ML20084M663

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Motion for Extension of Time to File Motions for Summary Disposition of Eddleman 11 (Qualification of Polyethylene Cable insulation),45 (Water Hammer) & 116 (Fire Protection) by 840525.W/Certificate of Svc.Related Correspondence
ML20084M663
Person / Time
Site: Harris  
Issue date: 05/14/1984
From: Baxter T
CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
References
OL, NUDOCS 8405150481
Download: ML20084M663 (5)


Text

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o l68 RELAT ED CORRESPONDENCE 00CKETE0 May 14, 1984

'84 HMf 15 r1:05 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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DEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN

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50-401 OL MUNICIPAL POWER AGENCY

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)

(Shearon Harris Nuclear Power

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Plant, Units 1 and 2)

)

APPLICANTS' MOTION FOR EXTENSION OF I,

TIME TO FILE MOTIONS FOR

SUMMARY

DISPOSITION OF EDDLEMAN 11, 45 AND 116 In its Memorandum and Order (Reflecting Decisions Made Following Second Prehearing Conference) at 7 (March 10, 1983),

the Board set May 16, 1984 as the last day for filing motions for summary disposition of safety contentions.

Applicants hereby move for an extension of time to file motions for summa-ry disposition of Eddleman 11 (qualificqtion of polyethylene cable insulation), 45 (water hammer) and 116 (fire protection) on or before May 25, 1984.

The basis for the requested extension is the assessment by Applicants and Mr. Eddleman that substantial progress was being t

achieved in their efforts to settle these three contentions.

These efforts, initiated approximately one month ago, have in-cluded meetings between Mr. Eddleman and Applicants' counsel 8405150481 840514 PDR ADOCK 05000400 0

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o and experts, and the exchange of substantive information on an informal basis.

Applicants and Mr. Eddleman had hoped to con-clude these discussions on a schedule which would avoid the po-tentially wasteful effort of preparing, and filing responses to, summary dispositon motions.

While the discussions have not yet concluded, Applicants find it prudent at this point to resume preparation of summary disposition motions.

Because these settlement efforts somewhat extended and diverted motion preparation, however, a brief ex-tension is necessary.

Mr. Eddleman has no objection to the re-quested extension.

Counsel for the NRC Staff also agrees to the extension, provided that the Staff is given some additional i

time after the environmental hearing to file its responses.

It was agreed that the schedule for the Staff's responses would be discussed at the environmental hearing.

Respectfully submitted, Thomas A.

Baxter, P.C.

SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Str,eet, N.W.

Washington, D.C.

20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants DATED:

MAY 14, 1984 t

May 14, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN

)

50-401 OL MUNICIPAL POWER AGENCY

)

)

(Shearon Harris Nuclear Power

)

Plant, Units 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion for Extension of Time to File Motions for Summary Disposition of Eddleman 11, 45 and 116" were served this 14th day of May, 1984, by hand delivery to the parties identified with one as-terisk and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.

Thomas A.

Baxter, P.C.

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o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

CAROLINA POWER & LIGHT COMPANY

)

Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN

)

50-401 OL MUNICIPAL POWER AGENCY

)

)

(Shearon Harris Nuclear Power

)

Plant, Units 1 and 2)

)

SERVICE LIST

  • Janes L. Kelley, Esquire John D. Rtmkle, Esquire Atmic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Comission 307 Granville Road Washington, D.C.

20555 Chapel Hill, North Carolina 27$14

  • Mr. Glenn O. Bright M. Travis Payne, Esquire Atmic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Comission P.O. Box 12607 Washington, D.C.

20555 Raleigh, North Carolina 27605 I

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  • Dr. James H. Carpenter Dr. Richard D. Wilson

'l Atatic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory C h asion Apex, North Carolina 27502 Washington, D.C.

20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, Esquire Durham, North Carolina 27705 Office of Executive Imgal Director U.S. Nuclear Regulatory Cmmission Richard E. Jones, Esquire Washington, D.C.

20555 Vice President and Senior Counsel Carolina Power & Light Cmpany i

Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Ca mission Washington, D.C.

20555 Dr. Linda W. Little Governor's Waste Managenent Board Mr. Daniel F. Read, President 513 Alhanarle Building GANGE/EIP 325 North Salisbury Street 5707 Waycross Street Raleigh, North Carolina 27611 Raleigh, North Carolina 27606 i

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l Bradley W. Jones, Esquire l

U.S. Nuclear Regulatory Ccmnission l

Region II 101 Marrietta Street l

Atlanta, Georgia 30303 i

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  • Steven F. Crockett, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Regulatory Ccmnission Washington, D.C.

20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 dv e

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