ML20041E409

Response to Charlotte-Mecklenburg Environ Coalition 820222 Request for Conference W/Applicant.Applicants Will Not Respond to Request Since Request Is Discovery Request in Fact & No Discovery Schedule Has Been Set

ML20041E409
Person / Time
Site:	Catawba
Issue date:	03/04/1982
From:	Carr A DUKE POWER CO.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8203100483
Download: ML20041E409 (4)

Text

.

ta

~>

1 xxETEr- -

UNITED STATES OF AMERICA UDP NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'82 WA -8 P m ..... W 0 C Z."g'y In the Matter of )

)

-[v .:. .

DUKE POWER COMPANY, et al. ) Docket Nos. 50-413 c I n, -

(Catawba Nuclear Station.,

) -

50-414,@

Units 1 and 2)

) 9 /,'A g\

)

f _g 3 o . .

-1 D0 1932' APPLICANTS' RESPONSE TO CHARLOTTE-MECKLENBURG {'3, u -,

ENVIRONMENTAL COALITION'S ' REQUEST -^

FOR CONFERENCE WITH APPLICANT' (' 7; '"

N, ,a '

Duke Power Company, et al. , hereby responds to the'" Request [ . '

for Conference with Applicant" filed February 22, 1982 by the Charlotte-Mecklenburg Environmental Coalition (Coalition).

In its request, the Coalition requests a meeting with Applicants to discuss technical questions relating to its proposed contentions in this proceeding. Counsel for Applicants has today by letter (copy attached) informed the Coalition's representative that in Applicants' view this is in the nature .

ot a discovery request. As the Board has not yet set a discovery schedule, Applicants believe the Coalition's request

~

is premature, and thus Applicants will 'not respond at this tj , t.: .'; f ,

pyfa '

Respectfully submitted, ,s I

DUKE POWER COMPANY ff ,

', h r

Albert V. Carr, Jr. *

~

O. Box 33189 1

P. '

Charlotte, North Caro na 28242 ~ '

March 4, 1982 3 ~j

'Q -

)/

8203100483 820304 i PDR ADOCK 05000413 l G PDR - -

t

. b . .

i

. i Mr'. Chase R. Stephens .

Docketing and Service Section ,

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 J. Michael McGarry, III, Esq.

Debevoise & Liberman 1200 Seventeenth Street, N.W.

Washington, D. C. 20555 I

~

M Albert V. Carr,' r.

9 e

I

)

i i

l e

[ i, '

DUKE POWER GOMPANY '

LEGAL DEPARTMENT

. E O. Box 30189 GnAnLorrE, N. G. sanIn Atm e nt v. can n. .sn.

............. - -. 6 March 4, 1982 Mr. Henry A. Presler 943 Henley Place Charlotte, North Carolina 28207 Re: Catawba Nuclear Station, Units 1 & 2 Docket Nos. 50-413 & 50-414

Dear Mr. Presler:

I am in receipt of the letter dated February 8, 1982 from you, on behalf of the Charlotte-Mecklenburg Environmental Coali-tion, to Mr. W. S. Lee. You also filed on February 22, 1982, as the Coalition's representative, a pleading entitled " Request for Conference with Applicant" with the Licensing Board in this docket. (Copies of each are attached.)

It appears that the information sought in these two requests is in some respects identical, and in any event relates to the subject matter of the contentions advanced by the Coalition in '

this proceeding. As such, we believe that the requests encom-passed by your letter and your pleading can properly be viewed as discovery requests in this matter. Given the fact that the Licensing, Board has not yet ruled'on your. contentions (though' we of course recognize that Applicants have agreed with you that your contentions are admissible as issues in the proceeding) and has not yet set a schedule for discovery, your requests are premature.

If you have any questions, please do not hesitate to contact me..

Very truly y rs Albert V. Ca , Jr.

AVCJr/fhb Attachments

~

bharlotte-MecklenburgEnvironmentalCoalition  !

Audubon Society .. February 8, 1982 j Dick Brown, -

Mr. Bill Lee Owohne Action Duke Power Company Brenda h 500 South Church Stre'et Charlotte, R.C.

OnoEna Envuonmental Study Gmup E* ** N * ***

- Jesse Riley As perhaps you are aware, a number of Charlotte residents are concerned about the discharge of radionuclides into the Catawba David,on Energy Gmup River from the McGuire plant inasmuch as mg Charlotte draws its drinking water from the Catawba. Perhaps some of our alarm sprin5s qg ,yg, from a, lack of precise knowledge about the ggg mechanics of these releases e.5. how often will radionuclides be released, what amounts safeEnerryAlhance are to be released,.how are these amounts Mike FM calculated and so on.-

'de wonder if there is a technically h Cub knowledgeable person on your staff with gm whom we could meet for a discussion of M* these questions. Given the rather technical nature of the problem, it might be best if we were to submit a written list of our

~ major questions to your staff member before -

the meeting.

(-

Thank you for your attention.

"neere yours, I I E

6

i Henry esler

% 945 Henley Place

!; Charlotte, H.C. 28207 r

E IL

't t

l i

it l'r- i l

\ t.

il >

r

• Charlotte, North Carolina 28207 943 Henley Place y ~

r .. . . . . . . ...... .

~ ~ . . ._ ._ -

UNITED STATES OF AMERICL BEFORE THE NUCLEAR REGULLTORT COMMISSION Charlotte-Mecklenburg "

Environmental Coalition, Petitioner, Docket Ros. 50-413 In the Matter of: M 14 l Duke Power Company, et al. 1 l

(Catawba Nuclear Station, Units 1 & 2),  !

Applicanta Request for Conference with Applicant '

CMEC requests a conference with Duke Power's technical staff to discuss technical questions relating to gaseous and liquid radioactive effluents

.from the Catawba and McGuire plants. PES and ER for these plants have raised questions in our minds which the documents de not seem to resolve.

Such a request may be considered odd in light of the adversary nature of Applicants' and-Petitioner's relations in these proceedings. On the other hand, our conversations to this date have been frank and cordial and I expect that a good deal of time could be saved by all parties by such a conference.

H spectfully submitted, 4

Henry A.\Presler, Chairman Charlotte-Mecklenburg Environmental Coalition 91+5 Henley Place, Charlotte, N.C. 28207 704-333-8389 -

February 22, 1982 cc: Service List e

j J 2 AMA -