ML20003F675

Intervenors' Response.Use of Site More than one-half Mile North of Other Two Sites Was Prejudicial to Site Comparison W/Facility

ML20003F675
Person / Time
Site:	Perkins
Issue date:	04/16/1981
From:	Pfefferkorn W PFEFFERKORN & COOLEY, P.A.
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8104230364
Download: ML20003F675 (2)

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UNITED STATES OF AMERICAN '

2 7 fg a NUCLEAR REGULATORY COOiISSION  :[ {,

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 1 0'&.4 N w //

In the Matter of )

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DUY2 POWER COMPANY ) Docket Nos. STN 50-488

) 50-489 (Perkins Nuclear Station, ) 50-490 Units 1, 2 and 3) )

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INTERVENORS' RESPONSE The Applicant's opposition, Brief and Affidavit apparently concedes that the three maps show three different locations for Site E but state that the area of a typical power plant site would be a circle of approximately 5,000 feet in diameter. Each of the three different sites is within a 5,000 foot circle, however, onc of the sites is approximately 3,000 feet from the other two sites and the other two sites are approximately 600 or 700 feet from each other across the road.

Intervenors' position is that the site which is more than 15 mile north of the other two sites is closer to buildings and other development and the use of this site, which is not denied by the Applicants, was clearly prejudicial to a site comparison with Perkins.

Thisthe[ day of April, 1981.

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I CERTIFICATE OF SERVICE I hereby certify that copies of Intervences' Response have been served on the following by deposit in the United States Mail this the /6 W4 day of April, 1981.

Elizabeth S. Bowers, Esq. Charles A. Barth, Esq.

Chairman, Atomic Safety Counsel for NRC Regulatory Staff and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 '

Washington, D.C. 20555 Dr. Donald P. DeSylva William A. Raney, Jr. Esq.

Association Professor of Special Deputy Attorney General Marine Science State of North Carolina Rosenstiel School of Marine Department of Justice and Atmospheric Science Post Office Box 629 University of Miami Raleigh, North Carolina 27602 Miami, Florida 33149 William L. Porter, Esq.

Dr. Walter H. Jordan Associate General Counsel 881 West Outer Drive Duke Power Company 1 Oak Ridge, Tennessee 37830 Post Office Box 2178 Charlotte, North Carolina 28242 Chairman, Atomic Safety "

and Licensing Board Panel Mr. Chase R. Stephens U.S. Nuclear Regulatory Docketing and Service Section 1 Commission Of fice of the Secretary Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chaicman, Atomic Safety and Licensing Appeal Board Mr. J. Michael McGarry, III U.S. Nuclear Regulatory Debevoise and Liberman Commission 1200 Seventeenth Street, N.W. 4 Washington, D.C. 20555 Washington, D.C. 20036 l

Dr. John H. Buck Mr. Richard S. Salzman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. David Springer The Point Farm Mocksville, N.C. 27028 3

WILLIAM G. PFEFFERKOQ g [

Attorney for Inte rver,6rB PFEFFERKORN & COOLEY, P.A.

Post Of fice Box 43 202 West Third Street Winston-Salem, N.C. 27102 Telephone: (919) 725-0251