ML20083F554

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Amended Answer to Intervenor 831207 Motion to Add Contention & Witnesses.Opposition to Request to Call Addl Witnesses Withdrawn.Certificate of Svc Encl
ML20083F554
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 12/27/1983
From: Silberg J
KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8401030158
Download: ML20083F554 (5)


Text

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UNITED STATES OF AMERICA

) NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter ~of )

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KANSAS GAS & ELECTRIC CO., et al.

) Docket No. STN 50-482 t

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(Wolf Creek Generating Station, )

Unit No. 1) )

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APPLICANTS' AMENDED ANEWER TO INTERVENORS' MOTION TO j ADD CONTENTION AND WITNESSES 1

On December 23, 1983, Applicants submitted their answer to Intervenors' December 7, 198 3 motion to add a new contention and to call additional witnesses. Applicants oppcsed both aspects j

o f the Motion. As a result of information obtained af ter the answer was filed, Applicants would now withdraw their opposition i.

i to that portion of the motion seeking permission to call addi-tional witnesses.

Applicants' objection to Intervenors' request to call addi-tional witnesses was based in part on the Intervenors' "already a

voluminous list of potential witnesses . " See Pr hearing Con-ference Order, March 18, 1983, at 3-4; Memorandum and Order Ruling Upon Intervenors Objection to Prehearing Conference Order, May 5, 1983, at 4. Subsequent to the filing of Applicants' e401030158 831227 PDR ADOCK 05000482 O c' 9 ,{hD

o answer, counsel for Applicants was informed by Intervenors '

counsel that the only two witnesses which Intervenors would call were the two individuals for whom subpcenas were issued by the Licensing Board on December 19, 1983.

Although Applicants still believe that Intervenors' request to add additional witnesses was untimely and unspecific, the elimination of all but two of Intervenors' identified witnesses leads Applicants to withdraw their objection to this aspect of Intervenors' motion.1/

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE BY: I l Jn .

"n S::LBERG, P.C. [J DELI A. RIDGWAY U Counsel for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 DATED: December 27, 1933 1/ Intervenors' presentation of testimony by these witnesses remains subject to Intervenors' commitment to timely prefile, in lieu of prefiled direct testimony, a full statement of the testimony Intervenors will seek to elicit from the witnesses. See Transcript of March 10, 1983 Prehearing Conference, at 110-11.

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December 27, 1983 UNITED STATE 3 OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

KANSAS GAS & ELECTRIC CO., et al. ) Docket No. STN 50-482

)

(Wolf Creek Generating Station, )

Unit No. 1) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants '

Amended Answer to Intervenors' Motion to Add Contention and Witnesses" were served by deposit in the United States Mail, first class, postage prepaid, this 27th day of December, 1983, to all those on the attached Service List.

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JAY \

AS LBERG A DATED: December 27, 1983

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

KANSAS GAS AND ELECTRIC COMPANY, et al. ) Docket No. STN 50-482

)

(Wolf Creek Generating Station, )

Unit No. 1) )

SERVICE LIST Sheldon J. Wolfe 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 Wechington, 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

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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 Los Alamos, New Mexico 87544 Jefferson City, Missouri 65102 Myron Karman, Esquire A. Scott Cauger, Esquire Daputy Assistant Chief Assistant General Counsel Hearing Counsel Missouri Public Servi.ce Commission i Office of the Executive Post Office Box 360

! Legal Director Jefferson City, Missouri 65102 l U.S. Nuclear Regulatory Commission Wachington, D.C. 20555 Eric A. Eisen, Esquire Birch, Horton, Bittner & Monroe Atomic Safety and Licensing Board 1140 Connecticut Avenue, N.W.

2 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 Washington, D.C. 20555

Service List Page Two Dr. John H. Buck 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 m

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