ML20041C345

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Point of Information Notifying All Parties That Any Attempt by Applicant to Salvage Findings Produced by Incomplete Info,Studies & Misleading Pressure & Haste Should Be Rejected.Certificate of Svc Encl
ML20041C345
Person / Time
Site: Perkins  Duke Energy icon.png
Issue date: 02/19/1982
From: Pfefferkorn W
DAVIS, M.A., PFEFFERKORN & COOLEY, P.A., YADKIN RIVER COMMITTEE
To:
References
NUDOCS 8203010192
Download: ML20041C345 (4)


Text

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a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'82 nm D-E!i TS BEFORE THE ATOMIC SAFETY AND LIpENSING BOARD In the Matter of

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Docket Nos. STN 50-488 [

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STN 50-48?>

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(Perkins Nuclear Station

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Units 1,

2 and 3

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POINT OF INFORMATION U L[']$!.Nga rc.c NOW COME the Intervenors through counsel and poin hD d'

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out that they appreciate the opportunity which their counsel had to be present at the meeting of Duke Power attorneys and officials with some of the technical staff of the Nuclear Regulatory Commission but object and are deeply concerned that counsel was not allowed to speak during the formal portions of the meeting, and was not allowed to attend the meeting between Duke Power attorneys and the attorneys for the staff of the Nuclear Regulatory Commission.

Intervenors have been threatened for eight years with the clear and present threat of a nuclear plant.

They were told when they argued that it was a unreat to the water and financial resources, environment and public sa fety, that they were inaccurate and misinformed.

They were told that they should not have any postponements that they requested in that the applicant had to get on with censtruction.

In spite of the fact that these now discredited arguments by applicant were vital positions in those proceedings it is now being suggested:

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(1)

Not that applicant should withdraw with gpG Y#f prejudice.

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PDR ADOCK 05000489 O

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Not that applicant should withdraw without prejudice, but (3)

That applicant should be allowed to withdraw with prejudice to the Intervenors.

This point of information is to notify all interested parties that any attempt by applicant to salvage findings pro-duced by incomplete information and studies and misleading pressure and haste should be rejected.

As pointed out by counsel, after the conclusion of the formal meeting, the most vital information in regard to the impact of the McGuire Plant on Lake Norman can now be ascertained before a final and proper conclusion is reached on the question of alternative sites.

Also, a hearing which was previously scheduled by the Environmental Management Commission Commission of North Carolina in regard to its previous resolu-tion 76-41 can be carried out without the misleading and false creation of urgency which existed in 1976.

In due time, i

Intervenors will respond to applicants actual position in these proceedings.

This the 1901 day of Feb ary, 1982.

t er WILLIAM G. PFEFFERKORN, Attor(eyFfjc Intervenors 202 West Third Street, Post Office Box 43 Winston-Salem, North Carolina 27102 Telephone:

(919) 725-0251 2-l l

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CERTIFICATE OF SERVICE I hereby certify that copics of Point of Information

'd2 FER 25 rd1 :08 in the above-captioned matter have been served on:the J

following by deposit in the United States Mail this the.

22nd day of February, 1982.

Elizabeth S.

Bowers, Esq.

Charles A. Barth, Esq.

Chairman, Atomic Safety Counsel for NRC Regulatory Staff and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatcry Washington, D.C.

20555 Commission Washington, D.C.

20555 Dr. Donald P. deSylva Associate Professor of William A..

Raney, Jr., Esq.

Marin-Science Special Deputy Attorney General Rosenstiel School of Marine State of North Carolina and Atmospheric Science-Department of Justice University of Miami Post Office Box 629 Miami, Florida 33149 Raleigh, North Carolina 27602

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Dr. Walter H.

Jordan William L.

Porter, Esq.

881 West Outer Drive Associate General Counsel Oak Ridge, Tennessee 37830 Duke Power Company Post Office Box 2178 Chairman, Atomic Safety Charlotte, North Carolina 28242 and Licensing Board Panel U.S. Nuclear Regulatory Mr. Chase R. Stephens Commission Docketing and Service Section Washington, D.C.

20555 Office'of the Secretary U.S. Nuclear Regulatory, Chairman, Atomic Safety Commission and Licensing Appeal Board Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Mr.

J. Michael McGarry, III Washington, D.C.

20555 Debevoise and Liberman 1200 Seventeenth Street, N.W.

Washingt D.C.

20036 f

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William G.

Pfefferk6'In ff j

I If Attorney for 16tervenors PFEFFERKORN & COOLEY, P.A.

3 Post Office Box 43 202 West Third Street Winston-Salem, N.C.

27101 Telephone:

(919) 725-0251

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C Alan S.

Rosenthal, Esq., Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Mrs. Mary Davis Route 4, Box 261 Mocksville, North Carolina 27028 C

Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 O

Mr. Thomas S. Moore Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 De

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