ML20028C872

Reply to Concerned Fools of Darlington County 821227 Petition to Intervene & Request for Hearing.No Objection to Intervention If One Allowable Contention Filed.Interest & Aspect Requirements Met.Certificate of Svc Encl

ML20028C872
Person / Time
Site:	Robinson
Issue date:	01/11/1983
From:	Trowbridge G CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8301140252
Download: ML20028C872 (5)

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,_ :l/11/83 TG UNITED STATES OF AMERICA gC NUCLEAR REGULATORY COMMISSION. -

T3 JM 13 20:56 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD- ,.

MH5 0F SECRLTARY CCCdf.IING & SERVICE BRANCH

.In the Matter of )

) .

CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-261

) (Steam Generator (H.-B. Robinson Steam' Electric ) Repairs)

Plant, Unit 2) )

' APPLICANT'S REPLY TO PETITION TO INTERVENE AND REQUEST FOR HEARING BY CONCERNED FOOLS OF DARLINGTON COUNTY On November 24, 1982, the NRC published in the Federal Register a notice of opportunity to request a hearing and to intervene with respect to a proposed amendment to the operating license issued to Carolina Power & Light Company (Applicant) for the H. B. Robinson Steam Electric Plant, Unit 2 (Robinson). The amendment would revise the conditions of the operating license to permit repair of the Robinson steam generators. On December 27, 1982, the Concerned Fools of Darlington County (Concerned Fools) filed a timely petition to intervene and request for hearing.

At this stage of the proceeding petitioners to inter-vene need only identify their interest and the specific aspects of'the proceeding as to which they wish to intervene. As an organization representing members living in the vicinity of the plant whose health and safety would allegedly be affected by the steam generator repairs, Concerned Fools has adequately stated its interest in the proceeding. It has also identified at least B301140252 830111 DRADOCK05000g 3

one aspect of the proceeding in which it wishes to intervene.

Accordingly, Applicant has no objection to its petition for hear-ing and intervention provided that, in.accordance with 10 CFR 2.714, Concerned Fools files at least one allowable contention. ,

Applicant is currently pursuing procurement, engineer-ing, and licensing activities to enable it to effect a steam generator repair at a time which is contingent on present steam generator performance and which ideally would coincide with a j refueling outage. Repair is expected to take place during the ,

next refueling outage which,is scheduled to begin in February, l 1

1984, but which could begin as early as November, 1983. Appli-  !

F cant has requested the NRC Staff to gear its review schedule to l the earlier date. Accordingly, Applicant requests that the  !

Licensing Board establish an early date for the submission of contentions and the holding of a special prehearing conference  ;

pursuant to 10 CFR 2.751a. To facilitate the preparation of contentions and to assure that they are accompanied by a proper statement of bases Applicant is supplying to Concerned Fools a i

copy of its Final Steam Generator Repair Report, filed with the .

NRC on January 6, 1983, which updates the oreliminary report i l l referred to in the NRC notice of opportunity for hearing. [

Respectfully submitted, i SHAW, PI MAN, POTTS & OWBRIDGE By MA '

//)JW d

', $eorfe F. Trowbridge, PyD. i Dated: January 11, 1983  ;

/

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETYj'YD LICENSING BOARD In the Matter of )'

)

CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-261

) (Steam Generator (H. B. Robinson Steam Electric ) Repairs)

Plant, Unit 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Reply to Petition to Intervene and Request for. Hearing by Concerned Fools of Darlington County," dated January 11, 1983, were served upon those persons on the attached Service List by de-posit in the United States mail, postage prepaid, this lith day of January, 1983.

NA N }./

YGeo e F. Trowbridge,[C.

Dated: January 11, 1983

-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD ~

> In the Matter of )

-)

CAROLINA POWER & LIGHT COMPANY .) Docket No. 50-261

) (Steam Generator (H. B. Robinson Steam Electric ) Repairs)

Plant, Unit.2) )

SERVICE LIST Administrative Judge Morton B. Margulies Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555-Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge David L. Hetrick Atomic Safety and Licensing Board

{ Professor of Nuclear Engineering University of Arizona Tuscon, Arizona 85721 Docketing E Service Section (3)

Office of the Secretary U.S.* Nuclear Regulatory Commission Washington, D.C. 20555 Myron Karman, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

B. A. Matt $ hews i

Hartsville Group P. O. Box 1089 Hartsville, South Carolina 29550

. \

Jacqueline Kirven J Concerned Fools of Darlington County P. O. Box 835 Hartsville,-South Carolina 29550 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 e

a l

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