ML19274E436

State of Oks Petition to Participate as Interested State. Notices of Appearance of Jg Thomas & CS Rogers & Certificate of Svc Encl

ML19274E436
Person / Time
Site:	Black Fox
Issue date:	02/27/1979
From:	Rogers C, John Thomas OKLAHOMA, STATE OF
To:
References
NUDOCS 7903260103
Download: ML19274E436 (6)

Text

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MAR 3 1973 5 r UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION

%i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD bC8 d

IN THE MATTER OF

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PUBLIC SERVICE COMPANY OF

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OKLAHOMA, ASSOCIATED ELECTRIC

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Docket Nos.

COOPERATIVE, INC.,

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STN 50-556 WESTERN FARMERS ELECTRIC

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STN 50-557 COOPERATIVE, INC.

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(Black Fox Stations,

)

Units 1 and 2)

)

PETITION BY THE STATE OF OKLAHOMA FOR PARTICIPATION AS AN INTERESTED STATE Comes now the State of Oklahoma by and through its Attorney General, Jan Eric Cartwright, and petitions this Commission for leave to participate pursuant to 10 C.F.R. Section 2.715(c). In support of such application the petitioner states as follows:

(1) That at the commencement of hearings on this matter no request pursuant to 74 0.S. Section 18b had been recieved, and that a request for the Attorney General to appear on behalf of the State of Oklahoma was made by the House Environmental and Natural Resources Committee just prior to the commencement of the February hearings; (2) That petitioner desires to participate to protect the health, safety, and welfare of its citizens and to become aware of the issues and questions involved in these hearings; 790326O/O3

(3) That no party to this proceeding can adequately represent those interests; (4) That such representation will in itself aid in developing a sound record as the interests of the state will thereby be reflected; (5) That petitioner's representation should not serve to substantially broaden the issues nor delay the proceedings; (6) That the state is interested in those matters relating to design analysis and the issues raised by the Reed Report as matters bearing on the safety and welfare of its citizens.

(7) That without such participation, the issuance of a permit will leave the state without a clear understanding of the relative safety or risk of the facilities herein concerned.

Wherefore petitioner prays that this Commission grant the right to participate pursuant to 10 C.F.R. Section 2.715(c) without stating a position on the merits involved; that it be allowed to attend all sessions of the Board by and through its attorneys; that it be allowed to inspect a

copy of the Reed Report subj ec t to those terms and conditions the Board deems proper; and that it be allowed generally to participate in all aspects of the hearings, JAN ERIC CARTURIGHT ATTORNEY GENERAL OF OKLAHOMA

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GREGORYGTHOMAS

1. ASSISTANT ATTORNEY GENERAL 112 STATE CAPITOL BLDG.

OKLAHOMA CITY, OKLAHOMA 73105

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(CVV HARLES S.

ROGERS,/)

ASSISTANT ATTORNET GENERAL

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UNITED STATES OF AMERFA gma S

NUCLEAR REGULATORY CO:OIISSION p,1AR S ggggg 3 BEFORETHEATOMICSAFETYANDLICENSINGBOARDfu cm.

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PUBLIC SERVICE COMPANY OF

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OKLAHOMA, ASSOCIATED ELECTRIC

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Docket Nos, COOPERATIVE, INC., and

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STM 50-556 WESTERN FARMERS ELECTRIC

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STN 50-557 COOPERATI/E, INC.

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)

(Black Fox Stations,

)

Units 1 and 2)

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NOTICE OF APPEARANCE Comes now the Attorney General of the State of Oklahoma, Jan Eric Cartwright, by and through the attorneys hereinafter listed, who are licensed to practice before the Supreme Court of the State of Oklahoma, and gives notice of the appearance of John Gregory Thomas and Charles S. Rogers, Assistant Attorneys General of the State of Oklahoma.

JAN ERIC CARTWRIGHT ATTORNEY GENERAL OF OKLAHOMA

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JOHN GREGOP T

MAS ASSISTANT ATTORNEY GENERAL

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cCHARLES S. ROGERS ASSISTANT ATTORNEY GENERAL

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IU THE MATTER OF

)

)

PUBLIC SERVICE COMPANY OF

)

OKLAHOMA, ASSOCIATED ELECTRIC

)

Docket Nos.

COOPERATIVE, INC,, and

)

STN 50 556 WESTERN FARMERS ELECTRIC

)

STN 50-557 COOPERATIVE, INC.

)

)

(Black Fox Stations,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that service has been on this day effected by personal delivery or first class mail on the following:

Sheldon J, Wolfe, Esq, L. Dow Davis, Esq.

Atomic Safety and Licensing William D.

Paton, Esq.

Board Panel Colleen Uoodhead, Esq.

U.S. Nuclear Regulatory Counsel, Nuclear Regulatory Commission Staff Washington, D,C, 20555 U.S. Nuclear Regulatory Commission Mr. Frederick J. Shon, Member Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Mr. Clyde Wisner U.S. Nuclear Regulatory NRC Region 4 Commission Public Affairs Officer Washington, D.C, 20555 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Dr, Paul W, Purdom Director, Environmental Studies Joseph R. Farris, Esquire Group John R. Woodard, III, Esq.

Drexel University Green, Feldman, Hall & Woodard 32nd and Chestnut Streets 816 Enterprise Building Philadelphia, Pennsylvania 19104 Tulsa, Oklahoma 74103 Andrew T. Dalton, Esq.

Joseph Gallo, Esq.

1437 S. Main Street, Suite 302 Isham, Lincoln & Beale Tulsa, Oklahoma 74119 1050 17th Street Washington, D.C. 20036

,4 Mrs, Ilene H.

Youngheim 3800 Cashion Place Oklahoma City, Oklahoma 73112 Mr. Vaughn L. Conrad Public Service Company o'f Atomic Safety and Licensing Oklahoma Appeal Board Panel P.O.

Box 201 U.S. Nuclear Regulatory Tulsa, Oklahoma 74102 Commission Washington, D.C. 20555 Mr. T.N. Ewing Acting Director Atomic Safety and Licensing Black Fox Station Nuclear Board Panel Proj ect U.S. Nuclear Regulatory Public Service Company of Commission Oklahoma Washington, D.C.

20555 P.O. Box 201 Tulsa, Oklahoma 74102 Docketing and Service Section Office of the Secretary of Mrs. Carrie Dickerson the Commission Citizens Action for Safe Washington, D.C. 20555 Energy, Inc.

(20 copies)

P.O. Box 924 Claremore, Oklahoma 74107 Mr. Lawrence Burrell Route 1, Box 197 Mr. Maynard Human Fairview, Oklahoma 73737 General Manager Western Farmers Electric Mr. Gerald F. Diddle Cooperative General Manager P.O. Box 429 Associated Electric Cooperative Anadarko, Oklahoma 73005 P.O.

Box 754 Springfield, Missouri 65801 Dr. M.J. Robinson Black and Veatch P.O. Box 8405 Kansas City, Missouri 64114 Done this 27th day of February, 1979 4-JEp

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John Gregor F fhomas b

Assistant Attorney General