ML20041C293

Requests Leave to Withdraw 820201 Proposed Change to Charlotte-Mecklenberg Environ Coalition Contentions & to Add Final Paragraph to First Contention

ML20041C293
Person / Time
Site:	Catawba
Issue date:	02/22/1982
From:	Presler H CHARLOTTE-MECKLENBERG ENVIRONMENTAL COALITION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20041C294	List: ML20041C293 ML20041C297 ML20041C298
References
NUDOCS 8203010118
Download: ML20041C293 (1)

Text

-

UNITED STATES OF AMERICA mW "

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 32 FEB 25 A10:57 In the Matter of DUKE POWER COMPANY, et al.

) ***'7

Docket Nos. 50-413 Catawba Nuclear Station, '

. .dil:30-414 Units 1 & 2

)

A Futher Proposal Regarding CMEC's Contentions I.

Introduction:

After the conference call with Chairman Kelley on February 16, 1982, Petitioner (Charlotte-Mecklenburg Environmental George Johnson,Coalition) has had a number of discussions with Michael McGarry and Albert Carr. We have come to a general agreement about CMEC's col.entions. I set forth the substance of our agreement as follows.

a. CMEC should withdraw its filing of February 1,1982 entitled 'A Proposed Change in CMEG's contentions.

b. The NRC Staff undertakes to withdraw its objections to CMEC's original contention #1 in its filing of December 9, 1981 provided that a final paragraph be added to this contention.

This final paragraph should read as follows:

"Due to these inadequate projections, the cost / benefit balance does not support operation of the Catawba Nuclear Station."

c. Applicant continues to agree to its stipulation of CMEC's contention #1 as reworded in (b.) above.

d. Staff maintains- its objections to CMEC's contentions #2 & #4.

e. Staff is, however, prepared to withdraw its objections to CMEC's contention #3 provided that it is reworded. Mr. McGarry, Mr. Johnson and I are in agreement about this rewording.

Owing to NRC rules and procedures, it is necessary for Petitioner to file a separate document relating to this document.

Applicant will continue its stipulation to this reworded -,

contention. NRC Staff will atipulate to this reworded &

contention except insofar as it mentions: CMEC' a contention #2' -

to which Staff continues to object.

l In sum then, we have developed two contentions, #1 and #3 to which both Staff and Applicant are prepared to stipulate and \ W ns two contentions, #2 and #4 to which only Applicant is prepare to stipulate. 8 mz g[>

Qg@ II. Accordingly, I request the Board to notice and admit thpq/ c 7 r"o 4 0 "'

rao oo following changes in CMEC's: filings:

i 23 a. CMEC withdraws its filing of February 1,1982. I w ,3 7982b oji m b. CMEC adds e final paragraph to its first contention as $( (. g LEp# m 06 in (I.b) above. '

h

c. CMEC enters a separate filing, 'CMEC's Contention #3 revis n

Ox which I include with this filing.

Q@o Enspectfi l: s bmitted, 6

f)$O Februay 2g 1982 M33@

A$_ 60/