ML20073G421
| ML20073G421 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/12/1983 |
| From: | Newman P, Newman S CITIZENS AGAINST NUCLEAR POWER |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8304180281 | |
| Download: ML20073G421 (3) | |
Text
REIATED CODRESPOVnENr p r
April 12, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
, ;a. n -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD D [@R 15 In the Matter of A;g:43 CAROLINA POWER & LIGHT COMPANY
)
AND NORTH CAROLINA EASTERN
)
EC MUNICIPAL POWER AGENCY
)
-11/95'
)
Docket Nos. 50-400' OL (Shearon Harris Nuclear Power
)
50-401 OL Plant. Units 1 and 2)
)
COMMENTS BY CITIZENS AGAINST NUCLEAR POWER (CANP) REGARDING APPLICANTS' INTERROGATORIES (FIRST SET) AND REQUEST FOR PRODUCTION OF DOCUMENTS Citizens Against Nuclear Power (CANP) herewith acknowledges its failure to date to make a timely filing of responses to Applicants' first set of interrogatories and request for production of documents of March 9,1983. CANP wishes to make the following comments in explanation of this circumstance:
CANP finds that it lacks the resources to stay afloat in the wake of the tidal waves of paper generated in tF ;2 proceeding.
More specifically, CANP members' employment obligations sev.cely limit the time they can devote to this proceeding and CANP members lack the financial resources to hire the clerical and technical support which would be required to keep adequate pace with the paper output of Applicants' large stable of legal talent. CANP finds Applicants' blunderbuss interrogatories to be overwhelming, but perhaps not only in the way Applicant intended. We find them to be overwhelming evidence of the injustice worked upon us by the great disparity of resources between CANP and Applicants.
In response to broadly exhaustive interrogatories from CANP, Applicants need only--and could easily--throw a few more person-hours into the fray.
But CANP, facing a similar challenge from Applicants, cannot even begin to mount a reply in the short time allowed, and is effectively prevented from pressing its case.
As a citizens group we note the tragic irony of our circumstance:
on the l
one hand, our standing before the Board in this proceeding represents an admirable admission of our input to a regulartory process substantially affecting our health and welfare; on the other hand, the real context of our participation is such.as co actually deny us the rights we appear to be granted.
In the face of Applicants' overwhelmingly superior resources, a citizens' group such as CANP cannot hope to press its case before the Board without the help of full-time, professional support services; such professional support is entirely beyond the financial capacity of CANP, as it would be of most similarly circumstanced citizen groups.
8304180281 830412 PDR ADOCK 05000400 0
PDR Q
b
1 9
Page 2 As citizen intervenors, then, we find ourselves facing the possibility that the fate of our contentions will rest not on their substantive aerits, duly adjudicated, but on the entirely irrelevant accident of CANP's financial resources. The prospect deeply disturbs us.
We trust that it disturbs the Board. We hope that it disturbs the Applicants.
We address the following question to the Board:
In the light of the foregoing, what are CANP's options in this proceeding?
Sincerely, 7
j MS f a bd@tb Patricia T. Newman Co-coordinator, Citizens Against Nuclear Power 2309 Weymouth Court Raleigh, North Carolina 27612 a'WfW Slater E. Newman Co-coordinator, Citizens Against Nuclear Power 2309 Weymouth Court Raleigh, North Carolina 27612 s
e
i i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r-s, In the matter of CAROLINA POWER & LIGHT CO. et al.)
Dockets50-40d Shearon Harris Nuclear Power Plant, Units 1 and 2 )
and 50-401 0.L.
CERTIFICATE OF SERVICE APO 13 A10:48 I hereby certify that copies of Comments by Citizens Against Nuclear Power (CANP) 1
.y.-c fo'rhtbkuctionof 4
Regarding Applicants' Interrocatories (First Set) and Recuest Documents HAVE been served this 13th day of April, 1983, by deposit in the U.S.
Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was accomplished by Judge James Kelly Phyllis Lotchin, Ph.D.
Atomic Safety and Licensing Board 108 Bridle Run US Nuclear Regulatory Commission Chapel Hill, NC 27514 Washington, DC 20555 i
l Dan Read George F. Trowbridge (attorney for CHANGE /ELP Applicants)
Box 524 Shaw, Pittman, Potts, & Trowbridge Chapel Hill, NC 27514 1800 M. St. NW Washington, DC 20036 Richard D. Wilson, M.D.
729 Hunter St.
Office of the Executive Legal Director Apex, NC 27502 Attn: Dockets 50-400/401 0.L.
USNRC Ruthanne G. Miller, Esq.
Washington, JC 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Docketing and service Station Deborah Greenblatt, Esq.
Attn: Dockets 50-400/401 0.L.
1634 Crest Rd.
USNRC Raleigh, NC 27606 Washington, DC 20555 John Run kle Bradley W. Jones, Esq.
CCNC
.S.
Nuclear Regul' tory Commission Reg.
101 Marrietta St.
307 Granville Rd.
Chapel Hill, NC 27514 Atlanta, GA 30303 Travis Payne Karen E. Long, Esq.
Edelstein & Payne Staff Attorney, Public Staff-NCUC P.O. Box 991 Box 12643 Raleigh, NC 27605 Raleigh, NC 27602 Wells Eddleman 781-A Iredell St.
Durham, NC 27705 Certified by Mil./'/ 6-
/,
} Ell /7th
--~~
& gLL. E.
W
- - - -