ML19261E370
| ML19261E370 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 05/18/1979 |
| From: | Gallo J, Gibbs M ISHAM, LINCOLN & BEALE |
| To: | |
| References | |
| NUDOCS 7907060367 | |
| Download: ML19261E370 (21) | |
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,[ w2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,, .
E Before the Atomic Safety and Licensing Board In the Matter of the .Npplication of )
Public Service Company of Oklahoma, )
Associated Electric Cooperative, Inc.) Docket Nos. STN 50-556 and ) STN 50-557 Western Farmers Electric Cooperative )
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(Black Fox Station, Units 1 and 2) )
APPLICANTS' REPLY TO INTERVENORS' RESPONSE
_ OF APRIL 27, 1979 On April 27, 1979, Citizens' Action for Safe i I
Energy, Lawrence Burrell and Ilene Younghein ("Intervenors"), j filed their " Response to Motion of the State of Oklahoma ,
for an Indefinite Stay in the Issuance of an Initial Deci-sion in the Above-Captioned Proceeding". In addition to supporting the State of Oklahoma's motion for a stay, how-ever, Intervenors sought additional relief, asking this Atomic Safety and Licensing Board (" Licensing Board") to reopen the record for the reception of further evidence concerning four matters. Because Intervenors' response expanded the scope of the State of Oklahoma's Motion, Public Service Company of Oklahoma ("PSO"), Associated Electric Cooperative, Inc., and Western Farmers Electric Cooperative
(" Applicants" ) asked for and received leave from the Licensing t
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Board to reply.b! Accordingly, Applicants hereby file this reply opposing the grant of the relief sought by Intervenors.
As a result of the accident at Three Mile Island, Intervenors have asked that the record in this Nuclear Regulatory Commission ( " N RC " or the " Commission") proceed-ing be reopened for the reception cf evidence concerning financial qualifications, the relevance of the Three Mile Island accident to the Black Fox Station, Class 9 accidents and emergency plans and post-accident monitoring.2/ Inter-venors have failed to set forth sufficient facts to warrant this Licensing Board taking the extraordinary step of re-opening the record. Furthermore, Intervenors' arguments !
reveal a misapprehension of the nature of the inquiry into financial qualifications and emergency planning at the con-struction permit stage, and of the circumstances under which Class 9 accidents may be examined at any stage of the pro-ceedings. For these reasons, Intervenors' request for relief must be denied.
I. LEGAL STANDARDS GOVERNING REOPENING THE RECORD OF A COMMISSION PROCEEDING The framework in which Intervenors' request to reopen must be analyzed is the set of legal precepts 1/ Applicants' Motion for Leave to File Reply of May 4, 1979, was granted by Order of the Licensing Board dated May 4, 1979.
2/ Intervenors' Response at 7.
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fashioned by the Atomic Safety and Licensing Appeal Board
(" Appeal Board") in a series of related decisions concern-ing Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nucl. ear Power Station), ALAB-124, 6 AEC 358 (1973); ALAB-138, 6 AEC 520 (1973); ALAB-167, 6 AEC 1151 (1973). In that case an intervenor group had, prior to the issuance of the Initial Decision authorizing an operating license, submitted a motion to the Licensing Board to reopen the record so that certain letters between the NRC Staff and the applicant could be admitted into evidence. Allegedly, these letters set forth serious unresolved safety questions concerning the Vermont Yankee plant. The Licensing Board denied the motion and issued the Initial Decision. The Appeal Board, finding that the Licensing Board had not fully articulated its reasons for denying the motion, remanded the case for a new deter-mination of whether the record should be reopened.
Because the subject of reopening the record of a proceeding had not been touched upon to any extent in pre-vious decisions,3/ the Appeal Board engaged in lengthy dis-cussions of the standards governing reopening in the Vermont Yankee opinions. In ALAB-124, the Appeal Board pointed out 3/ In Wisconsin Electric Power Comnany (Point Beach Nuclear Plant, Unit 2), ALAB-86, 5 AEC 376 (1972), the Appeal Board discussed the Licensing Board's authority to reopen the record before issuance of the complete Initial Decision. General standards to be used in doing so were not articulated.
that both the timeliness of the motion and the significance of the matters raised should be considered, for a Licensing Board is required to reopen the record only when the matters raised are of major significance to plant safety.S/
In addition, the Appeal Board examined the type c f evidence which must be presented in order to support a notion to reopen the record. As the Appeal Board acknowl-edged, in most cases the proponent of a motion to reopen the record inust supply the affidavit of a competent expert setting forth his belief that the matter in question raises serious safety concerns thich must be explored. In Vermont Yankee the Appeal Board found that an affidavit would not be required if the letter from the NRC Staff concerning the plant at issue which the intervenor relied upon raised a serious safety question on its face. If the seriousness or relevance of the matter raised by the letter were not appar-ent, the intervenor would need to reinforce the letter with a suitable affidavit.5!
The use of affidavits was elaborated upon, and an-other facet of the test for reopening was set forth, in ALAB-138. There, the Appeal Boarc explained that:
4/ 6 AEC at 364-65.
5/ Id. at 364.
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In other words, to justify the granting of a motion to reopen the moving papers must be strong enough, in the light of any opposing filings, to avoid summary disposition. Thus, even though a matter is timely raised and involves significant safety considerations, no reopening of the evi-dentiary hearing will be required if the affida-vits submiti% in response to the motion demon-strate that chere is no genuine unresolved issue of fact, i.e., if the undisputed facts establish that the apparently significant sufety issue does not exist, has been resolved, or for some other reason will have no effect upon the outcome of the licensing proceeding. 6 AEC at 523 (footnote omitted).
Thus, in order to prevail on a motion to reopen the record, the proponent must show that the outcome of the proceeding could be affected by .T consideration of the matter presented.
In the last decision in this series, ALAB-167, the Appeal Board responded to the charge that the require-ment that a mction to reopen be supported constituted an impermissible shifting of the burden of proof from the applicant to the intervenor. The Apoeal Board disagreed:
Rather, that requirement represents a straight-forward application of the rule that a party advocating the extraordinary step of reopening a hearing must assign some substantial basis for its request that at least must establish that it is raising a significant safety-related
issue. 6 AEC at 1152.
The standards delineated in the Vermont Yankee
, decisions have consistently been cited and followed in the opinions of NRC tribunals faced with a motion to reopen the record. In Georgia Power Company (Alv'.n W. Vogtle i Nuclear Plant, Units 1 and 2), ALAB-291, 2 NRC 404 (1975),
the Appeal Board found that the Vermont Yankee test also s 2 e
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applied to the reopening of the record on an environmental issue.5/ Another decision relying upon Vermont Yankee stressed the fact that normally, a request for reopening must be accompanied by a showing that the outcome of the proceeding might be affected thereby. Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2),
ALAB-422, 6 NRC 33, 64 n.35 (1977) affirmed, CLI-78-1, 7 NRC 1 (1978). More recently, the tests governing a motion to reopen were reiterated with c.pproval by the Appeal Board in Kansas Gas and Electric Company (Wolf Creek Generating Station, Unit No. 1), ALAB-462, 7 NRC 320, 338 (1978).
The standards described above are clearly appli-cable to Intervenors' request to reopen the record of the Black Fox proceeding. It should be remembered that this proceeding is in the same posture that the Verr.ont Yankee case was in when the motion to reopen the record was sub-mitted--in both instances the hearings were concluded and the record closed, but the Initial Decision had not yet issued.2/ Measuring Intervenors' request against the Vermont Yankee standards, the insufficiency of that request is apparent. In order to demonstrate this insufficiency, Applicants will discuss each of the four areas in which Intervenors seek to reopen the record seriatim.
6/ 2 NRC at 409 n.6.
7/ Vermont Yankee, ALAB-124, supra, 6 AEC at 365.
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II. INTERVENORS HAVE NOT JUSTIFIED REOPENING THE RECORD ON FINANCIAL QUALIFICATIONS Intervenors first allege that, because of t.se accident at the Three Mile Island plant, the record on the issue of Applicants' financial qualifications should be reopened. In support of this statement, Intervenors cite to various stories in the Wall Street Jcurnal which reported that the ratings of debt cecurities issued by utilities owning Threa Mile Island had been downgraded, that the bonds of other util' ties involved with nuclear power had been affected, and that a utility which owns nuclear plants had had to pay more in order to sell its latest bond issue.
it is immediately clear that these references to newspaper articles are not the type of support for a motion to reopen the record which the Appeal Board in Vermont Yarkee envisioned. It is well established in NRC practice that a newspaper crticle is hearsay and cannot be used to prove the truth in the assertians stated therein.
Illinoic Po er Company (Clinton Power Station, Units 1 and 2), LBP-75-59, 2 NRC 579, 587 (1975). Thus, a newspaper article cannot substitute for the affidavir f a competent expert required by Vermont Yankee.
Another area in which Intervenors' request falls short of meeting the standards far reopening the record is the requirement that the motion relate to a significant 4
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safety or environmental issue. The issue of financial qualifications has no environmental implications. Further-more, t.here is serious question as to whether it is a safety-related issue. Thc only argument that has been put forward connecting the two areas is the theory that a shortage of funds would cause a utility to " cut corners on safety". However, in the definitive discussion of this subject to date, Seabrook, CLI-78-1, supra, the Cor-mission confronted this issue and expressed skepticism that financial qualifications had any such relationship to safety.8/ First, the Commission found that the argument presented above "is less compelling in the case of a regu-lated public utility engaged in a construction project which is itself subject to high safety standards and ongoing inspection".2/ Second, the Commission stat,ed that recent experience did not suggest that a utility short of funds would cut corners on safety -- rather, common responses to the problem were to slow down or suspend construction on the nuclear facility.bS/ In view of these facts, the Commission cal]ed the link between safety and financial qualifications " seemingly tenuous".11/ Thus, it seems 8/ 7 NRC at 8-23.
9/ Id. at 18.
10/ Id. at 18-19.
11/ Id. at 19.
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unlikely that a motion to reopen the record would lie with respect to the issue of financial qualifications.
The final reason why Intervenors' request to reopen on this question may not be granted is that the premise underlying Intervenors' argument is ill-founded.
What Intervenors seem to be saying by referencing the news-paper articles described above in that Applicants in general and PSO in particular may have increased difficulty in raising the capital to construct Black Fox because of the effects of Three Mile Island upon the financial community.
9 wever, the on]y showing required with regard to financial qualifications under the NRC's regulations is that the appli-
- cants for a construction permit have reasonable assurance of obtaining the necessary funds.12/ This point was empha-sized, and the reasonable assurance standard was explained, by the Commission in Seabrook:
On the other hand, given the history of the present rule and the relatively modest implementing requirements in Appendix C, a ' reasonable assurance' does not mean a demonstration of near certainty that an applicant will never be pressed for funds in the course of construction. It does mean tnat the applicant must have a reasonable financ-ing plan in the light of relevant cir-cumstances. 7 NRC at 18 (footnote omitted) (emphasis supplied) .
12/ 10 C.F.R. S 50.33(f). The Atomic Energy Act itself does not impose any financial qualifications requirement; the Act merely authorizes the Commission to impose such financial requirements as it may deem appropriate. 42 U.S.C. S 2232 (a) .
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- Thus, the NRC regulations as interpreted by the Commission acknowledge that a utility may occasionally experience short-term difficulties in raising funds. Furthermore, the Commis-sion went on to say that because of a number of variables, e.g., interest rates, the state of the stock and bond markets, the regulatory climat- and the cost of fuel, a public utility cannot provide more than a reasonable assur-ance that funds will be available through the course of a multiyear construction project.13/
In view of this background explaining what the financial qualifications requirement means, and tho fact that Intervenors have not made the type of showing in sup-port of their request mandated by Vermont Yankee, the record on this issue cannot be reopened.
III. INTERVENORS HAVE NOT JUSTIFIED REOPENING THE RECORD ON THE RELEVANCE OF THREE MILE ISLAND TO BLACK FOX The second area in which Intervenors seek to reopen the record concerns the general topic of Three Mile Island, for Intervenors want "to determine the relevance, if any, of the nuclear accident at TMI-2 to Black Fox Station."13/ This topic is obviously quite broad, and Intervenors' discussion of it fails to narrow the issue.
13/ 7 NRC at 19.
14/ Intervenors' Response at 7.
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The gist of Intervenors' thesis appears to be, however, that design deficiencies, human error and equipment mal-functions were involved in the Three Mile Island accident.
As these same elements will exist at the Black Fox Station, the theory goes, Black Fox should be analyzed to account for them. Intervenors' asserted relationship between the alleged " design deficiencies, human error and equipment malfunctions" at Three Mile Island and the Black Fox Station construction permit proceedingb5[ is neither supported by the affidavit of a qualified expert nor any other informa-tion entitled to evidentiary weight. Instead, it appears that Intervenors, as well as the Attorney General for the State of Oklahoma, hope to achieve their objective of delay by relying on the shock of the TMI-2 accident to cause a catatonic effect on the decision-making process of the Nuclear Regulatory Commission and this Licensing Board in
, particular. The Commission has not directed, as a result of the TMI-2 accident, postponement of the decision-making process by needlessly reopening records or otherwise. In i
this connection we note that the Licensing Board in McGuire l recently issued an Initial Decision in an operating license proceeding.15!
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l 16/ Duke Power Company (William B. McGuire Nuclear Station, U its 1 and 2), LBP-79 __, 9 NRC (April 18, 1979).
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Counsel for Applicants will not enter the engineer-ing arena by attempting to explain the significant design differences between Three Mile Island and the Black Fox Station. However, the Licensing Board can take official notice of the fact that TMI-2 is a Pressurized Water Reactor
(" PWR" ) . There can be no quarrel from any quarter that the Black Fox Station will consist of two Boiling Water Reactors ("BWRs"), and that significant design differences exist between these two types of nuclear power reactors.
This factor was undoubtedly taken into account by the NRC Staff during their follow-up advice with respect to the Three Mile Island matter to operators of nuclear power i reactors. Specific actions involving potential design changes, changes to technical specifications and changes in operating procedures were directed to holders of oper-ating licenses of PWRs of various manufacture.b1! On the other hand, holders of operating licenses for BWRs were merely requested to review the applicability, if any, of the Three Mile Island information to operating BWRs.bS!
Second, it is essential to keep in mind that this is a construction permit proceeding. To date, the only action taken by the NRC Staff with regard to BWRs in light 17/ See IE Bulletin Nos.79-05A, 79-06,79-06A and 79-06B Included in NRC Staff Board Notifications dated April 24 and 30.
18/ See IE Bulletin No. 79-08, April 14, 1979, included in NRC Staff Board Notification dated April 24, 1979.
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of Three Mile Island has been to send IE Bulletin No. 79-08 to owners of operating BWRs. No action has been required of'BWR. construction permit holders. This is logical and proper in view of the fact that at the construction permit stage the design of the plant has not been finalized and there is ample opportunity to make any necessary changes before issuance of the operating license. The matters com-plained of by Intervenors, i.e., stuck relief valves, mal-functioning instrumentation and inadequate operating proce-dures and operator training, are all matters (assuming the various investigations confirm Intervenors' allegations) for consideration at the operating license stage of the Black Fox Station. Construction of the earlier unit of Black Fox Station will not be completed until 1985; Unit 2 is scheduled for completion in 1988. As there is ample time and opportunity to incorporate any lessons learned from TMI-2 into the operating features of the Black Fox Station, there is clearly no warrant to reopen the record now to consider these matters. The Interveaors have pro-vided no such justification as required by Vermont Yankee, and none exists.
IV. INTERVENORS HAVE NOT SHOWN SPECIAL CIRCUMSTANCES WHICH WOULD JUSTIFY REOPENING THE RECORD TO CONSIDER CLASS 9 ACCIDENTS The next subject with regard to which Intervenors attempt to reopen the record is Class 9 accidents. Alleg-edly, because what happened at Three Mile Island would 909 U,L
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previously have been considered " incredible," the Licensing Board must a "./ evaluate Class 9 accidents generically in the Black Fox docket. Again, no expert testimony supports this position; nothing but lawyer's argument is presented.
According to the teachings of Vermont Yankee, this lack of support defeats a request to reopen the record.
Intervenors' argument contains another defect, however, for nothing has been presented which would justify a consideration of Class 9 accidents in this proceeding even if the record were not already closed. The policy of the NRC as to the circumstances under which Class 9 accidents may be considered was recently discussed in Offshore Power ;
Systems (Floating Nuclear Power Plants), ALAB-489, 8 NRC 194 (1978). In that decision the Appeal Board explained that the Commission had, in its 1971 proposed Annex to the regu-lations implementing the National Environmental Policy Act,bE! divided the spectrum of nuclear power plant accidents into classes from the least consequential (Class 1) to the most severe (Class 9) . The Commission determined that, although the results of a Class 9 accident might be extremely severe, the likelihood of one occurring was deemed to be highly improbable. It was found to be so incredible, in fact, that a nuclear plant need not be designed with pro-tective systems or safety features to guard against it, 19/ 36 Fed. Reg. 22851-52 (1971).
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and therefore it is not necessary to discuss such accidents in environmental impact statements.2g/
The rule that Licensing Boards do not consider the effects of Class 9 accidents is not absolute. That type of accident could be considered in an individual proceeding if a party made a showing that, with respect to the reactor in question, there is a reasonable possibility of the occur-rence of a particular type of accident generically regarded as being in Class 9. Offshore Power Systems, 8 NRC at 214 n.66, citing Long Island Lighting Company (Shoreham Nuclear Power Station) ALAB-156, 6 AEC 831, 836 (1973). The same principle was applied in Duke Power Company, (Catawba Nuclear Station, Units 1 and 2), ALAB-355, 4 NRC 397 (1976), in which a Licensing Board decision declining to consider Class 9 accidents without a showing that special circumstances rendered such an occurrence more likely at Catawba than at nuclear power plants generally was upheld. Cf. Consolidated Edison Company (Indian Point Unit No. 2), CLI-72-29, 5 AEC 20 (1972).
The Commission's policy that a showing of special circumstances which increase the probability of a Class 9 accident is a prerequisite to its consideration has been upheld in the courts. Carolina Environmental Study Group
- v. United States, 510 F.2d 796, 798-800 (D.C. Cir. 1975),
20/ Offshore Power Systems, 8 NRC at 209-10, 212.
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affirming Duke Power Company, (Willaim B. McGuire Nuclear Station, Units 1 and 2), ALAB-128, 6 AEC 399 (1973).
The rules discussed above were recently reiterated and followed in Houston Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1) LBP , 9 NRC (March 15, 1979), in which the Licensing Board rejected certain contentions which improperly attempted to raise the issue of Class 9 accidents in a construction permit proceeding.
The rules regarding the consideration of Class 9 accidents in NRC proceedings are quite clear. It is equally clear that Intervenors have failed to set forth any special circumstances or other reasons justifying a i consideration of those accidents in this case. The f at that an accident happened at Three Mile Island does not mean that the established rules and principles governing the conduct of a licensing proceeding are automatically dispensed with. Intervenors must do more in order to- warrant an examination of Class 9 accidents under any circumstances, and especially in view of the fact that this is a motion to reopen the record which must be judged, in addition, by the Vermont Yankee criteria.
V. INTERVENORS HAVE NOT JUSTIFIED REOPENING THE RECORD CONCERNING EMERGENCY PLANS AND POST-ACCIDENT MONITORING This argument is phrased in somewhat different terms than Intervenors' other requests to reopen the record, for Intervenors ask for a reopening:
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to reconsider the Board's ruling in its Order ruling on Motions for Summary Dis-position insofar as same limited Inter-venors' contention 13 to Board Question 13-1. Intervenors' Reponse at 7.
Regardless of how this proposition is couched, what Inter-venors are asking for is a reopening of the record and it is by those standards that the request should be judged.
As with the other three issues for which Inter-venors seek to reopen the record, no justification is given other than a general reference to the events at Three Mile Island. According to the Vermont Yankee criteria detailed in Section I, supra, Intervenors have failed to demonstrate that any significant issue exists with respect to emergency ,
plans or post-accident monitoring.
Moreover, Intervenors once again misapprehend the scope of the issue in question. As this Licensing Board recognized in its September 8, 1978 Order Ruling on Motions for Summary Disposition, the Commission's regulations do not require an applicant for a construction permit to submit detailed plans for coping with emergencies--those 21 need not be filed until the operating license stage.- /
All that the regulations mandate at the construction permit stage with regard to emergency planning is that the applicant provide certain general information.22/ -
For this reason it 21/ 10 C.F.R. Part 50, Appendix E S III.
22/ Id. at S II.
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would not be appropriate to reopen the record to receive evidence regarding the details of the emergency plan for Black Fox Station in this construction permit proceeding, even assuming Intervenors had made the requisite showing under Vermont Yankee.
The question of post-accident monitoring was litigated at the hearing as Board Question 13-1. As the testimony at the hearings demonstrated, the post-accident monitoring for the Black Fox Station will be judged against the version of Regulatory Guide 1.97 which results from the completion of Task Action Plan A-34.23/ -
The design of the plant can be modified during construction to accommodate any additional instrumentation required by the revised Regulatory Guide. A! Thus, once again, this is a subject which may properly be left for consideration at the operating license stage. Therefore, both the emergency planning and the post-accident monitoring issues fall outside the. scope of this proceeding.
23/ Applicants' Proposed Findings of Fact at Paragraphs 119-122.
24/ Id.
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CONCLUSION For the reasons set forth above, Intervenors' request to reopen the record of this proceeding with regard to the four specified issues should be denied.
4<Lem, J o Josej5h Gallo Odqe -
regs Martha E. Gibbs "
Attorneys for Applicants ISHAM, LINCOLN & BEALE 1050 17th Street, N.W.
Suite 701 I
Washington, D.C. 20036 202/833-9730 ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 312/558-7500 May 18, 1979
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of the Application of )
Public Service Company of Oklahoma, )
Associated Electric Cooperative, Inc. ) Docket Nos. STN 50-556 and ) STN 50-557 Western Farmers Electric Cooperative )
)
(Black Fox Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing APPLICANTS' REPLY TO INTERVENORS' RESPONSE OF APRIL 27, 1979 has been served on each of the following persons by deposit in the United States mail, first class postage :
prepaid, this 18th day of May, 1979.
Sheldon J. Wolfe, Esquire Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of Board Panel the Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 (20 copies)
Mr. Frederick J. Shon, Member Atomic Safety and Licensing Atomic Saiety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Paul W. Purdom, Director Atomic Safety and Licensing Envirtnmental Studies Group Appeal Board Panel Drexel University U.S. Nuclear Regulatory 32nd and Ches tnut Streets Commission Philadelphia, Pennsylvania 19104 Washington, D.C. 20555 m o i' l J/L '
L. Dow Davis, Esquire Mr. Gerald F. Diddle William D. Paton, Esquire General Manager Colleen Woodhead, Esquire Associated Electric Cooperative, Inc.
Counsel for NRC Staff P.O. Box 754 U.S. Nuclear Regulatory Springfield, Missouri 65801 Commission Washington, D.C. 20555 Mr. Maynard Human General Manager Joseph R. Farris, Esquire Western Farmers Electric Cooperative John R. Woodard, III, Esquire P.O. Box 429 Green, Feldman, Hall & Woodard Andarko, Oklahoma 73005 816 Enterprise Building Tulsa, Oklahoma 74103 Mr. Vaughn L. Conrad Public Service Company of Oklahoma Mr. Clyde Wisner P.O. Box 201 NRC Region 4 Tulsa, Oklahoma 74102 Public Affairs Officer 611 Ryan Plaza Drive Mr. T. N. Ewing, Manager Suite 1000 Black Fox Station Nuclear Project Arlington, Texas 76011 Public Service Company of Oklahoma P.O. Box 201 Andrew T. Dalton, Esquire Tulsa, Oklahoma 74102 1437 South Main Street Room 302 Mr. M. J. Robinson Tulsa, Oklahoma 74119 Black & Veatch
- Citizens Action for Safe Energy, Inc. George L. Edgar, Esquire P.O. Box 924 Kevin P. Gallen, Esquire Claremore, Oklahoma 74107 Morgan, Lewis & Bockius Suite 700 Mrs. Ilene H. Younghein 1800 M Street, N.W.
3900 Cashion Place Washington, D.C. 20036 Oklahoma City, Oklahoma 73112 Charles S. Rogers, Esquire Mr. Lawrence Burrell Assistant Attorney General Route 1, Box 197 112 State Capitol Building Fairview, Oklahoma 73737 oklahoma City, Oklahoma 73105 Martha E. Gibbs Mr. Gregory Minor Michael I. Miller MHB Technical Associates Isham, Lincoln & Beale 1723 Hamilton Avenue One First National Plaza Suite K Suite 4200 San Jose, California 95125 Chicago, Illinois 60603 un x gfseph Mneom/Gallo the Attorneys for the Applicants 3 i' l
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