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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] Category:PLEADINGS
MONTHYEARML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20205A9201999-03-26026 March 1999 Motion for Approval of Protective Order.* Orange County,With Support of CP&L & Nrc,Requests Board Approval of Encl Protective Order.With Certificate of Svc ML20204E5341999-03-17017 March 1999 Orange County Second Motion for Extension of Time to File Proposed Protective Order.* Licensing Board Granted Motion to Extend Deadline for Filing Proposed Protective Order Until 990304.With Certificate of Svc ML20207L4041999-03-16016 March 1999 NRC Staff Answer to Orange County Motion to Relocate Prehearing Conference.* NRC Has No Objections to Relocating Prehearing Conference,Time or Place.With Certificate of Svc ML20204C9721999-03-15015 March 1999 Applicant Response to Bcoc Motion to Relocate Prehearing Conference.* Applicant Requests That Prehearing Conference Be Held in Hillsborough,Nc.Location Available to Hold Prehearing Conference on 990513.With Certificate of Svc ML20207K1391999-03-0909 March 1999 Orange County Motion to Relocate Prehearing Conference.* Requests Licensing Board Relocate Prehearing Conference Scheduled for 990511 to Site in Area of Shearon Harris Npp. with Certificate of Svc ML20127M4091992-10-0202 October 1992 CP&L Response to Appeal to NRC Commissioners of NRC Staff Denial of Nirs Petitions for Immediate Enforcement Action of 920721 & 0812.* Commission Should Affirm NRR Denial of Nirs Petitions.Certificate of Svc Encl ML20213A0091987-01-28028 January 1987 NRC Staff Response to Intervenor Application for Stay of ALAB-856.* Motion Should Be Denied Since Coalition for Alternatives to Shearon Harris Lacks Standing to File Motion & 10CFR2.788 Criteria Not Met.Certificate of Svc Encl ML20212R6431987-01-27027 January 1987 NRC Staff Motion for Extension of Time.* Motion for Extension Until 870128 to File Response to Intervenors Motion for Stay of ALAB-856.Certificate of Svc Encl ML20212R6861987-01-27027 January 1987 Licensees Answer to Conservation Council of North Carolina/ Eddleman Motion for Stay.* Motion Should Be Summarily Denied.Certificate of Svc Encl ML20209A7191987-01-27027 January 1987 NRC Staff Motion for Extension of Time.* One Day Extension of Time Until 870128 to File Response to Intervenors Motion for Stay of ALAB-856 Requested.Granted for ASLB on 870128.W/ Certificate of Svc ML20207N6051987-01-10010 January 1987 Conservation Council of North Carolina,Wells Eddleman,Pro Se & Coalition for Alternatives to Shearon Harris Motion to Stay Effectiveness of Licensing of Shearon Harris Nuclear Power Plant.* W/Certificate of Svc ML20207M0191987-01-0808 January 1987 Motion to Continue Commission decision-making Re Licensing of Shearon Harris Nuclear Power Plant.* Requests NRC Refrain from Issuing Full Power OL Until Criteria Assuring Safe Operation Met.Certificate of Svc Encl ML20214A5171986-11-17017 November 1986 Response Opposing State of Nc Atty General 861028 Motion Re Applicant Request for Exemption from Portion of 10CFR50, App E & Part IV.F.1.Certificate of Svc Encl ML20197C8511986-11-0303 November 1986 Response to Atty General of State of Nc 861028 Motion to Dismiss,As Moot,Util 860304 Request for Exemption from 10CFR50,App E Requirement for Full Participation Exercise 1 Yr Prior to Full Power License.W/Certificate of Svc ML20215M2281986-10-28028 October 1986 Motion for Inquiry Into Feasibility of Applicant 860304 Request for Exemption from Requirement That full-scale Emergency Preparedness Exercise Be Conducted within 1 Yr Prior to Issuance of Ol.Certificate of Svc Encl ML20215G7061986-10-17017 October 1986 Response Opposing W Eddleman & Coalition for Alternatives to Shearon Harris 861006 Brief Requesting Hearing on Util Request for Exemption from Performing full-scale Emergency Exercise,Per Commission 860912 Order.W/Certificate of Svc ML20215J6121986-10-17017 October 1986 W Eddlemen & Coalition for Alternatives to Shearon Harris Petition,Per 10CFR2.206 to Revoke,Suspend or Modify Cp. Certificate of Svc Encl ML20203N9191986-10-14014 October 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman 860731 Request for Hearing on Util Request for Exemption from Requirement to Conduct Full Participation Exercise.Certificate of Svc Encl ML20210V1571986-10-0606 October 1986 Answer in Opposition to Coalition for Alternatives to Shearon Harris,W Eddleman & Conservation Council of North Carolina 860915 Motion to Reopen Record.Related Info & Certificate of Svc Encl ML20210S9871986-10-0606 October 1986 Brief Opposing Applicant 860304 & 0710 Requests for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Mgt Plan within 1 Yr Prior to Operation.W/Certification of Svc ML20214S0831986-09-25025 September 1986 Applicant Answer Opposing 860915 Coalition for Alternatives to Shearon Harris (Cash) Motion to Reopen Record.Motion Opposed Since Cash Not Party in OL Proceeding.Certificate of Svc Encl ML20214R0531986-09-24024 September 1986 Response Opposing Eddleman/Coalition for Alternatives to Shearon Harris 860919 Request for Extension of Time to Respond to Commission 860912 Order.W/Certificate of Svc ML20214R3681986-09-23023 September 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman Request for 2-wk Extension to Respond to Commission 860912 Order Re Exemption from Requirements of 10CFR50,App E.W/Certificate of Svc ML20214Q9531986-09-19019 September 1986 Requests Extension of Time Until 2 Wks from 860929 Deadline to Respond to 860912 Order Requiring Analysis of 10CFR50.12 Specific Exemptions ML20210D9001986-09-15015 September 1986 Motion to Reopen Record,Per 10CFR2.734,asserting That Commission Unable to Determine Reasonableness of Assurance That Plant Can Operate W/O Endangering Public Health & Safety.Certificate of Svc & Insp Rept 50-400/85-48 Encl ML20203M0021986-08-28028 August 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman 860731 Joint Petition for Hearing on Exemption Request Re Full Participation Emergency Preparedness Exercise.W/Certificate of Svc ML18004A4681986-08-15015 August 1986 Response to Coalition for Alternatives to Shearon Harris 860702 Show Cause Petition Re Emergency Planning Requirements,Filed Per 10CFR2.206.Petition Should Be Denied Due to Lack of Basis for Action.Certificate of Svc Encl ML20205F3591986-08-15015 August 1986 Response to Coalition for Alternatives to Shearon Harris 860702 2.206 Petition to Show Cause Re Emergency Planning Requirements,P Miriello Allegations & Welding Insps.Show Cause Order Unwarranted.W/Certificate of Svc ML20205F4131986-08-14014 August 1986 Answer Opposing Intervenor 860730 Petition for Review of Aslab 860711 Memorandum & Order Denying Two Requests for Relief.Petition Lacks Important Procedural Issue.Certificate of Svc Encl ML20205F2251986-08-14014 August 1986 Answer Opposing Coalition for Alternatives to Shearon Harris & W Eddleman 860730 Petition for Commission Review Per 10CFR2.786.W/Certificate of Svc ML20203K1511986-07-30030 July 1986 Petition for Commission Review of Aslab 860711 Memorandum & Order Denying Coalition for Alternative to Shearon Harris 860609 Petition to Intervene.Certificate of Svc & Svc List Encl ML20212A6071986-07-25025 July 1986 Response to ASLAP 860708 Order Requiring Licensee to Update Re Emergency Plan.Chatham County Resolution Does Not Resolve Issues Re Adequacy of Plan.Resolution False. Certificate of Svc Encl ML20207J8281986-07-24024 July 1986 Response Opposing W Eddleman 860403 Request for Hearing on Util Request for Exemption from Emergency Preparedness Exercise Requirement.W/Certificate of Svc ML20211Q5221986-07-23023 July 1986 Answer Opposing Coalition for Alternatives to Shearon Harris 860721 Motion for 10-day Extension to File Brief Supporting 860721 Notice of Appeal & Request for Review of Aslab 860711 Memorandum & Order.W/Certificate of Svc ML20207E4231986-07-18018 July 1986 Response to Aslab 860708 Order to File Update to Re Chatham County,Nc Rescission of Prior Approval of Emergency Response Plan.Chatham County Endorsed Plan on 860707.W/Certificate of Svc ML20199L1671986-07-0808 July 1986 Suppl to 860624 Response to Conservation Council of North Carolina & Eddleman Request to Continue Stay Indefinitely.On 860707,Chatham County Adopted Resolution Which Endorses Emergency Plan.W/Certificate of Svc ML18019B0891986-07-0202 July 1986 Petition Requesting Institution of Proceedings Per 10CFR2.206,requiring Util to Respond to Show Cause Order Due to Failure to Meet Required Stds in Areas of Emergency Planning,Plant Safety,Security & Personnel Stress ML20206R8691986-06-30030 June 1986 Response Opposing Coalition for Alternatives to Shearon Harris (Cash) 860609 Petition for Leave to Intervene.Any Cash Participation Would Cause Delay in Proceedings.Petition Should Be Rejected as Untimely Filed ML20206P6641986-06-25025 June 1986 Response to Coalition for Alternatives to Shearon Harris & W Eddleman 860428 Motion for Stay of Immediate Effectiveness of Final ASLB Decision.Motion Should Be Denied.Certificate of Svc Encl ML20206J3641986-06-24024 June 1986 Response Opposing Conservation Council of North Carolina & W Eddleman 860609 Motion to Stay All Power Operations Per ASLB 860428 Final Decision.Motion Fails to Show Single Significant Safety Issue.W/Certificate of Svc ML20206J2051986-06-24024 June 1986 Response to Intervenors Conservative Council of North Carolina & W Eddleman Request to Continue Stay Indefinitely. Certificate of Svc & Svc List Encl ML20211D8641986-06-0909 June 1986 Requests to Continue Temporary Automatic Stay of ASLB Authorization of Full Power Operations Indefinitely.Low Power Operations Should Be Stayed Until NRC Completes Immediate Effectiveness Review & Encl Comments Resolved ML20199E4441986-06-0909 June 1986 Request to Indefinitely Continue Temporary Automatic Stay as to ASLB Authorization of Full Power Operations Until Commission Resolves Issue Raised in Encl Comments on Immediate Effectiveness Review ML20205T4001986-06-0909 June 1986 Appeal from Final Licensing Board Decision to Grant Ol.Board Erred in Determining That Widespread Drug Abuse Had No Effect on Const,In Accepting Applicant Nighttime Alert & Notification Plans & in Rendering Final Decision 1999-07-21
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July 8, 1986
\f UNITED STATES OF AMERICA DOCKETED USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION -
6 C
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In the Matter of ) k?g((C' HC::e7:!{j.jG
,n
)
CAROLINA POWER & LIGHT COMPANY )
and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL
- MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant) )
SUPPLEMENT TO APPLICANTS' RESPONSE TO CCNC AND EDDLEMAN REQUEST TO CONTINUE STAY INDEFINITELY On June 24, 1986, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency filed with the Commission
" Applicants' Response to CCNC and Eddleman Request to Continue Stay Indefinitely." Pages 12 to 15 of Applicants' Response take issue with the intervenors' characterization of a resolution f (Attachment A to Applicants' Response) adopted by the Chatham County Board of Commissioners on May 27, 1986. Intervenors had j stated that the county " withdrew from the Emergency Response Plan."1! Applicants pointed out that the county had not finally approved the plan, but there was no indication the county had withdrawn from the plan, that it will no longer participate in planning, or that it would not respond in the event of a 1/ Comments on Immediate Effectiveness Review of Final Licens-ing Board Decision, June 9, 1986, at 7.
8607090325 860708 PDR ADOCK 05000400 C PDR
e i
radiological emergency at the Shearon Harris Nuclear Power Plant.
This supplement addresses new information on this point, not available when Applicants' Response was filed.
On July 7, 1986, the Chatham County Board of Commissioners unanimously adopted "A Resolution Concerning the Shearon Harris Nuclear Power Plant." The resolution states, in part, that "Chatham County endorses the emergency plan jointly developed with Wake, Lee and Harnett Counties and the State of North Carolina," and "Chatham County agrees to carry out the responsi-bilities identified in the plan both during training exercises and in the event of an actual emergency." This resolution elimi-nates any doubt about the County's participation in off-site emergency preparedness for the Harris plant.
Attached hereto are copies of the resolution and letters of July 7, 1986, from Chairman Thompson of the Chatham County Board of Commissioners to Chairman Zech and Governor Martin.
Respectfully submitted, Thomas A. Baxter, P.C.
Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.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) 836-8161 Counsel for Applicants Dated: July 8, 1986
4 I
July 8, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY )
and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Supplement to Applicants' Response to CCNC and Eddleman Request to Continue Stay Indef3-nitely" were served this 8th day of July, 1986, by hand delivery to the parties identified with one asterisk, and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
L A. & %
Thomas A. Baxter, P.C. j I
l l
l
4 b
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY )
and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY. )
)
(Shearon Harris Nuclear Power )
Plant) )
SERVICE LIST
~
Lando W. Zech, Jr.
- Dr. Reginald L. Gotchy Atcmic Safety and Licensing Chairman Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Commissioner Thomas M. Roberts
- Mr. Howard A. Wilber U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Commission Commissioner James K. Asselstine Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James L. Kelley, Esquire Commissioner Frederick M. Bernthal Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 20555 Washington, D.C. 20555 Washington, D.C.
- Thomas S. Moore, Esquire Mr. Glenn O. Bright Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Commission Dr. James H. Carpenter Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
t
- Charles A. Barth, Esquire Dr. Richard D. Wilson Janice E. Moore, Esquire 729 Hunter Street Office of Executive Legal Director Apex, North Carolina 27502 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Wells Eddleman 812 Yancey Street Durham, North Carolina 27701
- Docketing and Service Section Office of the Secretary Richard E. Jones, Esquire U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Vice President and Senior Counsel Carolina Power & Light Company P.O. Box 1551 Mr. Daniel F. Read, President Raleigh, North Carolina 27602 CHANGE P.O. Box 2151 Dr. Linda W. Little i Raleigh, North Carolina 27602 Governor's Waste Management Board 513 Albemarle Building Bradley W. Jones, Esquire 325 North Salisbury Street U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27611 Region II 101 Marrietta Street H. A. Cole, Jr., Esquire Atlanta, Georgia 30303 Special Deputy Attorney General Mr. Robert P. Gruber 200 New Bern Avenue Raleigh, North Carolina 27601 Executive Director Public Staff - NCUC Joseph Flynn, Esquire P.O. Box 991 Federal Emergency Management Agency-Raleigh, North Carolina 27602 500 C Street, S.W.,
Washington, D.C. 20740 John D. Runkle, Esquire Conservation Council of Steven Rochlis, Esquire North Carolina Regional Counsel 307 Granville Road Federal Emergency Management Agency i Chapel Hill, North Carolina 27514 1371 Peachtree Street, N.E.
Atlanta, Georgia 30309 M. Travis Payne, Esquire Edelstein and Payne
! P.O. Box 12607 I Raleigh, North Carolina 27605
s COUNTY OF CHATHAM A .. -c COMMISSION E RS 'f f MARVIF K. HOFFMAN E ARL D. THOMPSON, Chairman County Administrator HENRY DUNLAP,JR. 3 i
CUS MURCHISON, JR. ,
ROBERT L. GUNN !
C.W.LUTTERLOH CARL THOMPSON
- yi{pf 8
ga g
$ r r .$ County Attorney
, , ,3
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P. O. BOX 87 PlTTSBORO, N. C. 27312 ORGANIZED 1770 707 SQUARE MILES July 7, 1966 Mr. Lando W. Zech, Jr.
Chairman Nuclear Regulatory Commission 1717 H Street NW Washington, D.C. 20555
Dear Mr. Chairman:
The Chatham County Board of Commissioners considered the matter of the Emergency Plan in Support of the Shearon Harris Nuclear Power Plant operated by Carolina Power and Light Company at its July 7, 1986 regular meeting. The Board unanimously adopted a resolution, a copy of which is attached, indicating that Chatham County agrees to carry out its operational roles as outlined in the Plan. County agencies and departments will participate in exercises of the plan and will render support in the event of an emergency at the Harris facility.
A copy of this letter is being forwarded to Governor James G. Martin and to the Federal Emergency Management Agency.
Sincerely yours, L
Earl D. Thompson Chairman
s COUNTY OF CHATHAM A -
.e COM MISSION E RS 'f g MARVIN K. HOFFMAN E ARL D. THOMPSON, Chairman ,
County Administrator HENRY DUNLAP,JR. g J'
CUS MURCHISON,JR. / .
ROBERT L. GUNN C.W.LUTTERLOH g/ TT f MP '1 County Attorney CARL m urSON ,3J jga_ ._ gj 7, ,
".?1 XR 13&
P. o. Box 87 PlTTSBORO,N.C. 27312 ORG ANIZED 1770 107 SQUARE MILES July 7, 1986 The Honorable James G. Martin Governor of North Carolina Raleigh, N.C. 27611
Dear Governor Martin:
On July 7, 1986 at a regular meeting of the Chatham County Board of Commissioners, the Commissioners unanimously adopted the enclosed resolution concerning the Shearon Harris Nuclear Power Plant owned by Carolina Power and Light Company and the Eastern North Carolina Power Agency.
In the past six weeks, the Board has carefully reviewed the Emergency Plan in Support of the Shearon Harris Nuclear Power Plant and by this resolution agrees to carry out its planning and operational roles as outlined in the plan.
A copy of our formal letter to the Nuclear Regulatory Commission is enclosed.
Sincerely yours, Earl D. Thompson Chairman O
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A RESOLUTION CONCERNING THE SHEARON HARRIS NUCLEAR POWER PLANT WHEREAS, on May 27, 1986, the Board of Commissioners rescin- '
ded its prior approval of the Shearon Harris Emergency Plan, said action being taken in response to a great deal of public concern which was expressed to the Commissioners over Memorial Day Weekend during which the Commissioners were repeatedly asked by the Coalition for Alternatives to Shearon Harris (CASH) and by other ai.:
citizens for the Commissioners to examine the Emergency Plan because of numerous alleged defects. In our meeting, and in numerous per-sonal visits, many citizens requested a delay so that the Commissioners could take time to examine the plan; and WHEREAS many persons who oppose nuclear energy have come to the Board of Commissioners asking it to be a court of last resort and somehow initiate a complete review of the nation's energy policy as well as all of the economic and construction details of the Harris Plant which was started fifteen years ago, but after hearing the concerns and carefully studying the issue, we find that legall'y the Commissioners have no authority to conduct this review, and that questions of this type must be settled by the appropriate federal and state agencies, or in the Courts; and WHEREAS, THE Board of Commissioners was asked to give the public both kithin and in the surrounding counties time to consider the plan, and now, after six weeks of this debate, no other county has found the jointly developed Emergency Plan to be unacceptable; ,
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.WHEREAS,-nothing.in.the:past sixvweeks has-happened ~to
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- .s. cop. the iminent fueling of the Harris Pl ant, autho rization for which comes'from the federal government and does not r'equire an approved emergency plan to be in place, and no action of Chatham County Commissioners can stop the fueling, and the Commissioners the have, therefore concluded that it is time to insure that emergency planning for residents of Chatham County is done by local, rather than State or federal officials; and WHEREAS, over the past'six weeks the Commissioners have studied the plan, and consulted with state and local emergency personnel and the public at large; and "The WHEREAS, N. C. G. S. Section 166A-7 provides that, governing body of each county is responsible for emergency management, ... within the geographical limits of such county." and in order to effectively perform its mandated duties, each county must have an effective emergency management plan; and WHEREAS, after hearing from the public over the past l
six weeks the board is convinced that the majority of the public s,upports the County strengthening its ability to respond to all emergencies, whether that emergency be from a nuclear plant, from a hazardous materials spill or a weather-six I related emergency. Listening to the public for the last I
weeks has shown that some of our residents felt that the original pl'an was adequate, some felt that more public education was needed, others wanted the evacuation planning area enlarged, and still others stated that they did not .
want any plan at all. Our responsibility is, however, to !
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act in the interest of the public as a whole; and WHEREAS, the Commissioners have determined that certain steps must be taken at this time in order to carry out their mandated responsibilities; NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COMMISSIONERS OF CHATHAM COUNTY AS FOLLOWS:
Section 1. Because of public concern about the adequacy of a ten mile planning area, Chatham County, with State assistance, will develop an all hazards emergency plan for Chatham County which will deal with the possibility that other areas of the County may need to be evacuated. This plan will far exceed any federal or state requirement.
Section 2. Improvements will be made to the County communications systems in order to insure that additional personnel in the County Government, including. Commissioners, school authorities, department heads, additional personnel from the Social Services and the Health Departments , and others who may need to be alerted can be instantly contacted should any emergency arise.
Section 3. Additional training will be provided for each person involved in the emergency respense plan in order to minimize confusion about each persons emergency duties under the Plan. This training shall henceforth be an on-going activity.
Section 4. The County Director of Emergency Preparedness shall see that clearly written standard operating procedures I
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are given to each emergency worker as to his or her duties in an emergency.
Section 5. Chatham County personnel will fully participate in a Shearon Harris exercise now scheduled for later this summer. This exercise will be carefully evaluated in order to further refine the County's needs in the area of emergency preparedness. In order to assure a continuing high level of preparedness for emergencies, a county policy is hereby established that a major disaster exercise will be conducted each year within Chatham County. This annual exercise will involve those personnel and agencies which would be expected to respond in an emergency.
Section 6. A Disaster Preparedness Advisory Committee is hereby created which will function to advise the Commissioners on emergency management planning matters. The membership of this committee is as follows:
Section 7. The plan for emergency evacuation of approxi-mately two thousand residents of the emergency planning zone around the* plant within a maximum four hour time frame is feasible.
Section 8. Chatham County will resume participation in the Shearon Harris planning in order to insure that the County's interests are protected by Chatham County officials.
Section 9. Chatham County endorses the emergency plan jointly developed with Wake, Lee, and Harnett Counties and the State of North Carolina. .
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$- Section 10. Chatham County agrees to carry out the
- responsibilities identified in the plan both during training exercises and in the event of an actual emergency. ,
Section 11. The medical staff at Chatham Hospital is being asked to identify its needs for specialized equipment and/or training to deal with radiation emergencies. Agreement has been reached with Carolina Power and Light to pay all Cohf4Sl A
reasonable costs in this regard.
Section 12. This Resolution is effective upon its adoption.
This ,7 day of July 1986.
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h Eafl D. Thompson /
Chairman
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Hazel'P. Boone W
Clerk of the Board O
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