ML20028G273
| ML20028G273 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/02/1983 |
| From: | Kirven J AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8302070582 | |
| Download: ML20028G273 (4) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Q}TED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
[83 W B ~ 4 m o :3 9 In the matter of
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mn,
)
3 4 5EPvg e CAROLINA POWER & LIGHT COMPANY
)
DOCKET NO. 50-261 (H. B. Robinson Steam Electric' (Steam Generator Repairs)
Plant, Unit 2)
)
REQUEST FOR RECONSIDERATION
(' F ORDER SCHEDULING PREHEARING CONFERENCE)
O On January 21, 1983, the Licensing Board in the above-captioned docket caused to be served on Petitioners Concerned Fools of Darlington County (hereafter " Fools") an order establishing March 24, 1983, as the date for the Special Prehearing Conference and February 24, 1983, as the date for filing contentions.
That Order was received in the mail by Fools on January 28, 1983.
Fools request the Board to reconsider both rulings for the reasons set forth herein.
- 1) The Authorized Representative of the Fools, Jacqueline Kirven, has a conflicting engagement which requires her to be in Washington, D.C. on March 24, 1983, on business related to her vocation as a painter.
Although Kirven could be in South Carolina on that date, it would only be possible at considerable difficulty and expense to her and by placing in danger the viability of a long-term project on which she is employed.
- 2) The Board's Order suggests a clear desire to get the show on the road and speed up these proceedings.
Fools would assert that despite political pressure applied to the Congress and Commission by utility executives, not least of whom Sherwood Smith of Carolina Power & Light Company, intervenors still have some rights, even in Wonderland.
Although Fools can see that fg%
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i the Board desires to hurry things up, Fools travel by burro and cannot move as fast as a railroad train.
- 3) No good cause exists for not delaying the Prehearing Conference.
- 4) The Board attempts in its Order to undermine the ability of these Fools to adequately litigate this foolishness by re-quiring that they file their Supplement 30 days prior to the Special Prehearing Conference.
As good cause, the Board asserts, in essence, that it wants more time to review the Supplement.
Presumably, the Commission took into account the needs of Boards to examine Supplements prior to Special Prehearing Conferences when it prescribed its fifteen-day limit at 10CFR 2.714(b).
Mere convenience of the Board is hardly good cause.
- 5) Petitioners are diligently pursuing preparation of their Supplement, setting forth all the foolishness and nonsense in the Applicant's steam generator repair plans which we wish to contend the NRC ought not to abide.
Shortening our tire in no way assists the Board to make its decision and deprives these poor Fools and other petitioners of due process.
At least, we beg of you, give us a fair trial before you hang.us.
- 6) Fools would further note that the Board adopts the Staff's conceit of referring to the Fools as CFDC.
We are Fools or we would not be pursuing this foolishness. Of course, a bureau-cracy which has persisted in licensing the biggest hoax ever played on the American political-economy wouldn't know a Fool from a utility executive.
But we know we're Fools and desire to be recognized as such.
THEREFORE, Fools most humbly beg this Board to reconsider its Order of January 21, 1983, to reschedule the Special Pre-hearing Conference to a date after March 24, 1983, and to restore unto these Fools the rights that the NRC in its wisdom had originally granted Petitioners.
t acas wn (hp/cqddlineKirven Authorized Representative Concerned Fools of Darling-ton County
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 (H.
B. Robinson Steam Electric (Steam Generator Plant, Unit 2)
Repairs)
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 Tucson, Arizona 85721 Docketing & 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 George F. Trowbridge Shaw, Pittman, Potts & Trowbridge 1800 M.
Street, N.W.
Washington, D.C.
20036 Samantha Francis Flynn Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602
B. A. Matthews Hartsville Group Post Office Pox 1089 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 1
AFFIDAVIT OF SERVICE PERSONALLY APPEARED before me, Jacqueline Kirven, who does affirm that she did on this N day of N gac/
1983 serve copies of the attached Request for Reconsiderati (of Order Scheduling Prehearing Conference) upon the parties above named by depositing same in the U.S. Mail, first class, postage prepaid, Mll bjdklk e
line Kirven DONE before e this Orw/. day of
/,
1983 at Hartsville, (
\\'
J um A web NOTARY PUB CF R SOUTH CAROLINA (LSL My commission expires
. l9 J776
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