ML20054K466

Additions to Suppl to Petition to Intervene,Adopting W Eddleman Contentions & Correcting Previous Contentions Based on Applicant Responses to NRC Questions.Certificate of Svc Encl

ML20054K466
Person / Time
Site:	Harris
Issue date:	06/29/1982
From:	Runkle J CONSERVATION COUNCIL OF NORTH CAROLINA
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8207020228
Download: ML20054K466 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

, i, -\ 79 Q-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s '_M $

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3 In the matter of ) Docket Nos. 50-400

) 50-401 s.

CAROLINA POWER &. LIGHT, ET AL.  ?

(Shearon Harris Nuclear Power Plant, ) June 29, 1982 Units 1 and 2 )

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CONSERVATION COUNCIL OF HORTH CAROLINA (

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ADDITIONS TO SUPPLEMENT TO PETITION TO INTERVENE b

i Pursuant to 10 CFR 2 714(a)(3), Petitioner Conservation )

Council of North Carolina (Conservation Council) hereby files \4 Additions to its Supplement to Petition to Intervene, which l contains additional contentions which it seeks to have litigated in this matter, and the bases therefor, fully reserving its right to amend or expand this filing on the basis of informa-tion not now known to the Petitioner or for other good cause as provided by 10 CFR 2 714(a)(1).

The Conservation Council may amend its petition for leave to intervene without prior approval of the presiding officer at any time up to fifteen days prior to the holding of the first prehearing conference. Furthermore, as the additionc are f adoptions of specific contentions by Petitioner Eddleman, both the Applicant and the Staff have already responded to these, or similar contentions, and there should b'e no prejudice or surprise involved in the Conservation Council's adopting these l

contentions.

8207020228 820629 l l

l PDR ADOCK 05000400 C PDR

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. l Page 2 Should the Board construe any of these contentions as an attack upon any rule or regulation of the Commission, or any provision thereof, Petitioner requests that such rule or regulation be identified and that Petitioner be permitted to seek an excep-tion to or waiver of the application of such rule or regulation j with respect to this particular proceeding. It is the Petitioner's present intention to correct several of its previous contentions j in light of the responses from the Applicant and the Staff.

One such example is to correct Contention 2 (Cost-Benefit j Analysis) by complying with the procedural requirements of 10 CFR 2 758 to file a petition, accompanied by an affidavit, which makes a showing of special circumstances.

At this time the Conservation Council adopts the following ]

5 of Petitioner Eddleman's contentions (organized to facilitate f

discussion): l Power A 5ency: #58CII)., 66 l t

Need for power: #14-18, 20, 23A, 59, 60, 89, 90, 94, 95, 104 i l

Fuel transfer: #25, 27, 28, 64, 68, 69, 124 Security: #24, 26, 35, 52, 54(II), 55, 133 1

Design: #10, 11, 40, 45, 46, 50, 65, 77, 116 Emergency plan: #30, 32, 56, 57, 81, 97, 99, 117, 118, -

l 124, 137, 139, 140 TMI lessons learned: #73, 76, 87 I

l Monitoring: #1, 2, 13, 82, 91, 102 Management: #3(a), (d)-(f)., (i); 4, 44, 101, 123 The Conservation Council in reviewing each of the above conten-tions urgesthe Board to admit them as each is supported with i

Page 3 sufficient basis to give the other parties adequate notice of q the issues for litigation. The selection of these contentions over any of the others submitted by Petitioner Eddleman does not in any way reflect judgment on the Conservation Council's part that the others should not be admitted, but rather that j the contentions adopted herein need to be litigated, the Conservation Council desires to liti ate5 them, and our expertise in these areas will assist the Board in making its 'a decision on the suitability of Applicants' license.

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V John Runkle Executive Coordinator June 29, 1982 Conservation Council of North Carolina 307 Granville Rd.

Chapel Hill, NC 27514 for the Conservation Council of North Carolina l

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CERTIFICATE OF SERVICE I hereby certify that copies of this motion were served

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upon the following persons by deposit in the United Shatds LE!:23 ,

mail, postage prepaid, this 29th day of June, 1982. j,gggre .

George F. Trowbridge, Esq. Y n;.ntfii; Shaw, Pittman, Potts & Trowbridge SACn '

1800 M Street, NW Washington, D.C. 20036 Docket and Service Section Office of the Secretary US Nuclear Regulatory Commission '

Washington, D.C. 20555 Atomic Safety and Licensing Board Panel US Huclear Regulatory Commission Washington, D.C. 20555 Attention: James L. Kelley, Esq.

same Attention: Glenn O. Bright, Esq.

same Attention: Dr. James H. Carpenter Copies of this motion will be hand-delivered to the following persons at the meeting among the Applicants, the NRC Staff, and Petitioners on June 30, 1982:

Samantha Francis Flynn Associate General Counsel, CP&L NRC staff attending Wells Eddleman, Petitioner George Jackson, ELP, Petitioner Travis Payne, Esq., Petitioner Daniel F. Read, CHANGE, Petitioner Patricia T. and Slater E. Newman, Citizens Against Nuclear Power, Richard D. Wilson, M.D., Petitioner Petitioners Dr. Phyllis Lotchin, Petitioner I herby certify that copies will be sent by deposit in the United States mail, postage paid, on June 30, 1982, to any of the above persons not attending the meccing.