ML20082D692

Motion for Extension of Time Until 15 Days After Close of Hearing on Environ Contentions & Protective Order Re Applicant Fourth & Fifth Sets of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20082D692
Person / Time
Site:	Harris
Issue date:	11/16/1983
From:	Payne M EDELSTEIN & PAYNE, KUDZU ALLIANCE
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8311220508
Download: ML20082D692 (4)

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-l# y DOCKETED USNEC November 16, 1983

'83 NOV 21 Pl2:39 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ogy;g 3 g 00CWdi;M & SEgyn:t BRM:CH .

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER AND LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 JL

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

JOINT INTERVENORS' MOTION FOR AN EXTENSION OF TIME AND PROTECTIVE ORDER WITH REGARD TO APPLICANTS' FOURTH AND FIFTH SET OF INTERROGATORIES JOINT INTERVENORS request, pursuant to 10 C.F.R. Section

2. 740 ( c) , that a protective order enter with regard to Applicants '

Fourth and Fifth Sets of Interrogatories to Joint Intervenors ,

directing that Joint Intervenors not be required to respond to these interrogatories until 15 days af ter the close of the hearing on environmental contentions. In support of this Motion,-Joint

-Intervenors show the Board the following:

1. Applicants' Fourth Set of Interrogatories to Joint Intervenors cor.cern Joint Contentions IV and V.

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2. Applicants'-Fifth Set of Interrogatories to Joint Intervenors concern Joint Contention VI.

3: Applicants and Joint Intervenors all agree that Joint Contentions IV, V, and VI are safety contentions not environmental contentions.

4. Joint Contentions IV,V, and VI are scheduled to be addressed in " Phase II" of the hearing on safety contentions which is now set for.0ctober, 1984.

5. LGiven the press of responding to Applicants' discovery requests and motions on individual contentions, Joint Intervenors would be unduly burdened by having to respond to ' Applicants ' Fourth and Fifth Sets of Interrogatories at this time.

6. The undersigned counsel for Kudzu Alliance was contacted by Mr. O'Neill, counsel for Applicants , regarding Joint Intervenors' response to these interrogatories. The parties were unable to reach an agreement concerning an extension of time.

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7. . Applicants will suffer no prejudice by delaying Joint Intervenors' response to the Fourth and Fifth Sets of Interrogatories until after the close of the hearing on environmental contentions.

l WHEREFORE Joint Intervenors respectfully request that an order enter directing that they have until and including the 15th day after the close of the hearing on environmental contentions in which to respond to Applicants ' Fourth and Fifth Sets of Interrogatories.

l This the /[ day of November, 1983.

Edelstein, Payne and Jordan Attorneys for Kudzu Alliance by ,_ n:u ng M. Travis Payne i

723 W. Johnson St.

P.O. Box 12607 Raleigh, NC 27605 4 - -- -

I hereby certify that copies of this document were served this j day of //, M ,,a _

GOLKETED

, 1983, by deposit in the d$f 6 d States Mail, first

- class, postage prepaid to the folgg:21 PI2:39 James L. Kelley, Esquire Richard E. Jones, Es uire Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission "Vice CP&L Presigg,3%q),i1. Counsel Washington, D.C. 20555 SRANCH P.O. Box 1551 Mr. Glenn O. Bright Raleigh, NC 27602 same address as above Dr. Phyllis Lotchin Dr. James H. Carpenter 108 Bridle Run same address as above Chapel Hill, NC 27514 Charles A. Barth, Esquire Dr. Linda Little Myron Karman,. Esquire Governor's Waste Management Off' ,e of Executive Legal Director Board U.S. Nuclear Regulatory Commission 513 Albemarle Building Washington, D.C. 20555 325 North Salisbury Su. ,

Raleigh, NC 27611 l Docketing and Service Section i Office of the Secretary Bradley W. Jones, Esquire .

.U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory -:

Washington, D.C. 20555 Connission  !

Region II 101 Marrietta Street Mr. Daniel F. Read, President Atlanta, GA i:

Chapel Hill Anti-Nuclear Group Effort 30303 i P.O. Box 524' i Chapel Hill, NC 27514 Ruthanne G. Miller, Esquire !i Atomic Safety and Licensing l John D. Runkle, Esquire Board Panel E Conservation Council of N.C. U.S. Nuclear Regulatory i 307 Granville Road Commission 5 Chapel Hill, NC 27514 Warhington, D.C. 20555 i~

i

. Dr. Richard D. Wilson Robert B. Gruber s 729 Hunter Street Public Staff - NCUC "

Apex, NC 27503 P.O. Box 991 it Raleigh, NC 27602- Er Mr. Wells Eddleman is 718-A Iredell St. Atomic Safety and Licensing

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Durham, NC 27705 Board Panel - -

U.S. Nuclear Regulatory [

-Thomas A. Baxter, Esquire C ss Cearge Tros; bridge, Esq. -

Wash ,

C 20555 i-John O'Neill, Esq.

Shaw. Pitta.in, Potts and Trowbridge t=.

1800 H Street, NW  :

Washington, DC 20036 a

bm M. Trav2.s Payne iW f,/

Attorney for Kudzu Alliance ..