ML20083P747

Motion to Require Svc of All Amends & Changes to Emergency Plan on Intervenor & Motion to Amend Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence

ML20083P747
Person / Time
Site:	Harris
Issue date:	04/16/1984
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404200142
Download: ML20083P747 (2)

Text

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loL5. I b@MNaNce g u tTEn nwc UNITED STATES OF AMERICA NUCLEAR REGULATOBY COMMISSIO54 APR Igtpp 3129.6,1984 J n:a musweite!h.

& SE6V BEFORE THE ATOMIC SAFETY AND LICENSING ~ BOA 1DCH Glenn O. Bright Dr. Janes H. Carpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unit 1) ) ASLBP No. 82-h68-01

) OL Motion to Require Service of All Amendments or Changes to Emergency Plan on Intervenor and Amend &ent to Emergency Planning Contentions Intervenor Wells Eddleman hereby moves the Board, to the extent Applicants have not already committed to do so, to require service of all amendments or changes to the Harris offsite emergency plan on intervenor. In support of this motion, I point out that the present plan is quite incomplete (e.g. as shown in the contentions filed April 12 by me); that it is an unreasonable burden to always be checking with various state and county offices for changes in the plan; and that the public right to know concerning such plan will be served by service of all such amendments on intervenor. In fairness I believe dgg that such amendments or changes should also be served on all other parties e n. ***

gg Under 10 CPR 2.714, it being 15 days until the prehearing to C8 conference, Wells Eddleman hereby amends his contentions by adding

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• d this preamble to the contention filing of April 12: Because the plan I

,4 is inconnlete, I request leave to amend or modify these contentions og

$a.o as new information becomes available; also I assume that for new information (e.g. changes to the plan) I have 30 days from the time the document is in my hand to file new or amended contentions based thereon.

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UNITED STATES oF AMERICA NUCLTAR REGULATORY CoHMISSIoN In the matter of CAROLIhA POWER k LIGHT CO. Et al. ) Docket 50-h00 Shearon Harris Nuclear Power Plant, Unit 1* )

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CERTIFICATEoFgVICQ yt.

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n mpel Macovery on I hereby certify that copies o A Disposition on1gAA:Edd enan WE Contention Notion to 6pe;cruinWB Mamri ca Response nr 1r pl& a Affidavits n mny re ?M Summary! M r rts, and amendment to Emergpncy PlanningA f HAVE been served this1C day of n PA i ContIN ~uti ns/ , %y deposit in 16 W the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are tarked with including an asterisk, for whom service was accomplished by copies of 4-12 filings, per oral order by Judge Kelley. Payne was served by hand.

JudEes Jays Kelley, Glenn Bright and Jav.as Carpenter (1 copy each)

Atenic Safety and Licensirp Board US Nuclear Regulatcry Comission Washington DC 20555 GeorEe F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2C55 5 l' office of the Executive Legal Director 111s Letchin, Ph.D.

Attn Docke ts 50-400/hol 0.L. *Ph$BridleRun 10 USNRC Chapel Hill NC 2751h Washington DC 2o555

• Dan Read

, Docketing and Service Section (3x) CEA?E /FLP i Attn Dockets 50-hoo/hol o.L. .

Raleigh, Fro 7NC waveross

office of the Secretary h760'6 a ngton DC 20555

• " " ' Li"d* "* Littl*

Governor's Waste Mgt. Bd.

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• John Runkle _

Ra e , C 11 Granville Rd ,

Chapel Hill Ne 2751L Bradley W. Jones

• Robert Gruber USNRC Region II

• • Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 3o3o3 Blox 12607 Box 991 Raleigh NC 276o5 Ra1.ish NC 27602

• Richard Wilson, M.D. Certified by h 729 Hunter St.

Apex NC 27502

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