ML20041F065
| ML20041F065 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/10/1982 |
| From: | Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8203160154 | |
| Download: ML20041F065 (3) | |
Text
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March 10, 1982
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 82 Wo 12 P1:14 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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Docket Nos. 50-400 OL AND NORTH CAROLINA MUNICIPAL
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50-401 OL POWER AGENCY NO. 3
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(Shearon Harris Nuclear Power
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Plant, Units 1 and 2)
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APPLICANTS' RESPONSE TO PETITION TO INTERVENE BY RICHARD D. WILSON On January 27, 1982, notice was published in the Federal
,e Register concerning the application of Carolina Power & Light' Company and North Carolina Municipal Power Agency No. 3 (Applicants) for licenses to operate the Shearon Harris Nuclear Power Plant, Units 1 and 2.
The notice afforded interested persons an opportunity to request a hearing and to petition for leave to intervene.
On February 25, 1982, a petition to intervene was filed 6-by Richard D. Wilson (Petitioner).
Petitioner bases his interest on his' residence, employment and agrarian activities in the town of Apex, N.C.,
a distance of approximately 7 miles from the Harris Plant.
He asserts among other things that his interest would be affected by the possibility of nuclear accidents and by small radiation or algicide releases from the Plant.
The specific aspects of the proceeding as to which Petitioner wishe vene P
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include safe operation of the Plant and the impact of Plant operations on his small orchard.
To this extent Petitioner has in Applicants' view sufficiently stated an interest in the proceeding to meet the initial requirements for intervention under Section 2.714 of the Commission's Rules of Practice.
Petitioner has alleged other interests and effects upon those interests, some of which in Applicants' view are not cognizable in an NRC operating license proceeding.
Applicants propose, however, to await the formulation of Petitioners' contentions pursuant to Section 2.714(b) and to address at that time the allowability of the contentions, including their relationship to an interest cognizable in the proceeding.
, Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE L A. R George F. Trowbridge, P.C.
Thomas A. Baxter, P.C.
I John H. O'Neill, Jr.
Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
March 10,1982
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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Docket Nos. 50-400 OL AND NORTH CAROLINA MUNICIPAL
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50-401 OL POWER AGENCY NO. 3
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(Shearon Harris Nuclear Power
)
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Plant, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Petition to Intervene by Richard D. Wilson," dated March 10, 1982, were served upon the following persons by deposit in the United States mail, postage prepaid, this 10th day of March, 1982.
James L.
Kelley, Esq., Chairman Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C.
20555 Docketing and Service Section (3)
Mr. Glenn O. Bright Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Board
' r. James H. Carpenter Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Appeal Charles A.
Barth, Esq.
Board Panel Stuart A. Treby, Esq.
U.S. Nuclear Regulatory Commission 20555 Washington,D.C.f Marjorie Rothschild, Esq.
Office of Executive Legal Director U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 i
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-x John
. O'Neill, Jr.
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