ML20053D140
| ML20053D140 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/24/1982 |
| From: | Runkle J CONSERVATION COUNCIL OF NORTH CAROLINA |
| To: | Carpenter J Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8206040118 | |
| Download: ML20053D140 (1) | |
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'e2 ' W 28 A10:25 THE CONSERVATION COUNCIL OF NORTH CAROLINA c.7-307 Granville Road, Chapel Hill, N.C. 27514 ICt'35IC
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May 24, agg[0 MAy 281982 To:
James H. Carpenter, Administrative Judge Atomic Safety and Licensing Board From:
John Runkle, Executive Coordinator Conservation Council of North Carolina Re Response to Memorandum dated May 14, 1982 We agree that it is unlikely that your prior relationship with Carolina Power and Light Company should interfere with your judgment in the Shearon Harris Nuclear Power Plant OL proceeding (Docket Nos. 50-400 and 50-401).
However we would like to reserve our right to question your participation if something unexpected arises.
Thank you for your disclosure.
cc. George F. Trowbridge, Esq.
Docketing and Service Section, NRC Atomic Safety and Licensing Board Panel, NRC
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0:01ISSION ATOMIC SAFETY AND LICENSING BOARD In.the matter of
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Docket Nos. 50-400 CAROLINA POWER & LIGHT, ET AL.
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50-401
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Shearon Harris Nuclear Power Plant
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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' response would be reasonable, and that June 7 would give them adequate time.
At that time, we would like to be served in person, leaving it to the Applicant and ourselves to come with l
l some mutually agreeable method of service at that time.
It was however our understanding that the N C Staff's response which was to be filed on June 7 would iuclude not only j
the Staff's response to the contentions filed by the petitioners g
but also would include the Staff's response to the: Applicants' response.
We do not feel that the Licensing Board would fully benefit from the Staff's response unless it also gave ample consideration to the Applicants' response.
Regardless of the Staff's apparent willingness to file on the same day as the Applicant, we feel that as complete written responses are essential to the Licensing Board's consideration of the supplemental A(E-fC66o 407f
. petitions, the Board should require the Staff to consider the A pplicants ' 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 tht special prehearing conference.
Instead of having from May 28 to June 14-15 to respond to the Applicants' response and from June 5 to June 14-15 to respond to the Staff's response, the petitioners will only have seven days to respond to both.
This 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.
As a result of the burdens placed on us by the reasonable extension of time requested by the Applicants, we move that the special prehearing conference be moved to June 28-29 or later, 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 Staff before the Licensing Board issues its Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference).
Respectfully submitted, J6hn Runkle Executive Coordinator, Conservation Council of North Carolina 307 Granville Rd.
Chapel Hill, NC 27514
f 7sW CERTIFICATE OF SERVICE I hereby certify that copies of this response were served upon the following persons by deposit in the United States mail this 24th day of May, 1982.
George F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Docketing and Service Section Office of the Secretary US Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel US Nuclear Regulatory Commission Washington, D.C.
20555 n
John Runkle i
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