ML20092N213
| ML20092N213 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/28/1984 |
| From: | Trowbridge G GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8407020540 | |
| Download: ML20092N213 (4) | |
Text
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- QMG DOCKETED USNRC June 28, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-q ;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-In the Matter of
)
)
)
Docket Nos. 50-424
)
50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' RESPONSE TO CPG'S SECOND AMENDMENT TO SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR A HEARING On June 13, 1984, Campaign for a Prosperous Georgia (CPG) filed its Second Amendment to Supplement to Petition for Leave
~
to Intervene and Request for Hearing.
Therein, CPG provided some additional information as a basis for CPG contentions 2, 3
and 11.
CPG's amendment is untimely.
10 C.F.R. 5 2.714(b).
CPG does not justify the late-filing, as is its responsibility under the Commission's Rules of practice. 10 C.F.R. 5 2.714(a)(1).
See also 10 C.F.R. S 2.732.
However, because CPG's amendment does not affect Applicants' previous response to the proposed contentions and therefore does not necessitate further response,l/ Applicants do not object to CPG's amendment l
1/
Applicants wish to remark, however, that in its amendment l
to CPG-3, CPG inaccurately characterizes the testimony of l
Georgia Power Company officials during its most recent Fuel Cost Recovery proceeding at the Georgia Public Ser-vice Commission.
No witness " acknowledged" that the Com-l (Continued next next page) 8407020540 840628 '
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in this instance.
But Applicants will object to future untime-ly amendments that fail to conform to the Rules of Practice.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE b/
/]da)
//
Gprge'g. TrowMidge, P.C David R. Lewis Counsel for Applicants Dated:
June 28, 1984 (Continued) pany's employees " attempted to override safety systems at Plant Hatch due to financial considerations," as CPG as-serts.
Instead, the testimony before the Georgia Public Service Commission was that the Company's employees were
" conscientious" and were " mindful" of maintaining plant availability.
s Juna 28, 1984 I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORS THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of
)
)
GEORGIA POWER COMPANY, --ET AL.
) Docket Nos. 50-424
)
50-425 (Vogtle Electric Generating Plant,)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I.hereby certify that copies of " Applicants' Response to CPG's Second Amendment to Supplement to Petition for Leave to Intervene and Request for a Hearing," dated June 28, 1984, were served upon the persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk by hand delivery, this 28th day of i
June, 1984.
I
\\
~..._dCe4-
' k 'N David R.
Lewis DATED:
June 28, 1984
[
UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION P
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
In the Matter of
)
)
)
Docket Nos. 50-424
)
50-425 i
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
SERVICE LIST
- Morton B. Margulies, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission i Washington, D.C.
20555 Washington, D.C.
20555
- Mr. Gustave A. Linenberger Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission '
Washington, D.C.
20555 Washington, D.C.
20555
- Dr. Oscar H. Paris Bernard M.
Bordenick, Esq.
Atomic Safety and Licensing Board Office of Executive Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Board Tim Johnson i
Panel Campaign for a Prosperous Georgia U.S. Nuclear Regulatory Commission 175 Trinity Avenue. S.W.
i Washington, D.C.
20555 Atlanta, GA 30303 i
Douglas C. Teper Carol A.
Stangler 1253 Lenox Circle 425 Euclid Terrace Atlanta, GA 30306 Atlanta, GA 30307 Jeanne Shorthouse Dan Feig 507 Atlanta Avenue 1130 Alta Avenue i
Atlanta, GA 30315 Atlanta, GA 30307 Laurie Fowler & Vicki Breman Legal Environmental Assistance Foundation 1102 Healey Building Atlanta, GA 30303 L
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