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| | number = ML20076L586 | | | number = ML20076L586 |
| | issue date = 07/15/1983 | | | issue date = 07/15/1983 |
| | title = Responds to Intervenor 830622 Ltr Advancing,For ASLB Ruling, Mods & Expansions of Interrogatory Answers.List of Contentions & of Spec of Underlying Interrogatory Answer & Svc List Encl | | | title = Responds to Intervenor Advancing,For ASLB Ruling, Mods & Expansions of Interrogatory Answers.List of Contentions & of Spec of Underlying Interrogatory Answer & Svc List Encl |
| | author name = Silberg J | | | author name = Silberg J |
| | author affiliation = KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE | | | author affiliation = KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
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| | contact person = | | | contact person = |
| | document report number = NUDOCS 8307190240 | | | document report number = NUDOCS 8307190240 |
| | | title reference date = 06-22-1983 |
| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, LEGAL/LAW FIRM TO NRC | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, LEGAL/LAW FIRM TO NRC |
| | page count = 9 | | | page count = 9 |
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| L (Wolf Creek Generating Station, Unit 1) | | L (Wolf Creek Generating Station, Unit 1) |
| ! Docket No. Sa-482 Gentlemen: | | ! Docket No. Sa-482 Gentlemen: |
| In a June 13, 1983 letter, Applicants provided to the Board and the other parties a compilation of Intervenors' interrogatory answers which -- by agreement of the parties -- is to serve as the statement of issues for litigation in this proceeding. On June 20, l i | | In a {{letter dated|date=June 13, 1983|text=June 13, 1983 letter}}, Applicants provided to the Board and the other parties a compilation of Intervenors' interrogatory answers which -- by agreement of the parties -- is to serve as the statement of issues for litigation in this proceeding. On June 20, l i |
| l l | | l l |
| 8307190240 830715 PDRADOCK05000g Tso3 , | | 8307190240 830715 PDRADOCK05000g Tso3 , |
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| , Page Two 1983, Intervenors' counsel conferred with Applicants' counsel | | , Page Two 1983, Intervenors' counsel conferred with Applicants' counsel |
| * to request modifications to the June 13 compilation of inter-rogatory answers. As a result of those discussions, Applicants agreed.to certain of the requested modifications, which are memorialized in Applicants' June 21 letter to the Board.. Counsel for Intervenors also proposed other modifications and expansions i of the designated interrogatory answers in the June 20 discussions, as to_which Intervenors and Applicants were unable to reach agree- , | | * to request modifications to the June 13 compilation of inter-rogatory answers. As a result of those discussions, Applicants agreed.to certain of the requested modifications, which are memorialized in Applicants' June 21 letter to the Board.. Counsel for Intervenors also proposed other modifications and expansions i of the designated interrogatory answers in the June 20 discussions, as to_which Intervenors and Applicants were unable to reach agree- , |
| ment. By letter dated June 22, 1983, counsel for Intervenors | | ment. By {{letter dated|date=June 22, 1983|text=letter dated June 22, 1983}}, counsel for Intervenors |
| ; advances for Board ruling the modifications and expansions of interrogatory answers which Applicants oppose. Applicants respond herein to that June 22 letter. | | ; advances for Board ruling the modifications and expansions of interrogatory answers which Applicants oppose. Applicants respond herein to that June 22 letter. |
| In paragraph 3 of the June 22 letter, Intervenors propose that the following language be added to the compilation as Con-i tention 29.w [sicr 29.v]: | | In paragraph 3 of the June 22 letter, Intervenors propose that the following language be added to the compilation as Con-i tention 29.w [sicr 29.v]: |
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| : 65 o$ the interrogatory answers reflected.in.the June 13 compilation, | | : 65 o$ the interrogatory answers reflected.in.the June 13 compilation, |
| : j. to include reference to the evacuation of the_ entirety'of coffey 4 | | : j. to include reference to the evacuation of the_ entirety'of coffey 4 |
| County.*/ See June 22, 1983 letter, at 11'2, 5. As counsel'for | | County.*/ See {{letter dated|date=June 22, 1983|text=June 22, 1983 letter}}, at 11'2, 5. As counsel'for |
| ! Intervenors observes, all parties have agreed that: | | ! Intervenors observes, all parties have agreed that: |
| _The scope of the issues to be litigated excludes-the ability to_ evacuate or shelter the people living outside the Plume Exposure Pathway EPZ l but inside Coffey County. The scope includes the effect on evacuation of.the Plume Exposure | | _The scope of the issues to be litigated excludes-the ability to_ evacuate or shelter the people living outside the Plume Exposure Pathway EPZ l but inside Coffey County. The scope includes the effect on evacuation of.the Plume Exposure |
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| : s. Intervenors have also referenced Contentions 18.z, 20.d, 20.k, | | : s. Intervenors have also referenced Contentions 18.z, 20.d, 20.k, |
| ! and 24.d in their June 22 letter. These contentions (as well as others i not listed by Intervenors) already incorporate language referring to the impact of order to evacuate the entire County on the evacuation of the plume EPZ, and thus need not be the subject of Board ruling. | | ! and 24.d in their June 22 letter. These contentions (as well as others i not listed by Intervenors) already incorporate language referring to the impact of order to evacuate the entire County on the evacuation of the plume EPZ, and thus need not be the subject of Board ruling. |
| Finally, in the concluding paragraph of.the June 22, 1983 letter, counsel for-Intervenors represents that Intervenors' concurrence in the June 13 compilation as the statement of issues for litigation 4 | | Finally, in the concluding paragraph of.the {{letter dated|date=June 22, 1983|text=June 22, 1983 letter}}, counsel for-Intervenors represents that Intervenors' concurrence in the June 13 compilation as the statement of issues for litigation 4 |
| is dependent on a ruling'in Intervenors' favor on the additions and expansions requested in Intervenors' June-22 letter. The parties' agreement to accept the compilation, based on the mid-May and June 20 I -telephone conferences, was unconditional, though it was understood | | is dependent on a ruling'in Intervenors' favor on the additions and expansions requested in Intervenors' June-22 letter. The parties' agreement to accept the compilation, based on the mid-May and June 20 I -telephone conferences, was unconditional, though it was understood |
| ; that counsel for Intervenors might seek to amend the compilation,. | | ; that counsel for Intervenors might seek to amend the compilation,. |
|
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Category:CORRESPONDENCE-LETTERS
MONTHYEAR05000482/LER-1999-002, Forwards LER 99-002-00,re Identification of Surveillance Performed in Modes Other than Those Required by TS SR 4.6.3.2.a.Commitments Made by Util Are Encl1999-10-15015 October 1999 Forwards LER 99-002-00,re Identification of Surveillance Performed in Modes Other than Those Required by TS SR 4.6.3.2.a.Commitments Made by Util Are Encl 05000482/LER-1994-014, Forwards LER 94-014-00 Re Util Identification of Missed Surveillance Required by TS Prior to Changing Modes.List of Commitments Made by Licensee,Encl1999-10-15015 October 1999 Forwards LER 94-014-00 Re Util Identification of Missed Surveillance Required by TS Prior to Changing Modes.List of Commitments Made by Licensee,Encl ML20217F7481999-10-14014 October 1999 Informs That Based on Approval of Core Assessment Damage Guidance in WCAP-14696,rev 1 for Westinghouse Nuclear Power Plants,Licensee May Use WCAP-14696,rev 1 at Wolf Creek Generating Station ML20217F8701999-10-13013 October 1999 Provides Summary of Meeting on 991007 with Representatives of Wolf Creek Nuclear Station in Burlington,Kansas Re Status of Licensee Radiation Protection Program.List of Meeting Attendees & Licensee Presentation Encl ML20217C1721999-10-0707 October 1999 Forwards Insp Rept 50-482/99-09 on 990830-0903.No Violations Noted.Purpose of Insp to Perform Routine Operational Status Insp of Emergency Preparedness Program & to Resolve Questions Re Revised Emergency Plan ML20217A4881999-09-29029 September 1999 Forwards Changes to Plant Data Point Library,Iaw 10CFR50,App E,Section VI.3.a.ERDS Point Affected Is RDS0001 ML20216H9291999-09-29029 September 1999 Informs That Licensee Responses to GL 97-06, Degradation of Steam Generator Internals Acceptable & Did Not Identify Any New Concerns with Condition of SG Intervals at Plant ML20212G1681999-09-24024 September 1999 Notifies NRC of Change in Status of Licensed Individual at Plant,Per 10CFR50.74.RL Acree Holds License OP-42654 at Plant,But Has Been Permanently Reassigned from Position for Which Plant Has Certified Need for RO License ML20216F9591999-09-22022 September 1999 Forwards Withdrawal of Amend Request Re Ultimate Heat Sink Temp for Wolf Creek Generating Station ML20212G5641999-09-20020 September 1999 Forwards Insp Rept 50-482/99-13 on 990725-0904.Three Violations Being Treated as Noncited Violations 05000482/LER-1999-011, Forwards LER 99-011-00 Re Identification of Missed Surveillance Due to Exceeding Flow Rate Specified in TS for Ccps.List of Util Commitments Contained in Attachment I1999-09-17017 September 1999 Forwards LER 99-011-00 Re Identification of Missed Surveillance Due to Exceeding Flow Rate Specified in TS for Ccps.List of Util Commitments Contained in Attachment I 05000482/LER-1999-010, Forwards LER 99-010-00,re Failure to Correctly Perform TS Surveillance 4.3.3.6.Encl Identifies Actions Committed to by Util1999-09-16016 September 1999 Forwards LER 99-010-00,re Failure to Correctly Perform TS Surveillance 4.3.3.6.Encl Identifies Actions Committed to by Util ML20212D9381999-09-16016 September 1999 Informs That NRC Staff Completed Midcycle PPR of WCGS on 990818.Areas of EP & Engineering Warranted Increase in NRC Action.Nrc Plan to Conduct Add Insp Beyond Core Insp Program Over Next 7 Months to Address Listed Questions 05000482/LER-1999-006, Forwards LER 99-006-01,re Identification of Failure to Enter LCO for TS 3.6.1.1 While Taking Containment Atmosphere Samples During Power Operation.Commitments Made by Util Are Encl1999-09-15015 September 1999 Forwards LER 99-006-01,re Identification of Failure to Enter LCO for TS 3.6.1.1 While Taking Containment Atmosphere Samples During Power Operation.Commitments Made by Util Are Encl ML20212C9211999-09-15015 September 1999 Forwards NRC Form 536, Operating Licensing Examination Data, in Response to NRC Administrative Ltr 99-03 ML20216F1641999-09-14014 September 1999 Forwards Insp Rept 50-482/99-12 on 990816-20.No Violation Noted.Determined That Solid Radwaste Mgt & Radioactive Matls Transportation Programs Were Properly Implemented 05000482/LER-1999-009, Forwards LER 99-009-00 Re Util Identification of Fire Suppression Issue Affecting Safe Shutdown Components. Attachment I Identifies Actions Committed to by Licensee in Encl LER1999-09-10010 September 1999 Forwards LER 99-009-00 Re Util Identification of Fire Suppression Issue Affecting Safe Shutdown Components. Attachment I Identifies Actions Committed to by Licensee in Encl LER ML20212A5651999-09-10010 September 1999 Informs of Completion of Review of & Encl Objectives for Wolf Creek Generating Station 1999 Emergency Preparedness Exercise Scheduled for 991117.Determined Exercise Objectives Appropriate to Meet EP Requirements 05000482/LER-1999-008, Forwards LER 99-008-00,re Efsa at Plant.Attachment I Identifies Actions Committed to by Licensee in LER1999-09-0303 September 1999 Forwards LER 99-008-00,re Efsa at Plant.Attachment I Identifies Actions Committed to by Licensee in LER ML20211M7151999-09-0303 September 1999 Forwards Changes to Wolf Creek Generating Station Data Point Library.Emergency Response Data Sys Points Affected Are EJL0007 & EJL0008 ML20211N0081999-09-0202 September 1999 Informs That NRC Staff Has Reviewed Submittals & Concluded Util Adequately Addressed Actions Requested in GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power- Operated Gate Valves ML20211K8301999-09-0202 September 1999 Forwards marked-up TS Page Deleting Inequality Signs from Trip Setpoints in SR 3.3.5.3 & Reflecting Info on Calibr Tolerance Band,Per 990708 Application to Amend License NPF-42 ML20211K1941999-08-31031 August 1999 Forwards Rev 31 to WCGS Physical Security Plan,Safeguards Contingency Plan & Training & Qualification Plan,Iaw 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 ML20211H1491999-08-26026 August 1999 Forwards Insp Rept 50-482/99-16 on 990809-13.No Violations Noted.Insp Focused on Low as Is Reasonably Achievable Program,Training Program for Contract Radiation Protection Personnel & Radiation Protection QA Program ML20211A8581999-08-18018 August 1999 Forwards Insp Rept 50-482/99-08 on 990316-0724.One Violation Being Treated as Noncited Violation ML20211G2201999-08-17017 August 1999 Forwards Exam Rept 50-482/99-301 on 990726-29.Exam Evaluated Six Applicants for SO Licenses & Three Applicants for RO Licenses ML20210U0991999-08-13013 August 1999 Forwards Insp Rept 50-482/99-11 on 990712-16.No Violations Noted.Insp Was to Review Radiological Environ Monitoring Program ML20210U9751999-08-13013 August 1999 Informs That Licensee Identified That Answer Key for One Question on 990720 Written Exam & Event Classification for on Job Performance Measure Required Mod.Description & Justification for Proposed Mod,Including Technical Ref,Encl ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210R5621999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Wolf Creek Generating Station,Per TS 6.9.1.8 & GL 97-02.Revised Repts for Apr,May & June 1999,correcting Number of Hours Reactor Critical,Encl ML20210P7491999-08-0909 August 1999 Ack Receipt of ,Which Transmitted Wolf Creek Radiological Emergency Response Plan 06-002,Rev 0,under Provisions of 10CFR50,App E,Section V ML20210N0061999-08-0303 August 1999 Forwards Response to NRC 990401 RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Motor-Operated Gate Valves ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210H2551999-07-29029 July 1999 Provides 180-day Response to NRC Request for Info Re GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal ML20210J1371999-07-29029 July 1999 Requests NRC Approval of Methodology for Determining RCS Pressure & Temp & Overpressure Mitigation Sys PORV Limits. Attachment I Provides Proposed Changes to Improved TS ML20210F5931999-07-27027 July 1999 Forwards semi-annual Fitness for Duty Performance Data Rept for Wcnoc,Per 10CFR26.71(d).Rept Covers Period of 990101- 0630 ML20210F5881999-07-23023 July 1999 Submits Response to Administrative Ltr 99-02, Operator Reactor Licensing Action Estimates, ML20210B8191999-07-20020 July 1999 Ack Receipt of ,Which Transmitted Wolf Creek EP Implementing Procedure 06-005,Rev 1.Implementation of Changes Will Be Subj to Insp to Confirm That Changes Does Not Decrease Effectiveness of EP ML20209H5411999-07-15015 July 1999 Forwards Insp Rept 50-482/99-07 on 990614-18.No Violations Noted.Insp Focused on Radiation Program During Normal Operating Conditions ML20209H0441999-07-14014 July 1999 Forwards Response to NRC 990326 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. Summary of Util Commitments Provided in Attachment 2 ML20209H0751999-07-14014 July 1999 Forwards Monthly Operating Rept for June 1999 for Wolf Creek Generating Station,Per TS 6.9.1.8 & GL 97-02.Max Dependable Capacity Has Been Updated from 1163 to 1170,as Determined by Calculations Based on Capacity Test Results of July 1998 ML20209G9871999-07-14014 July 1999 Informs of Changes Affecting Wolf Creek Security Plan,Per 10CFR50.54(p)(2).Encl Provides Description of Changes & Justification for Changes ML20209E3581999-07-12012 July 1999 Discusses Util 980925 Response to GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Wolf Creek Generating Station ML20209E0611999-07-0808 July 1999 Forwards Addl Pages to Rev 12 of USAR & Commitment Changes, Inadvertently Omitted from 990311 Submittal ML20196K8231999-07-0606 July 1999 Submits Kansas Electric Power Cooperative,Inc Ltr Pursuant to Commission Direction in Memo & Order CLI-99-19.Addresses Disposition of Existing Antitrust Conditions Attached to License for Wolf Creek Unit 1 Re Proposed License Transfer ML20209C6031999-07-0606 July 1999 Provides Applicants View as Result of 990618 Memo & Order Directing Parties to Address Proper Disposition of Existing Antitrust License Condition Attached to OL for Facility Due to Planned Changes in Ownership of Facility.With Svc List ML20196K0501999-07-0202 July 1999 Forwards Insp Rept 50-482/99-06 on 990502-0612.Three Violations Occurred & Being Treated as Noncited Violations, Consistent with App C of Enforcement Policy ML20209B7131999-07-0101 July 1999 Submits Response to NRC Request for Info Re GL 98-01, Suppl 1, Y2K Readiness of Computer Sys at Npps. Response on Status of Facility Y2K Readiness Was Requested by 990701.Disclosure Encl ML20209A7461999-06-29029 June 1999 Informs of Changes in Project Mgt Staff Assigned to Wcgs. Effective 990628,J Donohew Will Assume PM Responsibilities ML20209B5151999-06-29029 June 1999 Informs That Util Completed Analyses & Modifications to Address Items Discussed in GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEAR05000482/LER-1994-014, Forwards LER 94-014-00 Re Util Identification of Missed Surveillance Required by TS Prior to Changing Modes.List of Commitments Made by Licensee,Encl1999-10-15015 October 1999 Forwards LER 94-014-00 Re Util Identification of Missed Surveillance Required by TS Prior to Changing Modes.List of Commitments Made by Licensee,Encl 05000482/LER-1999-002, Forwards LER 99-002-00,re Identification of Surveillance Performed in Modes Other than Those Required by TS SR 4.6.3.2.a.Commitments Made by Util Are Encl1999-10-15015 October 1999 Forwards LER 99-002-00,re Identification of Surveillance Performed in Modes Other than Those Required by TS SR 4.6.3.2.a.Commitments Made by Util Are Encl ML20217A4881999-09-29029 September 1999 Forwards Changes to Plant Data Point Library,Iaw 10CFR50,App E,Section VI.3.a.ERDS Point Affected Is RDS0001 ML20212G1681999-09-24024 September 1999 Notifies NRC of Change in Status of Licensed Individual at Plant,Per 10CFR50.74.RL Acree Holds License OP-42654 at Plant,But Has Been Permanently Reassigned from Position for Which Plant Has Certified Need for RO License 05000482/LER-1999-011, Forwards LER 99-011-00 Re Identification of Missed Surveillance Due to Exceeding Flow Rate Specified in TS for Ccps.List of Util Commitments Contained in Attachment I1999-09-17017 September 1999 Forwards LER 99-011-00 Re Identification of Missed Surveillance Due to Exceeding Flow Rate Specified in TS for Ccps.List of Util Commitments Contained in Attachment I 05000482/LER-1999-010, Forwards LER 99-010-00,re Failure to Correctly Perform TS Surveillance 4.3.3.6.Encl Identifies Actions Committed to by Util1999-09-16016 September 1999 Forwards LER 99-010-00,re Failure to Correctly Perform TS Surveillance 4.3.3.6.Encl Identifies Actions Committed to by Util 05000482/LER-1999-006, Forwards LER 99-006-01,re Identification of Failure to Enter LCO for TS 3.6.1.1 While Taking Containment Atmosphere Samples During Power Operation.Commitments Made by Util Are Encl1999-09-15015 September 1999 Forwards LER 99-006-01,re Identification of Failure to Enter LCO for TS 3.6.1.1 While Taking Containment Atmosphere Samples During Power Operation.Commitments Made by Util Are Encl ML20212C9211999-09-15015 September 1999 Forwards NRC Form 536, Operating Licensing Examination Data, in Response to NRC Administrative Ltr 99-03 05000482/LER-1999-009, Forwards LER 99-009-00 Re Util Identification of Fire Suppression Issue Affecting Safe Shutdown Components. Attachment I Identifies Actions Committed to by Licensee in Encl LER1999-09-10010 September 1999 Forwards LER 99-009-00 Re Util Identification of Fire Suppression Issue Affecting Safe Shutdown Components. Attachment I Identifies Actions Committed to by Licensee in Encl LER 05000482/LER-1999-008, Forwards LER 99-008-00,re Efsa at Plant.Attachment I Identifies Actions Committed to by Licensee in LER1999-09-0303 September 1999 Forwards LER 99-008-00,re Efsa at Plant.Attachment I Identifies Actions Committed to by Licensee in LER ML20211M7151999-09-0303 September 1999 Forwards Changes to Wolf Creek Generating Station Data Point Library.Emergency Response Data Sys Points Affected Are EJL0007 & EJL0008 ML20211K8301999-09-0202 September 1999 Forwards marked-up TS Page Deleting Inequality Signs from Trip Setpoints in SR 3.3.5.3 & Reflecting Info on Calibr Tolerance Band,Per 990708 Application to Amend License NPF-42 ML20211K1941999-08-31031 August 1999 Forwards Rev 31 to WCGS Physical Security Plan,Safeguards Contingency Plan & Training & Qualification Plan,Iaw 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 ML20210U9751999-08-13013 August 1999 Informs That Licensee Identified That Answer Key for One Question on 990720 Written Exam & Event Classification for on Job Performance Measure Required Mod.Description & Justification for Proposed Mod,Including Technical Ref,Encl ML20210R5621999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Wolf Creek Generating Station,Per TS 6.9.1.8 & GL 97-02.Revised Repts for Apr,May & June 1999,correcting Number of Hours Reactor Critical,Encl ML20210N0061999-08-0303 August 1999 Forwards Response to NRC 990401 RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Motor-Operated Gate Valves ML20210J1371999-07-29029 July 1999 Requests NRC Approval of Methodology for Determining RCS Pressure & Temp & Overpressure Mitigation Sys PORV Limits. Attachment I Provides Proposed Changes to Improved TS ML20210H2551999-07-29029 July 1999 Provides 180-day Response to NRC Request for Info Re GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal ML20210F5931999-07-27027 July 1999 Forwards semi-annual Fitness for Duty Performance Data Rept for Wcnoc,Per 10CFR26.71(d).Rept Covers Period of 990101- 0630 ML20210F5881999-07-23023 July 1999 Submits Response to Administrative Ltr 99-02, Operator Reactor Licensing Action Estimates, ML20209G9871999-07-14014 July 1999 Informs of Changes Affecting Wolf Creek Security Plan,Per 10CFR50.54(p)(2).Encl Provides Description of Changes & Justification for Changes ML20209H0441999-07-14014 July 1999 Forwards Response to NRC 990326 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. Summary of Util Commitments Provided in Attachment 2 ML20209H0751999-07-14014 July 1999 Forwards Monthly Operating Rept for June 1999 for Wolf Creek Generating Station,Per TS 6.9.1.8 & GL 97-02.Max Dependable Capacity Has Been Updated from 1163 to 1170,as Determined by Calculations Based on Capacity Test Results of July 1998 ML20209E0611999-07-0808 July 1999 Forwards Addl Pages to Rev 12 of USAR & Commitment Changes, Inadvertently Omitted from 990311 Submittal ML20209C6031999-07-0606 July 1999 Provides Applicants View as Result of 990618 Memo & Order Directing Parties to Address Proper Disposition of Existing Antitrust License Condition Attached to OL for Facility Due to Planned Changes in Ownership of Facility.With Svc List ML20196K8231999-07-0606 July 1999 Submits Kansas Electric Power Cooperative,Inc Ltr Pursuant to Commission Direction in Memo & Order CLI-99-19.Addresses Disposition of Existing Antitrust Conditions Attached to License for Wolf Creek Unit 1 Re Proposed License Transfer ML20209B7131999-07-0101 July 1999 Submits Response to NRC Request for Info Re GL 98-01, Suppl 1, Y2K Readiness of Computer Sys at Npps. Response on Status of Facility Y2K Readiness Was Requested by 990701.Disclosure Encl ML20209B5151999-06-29029 June 1999 Informs That Util Completed Analyses & Modifications to Address Items Discussed in GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20196G9681999-06-22022 June 1999 Informs NRC That BC Ryan Will Be Leaving Ks State Univ for Position with Wolf Creek Nuclear Operating Corp,Effective 990701 05000482/LER-1999-007, Forwards LER 99-007-00,re Condition in Which Wolf Creek Generating Station TS 3.3.2 Was Not Met.Commitments Made by Util Also Encl1999-06-18018 June 1999 Forwards LER 99-007-00,re Condition in Which Wolf Creek Generating Station TS 3.3.2 Was Not Met.Commitments Made by Util Also Encl ML20196A0251999-06-17017 June 1999 Requests That Written Exams for Reactor Operator & SRO for Plant Be Administered Beginning Wk of 990719 & Followed by Operating Exam During Wk of 990726 to Personnel Listed in Attachment.Proprietary Info Encl.Proprietary Info Withheld ML20195K0641999-06-15015 June 1999 Forwards MOR for May 1999 for Wolf Creek Generating Station & Corrected Page 2 of 2 of Apr 1999 Mor,Adding That Unit Entered Intomode 5 for Restart During Month of Apr & Correcting Shutdown Duration Hours from 672 to 671 ML20195G4391999-06-11011 June 1999 Provides Details for Missed Rept Re 10CFR50.46 Thirty Day Rept of ECCS Model Revs.Attachment I Provides Summary of Commitments Made in Submittal 05000482/LER-1999-005, Forwards LER 99-005-00,re Esfa.Commitments Made by Util Are Encl1999-06-11011 June 1999 Forwards LER 99-005-00,re Esfa.Commitments Made by Util Are Encl 05000482/LER-1997-027, Forwards LER 97-027-00 Re Identification of Missed Surveillance Required by TS 4.3.3.5.2.Encl 1 Identifies Actions Committed to by Util1999-06-0404 June 1999 Forwards LER 97-027-00 Re Identification of Missed Surveillance Required by TS 4.3.3.5.2.Encl 1 Identifies Actions Committed to by Util ML20195B9811999-05-26026 May 1999 Forwards 1998 Annual Repts for Ks Electric Power Cooperative Inc,Ks City Power & Light Co & Western Resources,Inc, Including Wholly Owned Subsidiary Kg&E Co ML20196L3361999-05-18018 May 1999 Forwards Rev 1 to Cycle 11 COLR for WCGS, IAW TS Section 6.9.1.9 05000482/LER-1999-004, Forwards LER 99-004-00 Re Failure to Maintain Containment Closure During Fuel Movement as Required by TS 3.9.4.c. Attachment I to Ltr Identifies Actions Committed to by Plant in Encl LER1999-05-12012 May 1999 Forwards LER 99-004-00 Re Failure to Maintain Containment Closure During Fuel Movement as Required by TS 3.9.4.c. Attachment I to Ltr Identifies Actions Committed to by Plant in Encl LER ML20206Q8141999-05-11011 May 1999 Requests NRC Work with Industry to Resolve Generic Changes to Allow Permanent Change to TSs Prior to June 2000.Encl Provides TS Limited Duration Action Statement Until 990930 05000482/LER-1999-003, Forwards LER 99-003-00,re Failure to Perform TS SR 4.9.2.c Prior to Entering Mode 6.Commitments Made by Util Are Encl1999-05-10010 May 1999 Forwards LER 99-003-00,re Failure to Perform TS SR 4.9.2.c Prior to Entering Mode 6.Commitments Made by Util Are Encl ML20206K5141999-05-0707 May 1999 Provides Info Re Number of Tubes Plugged in Each Sg,As Required by TS 4.4.5.5.ISI of SGs B & C Completed on 990424,resulting in Mechanical Plugging of One Tube in SG B & Five Tubes in SG C ML20206J0711999-05-0505 May 1999 Forwards Guarantees of Payment of Deferred Premiums for Owners of Wolf Creek Generating Station,As Required by 10CFR140.21 ML20206D9551999-04-29029 April 1999 Forwards 1999 Annual Radioactive Effluent Release Rept 22, for Reporting Period Jan-Dec 1998,per Section 6.9.1.7 of WCGS Ts.Attachment to Ltr Identifies Commitments Resulting from Correspondence ML20206C7321999-04-22022 April 1999 Provides Notification of Changes at WCGS Affecting Plant Physical Security Plan,Per 10CFR50.54(p).Changes Identified in Attachment I Will Be Incorporated Into Plan by 990831. Commitments Made by Util Are Included in Attachment II ML20206B2051999-04-20020 April 1999 Forwards Revs to RERP Implementing Procedures,Including Rev 1 to EPP 06-001, CR Operations, Rev 1 to EPP 06-002, TSC Operations, Rev 3 to EPP 06-004, Public Info Organization & Rev 1 to EPP 06-005, Emergency.. ML20205L7431999-04-0606 April 1999 Confirms 990401 Telcon with NRC Re Late Payment Notice That Util Received for Invoice RL0295-99.Licensee Understands Invoice to Be Cancelled ML20205F1601999-03-30030 March 1999 Forwards Rept Re Status of Decommissioning Funding for WCGS, Per 10CFR50.75.Kansas Gas & Electric Co Decommissioning Trust Agreement,Encl ML20205K9481999-03-26026 March 1999 Responds to NRC Ltr Re Violations Noted in Insp Rept 50-482/98-05.Corrective Actions:Training Was Provided to Mrep Members Through Use of Contract Individual Experienced in Maint Rule Programs.Change to Commitment Date,Encl ML20196K7261999-03-26026 March 1999 Forwards Certified Copy of ITS & ITS Bases,As Committed in Licensee to Nrc.Summary of Editorial Corrections, Also Encl ML20205A1961999-03-25025 March 1999 Provides Suppl 2 to 970515 Application for Amend to License NPF-42,providing Changes to TS Based on 990310 & 19 Discussions with NRC Re Conversion to Improved TS 1999-09-03
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20248E6641989-08-25025 August 1989 Forwards Corrected Copy of to Jm Taylor Re Plant ML20247H4411989-08-21021 August 1989 Attempts to Determine If NRC Aware & Approved of Existence of Const QC Dept at Facility During Const Phase of Plant & If Dept Approved by Nrc,On What Basis NRC Approval Granted. Info Needed in Connection W/Litigation Re Facility ML20247F7421989-04-14014 April 1989 FOIA Request for Records Re Const QC Program at Plant During Const Phase from 1979-1984 ML20151S1351988-01-25025 January 1988 FOIA Request for Info Re Death of T Arehart at Facility ML20148F5541987-01-0606 January 1987 Partially Withheld FOIA Request for All Records Re Investigation of Deficiencies in Const & Procedures at Facility ML20148F4511986-12-12012 December 1986 Partially Withheld Ltr Requesting Investigatory Documents Re Client Concerns for Lawsuit Against Daniel Intl ML20206S2701986-09-17017 September 1986 Notifies of Address Change Effective on 860927.Requests Address on Encl List of Dockets Be Changed ML20128P2661985-05-29029 May 1985 Responds to Gap/Nuclear Awareness Network 850515 Petition Filed Per 10CFR2.206 Re Actions to Be Taken by NRC Concerning Util Quality First Program ML20101B2421984-12-18018 December 1984 Forwards Util 841213 Press Release Re Fuel Loading Schedule for Facility.Related Correspondence ML20090F5361984-07-17017 July 1984 Forwards Util Revising Performance Date of 1984 Emergency Exercise.Certificate of Svc Encl.Related Correspondence ML20092N7071984-06-28028 June 1984 Informs That Util Furnishing,Under Separate Cover,Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power & State Plan.Svc List Encl.Related Correspondence ML20092H2011984-06-21021 June 1984 Agrees W/Nrc 840614 Filing Re Acceptability of Plant Operation & Comments on Unresolved Safety Issue A-46 Concerning Seismic qualification.A-46 Inapplicable to Plant. Related Correspondence ML20092H2041984-06-21021 June 1984 Forwards Util Re Revised Const Completion/Fuel Load Schedule.Svc List Encl.Related Correspondence ML20084F4511984-05-0202 May 1984 Forwards 840502 Memo Concerning Commission Disposition of Financial Qualification Rule Matter Re Pending OL Application.Failure of Court to Stay Mandate Should Not Be Treated as Direction to Vacate Rule ML20087P9521984-04-0606 April 1984 Forwards Affidavit of CM Wilcox Re Addl Schools within Plume Exposure Pathway Emergency Planning Zone.Schools Do Not Affect Evacuation Plan.Related Correspondence ML20087N0951984-03-30030 March 1984 Informs That full-scale Emergency Plan Exercise Scheduled for 840705 Rescheduled to 840912.Certificate of Svc Encl. Related Correspondence ML20087F2741984-03-15015 March 1984 Submits Best Estimate Dates,Per 830412 Conference Call. Completion of Const Scheduled for 840923,fuel Load Scheduled for 840923 & Commercial Operation Scheduled for Spring 1985. Certificate of Svc Encl.Related Correspondence ML20080F8991984-02-0808 February 1984 Forwards Joint Stipulation on Waverly Contention.Stipulation Obviates 840208 Filing of Written Direct Testimony. Certificate of Svc Encl ML20080D4851984-02-0606 February 1984 Forwards Applicants & Intervenors Joint Stipulation on Contention Adding City of Waverly to Emergency Planning Zone ML20080B5791984-02-0303 February 1984 Forwards Applicants Response to Nuclear Awareness Network, Inc Petition for Leave to Intervene & Request for Hearing. Attachments 2-5,although Stamped Confidential,Should Not Be Withheld from Public Disclosure.Certificate of Svc Encl ML20079E2881984-01-12012 January 1984 Requests Opportunity to Make Oral Comments on 840117 & at Any Proposed Public Hearings Re Proposed Licensing ML20083F5791983-12-27027 December 1983 Forwards Prof Qualifications Statements for All non-Coffey County Witnesses for Testimony on Emergency Evacuation Plan Issues ML20083F5481983-12-27027 December 1983 Forwards Flint Hills Natl Wildlife Refuge to Coffey County Board of Commissioners,Outlining Agreement Re Emergency Procedures ML20082R3521983-12-0909 December 1983 Submits Summary of 831205 Settlement Meeting in Kansas City, Ks Re 67 Contentions to Be Dismissed,Per Chairman Wolfe 831205 Request.Voluntary Agreement to Dismiss Contentions Signed by Intevenors ML20024C9691983-07-19019 July 1983 Submits List of Expert Witnesses to Be Called.Counsel for Other Parties Have No Objection ML20076L5861983-07-15015 July 1983 Responds to Intervenor Advancing,For ASLB Ruling, Mods & Expansions of Interrogatory Answers.List of Contentions & of Spec of Underlying Interrogatory Answer & Svc List Encl ML20072N9711983-07-13013 July 1983 Notifies of Vr Harding Employment at Law Firm Per Disciplinary Rule 9-102.Harding Will Not Participate in Any Case Currently Pending Before NRC ML20072N9961983-07-13013 July 1983 Notifies of Author Employment at Law Firm Per Disciplinary Rule 9-102.VR Harding Will Not Participate in Any Case Currently Pending Before Nrc.Svc List Encl ML20072G4671983-06-24024 June 1983 Forwards Change Page 7,for Insertion Into 830613 Compilation.Svc List Encl ML20072H5471983-06-22022 June 1983 Responds to Applicant Collation of Intervenor Interrogatory Responses,Submitted in .Some Responses Will Be Amended.Listed Amends Not Agreed Upon.Svc List Encl.Related Correspondence ML20072D6481983-06-21021 June 1983 Forwards Revised Pages Modifying Compilation of Intervenor Interrogatory Responses.Certificate of Svc Encl.Related Correspondence ML20024A7091983-06-15015 June 1983 Forwards Map Depicting Location & Range of Warning Sirens Recommended for Alert & Notification Sys,As Part of Rept Served on 830613.Svc List Encl.W/O Map ML20076J0661983-06-15015 June 1983 Forwards Util Informing NRC of Revised Schedule for Fuel Load & Commercial Operation.Fuel Load Scheduled for 840815.Commercial Operation Planned for 850215.Svc List Encl ML20076H4961983-06-13013 June 1983 Forwards Collation of Intervenor Interrogatory Responses Identified in Paragraphs 6(a)-(h) of Intervenor 830512 Response to Util Objections.Svc List Encl ML20076J0761983-06-13013 June 1983 Forwards Wyle Research Rept (WR 82-36),Final Design of Alert & Notification Sys for Wolf Creek Generating Station. Svc List Encl.Related Correspondence.W/O Rept ML20071G6431983-05-19019 May 1983 Informs of Agreement to Develop Acceptable Statement of Contentions & Resolution of All But One Objection to Proposed Issues for Litigation,Per Applicant 830503 Objections ML20028E8731983-01-26026 January 1983 Forwards Nov 1982 Rev to Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power,Superseding Nov 1981 Rev.Svc List Encl.W/O Rev ML20065A9721982-09-10010 September 1982 Estimates June 1983 to Be Appropriate Time for Commencing Evidentiary Hearing.Intervenor Agrees.Svc List Encl. Related Correspondence ML20052C6051982-04-30030 April 1982 Advises That Licensee Supports NRC 820423 Motion to Dismiss Kansans for Sensible Energy Contention & as Party.Svc List Encl ML20040E5081982-02-0202 February 1982 Advises That Financial Qualifications Rule Is Scheduled for Consideration at 820211 Affirmation Session.Applicants' 820120 Motion for Deferral of Discovery Should Be Granted. Svc List Encl ML19350E5721981-06-18018 June 1981 Requests That Future Correspondence Re Mo Public Svc Commission Be Directed to EA Eisen,Replacing CF Mathews ML19341D7221981-04-0101 April 1981 Forwards Kansans for Sensible Energy 810330 Amended Petition to Intervene ML19345E8591981-02-0303 February 1981 Informs That Applicant Does Not Object to Tm Wolken 810114 Request to Make Limited Appearance Statement.Svc List Encl ML19257C1441980-01-0303 January 1980 Notifies That Mo Public Svc Commission Has Been Placed on Svc List Re 791221 Petition to Intervene as Interested State.Requests ASLB Issue Order Terminating CP Amend Hearing ML19296C8391979-11-13013 November 1979 Requests Info Re Void in Concrete of Primary Reactor Wall Discovered in Jul 1979 ML19225C5281979-07-30030 July 1979 Forwards Util Application for Amend of CPPR-147 to Include Ks Electric Power Cooperative as co-owner of Facility ML19207B6931979-07-25025 July 1979 FOIA Request for All Documents Re Request from NRC to Army Corps of Engineers Concerning Concrete Used in Base Mat at Facility ML19225B2471979-07-18018 July 1979 Requests Substitution of Hh Voigt for Ae Upton on NRC 790713 Distribution List ML19224C7271979-05-15015 May 1979 Forwards Ks Bldg & Const Trades Council Request for Order to Show Cause Why CP Should Not Be Revoked 1989-08-25
[Table view] |
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ETZPMEN D. POTTS. P C. J. THOM AS LENMART. P C. TZLECOPtE R JOHN L CARR.JR. ( . J R.
GERALD CHARNCFF. P C. STEVEN L MELTZER. P C PMlWPJ.MARVEY THOM WENDELWA AS % $. WM8TI PMitup D SOSTwsCn. P C. DEAN D. AUuCn. P C. (202) e22.aoss & sa2 nes ROmERT M. GORDON STANLET w'liaRG R. TIMOTHY MANLON. P C. JOMN ENGEL. P.C. _
SARGARA J. MORG E N LESUE n. SMtTM SCORGE M. ROG ERS. J R.. R.C. CMARLES s.TEMKIN. P C SONNat S. GOTTUES virginia S. RUTLgDGE FREM A. UTTLE. P C. STEPMEN S. MUTTLER. P.C. RAptFAX 600 MowARD M. SMAFFERMAN MATMERINE P. CMEE R JOMN S. RMONELANDER P.C. weNTHROP N. SROWN. P C. DERORAMS.SAUSER JANsCE LEMRER STEIN L RUCE w. CMURCMILL. P.C. JAMES S. MAMUN. P C (202)8226072 SCOTT A. ANENBERG TRAVIS T. SRowN, JR.
LE.*UE A. NBCMOLSON.J R., P C. RANDAL 5. MELL. P C. _
CAMPSELL MILLEFER RICHARDM.MMONTHAL M1RTIN D. MRALL. P.C. RCS E RT E. ZAMLE R. P C. PAUL M. TMOMAS STEPMEN 3. MEIMANN KICMARD J. RENDALL, P.C. ROBE RT 3. ROSS8NS. P.C. Tgggx SETH M. MOOGASIAN SA DRA E. BRU$CA*
JAY E. SILBERG. P.C. STEVEN M LUCAS.PC. SMEILA MCC. MARVEY EsLEEN L SROWNELL BAI BARA M. ROSSOTTI. P C. david M.RUSENSTEIN PC 89-2693 (SMAwLAW wSM) DEUSSA A. AlDGwAv PAMELA M. ANDERSON GEORGE V. ALLEN, J R., P.C. R*CMARD E. GALEN MENNETH J. MAUTMAN CASLE ..SM AwLAW DAVID LAwmENCE MILLER ALEXANDER D. TOMASZCZUn FRES DRASNER. P C. LvhN wMlTTLESEY wtLSON "'d O' R. K4NLY wtBSTER. P C. MATIAS F.TRAVeESO DIA2 FREDERICK L KLEIN NATMANIEL P. SREED JR., P C. VSCTORSA J. PERONS STEVE N P. PITLER' M'OMAEL A* E*'OK R MARM AUGE NSLICK. P C. JOMN M. O NEILL. J R R6CHA RD J. PARRINO ELLEN SHERIFF ERNIST L SLAKE. JR., P.C. Jay A. EPSTIEN , ELLEN A. FREDEL* ANITA J. F8NMELSTEIN
"" MANNAM E. M. yE SCRM AN EILEEN M, GLESMER CAOLETON 3. JONE S. P.C. RAND L ALLEN TMOMAS A. SaxTER. P.C. EUSASETM M. PENDLETON COWNSEL SANDRA E. FOLSOM DAVID R. SAMR JAMES M. SURGER. P C. MARRY M. GLASSPtEGEL JUDITH A. SANDLER C.. SowDOIN
- m. TRAIN E.
WReTER S OtRECT NAL NUMBER (202) 822-1000 July 15, 1983 James A. Laurenson, Esq. Dr. George C. Anderson Administrative Judge Administrative Judge Atomic Safety and Licensing Department of Oceanography Board Panel University of Washington U.S. Nuclear Regulatory Commission Seattle, Washington 98195 Washington, D.C. 20555-Dr. Hugh C. Paxton Administrative ~ Judge 1229 - 41st Street Los Alamos, New Mexico 87544 I In the Matter of l
Kansas Gas and Electric Company, et al.
L (Wolf Creek Generating Station, Unit 1)
! Docket No. Sa-482 Gentlemen:
In a June 13, 1983 letter, Applicants provided to the Board and the other parties a compilation of Intervenors' interrogatory answers which -- by agreement of the parties -- is to serve as the statement of issues for litigation in this proceeding. On June 20, l i
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July 15, 1983 l
, Page Two 1983, Intervenors' counsel conferred with Applicants' counsel
- to request modifications to the June 13 compilation of inter-rogatory answers. As a result of those discussions, Applicants agreed.to certain of the requested modifications, which are memorialized in Applicants' June 21 letter to the Board.. Counsel for Intervenors also proposed other modifications and expansions i of the designated interrogatory answers in the June 20 discussions, as to_which Intervenors and Applicants were unable to reach agree- ,
ment. By letter dated June 22, 1983, counsel for Intervenors
- advances for Board ruling the modifications and expansions of interrogatory answers which Applicants oppose. Applicants respond herein to that June 22 letter.
In paragraph 3 of the June 22 letter, Intervenors propose that the following language be added to the compilation as Con-i tention 29.w [sicr 29.v]:
If a duty is assigned to a person that person is not adequately trained
- to handle that duty and would not be able to adequately handle that duty in an emergency.
As Intervenors note, this language is.a reiteration of part of one j of their interrogatory answers. However, unlike the interrogatory ,
i answers which have been included in the compilation, the proposed '
language is overly broad in the extreme. This~is particularly true 4
in light of the advanced stage of the proceeding, where discovery has
~
long been completed and the date'for filing of testimony is only one
, and one-half months away. Under such circumstances, the Board and the
- other parties are entitled to know precisely who Intervenors assert
- must be trained and what Intervenors assert they must be trained in.
Indeed, Intervenors provided the requisite level of specificity on this issue in their interrogatory responses elsewhere, identifying a
- very long " laundry list" of emergency workers alleged to need' training,
- along with an indication of the areas in which training is purportedly.
necessary. See, e.g. , Contentions 29.h (1) through 29.h (26) , at Compila-tion pp. 32-35, and Contentions 29.s (l) through 29.s (8) , at Compilatlon pp. 36-37, and Contentions 29.u(1) and 29.u (2) , at Compilation p.37.
i Nevertheless, apparently concerned that they may have neglected to list someone, Intervenors advance the profferred language in an 4
attempt to preserve their options to litigate at the hearing at the need i
- for training-any-individuals they may have failed to include on their. i
-list. If Intervenors later find that.they have failed to raise the
- need'for training of a particular group of. workers,-they are entitled 1 to amend their contentions to include that issue, upon the requisite
-showing. _See Duke Power Co. (Catawba Nuclear Stations, Units 1 and . 2) , ;
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. L SHAW.- PITTMAN, PoTTs & TROWBRIDGE A PARTNERS >etr OF P40FEgeaONAL CompORATaONS 3
-July 15, 1983 Page Three CLI-83-19, 17 N.R.C. (June 30, 1983). But, particularly in light of the advanced stage of the proceeding, the " catch-all" contention here proposed must be rejected.
- Paragraph.4 of the June 22 letter proposes that the follow-
. ing language be added to the compilation as Contention 32.c.:
1 The estimates of costs are very difficult to determine. For example,-we have assumed
- that certain vehicles might be rented. Perhaps, they might actually be purchased. Also. it is very difficult to determine the number of days that evacuees _would need to be sheltered, and it is difficult to. estimate the number of serious injuries that can occur. Changes in i
- these estimates can substantially effect [ sic]
the total number of dollars that will be required from Coffey County.
t This language is simply a. generalized statement of the assumptions i and uncertainties underlying Intervenors' estimates elsewhere of certain costs, and is not appropriate for' litigation.- Accordingly,-
. proposed Contention 32.c should be rejected:
1 Finally, Intervenors propose the expansion of approximately
- 65 o$ the interrogatory answers reflected.in.the June 13 compilation,
- j. to include reference to the evacuation of the_ entirety'of coffey 4
County.*/ See June 22, 1983 letter, at 11'2, 5. As counsel'for
! Intervenors observes, all parties have agreed that:
_The scope of the issues to be litigated excludes-the ability to_ evacuate or shelter the people living outside the Plume Exposure Pathway EPZ l but inside Coffey County. The scope includes the effect on evacuation of.the Plume Exposure
! Pathway EPZ of an order to evacuate the entire
, County. (See Applicants ' objections, pp. 12-13) .
l~
-Letter, Counsel for Applicants to Board (May 19, 19 8 3)-, _ at 2. However, the cited _ agreement -- reached in the course of May-16 and-18 conference calls among the parties -- was in. resolution of Applicants' objection Eto-the inclusion in the compilationLof specified individual-inter-
~rogatory responses which' expressly raised'the issue of the evacuation l=
i of the entire;co'unty rather than of-only the plume EPZ.- The partiec
~
l did_not agree, in the.mid-May calls, that~ language expanding inter-l rogatory answers to : include the evacuation 'of uthe entire county could:
be added to interrogatory answers where--it has-never before appeared. '
Rather,'the parties agreed.only-that the languagefabout the entirety.of Coffey: County could remain in the interrogatory answers .where Inter-L venors had alreadyfincluded :it,- provided that the language was inter-
- / For the convenience of the' Board, Applicants'have correlated the contentions
' referenced by Intervenors with the underlying int =. w toxy answers. 'Ihis cor-
. , _ . . _ . - . _ ~ ~ . . - . . - - , - -- ._ . ,
SHAw, PITTMAN, POTTs & TROWBRIDGE
t
. - July 15, 1983
- Page:Four-
) preted consistent with the' scope of the hearing as noted. Certainly, in the May 16-and 18 conference calls, counsel for Intervenors did not advance his list of 65 additional interrogatory answers which
- . he now proposes to expand to encompass an evacuation of the entire l . county.
i Conspicuously, and in contrast to their argument'on other
' proposed amendments to the compilation, Intervenors'do'not assert 1
that each of.the approximately-65 proposed changes reflects:an
- omission from the compilation of language which was included in
!L interrogatory answers. . Nor could they make such an, assertion. The
- following contentions are based on interrogatory responses (specified by Intervenors) , which responses include no reference whatsoever -to 1 the' entirety of Coffey County: 1.2, 2.c, 3.a, 7.a, 9.c, 9.e,110.a-10.d,
. ll.~c, ll.d, ll.f, ll.g, ll.i, ll.j, ll.k, 11.2, 12.f, 12.g, 13.a, 13.b, 14.b, 16.a-16.d, 16.f-16.h, 16.k-16.n, 18.c, 18.e, 18.h, 18.k, 18.q, 18.r, 18.y, 18.aa, 19.k, 19.hh, 19 44, 2 0. t, . 21.b , 2 2. b , 23.a, 23.b, 24.b, 24.c, 31.f, 31.j, 32.a and 32.b. Accordingly, Intervenors' request that these contentions be expanded to encompass evacuation.
i of the county beyond the EPZ should be-summarily. rejected.
Other contentions listed by Intervenors are based-on inter-
~
rogatory answers which do include some language which might be interpreted to raise the issue of-the evacuation of the entire' county, but.which are logically not litigable under the scope of the hearing as' '
agreed upon by the parties in the May 16 and 18 phone calls. These 1: contentions include 11.a,'11.b (also discussed in 1 5.c of June ' 22
! letter), 11.e, ll.h, 12.e, and 15.n. These contentions are addressed below.
i . .
l Contentions ll.a, ll.b, ll.e and ll.h are addressed to public
! - notification of an emergency, and the provisions for sirens-and tone-l alerts to effect such notification. The Commission's emergency plan-l ning regulations require only a capability for timely notification of the public'within the plume EPZ. See 10'C.F.R. SS 50.47 (b) (5) , 50.47 (c) (2) . Any contention to the contrary'would constitute an1 impermissible challenge to the regulations. See 10 C.F.R. S 2.758. And certainly.
l
-Intervenors have provided no indication how a failure to notify ~ County:
l residents outside the EPZ within the tim? limitstof 10 C.F.R. Part 50, K Appendix E, S IV.D.3 would in any way impede the evacuation'of residents inside the EPZ. For-theseTreasons, the proposed expansion of Conten-tions 11.a,fil.b, ll.e and ll.h must be rejected.
Contention 12.e challenges the provisions for the' dissemination l . of~ written emergency public education materials.to transients. Again, the Commission's regulations. require the dissemination-of such materials :
only within the plume EPZ, see.10 C.F.R. SS 50.47 (b) (7) , . 50.47.(c) (2) , andl the; litigation of any contention to the contrarylis barred as a challenge u
y
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July 15, 1983 Page Five to the regulations. Further, the proposed expansion lacks basis; Intervenors have failed to identify any concentrations of transients which are within the County but outside the plume EPZ. Moreover, Intervenors have not suggested how any failure to provide emergency
?
public education materials to transients outside the EPZ could
- adversely affect the evacuation of individuals inside the EPZ.
Accordingly, Intervenors' proposed expansion of Contention 12.e must
. -be rejected.
Contention 15.n asserts _that the County Health Nurse has not compiled a list of shut-ins and others who may.need special evacuation i assistance. The Commission's regulations require emergency planning,
- including provisions for protective actions, only within the plume EPZ.
See 10 C . F . :R. SS 50.47 (b) (10) , 50.47 (c) (2) . Thus, again, the litigation of evacuation assistance for County residents outside the EPZ is barred as a challenge to the regulations. Moreover, the preparation of such a list is a pre-emergency activity, and Intervenors have not explained how the advance preparation (or lack thereof) of a list of shut-ins outside.the EPZ would adversely affect the resources available at the time of an emergency for the evacuation of the population inside the J EPZ. Therefore, the proposed expansion of Contention 15.n must also be rejected.
i
- s. Intervenors have also referenced Contentions 18.z, 20.d, 20.k,
! and 24.d in their June 22 letter. These contentions (as well as others i not listed by Intervenors) already incorporate language referring to the impact of order to evacuate the entire County on the evacuation of the plume EPZ, and thus need not be the subject of Board ruling.
Finally, in the concluding paragraph of.the June 22, 1983 letter, counsel for-Intervenors represents that Intervenors' concurrence in the June 13 compilation as the statement of issues for litigation 4
is dependent on a ruling'in Intervenors' favor on the additions and expansions requested in Intervenors' June-22 letter. The parties' agreement to accept the compilation, based on the mid-May and June 20 I -telephone conferences, was unconditional, though it was understood
- that counsel for Intervenors might seek to amend the compilation,.
'= as reflected ~in the letters of counsel memorializing those conferences.
Sjg Letters Counsel for Applicants to Board, dated May 19, June-13 and
~
Jane 21,.1983. Counsel should not be permitted to repuduate his agreements of record.
4
'R,,
1 J l Si lberT' j- De .a Aq. Ridgway <
- Counsel for Applicants Enclosure I- cc
- Service List (w/ encl. including App. A).
l l
.._--a . ., _ a . . - -_.
4 . J., .. . .. -
APPENDIX A Contention Specification of Underlying Interrogatory Answer l
1Z item 1 under S1.2.2 on p.14 2c item 1 under S4.2.1 on p.41 3a item 2 under EP-12 on p.7; item 10 under 51.2.2 on p.15; item 1 under S4.2.2. on p.41 7a item 3 under Table 3-5 on p.40 9c item 11 under S3.3 on p.29 9e Special Contention #4 on p.5 10a item 2 under S1.2.5 10b item 15 under EP-4 on p.3; EP-5 on p.4; item 6 under EP-5 p.4; item 4 under S1.2.5 on p.8 10c item 4 under EP-12 on p.7; item 4 under 51.2.5 on p.18 10d item 3 under S1.2.5 on p.18 lla item 8 under S3.2 on p.26 11b item 10 under S3.2 on p.27 llc item 3 under EP-12 on p.12 11d Special Contention 3 on p.5 11e item 10 under S3.2 on p. 27 11f item 2 under EP-4 on p.1; EP-5 on p.3 11g item 2 under EP-12 cn p.9 11h item 5 under S3.2 on p.26 11i item 12 under S3.2 on p.27 11j item 12 under S3.2 on p.27 lik item 7 under S3.2 on p.26 111 item 13 under S3.2 on p.27 12e item 3 under S5.3 on p.43 12f Special Contention 5 on p.5.
. 12g item 2 under SS.3 on p.43 13a item 8 under S3.3 on p.28 13b item 15 under EP-12 on p.9; item-l under Table 3-2 (Sheet 8 of 15) on p.38 14b item 10 under EP-12 on p.8; item 1 under S3.31 on p.29 15n item 6 under S1.2.7 on p.21 16a item 8 under S1.2.5 on p.18 16b EP-4 on p.2 16c item 12 under EP-5 on p.5 16d item 12 under EP-5 on p.5 16f item 5 under S3.5 on p.32 16g item 5 under 53.5 on p.32 16h item 9 under EP-4 on p.2; item 3 under EP-5 on p.3 16k item 5 under S3.5 on p.32 16& item 6'under EP-12 on p.8; item 2 under S3.5 on p.32 16m item 9 under S1.2.5 on p.19 16n item 6 under EP-12 on p.8; item 2 under S3.5 on p.32 l
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. l Contention. Specification of Underlying Interrogatory Answer 18c item 4 under Table 1-1 on p.25 18e item 7 under EP-4 on p.2; EP-5 on p.4; item 2 under EP-5 on p.3 18h item 4 under Table 1-1 on p.25 4
18k item 2 under 53.3 on p.27 18q item 4 under S3.6 on p.33 18r item 2 under S3.6 on p.33 18y item'7 under 51.2.2 on p.15 18z item 4 under EP-5 on p.3 18aa item 7 under 51.2.2 on p.15 19k EP-4 on p.2; item 10 under EP-5 on pp.4-5; items
- 4,6,8 on p.34 19hh item 2 under S3.7 on p.33; item 1 under Tab K ..
on p.47 19EE item 5 under S3.7 on p.34 20d item 7 under EP-5 on p.4 20k item 7 under.51.1 on p.12 20s iten 8 under 53.8 on p.36 21b item 2 under S1.2.7 on p.20 22b Special Contention 7 on p.5 23a item 5 under Table 1-1 on p.25 23b EP-4 on p.2; item 11 under EP-5 on p 5 .
24b item 6 under S1.2.3 on p.16 24c item 9 under S3.3 on p.28 31f item 8 under EP-12 on p.10 31j item 3 under Tab A on p.44 32a EP-15 & 16 at 10-11; EP-15 & 16 at 10-11; 16 (g) at 7 _ .
32b. .EP-15 & 16 at 10-11; EP-15 & 16 at 10-11; 16 (g) at 7 l
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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, ej al. ) Docket No. STN 50-482
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(Wolf Creek Generating Station, )
Unit No. 1) )
SERVICE LIST i
James A. Laurenson Atomic Safety and Licensing Chairman Appeal Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 )
U.S. Nuclear Regulatory Commission j Wanhington, D.C. 20555 Docketing and Service Section Office of the Secretary Dr. George C. Anderson U.S. Nuclear Regulatory Commission Department of Oceanography Washington, D.C. 20555
. University of Washington Saattle, Washington 98195 Kent M. Ragsdale General Counsel Dr. Hugh C. Paxton Missouri Public Service Commission 1229 - 41st Street Post Office Box 360 Loc Alamos, New Mexico 87544 Jefferson City, Missouri 65102 Myron Karman, Esquire A. Scott Cauger, Esquire Deputy Assistant Chief Assistant General Counsel Hearing Counsel Missouri Public Service Commission Office of the Executive Post Office Box 360 Legal Director Jefferson City, Missouri 65132 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Eric A. Eisen, Esquire Birch, Horton, Bittner & Monroe Atomic Safety and Licensing Board 1140 Connecticut Avenue, N.W.
U.S. Nuclear-Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 C. Edward Peterson, Esquire Alan S. Rosenthal, Esquire Assistant General Counsel Atomic Safety and Licensing Kansas Corporation Commission Appeal Board State Office Building - 4th Floor U.S. Nuclear Regulatory Commission Topeka, Kansas 66612 Wachington, D.C. 20555
Service List Page Two Dr. John H. Buck
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Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Brian P. Cassidy, Esquire Federal Emergency Management Agency Region I J. W. McCormack POCH Boston, Massachusetts 02109 John M. Simpson, Esquire 4350 Johnson Drive, Suite 120 Shawnee Mission, Kansas 66205 Thomas S. Moore, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I
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