ML20010D178
ML20010D178 | |
Person / Time | |
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Site: | Wolf Creek ![]() |
Issue date: | 08/19/1981 |
From: | Silberg J KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
To: | Salava M AFFILIATION NOT ASSIGNED |
References | |
NUDOCS 8108240079 | |
Download: ML20010D178 (2) | |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196K7991999-07-0606 July 1999
[Table view]Comments of Nuclear Energy Institute,Inc on Treatment of Existing Antitrust Conditions in License Transfer Cases.* Recommends Establishing Basic Guidelines for Evaluating Disposition of Antitrust Conditions.With Certificate of Svc ML20196H1511999-06-30030 June 1999 Response of Wml Associates to Commission Memorandum & Order CLI-99-19.* Strongly Urge Commission to Reconsider Decision in CLI-99-19 & Seek Congressional Input,Per Commission Review Responsibilities.With Certificate of Svc ML20195J4341999-06-18018 June 1999 Memorandum & Order.* Concludes That AEA Does Not Require Antitrust Reviews of post-operating License Transfer Applications & Dismisses Kepco Petition to Intervene on Antitrust Grounds.With Certificate of Svc.Served on 990618 ML20206H3351999-04-30030 April 1999 Exemption from Certain Requirements of 10CFR50.60, Acceptance Criteria for Fracture Prevention Measures for Lightwater Nuclear Power Reactors for Normal Operation. Exemption Related to Application ML20205K9381999-04-0505 April 1999 Amicus Curiae Brief Wml Associates.* Commission Should Not Eliminate Antitrust Review of License Transfers,For Listed Reasons.With Certificate of Svc ML20205C8081999-03-31031 March 1999 Affidavit of D Penn.* Affidavit of D Penn in Support of NRC Antitrust License Conditions & Significant Impacts Conditions Have in Shaping Competitive Electric Markets ML20205C7681999-03-31031 March 1999 Amicus Filing National Association of State Utility Consumer Advocates.* Brief Submitted in Accordance with Memo & Order of 990302 & in Support of Argument 1 in Initial & Reply Briefs of Kepco & Nreca.With Certificate of Svc ML20205G0511999-03-31031 March 1999 Amicus Brief of Nuclear Energy Institute on Issue of Antitrust Reviews in License Transfer Cases.* Industry Supports Agency Actions & Urges Commission to Implement Recommended Changes.With Certificate of Svc ML20205C8701999-03-31031 March 1999 Motion to Submit Comments & Comments of Amici Curiae of American Antitrust Institute.* for Listed Reasons, Interpreting Act as If No Transfer Took Place Would Turn Statutory Purpose on Its Head.With Certificate of Svc ML20205C7791999-03-31031 March 1999 Joint Brief of American Public Power Association & Florida Municipal Power Agency.* Brief Addresses Question on Whether Commission May & Should Eliminate All Antitrust Reviews in Connection with License Transfers.With Certificate of Svc ML20204H5211999-03-23023 March 1999 Reply to Brief of Applicants in Response to Joint Brief of Kansas Electric Power Cooperative & National Rural Electric Cooperative Association.* Petition Should Be Dismissed.With Certificate of Svc ML20205A8561999-03-23023 March 1999 Reply Brief of Kansas Electric Power Cooperative Inc.* Facts of Case Warrant Changes Occurred.Commission Should Perform Changes Review in Case & Based on Results Should Perform Antitrust Review on Competition.With Certificate of Svc ML20207M8241999-03-16016 March 1999 Joint 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on 941202 ML20076L1471994-10-24024 October 1994 Comments on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Endorses Response Submitted by Nuclear Energy Institute ML20045D7351993-06-0303 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule ML20094L4441992-03-20020 March 1992 Application Under Exigent Circumstances to Extend Effective Period of NRC Approval of Transfer & Amend to OL NPF-42 in Connection W/Merger of Ksge W/Kansas Power & Light Co ML20091A2281992-03-18018 March 1992 Comment Endorsing Comments Provided by NUMARC Re Proposed Rule 10CFR51 Re Requirements for Environ Review of Applications to Renew OLs for Nuclear Power Plants ML20095B7741992-03-17017 March 1992 Application Under Exigent Circumstances to Extend Effective Period of NRC Approval of Transfer of & Amend to License NPF-42 in Connection W/Merger of Ksge W/Kansas Power & Light Co ML20073P7301991-05-16016 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery ML20073F9331991-04-25025 April 1991 Testimony Re Application of Kansas Power & Light Co & Kca Corp for Approval of Acquisition of All Classes of Capital Stock of Kansas Gas & Electric Co,To Merge W/Kansas Gas & Electric Co,To Issue Stock & Incur Debt Obligations ML20029A7471991-02-0606 February 1991 Testimony of Kpl Gas Svc & Ks G&E Re Co Merger ML20245J8761989-06-26026 June 1989 Director'S Decision 89-04,denying Sierra Club of Kansas 2.206 Petition to Revoke Ol,Based on Safety Concerns W/Qa Program & Mgt Failure to Safeguard Integrity of QA Program ML20116M7641989-01-30030 January 1989 Petition for Immediate Action to Protect Public Health & Safety from Undue Risks Posed by Lack of Quality Assurance Compliance at Wolf Creek Generating Station,Burlington,Ks ML20155G0961988-09-30030 September 1988 Exemption from Schedular Requirements of Property Insurance Rule 10CFR50.54(w)(5)(i),effective 881004 ML20151K0201988-07-28028 July 1988 Order Imposing Civil Monetary Penalty in Amount of $100,000 Re Mgt Oversight of safety-related Activities to Preclude Procedural Control Weaknesses ML20236Q2501987-11-12012 November 1987 Petition Per 10CFR2.206 Requesting Investigation of Plant Security Problems Resulting from Easy Access to Cooling Lake Which May Be Exploited by Terrorists.Supporting Info & Certificate of Mailing Encl ML20150C2791987-06-0303 June 1987 Sanitized Version of Investigative Interview of Rl Scott Conducted by Hb Griffin on 870603 Re Util Investigation ML20150C3011987-05-13013 May 1987 Sanitized Version of Investigative Interview of GL Koester on 870513 Re Investigation of Util ML20150C2931987-05-12012 May 1987 Sanitized Version of Interview of C Snyder by Hb Griffin on 870512 in Burlington,Ks Re Investigation of Util ML20150C2401986-08-21021 August 1986 Sanitized Version of 860821 Testimony of OL Thero in Lebo,Ks Re Investigation of Util ML20150C2581986-06-27027 June 1986 Sanitized Version of Investigative Interview of C Hill Taken by DD Driskill on 860627 Re Plant Quality First Program ML20125E0641985-06-0404 June 1985 Unexecuted Amend 3 to Indemnity Agreement B-99,changing Item3 Re License Number ML20138P8761985-06-0303 June 1985 Transcript of Closed Commission 850603 Meeting in Washington,Dc for Discussion of Pending Investigations. Pp 1-48.Portions Deleted ML20138B6151985-06-0303 June 1985 Transcript of Closed Commission 850603 Meeting in Washington,Dc Re Pending Investigations.Pp 1-38.Portions Deleted ML20126E3881985-06-0303 June 1985 Transcript of Commission 850603 Meeting in Washington,Dc Re Discussion/Possible Vote on Full Power OL for Facility. Pp 1-46 ML20128P2971985-05-28028 May 1985 Affidavit of Kr Brown Re Gap 850515 Petition Filed Per 10CFR2.206 Concerning Util Quality First Program.Program Provides Mechanism for Personnel to Confidentially Rept on Concerns Re Quality at Facility ML20128P3111985-05-28028 May 1985 Affidavit of CA Snyder Re Development,Staffing,Mgt, Implementation & NRC Review of Quality First Program. Supporting Documentation Encl ML20090F5211984-07-17017 July 1984 Motion for Clarification of ASLB 840702 Initial Decision Re Offsite Emergency Planning,Including Info on Two Conditions, Evacuation of Hosp & Nursing Home Patients & Redmond Reservoir Notification.Certificate of Svc Encl ML20092J7771984-06-25025 June 1984 Proposed Corrections to Transcript of Evidentiary Hearings 1999-07-06 Category:PLEADINGS MONTHYEARML20205K9381999-04-0505 April 1999
[Table view]Amicus Curiae Brief Wml Associates.* Commission Should Not Eliminate Antitrust Review of License Transfers,For Listed Reasons.With Certificate of Svc ML20205C7681999-03-31031 March 1999 Amicus Filing National Association of State Utility Consumer Advocates.* Brief Submitted in Accordance with Memo & Order of 990302 & in Support of Argument 1 in Initial & Reply Briefs of Kepco & Nreca.With Certificate of Svc ML20205C7791999-03-31031 March 1999 Joint Brief of American Public Power Association & Florida Municipal Power Agency.* Brief Addresses Question on Whether Commission May & Should Eliminate All Antitrust Reviews in Connection with License Transfers.With Certificate of Svc ML20205C8701999-03-31031 March 1999 Motion to Submit Comments & Comments of Amici Curiae of American Antitrust Institute.* for Listed Reasons, Interpreting Act as If No Transfer Took Place Would Turn Statutory Purpose on Its Head.With Certificate of Svc ML20204H5211999-03-23023 March 1999 Reply to Brief of Applicants in Response to Joint Brief of Kansas Electric Power Cooperative & National Rural Electric Cooperative Association.* Petition Should Be Dismissed.With Certificate of Svc ML20205A8561999-03-23023 March 1999 Reply Brief of Kansas Electric Power Cooperative Inc.* Facts of Case Warrant Changes Occurred.Commission Should Perform Changes Review in Case & Based on Results Should Perform Antitrust Review on Competition.With Certificate of Svc ML20207M8241999-03-16016 March 1999 Joint Brief of Kansas Electric Power Cooperative,Inc & Amicus Curiae Natl Rural Electric Cooperative Assoc.* Commission Should Perform Significant Changes Review Mandated by Statute & Regulations.With Certificate of Svc ML20236Q2501987-11-12012 November 1987 Petition Per 10CFR2.206 Requesting Investigation of Plant Security Problems Resulting from Easy Access to Cooling Lake Which May Be Exploited by Terrorists.Supporting Info & Certificate of Mailing Encl ML20090F5211984-07-17017 July 1984 Motion for Clarification of ASLB 840702 Initial Decision Re Offsite Emergency Planning,Including Info on Two Conditions, Evacuation of Hosp & Nursing Home Patients & Redmond Reservoir Notification.Certificate of Svc Encl ML20080R2471984-02-0909 February 1984 Motion for Addl 15 Days within Which to File Reply & Affidavits to ASLB 840209 Order.Notice of Appearance & Certificate of Svc Encl ML20083D8131983-12-23023 December 1983 Answer Opposing W Christy & Me Salava 831208 Motion to Add New Contention & Addl Witnesses.Motion Not Justified. Certificate of Svc Encl ML20024E2871983-08-0404 August 1983 Motion for Continuance of Hearing Scheduled for 830920-24, 26-29,1018-22 & 24-27.Revised County & State Plans Will Be Submitted to FEMA on 831001.Evidentiary Hearings Can Begin in Jan 1984.Certificate of Svc Encl ML20074B0321983-05-12012 May 1983 Response Opposing Util 830503 Objections to Issues & Motion for Adoption of Interrogatory Responses as Statement of Issues for Litigation.Aslb Should Adopt Intervenor Second Stipulation of Contentions.W/Certificate of Svc ML20073S2031983-05-0303 May 1983 Objections to Proposed Issues & Motion for Adoption of Interrogatory Responses as Statement of Issues for Litigation.Proposed Stipulation Lacks Specificity. Certificate of Svc Encl.Related Correspondence ML20073J1301983-04-15015 April 1983 Response in Opposition to Intervenors W Christy & Me Salava 830330 Objections to ASLB 830318 Prehearing Conference Order.Intervenors Failed to Demonstrate Good Cause to Amend List of Witnesses or Contentions.Certificate of Svc Encl ML20072P9101983-03-30030 March 1983 Objection to & Request for Mod of ASLB 830318 Prehearing Conference Order.Agreement Among Parties Re Amends to Stipulation of Contentions to Be Filed by Intervenors Should Be Reflected in Order.Certificate of Svc Encl ML20054J3061982-06-23023 June 1982 Appeal for Reconsideration of ASLB 820609 Memorandum & Order Dismissing Financial Qualification Contention & Intervention.Financial Qualification Issues Illegally Eliminated from Proceedings.Certificate of Svc Encl ML20052D8381982-05-0303 May 1982 Reply Opposing NRC & Applicant 820423 Motions for Dismissal of Financial Qualifications Contention & Kansans for Sensible Energy as Party.Nrc Does Not Have Statutory Authority to Adopt Final Rule.Certificate of Svc Encl ML20052A2601982-04-23023 April 1982 Motion for Dismissal of Financial Qualifications Contention & of Kansans for Sensible Energy.Contention Is Intervenor Only Contention & Is Moot Due to NRC Final Rule on Financial Qualifications.Certificate of Svc Encl ML20040D7641982-01-26026 January 1982 Answer Opposing Applicants' 820120 Motion for Deferral of Discovery of Financial Qualifications.Intervenor Will Be Prejudiced Because Time Will Not Be Available to Conduct Discovery Adequately.Certificate of Svc Encl ML20040C0701982-01-20020 January 1982 Motion for Deferral of Discovery on Financial Qualifications.Kansans for Sensible Energy 800113 Document Request Should Be Deferred Pending Rulemaking.Production Would Place Burden on Util.Certificate of Svc Encl ML20040A9171982-01-13013 January 1982 Motion for 10-day Extension to Respond to Applicants' Emergency Planning Interrogatories Described in ASLB 811230 Memorandum & Order.Applicant Counsel Does Not Object.W/ Proposed Order & Certificate of Svc.Related Correspondence ML20039B0831981-12-15015 December 1981 Renewed Motion to Compel Christy & Salava Answers to Applicants' Interrogatories EP-4,EP-5,EP-7,EP-8,EP-9,EP-11, EP-12,EP-15,EP-16 & Ep/Fq.Attempts to Resolve Disputes Informally Unsuccessful.Certificate of Svc Encl ML20011A6021981-10-23023 October 1981 Response Opposing Kansans for Sensible Energy 811008 Motion to Compel Applicant Response to Interrogatories 2,4,6,8,9, 11,12,13,20 & 21.Motion Fails to Specify Bases for Relief Adequately.W/Certificate of Svc.Related Correspondence ML20011A6051981-10-23023 October 1981 Answer Opposing Applicant 811008 Motion to Compel Answers to Applicant Interrogatories.Intervenors Responded as Fully as Possible & Will Respond Further When Contentions Are Fully Formed.W/Certificate of Svc.Related Correspondence ML20010D1781981-08-19019 August 1981 First Request to Intervenor Me Salva for Production of Documents Identified or Described in Answers to Applicant First Set of Interrogatories.Related Correspondence ML20009B7681981-07-10010 July 1981 Answer to Intervenors' 810702 Motion for Addl Time to File First Round Discovery Request.Applicants Do Not Object to Requested Extensions Provided That Extensions Are Granted to Other Parties.Certificate of Svc Encl ML20009A2071981-07-0202 July 1981 Intervenors W Christy,Me Salava & Kansans for Sensible Energy Motion for Addl 30 Days to File First Round Discovery Repts Due to Complexity of Matter Under Consideration. Certificate of Svc Encl ML19346A3581981-06-11011 June 1981 Answer to 810609 Notice of Hearing.Applicants Will Appear & Present Evidence Opposing Contentions Specified in 810603 Special Prehearing Conference Order.Certificate of Svc Encl ML20003A9091981-02-0606 February 1981 Answer to F Blaufuss 810127 Ltr.Opposes Intervention But Does Not Object to Limited Appearance Statement If Hearing Held.Certificate of Svc Encl ML19345E5971981-01-29029 January 1981 Answer to MO-KS Section of ANS 810116 Ltr Re Support of Facility.Ltr Is Not Petition for Leave to Intervene.No Objection to Limited Appearance Statement If Hearing Is Held.Certificate of Svc Encl ML20002E3101981-01-21021 January 1981 Response to PSC of Mo 810116 Petition to Intervene as Representative of State.Applicant Does Not Object to Participation If Hearing Is Ordered.Certificate of Svc Encl ML19341A6191981-01-21021 January 1981 Answer Opposing W Christy 810106 Petition to Intervene. Applicant Does Not Oppose Christy Limited Appearance Statement.Certificate of Svc Encl ML20002E3061981-01-21021 January 1981 Answer Opposing Me Salava 810113 Motion to Intervene. Applicant Does Not Oppose Salava Limited Appearance Statement.Certificate of Svc Encl ML19211C9241979-12-21021 December 1979 Suggestions Per ASLB 791123 Order in Support of Public Service Commission of Mo Petition to Intervene.Tj Hearne Affidavit,Notice of Appearance & Certificate of Svc Encl ML19211A1401979-12-0303 December 1979 Request by PSC of Mo for Extension Until 791221 to Respond to ASLB 791123 Order Re CP Amend.Order Was Received on 791203.Notice of Appearance of Tj Hearne on Behalf of PSC of Mo,Affidavit of Tj Hearne & Certificate of Svc Encl ML19210E5771979-11-0707 November 1979 Response to PSC of Mo 791023 Request to Intervene as Representative of State.Since No Request for Hearing Filed No Hearing Appropriate.Certificate of Svc Encl ML19262A9921979-10-23023 October 1979 Petition to Intervene by Public Svc Commission of Mo. Proposed Amend Adding Ks Electric Power Cooperative as co- Owner of 17% Interest Will Create Conflict of Jurisdiction on Rate Base.Affidavit & Certificate of Svc Encl ML19224C7321979-06-18018 June 1979 Request by Ks Bldg & Const Trades Council for Order to Show Cause Why CP Should Not Be Revoked.Const Work on Plant Is Substd;Operation Endangers Public Health & Safety ML20148H4281978-10-24024 October 1978 NRC Staff'S Response to Motion to Consolidate Hearings on Radon. Ecology Action,Intervenor in One of the Proc & Representing Intervenors in 4 Other Proc Filed 781003 to Consolidate.Nrc Requests Expeditious Ruling by Appeals Bd ML20064C9881978-10-18018 October 1978 Response to Motion to Consolidate Hearings on Radon Issue. Intervenor Has Standing Only in Sterling Hearing & Has No Authority to Represent Other Intervenors.Urges Denial of Motion.Certificate of Svc Encl ML20148A2451978-10-13013 October 1978 Motion for Aslab to Consolidate Cases Into Single Hearing in Answer to ALAB-480 Re Radon Issue.Evidence Is Generic & Will Apply to All Nuclear Reactors ML20197B2061978-10-0303 October 1978 Intervenor Motion to Consolidate Hearings on Radon Issue. Proposes Joint Representation of Intervenors,Applicants & Staff at Aslab Hearings & Compilation of Generic Proposed Findings ML19329E6441975-09-0808 September 1975 Lists Exceptions to ASLB Initial Decision.Certificate of Svc Encl 1999-04-05 |
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August 19, 1981 o
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/ Li UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,J i, W'"h
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KANSAS GAS & ELECTRIC COMPANY el al. Do,cke N 0-482 (Wolf Creek Generating 5tation, Unit No. 1)
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APPLICANTS' FIRST REQUEST TO INTERVENOR (s,'
MARY ELLEN SALAVA / ut FOR THE PRODUCTION OF DOCUMENTS l
In accordance with the Licensing Board's July 15, 1981
" Order (Extension of Time)" and pursuant to 10 C.F.R. S 2.741, Applicants request that Intervenor Mary Ellen Salava
("Intervenor") respond in writing to the following request for production of documents and produce the original or best copy of each of the documents requested below, on or before t September 24 1981 at the office of Richard Terrill, Esq.,
l Kansas Gas and Electric Company, or at a place mutually l convenient to the respective parties.
" Documents" means all writings and records of every type
I in the possession, control or custody of Intervenor, including but not limited to memoranda, correspondence, reports, surveys,
! tabulations, charts, boc'.s, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, i T)S[l0l 8108240079 810819 PDR ADOCK 050004'2 l 0 PA
9 transcripts and all other records, written, electrical, mechanical or otherwise.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of Intervenor.
Applicants request that Intervenor produce each and every document identified or described in the answers to Applicants' First Set of Ii:;arrogatories to Intervenor Mary Ellen Salava.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By \ p_ t/
\ E . Silberg lis sa A. Ridgwa unsel for Applicants 1800 M Street, N. W-Washington, D. C. 20036 (202) 822-1000 Dated: August 19, 1981 l
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