ML20053D099

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Response Supporting Util 820518 Motion for Addl Time to Respond to Suppls to Intervention Petitions.Extension Should Be Granted to 820607.Prehearing Conference Should Be Held on 820628 or Later.Certificate of Svc Encl
ML20053D099
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 05/24/1982
From: Runkle J
CONSERVATION COUNCIL OF NORTH CAROLINA
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8206040079
Download: ML20053D099 (3)


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  • '.i */ L UNITED STATES OF AMERICA NUCLEAR RBGULATORY COD!ISSION.62 3 28 O 3 ATOMIC SAFETY AND LICENSING BOARD :.. _.

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In the matter of Docket Nos. 50-400 CAROLINA POWER & LIGHT, ET AL.

50-401 Shearon Harris Nuclear Power Plant May 24,1982 Units 1 and 2

. CONSERVATION COUNCIL'S RESPONSE TO APPLICANTS ' MOTION FOR EXTENSION OF TIME The Applicants' Motion for Extension of Time dated May 18, 1982, requested that the Applicant be allowed additional time to respond to the various Supplements to Intervene by the petitioners.

We agree that an extension for the Applicants' reaponse would be reasonable, and that June 7 would give them adequate time.

At that time, we would like to be served in person, leavin6 it to the Applicant and ourselves to come with

'come mutually agreeable method of service at that time.

It was however.our. understanding that the NRC Staff's response which,wto to be filed on June 7 would include not only the Staff's responce to the contentions filed by the petitioners

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but also would include the. Staff's response to the Applicants',

response.

We do not feel that the Licensing Board would fully j

i benefit from the' Staff'c response unless it also gave ample.

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.I consideration tc 'the Applicants' response.

Regardless of the Staff's apparent willingness to file an the same day as..the

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Applictat we feel khat as complete written responses are p/l i

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s ebsential to the Licensing Board's consideration of the supplemental 820f2040079 820524 i

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petitions, the Board should require the Staff to consider the Applicants' response before they file their own response.

However, if the Applicant is allowed an extension in which to file its response, the petitioners will not have adequate time in which to prepare for the special prehearing conference.

Instead of having from May 28 to June 14-15 to respond to the

' Applicants' recponse and from June 5 to June 14-15 to respond to the Staff's response, the petitioners wl:1 only have seven days to respond to both.

Thin will place a serious burden on the petitioners, many of which are volunteers and can only respond to and research during off-work hours.

I myself only work part-time for the Conservation Council and would be hard pressed to establish factual and legal arguments in response to the Applicants' response.

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As a result of the burdens placed on us by the reasonable E

extension of time requested by the Applicants, we move that the e

special prehearing conference be moved to June 28-29 or later, e

or that, at a minimum, the petitioners be allowed ample time after the prehearing conference in order to respond fully to both the Applicants and the Otaff before the Licensing Board issues its Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference).

Respectfully submitted, l

J6hn Runkle Executive Coordinator, Conservation Council of North Carolina 307 Granville Rd.

Chapel Hill, NC 27514 i

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. r m w.9; E2 FAY 28 CERTIFICATE OF SERVICE I hereby certify that copies of this response were served upon the following persons by deposit in the United. States.. mail p

this 24th day of May, 1982.

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George F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Streete N.W.

Washington, D.C.

20036 Docketing and Service Section Office of the Secretary US Nuclear Regulatory Commission

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Washington, D.C.

20555 Atomic Safety and Licensing 3oard Panel US Nuclear Regulatory Commission Washington, D.C.

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J5hn Runkle l

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