ML20028G200

Regrets Failure to Agree on Extensions of Time Re Eddleman 830115 Discovery on Contention 15.Since Util Would Not Agree to Equal Extension for Eddleman,Extending Time to Answer Discovery Would Be Hardship.Certificate of Svc Encl

ML20028G200
Person / Time
Site:	Harris
Issue date:	01/31/1983
From:	Eddleman W EDDLEMAN, W.
To:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
References
NUDOCS 8302070514
Download: ML20028G200 (2)

Text

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718-A Irodoll St.

Durhan HC 2??O5 g AEll January 31, 1983 Tom Baxter-Attorney for CP&L Shaw, Pittman, Potts & Trowbridge 83 FEB -3 g f7 1800 M St NW Washington DC 20G36 {) ') _

, sG N -

Dear Tom Baxter,

7;f #

I regret we were unable to agree on extensions of time re discovery dated 1/15/83 on my Contention 15 Since you did not allege any inability to conn 17 with those interrogatories within the time limit provided, but simply sour.ht to sunnly the information only aften the 30 days given in 'ne Board's January 11 Order (served Jan.12) for revising Conted k inn 15 or filing new contentions re ER Amendument 5 had run, I nroposed to give CP&,L an extension if CP&L would not onnose an eaual extension.

Otherwise, as I said, I'll have to basically allege that all of the comolex inputs to the connuter runs ER Amendnent 5's " fuel Dis sav $ovegy i fox ngs daI,a is based are not necessary on, are intoerror. file such, but might avoid some.*

You did not agree to any extensions for me , and I am unable to give you an extension for the sole nutmose of janming ne against a deadline. I still believe it will considerably co molicate matters for CP&L, N90 Staff i

and the Board to have to deal with a larger numbe* of contentions than might be filed were CP&L to co"mly with my 1-15 discovery in a timely fashion. The Board lef t discovery re all contentions onen

in soite of CP&L's reauest to defer or deny admission of Eddlenan Centention 15, and I continue to believe you can answer the 1-15 interrogatories and should, on time.

Wells Eddleman E^ ' '

1 xc: Board members and all parties

$0-h00/401 operating license docket

• where CP&L's basis may appear accurate, if I saw it.

r302070514 830131 gDRADOCK05000

UNITED STATES OF AME9ICA NUCIJAR REGULATOFY COMMISSION In the matter of CAROLIKA PO'iER & LIGHT CO. Et al. ) Dockets 50-LOO Shearon Harris Nuclear Power Plant, Units 1 and 2 ) and 50leh01 0.L.

CERTIFICATE 0F SERVICE I hereby certify that copies of IN7 dC_hf N E'L f b Y(N94(- %VW Ye-- l-l 5 ~L tdN~@9G(l~b r~t?tts ,

HAVE been served this 3 day of ~[4NhMbf 198d, by deposit in i

the US Mail, first-cls ss posth6e prepaid, upon all parties whoes names are listed below, except those whose names are erked with l

[

an asterisk, for whom service was acconn11shed by i

Judges James Kelley, Glenn BaiEht and James Cavnter (1 cony each) l Atonic Safety and Licensing Board  ;

US Nuclear Regulatory Commission l Washington DC 20555  ;

GeorEe F. Trowbridge (attorney for Anplicants)  !

Shaw, Pittman, Potts & Trowbridge  :

1600 M St. NW ,

Washington, DC 20036 l

Office of the Executive Legal Director Phyllis Lotchin, Ph.D. .

Attn Dockets 50-400/h010?L. 108 Bridle Run  !

USNRC Chanel Hill

~ NC 2751h  !

Washington DC 20555 t Dan 9ead  !

Docketing and Service Section CEAUGT/FLP Attn Docke ts 50-k00/h01 0.L. Box 52h  !

Office of the Secretary Chapel Hill NC 2751h USNRC l Washington DC x 20555 Pat & Slater Newnan l CANP r John.Runkle 2309 Weynouth Court l CCNC Raleigh NC 27612  !

307 Granville Rd l Chapel Hill Nc 2751h Travias Payne Edelstein & Payne l Box 126h3 ,

Raleigh NC 27605  !

Richard Wilson, M.D. Certified by *h  !

729 Hunter St. I i Apex NC 27502 i I

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