ML20126J898
| ML20126J898 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/06/1985 |
| From: | Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-334 OL, NUDOCS 8506100728 | |
| Download: ML20126J898 (5) | |
Text
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Juna 6, 1985 00CKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION TS JWi10. N0:36 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0FFICE 0r SEC"F.?APY 00C4F. Tit 4G /. sEPvni; ERANCH In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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'~~s and NORTH CAROLINA EASTERN
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Docket No. 50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power
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Plant)
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APPLICANTS' MOTION FOR EXTENSION OF TIME TO ANSWER CCNC MOTION TO STAY PROCEEDINGS ON CONTENTION WB-3 (DRUG USE)
On May 24, 1985, intervenor Conservation Council of North Carolina filed with the Board a " Motion to Stay Proceedings on Contention WB-3 (Drug Abuse)."
Pursuant to 10 C.F.R. 5 2.730(c), Applicants' response to this motion would be due on or before June 10, 1985.
Applicants hereby move for an exten-sion until June 14, 1985, of the time period for filing an answer to the CCNC motion.
The extension requested is necessary to enable Applicants' counsel to ascertain factual information which may be relevant to the CCNC motion.
The CCNC motion seeks a stay of " proceed-ings" on the drug abuse contention until the resolution of cer-tain criminal proceedings in North Carolina.
The undersigned, who is personally representing Applicants on this matter, had scheduled efforts to marshall the facts on the status of these
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cases, but has been unavoidably diverted to a nearly around-the-clock effort to answer emergency stay motions before a U.S. Court of Appeals involving another NRC proceeding.
Wh'ile efforts today to contact Mr. Runkle, counsel for CCNC, to discuss this motion have been unsuccessful, Applicants submit that CCNC could not be prejudiced by the four-day ex-tention.
Discovery on Contention WB-3 is complete, but there is no established schedule for further litigative events on this contention, so that a stay of impending deadlines for CCNC is not at issue.
In effect, there is nothing to be stayed for the moment.
(Applicants intend to address the schedule for ad-judication of this contention at the same time they answer the CCNC motion.)
Counsel for the NRC Staff has been consulted and has no objection to the grant of this motion.
Respectfully submitted,
% " a-t Thomas A.
- Baxter, P.C.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, W.W.
Washington, D.C.
20036 (202) 822-1090 Richard E. Jones Dale E.
Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated:
June 6, 1985 ~
W June 6, 1985 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 15 JW110 M0:36 BEFORE THE ATOMIC SAFETY AND LICENSING BO&RD;E O SECliETAF uuv.EithG & SLRVICi.
BRANCH In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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and NORTH CAROLINA EASTERN
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Docket No. 50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power
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Plant)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion for Extension of Time to Answer CCNC Motion to Stay Proceedings on Contention WB-3 (Drug Use)" were served this 6th day of June, 1985, by deposit in the U.S. mail, first class, postage pre-paid, to the parties on the attached Service List.
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Thomas A.
- Baxter, P.C.
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a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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l CAROLINA POWER s LIGHT COMPANY
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Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN
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i MUNICIPAL POWER AGENCY
)
~)
(Shearon Harris Nuclear Power
)
Plant)
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SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C.
20555 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission P.O. Box 12607 Washington, D.C.
20555 Raleigh, North Carolina 27605 l
Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C.
20555 Charles A. Barth, Esquire Mr. Wells Eddleman 4
Janice E. Moore, Esquire 718-A Iredell Street Office of Executive Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 i
Docketing and Service Section Richard E. Jones, Esquire f
Office of the Secretary Vice President and Senior Counsel U.S. Nuclear Regulatory Commission Carolina Power s Light. company Washington, D.C.
20555 P.O. Box 1551 l
Raleigh, North Carolina 27602 Mr. Daniel F. Read, President Dr. Linda W. Little CHANGE Governor's Waste Management Board P.O. Box 2151 513 Albemarle Building Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carclina 27611 o
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Bradley W. Jones, Esqlire
'U.S.
Nuclear Regulatory Commission
-Region II 101'Marrietta Street s.
Atlanta, Georgia 30303 1
Mr.. Robert P. Gruber Executive Director Public Staff - NCUC
. P., O. Box 991~
.Raleigh, North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota Minneapolis, Minnesota 55455 i ~