ML20079M107

Motion for Extension to Respond to Applicant First Set of Interrogatories & Request for Production of Documents,Until 15 Days After Formal Ruling on Proposed Discovery Schedule. W/Certificate of Svc

ML20079M107
Person / Time
Site:	Harris
Issue date:	02/16/1983
From:	Eddleman W, Payne M, Read D, Runkle J CHAPEL HILL ANTI-NUCLEAR GROUP EFFORT, CONSERVATION COUNCIL OF NORTH CAROLINA, EDDLEMAN, W., EDELSTEIN & PAYNE, KUDZU ALLIANCE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20079M082	List: ML20079M077 ML20079M107
References
ISSUANCES-OL, NUDOCS 8302230579
Download: ML20079M107 (3)

Text

- - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _

. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 83 FEB 22 P2;:20 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

.a l'$.i! E:i In the Matter of ) .. at:0H

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY ) Docket No. 50-400 OL (Shearon Harris Nuclear Power 50-401 OL Plant, Units 1 and 2) )

MOTION OF CHANGE, CCNC, WELLS EDDLEMAN AND KUDZU ALLIANCE FOR EXTENSION OF TIME TO RESPOND TO APPLICANTS INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOINT INTERVENORS (FIRST SET)

The four Intervenors listed above respectfully request that they be granted an extension of time in which to respond to applicants' interrogatories and request for production of docu-ments regarding Joint Contentions IV, V, and VI. In support of this request, Intervenors show the Board the following:

1. Intervenors and Applicants have agreed that, with respect to the Joint Contentions , unified sets of discovery re-quests and responses to discovery requests would be filed jointly by the four Intervenors.

2. Although the Certificate of Service with regard to this discovery request indicates that it was mailed on January 31, 1983, none of the Intervenors received this document prior to February 8,1983, and some of the Intervenors received this document on or after February 12, 1983.

8302230579 830216 PDR ADOCK 05000400 0 PDR I

3. Intervenors have proposed to the Board that discovery be conducted sequentially according to a- specific s chedule to allow for the orderly development of the issues in this proceeding.

If the Board adopts that suggestion, discovery with regard to environmental issues would be appropriate at this time. As Applicants and Intervenors all agree, Joint Contentions IV, V, and VI raise safety issues not environmental issues. Therefore, under our proposed discovery schedule, discovery with respect to these three contentions would not be appropriate until some time later in this proceeding.

4. Simultaneously with the service of this discovery request with regard to Joint Contentions IV, V, and VI, Applicants served a substantial number of interrogatories and requests for documents on CHANGE, CCNC, and Wells Eddleman individually. Res-ponding to those requests for production, and at the same time preparing unified response to the discovery with regard to the Joint Contentions, presents an undue burden to Intervenors.

WHEREFORE CHANGE, CCNC, Wells Eddleman, and Kudzu Alliance respectfully request that the time in which they must respond to l

l Applicants' discovery request be extended up to and including i

15 days af ter a formal ruling on our proposed discovery s chedule.

l This the /ff*! d ay of February , 1983.

NY Daniel F'. Read YW ~ b, goohn D. Runkle W/>

l Chapel Hill Anti-Nuclear Conservation Council of N.C.

Group Effort 307 Granville Road P.O. Box 524 Chapel Hill, NC 27514 Chapel Hill, NC 27514 l

i W. Sa MD j Wells Edeleman ~?n67/o M. Travis Payne jfr 718-A Iredell St. Attorney for Kudzu Alliance Durh am , NC 27705 P.O. Box 12607 I

Raleigh, NC 27605 L

nr-CERTIFICATE OF SERVICE "

This is to certify that the foregoing document was tNSs FEB 22 P2:20 day served upon all parties by placing it in the United States o. ...

.M samci Mail, postage prepaid, addressed as follows: BRMi3 James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of N.C.

U.S. Nuclear Regulatory Commission 307 Granville Road Washington, D.C. 20555 Chapel Hill, NC 27514 Mr. Glen O. Bright Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, NC 27502 Washington, D.C. 20555 Mr. Wells Eddleman Dr. James H. Carpenter 718-A Iredell Street Atomic Safety and Licensing Board Durham, NC 27705 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Patricia T. Newman Mr. Slater E. Newman Charles A. Barth, Esquire Citizens Against Nuclear Power Myron Ka.rman, Esquire 2309 Weymouth Court Office of Executive Legal Director Raleigh, NC 27612 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard E. Jones , Esquire Vice President & Senior Counsel Docketing and Service Section Carolina Power & Light Co.

Office of the Secretary P.O. Box 1551 U.S. Nuclear Regulatory Commission Raleigh, NC 27602 Washington, D.C. 20555 Dr. Phyllis Lotchin Mr. Daniel F. Read, President 108 Bridle Run Chapel Hill Anti-Nuclear Group Effort Chapel Hill, NC 27514 P.O. Box 524 Chapel Hill, NC 27514 Thomas A. Baxter , Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 -

This the // day of - .p3 h % , 1983.

22 E<

M. Travis Payne i Va //

1

_ . _ _ _ _ _ _ _ _ _ _ _ _ _