ML20069B812

Response to Conservation Council of Nc 820222 Petition to Intervene.Petitioner Has Sufficiently Stated Interest in Proceeding Re Unresolved Safety Issues & Emergency Planning. Certificate of Svc Encl

ML20069B812
Person / Time
Site:	Harris
Issue date:	03/03/1982
From:	Trowbridge G CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8203080041
Download: ML20069B812 (3)

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~s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,82 MR -4 P12 :06 BEFORE THE ATOMIC SAFETY AND LICENSINbhBOARDi l:_

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA MUNICIPAL ) 50-401 OL- rss POWER AGENCY NO. 3 -Q (Shearon Harris Nuclear Power ) x y. , , , \[\

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APPLICANTS' RESPONSE TO PETITION TO INTERVE E #'28

• W ' s BY CONSERVATION COUNCIL OF NORTH CAROLINA q s en On January 27, 1982, notice was published in the Fed-eral Register concerning the application of Carolina Power &

Light Company and North Carolina Municipal Power Agency No. 3 (Applicants) for licenses to operate the Shearon Harris Nuclear Power Plant, Units 1 and 2. The notice afforded interested persons an opportunity to request a hearing and to petition for leave to intervene.

On February 22, 1982, a petition to intervene was filed by the Conservation Council of North Carolina (CCNC). CCNC bases its interest on the interests of its members, some of whom reside, work and/or own property in the vicinity of the Harris Plant. CCNC asserts among other things that their inter-est would be affected by the possibility of a radiological acci-dent and by radioactive releases from the Plant. The specific T)SC)

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aspects of the proceeding as to which CCNC wishes to intervene '

include unresolved safety issues and emergency planning. To this extent CCNC has in Applicants' view sufficiently stated an interest in the proceeding to meet the initial requirements for intervention under Section 2.714 of the Commission's Rules of Practice.

g CCNC has alleged other interests and effects upon those interests, some of which in Applicants' view are not cognizable in an NRC operating license proceeding. Applicants propose, howeve.r, to await the formulation of CCNC's contentions pursuant to Section 2.714 (b) and to address at that time the allowability l of the contentions, including their relationship to an interest cognizable in the proceeding.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE mi-George F.[Trowbridge, s>ahd P.C. /

Thomas A. Baxter, P.C.

John H. O'Neill, Jr.

Counsel for Applicants 1800 M Street, N.W.

Washington, D.C. '20036 (202) 822-1000 Dated: March 3, 1982 O

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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 ) Docket Nos. 50-400 OL AND NORTH CAROLINA MUNICIPAL ) 50-401 OL POWER AGENCY NO. 3 )

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(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

i i CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Peti-tion to Intervene by Conservation Council of North Carolina," dated March 3, 1982, were served upon the following persons by deposit in the United States mail, postage prepaid, this 3d day of March, 1982.

James L. Kelley, Esq., Chairman Mr. John Runkle Atomic Safety and Licensing Board Executive Coordinator U.S. Nuclear Regulatory Commission Conservation Council of North Washington, D.C. 20555 Carolina 307 Granville Road Mr. Glenn O. Bright Chapel Hill, N.C. 27514 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Docketing and Service Section (3)

- Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Dr. James H. Carpenter Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 Panel 4

U.S. Nuclear Regulatory Commission Charles A. Barth, Esq. Washington, D.C. 20555 4

Stuart A. Treby, Esq.

Marjorie Rothschild, Esq. Atomic Safety and Licensing Appeal Office of Executive Legal Director Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 N/

• N J l Geord F. Trowbridge,P[C.