMMISSION BE?!!C' BFFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY, et al. )
Docket No. STN
)
50-482 (Wolf Creek Generating Station,
)
Unit No. 1)
)
APPLICANTS' ANSWER TO MOTION OF KANSANS FOR SENSIBLE ENERGY TO HAVE STATUS AS INTERVENOR AND FINANCIAL QUALIFICATIONS CONTENTION REINSTATED-On February 22, 1984, Kansans for Sensible Energy ("KASE")
filed a motion asking that the Appeal Board decide KASE's June 23, 1982 appeal on reinstating it as an intervenor and l-l reinstating its financial qualifications contention.
The Appeal l
Board on June 28, 1982 had ordered that the appeal be held in abeyance pending a decision in the then pending judicial chal-lenge to the Commission's 1982 financial qualifications rule.
R KASE based its motion on the February 7, 1984 decision by the U.S. Court of Appeals for the District of Columbia Circuit on that challenge.
New England Coalition on Nuclear Pollution v.
NRC, 727 F.2d 1127 (D.C. Cir. 1984).
226 840615 84061 CK 05000482 PDR A PDR _
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On February 28, 1984, the Appsal Board continued its de-ferral of KASE's appeal in light of the Commission's February 27, 1984. Statement of Policy, 49 Fed. Reg. 7981, which directed li-censing and appeal boards.to continue to treat the 1982 financial qualifications rule as valid at least until the Court of Appeals issued'its mandate in-the New England Coalition case.
On April 18, 1984 the Appeal Board, noting that the Court's mandate had issued, ordered that responses be filed to KASE's February 22, 1984 motion.
By Order dated May 1, 1984, the Appeal l
L
. Board extended the deadline for filing responses to KASE's motion until the fourth business day following issuance by the Commis-sion of a new Statement of Policy on financial qualifications.
j On June 12, 1984, the Commission published in the-Federal Register a Statement of Policy responding to the issuance of the f
i 1
mandate in New England Coalition.
(A copy
[
of the Statement of Policy is' attached hereto.)
The Commission stated that it was responding to the Court's decision by con-a ducting a new rulemaking proceeding on financial qualifications,
.49 Fed. Reg. 13044 (1984).
The Commission went on to state its position that the 1982 financial qualifications rule "will con-tinue in effect until finalization of the Commission's response to the Court's remand.".The Commission therefore directed its licensing and appeal boards "to proceed accordingly."
49 Fed.
-Reg. at 24111.
As a result, licensing and appeal boards are not 1/
The Statement of Policy is dated June 7, 1984.
Applicants did not, however, learn of its issuance until they re-ceived the Federal Register notice on June 12, 1984.
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"to begin the process of accepting and litigating financial qual-ification contentions...."
Id.
Because the Commission has ordered its licensing and appeal boards to continue to treat the 1982 financial qualifications rule as valid pending completion of the on-going rulemaking, the Appeal Board can now rule on KASE's February 22, 1984 motion and on KASE's underlying June 23, 1982 appeal.
Applicants respect-fully submit that the Appeal Board should grant KASE's motion to the extent that it requests the Appeal Board to rule on its June 1982 appeal.
There is no reason to further defer action.
Having reached the merits of KASE's appeal, Applicants re-spectfully request that the appeal be dismissed.
The June 12, 1984 Statement of Policy directs. licensing and appeal boards to continue to treat the 1982 rule as valid.
Since the 1982 rule prohibits litigation.of financial qualifications issues in this proceeding (all three applicants being " electric utilities" as defined in the rule), KASE's financial qualifications contention must be dismissed.=
And since that contention was KASE's only
. contention, KASE must be dismissed as a party.
Respectfully submitted, dla BY:
/
J
- ILBERG, P.C.
TTMAN, POTTS &
WBRIDGE M
treet, N.W.
hinpton, D.C.
20036 (202) B22-1000 counsel for Applicants DATED:
June 15, 1984.
I
j Federal Register / vcl. 49. N:.114 / Tu:sday. Juna 12.1984 r Rules cnd Regulati:ns 24111 4 '
particular proceeding shall be qualified England Coalition on Nuclear Pollution utilities will be able to cover the costs of I
in the conduct of administrative v.NRC 727 F.2d 1127 (D.C. Cir.1984).
operation through the ratemaking l
proceedings. An alterrate may be the Nuclear Regulatory Commission process.
assigned to serve as a member of an issues a statement of policy clarifying its In the interim. the Court's mandate Atomic Safety and IJcensing Appeal response to the Court's remand.
has issued.The mandate contained no Board for a particular proceeding in the pOn PUltTHER NePORetAT1088 C0sf7ACT:
guidance other than that furnished in the event that a member asigned to such Carole F. Kagen. Office of the General Ccurt'a pini n.The Commission has proceeding becomes unavailable.
Counsel U.S. Nuclear Regulatory e neluded that theissuance of the (b)In the absence of a quorum, the Commission. Washington. D.C. 20555:
mandate does not have the effect of following Individuals are authorized to phone (202) 634-1493.
act for an Appeal Board on procedural rest ring the previous regulation under sUPPt.EssENTARY leePOHasATIOst On which financial qualification review was matters, including requests for stays of February 7.1984, the U.S. Court of orders by presiding officers:
Appeals for the District of Columbia re @ e as a pureWte f r a mactor (1)The Chairman of the Appea assigned for a particular proceedm,1 Board Circuit granted a petition for review by c nstruction permit or operating license.
(2) The permanent Chairman of the the New England Coalition on Nuclear In remanding the rule to the Commission g:
Atomic Safety and Licensing Appeal Pollution (NECNp) which challenged the without explicitly vacating the rule the Panelin the event that the Chairman for Commission's hfarch 31.1982, rule Court cited Williams v. Washirgten a particular proceeding is not available eliminating case-by. case financial Afetropolitan Area Transit Commission.
o act upon the matter in question, or qualification review requirements for 415 F.2d 922 (D.C. Cir.1968) (en bancl.
electric utilities. New England Coalition cert. denied 393 U.S.1081 (1969).
(3) st s or available full time on NuclearPollution v.NRC 727 F.2d Williams does not require that the member of the AppealPanel,in the 1127 (D.C. Cir.1984). The Court found agency action be vacated on remand.1n event that (;) the Chairman for a that the rule was not adequately another situation where the D.C. Circuit particular proceeding is unavailable or supported by its accompanying remanded a set of rules to an agency for has not been assigned, and (ii) the statement of basis and purpose and an adequate statement of basis and permanent Chairman of the Appeal remanded to the agency, but did not purpose, the Court allowed the old rules Panel is unavailable or the position is explicitly vacate the rule.,
to stand pending ency action to vacant.
In response to the decision, the comply with the Court's mandate.
(c)(1) Except with respect to requests Commission initiated a new financial Rodwo' v. UnitedStates Depa-tment of for stays of orders of presiding officers, qualification rulemaking to clarify its Agit uiture. 514 F.2d Q9 (D.C. Cir.1973).
action by a designated individual under pas,ition on financial qualification The Commissien is compmng with the the authority of paragraph (b) of this revtews for electric utilities. 49 FR 13044 Court's mandate by reproraulgating its section shall be reviewable by the (1984). One of the points focused upon in financial cualifications rule in a manner Appeal Board for the particular the Court's decisiori was the responsiva to the Court's concem.The proceeding, upon its own motion or Commission s observation in the Comm!schn anticipates that the new upon a motion filed within three (3) days hemem MonMerams p &
rule elimir.ating financial review at the of the date of the particular action in htarch 31.1982 rule that utilities operating license stage only will soon be accordance with I 2.730.
encountering financial difficulties in the in place. While there are no construction (2) Action under the authority of past during construction hava chosen to paragraph (b) of this section with abandon or postpone projects rather p:rmHs proceedings now in progress.
respect to requests for stays of orders of than cut corners or s.ifety. The Court there are several ongoing operating license proceedings to which the new
,$ presiding officers shall be reviewable by be i{d that such acticas by s me rule will apply. It would not appear d
o a mot n le wit n e
) days financially trou ed utilities would reasonable to construe the Court's of the date of the particular action iri follow the same course.The revised 0 pinion as requiring that the acccrdance with i 2.730.
proposed rule would eliminate financial Lommission mstruct its adjudicatory j
review only at the opcrating license panels m these proceedings to begm, the g
Dated at Washington. D.C., rh.'s 6th day of stage.The question of reasonable process of accepting and litigating I"* M84.
assurance of adequata construction financial quahfications cententions, a i
l'or the Nuclear Regulatory Commission.
funding can be an issue only at the process which wocid delay the licensing Samuel J. Chilk.
construction permit stage. Thus, the of several plants which are at or near Sarctorynfehe Commission.
Commission's current rulemaking is completion. only to be required to responsive to the Court's concern by dismiss the contentions when the new irm o.s.u.is. u rit.a o-um us I maintainmg the financial qualifications rule takes effect in the near future.
i caos nm rev:ew for construction permit Accordingly, the March 31,1982 rule upphcants, will continue in effect until finalization 1
- 10 CFR Parts 2 and 50 The Court was also troubled by what of the Commission's resoonse to the 1
it perceived to be an inconsistency Court's remand. The Commission directs l
p(nancial Qualifications Statemen between elimination of the review only its Atomic Safety and Licensing Board l
b-...
Panel and Atomic Safety and 1.icensing or s ion s se a i n that financial AGENCv:U.S. Nuclear Regulatory qualifications reviews are unnecessary Appeal Panel to proceed accordingly.
Commission.
because it finds no link between Commissioner Gilinsky did not AcTioet Policy statement.
financial qualifications and safety.This participate in this decision.,
f observation is not relied on in the new Commissioner Asselstine's dissent from susessany:In response to the issuance of proposed rule. Instead the rule is this decision and the separate views of i
the mandate of the U.S. Court of premised on the assumption that. at tha Chairman Palladino and Commissioners Appeals for the D.C. Circuit in New operating license level, regulated Roberts and Bernthal follow.
m
e 24112 Federal Register / Vol. 49. No.114 / Tuesd:y June 12. 1984 / nul:s cnd Regul2tirns i
Separate Statement of Chairman Separ* Views of Commissioner Commission's 1982 financial Palladino Bernthal qualifications rule. They told us that this f;n nct a$ificat s ul e
sn t
aa e
ininstitu ng a c e
ng Cenmission. The Commission promptly proceeding is fully responsive to the u e remov{ 3 ss
,om initiated rulemaking to address the Court's mandate. As the Commission's procce ings.
at our egal deficiencies identified by the Court. It policy statement indicates, the Court's advisors could say about the course fte o ss n: at ale p '
he ss s
t then faced the question of what to do jriti is m niss po
{ e,abse of expli t lar guage in perat ngI e nse ca eC u t i sues which.e en u der the re-1982 opinion did not say that the rule was rule, wou g e on y e
" vacated." Thus, the Commission was construction permit stage of review.
They ind;cated. however that theY presented with a question of Therefore. even if one assumes for the would not adsise taking this course interpretation of the Court's opinion.
sake of arg ent t at the C urt vacated ecaus o sig cant litigatio iak ss o s rationa$e nadequate.the leads me to e with their conclusion.
on e Court s p n on co d reasonably e interpreted as not vacating the rule for Commission took prompt action in is situation the operating license reviews' modifying the 1982 regulation by General Counsel proposed an mtenm The Commission has not sought t proposing a rule which woud reinstate policy statement which would have out t e Court or escape its mandate.
financial qualifications reviews for all enabled the boards and parties to The Commission has attempted to be construction permit applicants.
resolve the financial qualifications issue responsive to the Court s opinion and. at I have based my decision on a plain in indistdual cases in an expeditious the same time. has sought to avoid reading of the opinion of the Court.
manner.There would have been some wherein the Court listed the five unavoidable short-term delay and some unnecessary disruption of its licensing and regulatory program. It interpreted contentions raised by the appellants, inconvenience in a few cases. However.
the Court a opmion with full recognition and noted "We agree with the last lof had the Commission acted in a timely that the Court would correct its the five contentf onsJ." That is, the Court manner to adopt that policy statement mterpretation if the Court had intended held that "ths rule is not supported by when it was proposed a month ago, to vacate the rule.
its accompanying statement of basis and much of that inconvenience and delay ppose * * *** and accordingly would be over by now.
Seperate Statement of Commissioner remanded the rule to the agency. Civen Instead. the Commission has chosen Roberts that holding. I believe the Commission's to ignore the advice of all ofits legal action is directly and precisely advisors and to act as if the 1982 rule I j..om m the separate statement of rerpensive to the decision of the Court.
were still valid. By pursuing this course.
Chairman Palladino. In addition. I would it is unfcrtunate that the Commission the Commission risks reaction by the point out t.'at, of the five contentions was required to consider. elaborate D.C. Circuit which would not only reject perceived 1.y the Court to have been arguments and interpretations based on the Commission's erroneous l
raised by tie petitioners challenge. the legal precedent to resolve what should interpretation of the Court's previous Court agreeO only with the last-that have been a straightforward matter.
decision but which would also set out the rule is no' supported by its I concur in the views of the Chairman precisely what the Commission must do l
accompanying statement of bas,s and and Commissioner Roberts.
In the case of those proceedings decided i
i purpose. In discussing the grounds fqr under the invalid rule. Any llexibility in its remattd. the Court addressed only its Separate Views of Consmissioner dealing with these proceedings could basis for disagreement with that portion Asselstine well be lost to the Commission, and of the rule that would eliminate a The Commission's policy statement is serious delays and disruption could financial qualifications review in both shortsighted and most likely illegal. result if the Court decides several connection with consideration of The Commission is in effect betting that months from now that all of these applications for construction permits.
the D.C. Circuit will not now act 'o make proceedings must be reopened.
The Court concluded that. In refusing to it very clear that the Commission's Moreover,it is not clear that there consider. in a vacuum. the general "new" financial qualifications rule has exists an adequate factual basis to ability of utilities to finance the indeed been vacated and that the support a new rule eliminating financial construction of new generation Commission must re-open all those qualification issues from all nuclear facilities. the Commission had proceedings in which the rule was used powerplant operating hcense abandoned what seemed to the Court' to exclude financial qualification proceedings. For example, even if it is "the only rational basis enunciated for contentions. I choose not to join the possible to demonstrate that electric generally treating public utilities majority in this course because I believe utilities receive routine approval of differently for the purpose at hand."
that the Court's previous decision funding requests to cover the cost of The Court apparently did not focus on effectively vacates th3 Commission's operating a nuclear powerplant-an i
the rationality of the Commission's basis 1982 financial qualifications rule.
essential element in the justification for i
for treating public utilities differently for Moreover. I believe that the the Commission's new proposed the purpose of considering applications Commission's approach risks in the long financial qualification rule, this does not for operating licenses. 'llius. it appears run serious disruptions and delays to necessarily assure that these funds will unlikely that the Court intended, or had pending cases.
be used by the utility for meeting any reason, to vacate that portion of the Our Executive 1.egal Director, our operating plant safety needs. The rule eliminating a financial General Counsel and now the financial difficulties facing several qualifications review in connection with Department of Justice have all advised electric utilities in meeting the cost >f consideration of applications for the Commission that the decision of the ongomg construction programs and in operating licenses.
D.C. Circuit did indeed vacate the providing an adequate rate of return on f
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Federal Register / vel. 49. N:.114 / Tursdry. Jun? 12. 1984 / Ruhs and 'Regulati:ns 24113 e
i investment are widely publicized. lt is
- 4. On the same page, first column. line entry reading "1 per year per likely that in such cases these factors seventeen. " Commission" should read inspection"; and entries three and four can create pressures on the utility to
" Communication".
from the bottom should appear as one reallocate operating funds to other
- 5. On page 21295 first column.
entry reading "1 per 2 years per competing functions. In such Filminatice of Ceilings, paragraph three, inspection".
circumstances, ratemaking decisions first line. "not" should read "no".
- 22. On page 21308. first column in the sufficient to cover operating expanses
- 6. On page 21296, first column. second table, entry K. second line. " times" alone would not necessarily provide an complete paragraph. line eighteen, should read " items": and in entry P. first adequate lustification for excluding "four" should read "for".
line. "materaial" should read " material".
financial qualifkation issues from
- 7. On the same page. third column.
- 23. On the same page, column four in operating license proceedings, first complete paragraph. line three.
the table. lines three and four should Perhaps most disturbing of allis the "efective" should read " effective".
appear as one entry reading "I per year Cr,mmission's willingness in this case.
- 8. On page 21297. first column. first per inspection": lines seven and eight as well as in some other recent complete paragraph. line thirteen. "335" shculd appear as one entry reading. "I decialons, to take what are at best should read "355".
per 3 years per inspection":!!nes nme questionable legal positions for the sake
- 9. On page 21299. third column. first and ten should appear as one entry of gaicirg a perceived short-term c mplete paragraph, insert the sentence reading. "I per 3 years per inspection":
benef;t. ~1his approach does eseryone "An individual operator car no' be lines eleven and twelve. should appear involved in our licensing proceedings a licensed apart from a facility." between as one entry reading. "1 per 3 years per disservice and has several unfortunate lines fourteen and fifteen.
inspection": lines thirteen and fourteen consequences. Such procedural
- 10. On page 21300, third column.
should appear as one entry reading. "I shortcuts can ultimately be very deventh line from the bottom. "tht" per 3 years per inspection"; and lines
/ disruptive to many ongaing licensing should read "than".
fifteen and sixteen should appear as one proceedings if a court rejects the
- 11. On page 21301. first column.
entry reading. "1 per 3 years per Commission's approach months or years Regulatory Flexibility Certification. line inspection".
later,when the number of affected fourteen. " consider" should read proceedings has grown substantially.
" considered".
I 170.51 [ Corrected!
2Wn page 213a column one.
Furthermore. continually taking I 170.21 IC "* 'd 3 questionable legal positions can ensly 6170.51. line six. "10 CFR 5131" shosid lead to a much more searching and
- 13. On page 21304, fi st column.
read "10 CFR 15.31".
I '" 'e ne. line five "a" should appear critical attitude on the part of reviewing sumo coos inesai-es courts, and to adverse decisions that gef te.' specific ': and in line fourteen.
of should read "or.
can seriously restrict ao,ency flexibility in dealing with future cases. Finally. the gg[f,n sa pag Grst nb
,s otild DEPARTMENTOFHEALTH AND Commission's approach sier. ply read "has"*
HUMAN SERVICES reinforces the belief of msny that this agency will go to any lengths to deny g 170.31 (corrected)
Social Security Administration members of tite public a fair opportunity
- 15. On page 21305, column one, t3 raise issues in our licensing i 170.31. entry 3.B line seven.
20 CFR Part W proceedings and to have those issues
" licensees" should read " license": entry fully and fairly litigated.
3 E.,line one. "uses" should read "use";
Signed in Washington. D C. tNs 7th day of and in entry 3.C line one "uses" should FederalOld Age, Survivors,and i
June 1964.
read "use".
Disability insurance; Gender 6
8 -
For the Nuclear Regulatory Commissinn.
- 16. On the same page, column two.
Discrimination: Foreign Worts Test; Samuel I. Chilk, entry 3.K line eight. "licensess" should Spacial Age 72 Senefits; Benefit Secretary of the Commission.
read ' licenses,.
Reduction for Widows and Widowers:
pm ooe n-iru r'tw o-n-se m.m
- 17. On the same page, column three, and Acknowledgementof Natural entry 5.B. line five. "Licenes" should Child sumo caos msas read "I.lcense".
IS. On page 21306. column three.
AGENCY: Social Security Administration.
10 CFR Part 170 N-footnote 1(d), line sixteen. "in" should liHS.
appear between "10F." and "which".
action: Final rule.
[' ievision of Ucense Fee Schedule
- 19. On the same page, column three.
footnote 2. first line "or" should ' read suumany:The Social Security Correctan "for".
Administration is amending its re2ulations to implement certain Title !!!
In FR Doc. 84-13517 beginning on page I 170.32 (correctedl pe% g M. L wn_ me wg
- 20. On page 21307, i 170.32, column Security Amendments of 1983"-that a e t e ollo ng c ns one of the table, entry 2.A line four, eliminate gender based distinctions in
- 1. On page 21293. second column the "lon-exchanging" should read "lon.
the Social Security Act. We are also EFFECTIVE O ATE now reading " June 18.
exchange"; also in entry 2.B., line one, making changes to reflect two other Pub.
19S4" should read " June 20.1984".
.* possession" should read " processing".
L 98-21 provisions. One amendment
- 2. On the sa.ne page. third column.
- 21. On the same page column four of changes the work test for the second complete paragraph. line four, the table. the eleventh and twelfth beneficiary doing non covered work
" developed" should read " developing".
entries from the bottom. should appear outside the United States from 7 days in
- 3. On page 21294. first column. line as one entry read "I per 7 year per a month to more than 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> in a eleven. "Broadmter" should read inspection": entries seven and eight month before losing benefits for that
" Broadcasters". -
from the bottom should appear as one month. The other amendment eliminates 5
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June 15, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE CHE ATOMIC SAFETY AND LICENSING APPEAL BOARD l
'In the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY, et al. )
Docket No. STN
)
50-482 (Wolf Creek Generating Station,
)
Unit No. 1)
)
l CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer to Motion of Kansans for Sensible Energy to have Status as l
Intervenor and Financial Qualifications Contention Reinstated" were served by deposit in the 'init ' States Mail, first class, postage prepaid, this 15t1 June, 1984, to all those on the 1
attached Service Lis' h
/
l Jay Silberg DATED:
June 15, 1984 l
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UNITED STATES OF AMERICA N
. NUCLEAR REGULATORY COMM.CSSION 3
BEFORE THE ATOMIC. SAFETY AND LICENSING BOARD y
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In the Matter'of
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KANSAS GAS AND ELECTRIC COMPANY, et al. )
Docket No. STN 50-482 N
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(Wolf Creek Generating Station,
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Unit No. 1)
)
SERVICE LIS'Ii UN' :
m SheldonxCl Wolfe, Chairman Atomic Safety and Licensing Atomlc' Safety and Licensing Appeal Board y6 Board Panel U.S. Nuclear Regulatory Commission
['1. U.S. jNus:: leaf Regulatory Commission 2
Washington, D.C.
20555'
' Washirigton, D.C.
20555 Docketing and Service Section Dr. George-C. Anderson Office of the Secretary Dspartment'of Oceanography, U.S. Nuclear Regulatory-Commission University of Washington Washington, D.C.
20555 Saattle, Washington 98195 j
N Kent'M.'%Ragsdale, Esquire y
Dr. Hugh C. Paxton Missouri Public Service s
1229 - 41st Street Commission UlLos Alamos, New Mexico 87544 Post Office Box 360 Jefferson City, Missouri 65102 g
.., Myron Karman, Esquire
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Scott Cauger, Esquire 4 l^ puty Assistant Chief J
Hearing Counsel Assistant General Counsel WOffice of th4 Executive Missouri Public Service
[M^ Legal-Director Commission M U;S. Nuclear' Regulatory Commisuion Post Office Box 360
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- p "l Atomic Safdty and Licensing Boa'rd Eric A. Eisen, Esgrire
' U;S. Nuclear Regulatory Commission Birch, Horton,-Bittner & Honroe-sN' 9 Washington,' D.C.
20555.
1140 Connecticut Avenue, N.W.
Washington, D.C.-
20036 w
lan S..Rosenthal, Escuire JA
Diatomic Safety and Licensing / i C. Edward Peterson, Esquire ji Appeal Board D
Kansas Corporation Commission 1 ' U.S. Nuclear Regulatory Commission State Office Building - 4tr Floor
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20555 y.s Topeka, Kansas 66612 IR-h,
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Nuclear-Regulatory Commission Washington, D.C.
20555 Crian P. Cassidy, Esquire L
-Federal' Emergency. Management Agency
'Rrgion.I-J. W. McCormack POCH
" Boston, Massachusetts -02109
- t J hn M.lSimpson, Esquire 4350 Johnson Drive, Suite 120
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