ML20027D471

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Motion for Leave to File Reply to Objections by Other Parties to ASLB 820922 Prehearing Conference Memorandum & Order
ML20027D471
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 11/02/1982
From: Baxter T
CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20027D472 List:
References
ISSUANCES-OL, NUDOCS 8211040343
Download: ML20027D471 (2)


Text

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.') Novcmb:r 2, 1982 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

+82 W -3 P2:11 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD & cELHtiARY v m.dfNG & SERVICE BRANCH In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' MOTION FOR LEAVE TO FILE A REPLY TO OBJECTIONS BY OTHER PARTIES TO THE BOARD'S PREHEARING CONFERENCE ORDER l

On September 22, 1982, the Atomic Safety and Licensing Board issued a Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference). Pursuant to the schedule established therein, Applicants, the NRC Staff and i intervenors CHANGE, CCNC, Eddleman and Wi1 son have filed timely objections to the Memorandum and Order. Applicants Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency herein move the Board for leave to l i

file the attached reply to the objections by other parties.

The Board's permission to file a reply may be viewed  !

l to be necessary in view of the provision in the Commission's l Rules of Practice which states that "[plarties may not file replies to the objections unless the Board so directs."

10 C.F.R. S 2.751a (d) .

Applicants have limited their reply to a few challenged Board rulings, each of which has been the cubject of new I

8211040343 821102

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developments since the Memorandum and Order issued. Applicants' purpose is to ensure that, in considering the objections filed, the Board is fully informed of these new facts.

Respectfully submitted, L~ AA%

George F. Trowbridge, P.C.

Thomas A. Baxter, P.C.

John H. O'Neill,.Jr.

SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1090 Richard E. Jones Sanantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated: November 2, 1982 i

l 1/ In the case of other objections raised by the Intervenors, Applicants have not repeated their earlier positions advanced in response to proposed contentions. We have not abandoned those positions in the face of the objections, and assume that the Board would direct or invite the filing of any necessary replies.

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