ML20081K009

Response to Applicant & NRC 830929 Responses to Joint Intervenors 830906 Contentions Re Security Plan.Encl Withheld (Ref 10CFR73.21).Certificate of Svc Encl

ML20081K009
Person / Time
Site:	Harris
Issue date:	11/04/1983
From:	Runkle J JOINT INTERVENORS - SHEARON HARRIS, RUNKLE, J.D.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8311090231
Download: ML20081K009 (3)

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00CKETED November 4, 1983 usNac

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 13 IG -7 21:06 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GFFl0E OF SELRE?;.e' In the Matter of 00CKETmG & SEP'/i' -

) BRANCH

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NC EASTERN MUNICIPAL POWER ) 50-401 OL AGENCY )

)

(Shearon Harris, Units 1 & 2) )

INTERVENOR RESPONSE TO APPLICANT AND NRC STAFF RESPONSE TO INTERVENOR SECURITY CONTENTIONS After review by Intervenor Counsel and Security experts of the Security Plan, Intervenors filed " Contentions Arising From Review of Applicants' Security Plan" on September 6, 1983, vi.th the Board.

Both Applicants and Staff responded with filings on September 29, 1983. After conferring with NRC Staff attorney, Charles A. Barth, clerk to the Board, Ruthanne Miller, and Applicants' Counsel, Hill Carrow, Intervenors requested permission of the Board to respond in writing to the responses by the Staff and Applicants. A written response was requesteo rather than require an in person prehearing conference on the proffered contentions as scheduled in the Memorandum and Order, dated March 10, 1983. A telephone conference was precluded by the nece::sity of bringing Safeguards Information into any discussion among the parties.

On October 21, 1983, Ruthanne Miller informed Intervenors that Judge Kelley had orally granted Intervenors leave to respond by November 4, 1983, and at the same time, cut off further response by

$3i g gi o0 00 PDR YirEL $Erri!IO iC EUCLOSUEEb' c HANDLE THIS DOCUMENT AS DECONTROLLEO.

Applicants on Staff. It is our belief that the Board will have -

enough before them to determine whether to admit any of the proffered contentions. We will attempt to limit our response to those points #

raised by the Staff and Applicants in their responses to the contentions.

Attachment I contains material that is classified as " SAFEGUARDS INFORMATION" and is clearly marked as such. Attachment I should be protected under 10CFR73.21. The limited service list clearly delineates who have received Attachment I.

Respectfully bmitted n Ru , J. D.

ounsel for Intervenors (Security Plan)

Dated this 4th Day of November, 1983 Attachment - Refer to Service List l

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DOCKETED CERTIFICATE OF SERVICE USNPC 13 IDf-7 All:06 I hereby certify that copies of this filing were served in accordance to 0FFICE OF SEust:A,.

the Board's Protective Order to the following Modified Servicp0Gf4g 5f610pt Contentions) on this 4th day of November, 1983, by deposit in the United States mail, first class postage prepaid, or by hand-delivery, to the following:

James L. Kelley* Richard E. Jones

• Atomic Safety and Licensing Board Vice President and Senior Counsel US Nuclear Regulatory Commission Carolina Power & Light Company Washington, D.C. 20555 PO Box 1551 Raleigh, NC 27602 Glenn 0. Bright Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James H. Carpenter Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary US Nuclear Regulatory Commission Washington, D.C. 20555 Charles A. Barth* i

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Myron Karman dahn D. Runkle Office of Executive Legal Director Attorney-at-Law US Nuclear Regulatory Commission Counsel for Intervenors Washington, D.C. 20555 (Security Contentions)

Ruthanne G. Miller Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter John H. O'Neill, Jr.

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

Washington, D.C. 20036

? Including Attachment I containing SAFEGUARDS INFORMATION.

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