ML20052H177

Environ Law Project Motion to Consolidate W/Chapel Hill Anti-Nuclear Group Effort.Interests Asserted in Petition to Intervene Will Be Adequately Represented by Consolidation. Certificate of Svc Encl

ML20052H177
Person / Time
Site:	Harris
Issue date:	05/12/1982
From:	Gerard Jackson AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20052H178	List: ML20052H177 ML20052H179
References
NUDOCS 8205200036
Download: ML20052H177 (3)

Text

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.. g UNITED STAT S 0? AMERICA I NUCLEAR RECULATORY C0;...IS3IC:' -

a EEFORE THE ATCEIC SAFETY ACD LICENSING FCARD In the Metter of Carolina Power and ))

Li-ht Conpsny, et al. (Shearon Har- ))

Dockets 50 400, 401 ris Nuclear Fower Plants, Units 1

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) Eay 12, 1982

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a.nd 2) )

MOTION EY THE t'VIEC:-:P:NTAL LA'..' FRCJECT Now cones the Environnental Law Froject (ELF), t:hich has filed a petition for leave to intervene in the above-captioned dockets, and moves that the Board, pursuant to 10 C.F.H. 2.715(a), consolidate the ELP with the Chars 1 3

Hill Anti Nuclear Group 7.ffort (CHANGE). The ELF mskes this request because it believes that although its interest and the interest of CHANGE nay be sonewhat different, it sn:1 CHAUGE .:111 be presenting substantially the sans quest-ions and representing substantially the sane interests.

The ELT also believes that the interests asserted in its oririnsi petition for leave to intervene, as anenied, will be adequately represented by consolidation with 5)5o3 CHANGE, and requests the Board grant this motion. The ELF does not waive any rights by naking this notion, other than the right to particpate and appear as an infavidual party-

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inter ~venor. The ELF will accept service throuf;h CHA:'G2 and i its ca. ling address of F.C. Eox 524, Chapel Hill, NC 2751h; l B205200036 820512 PDR ADOCK 05000400 0 PDR

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• T all further inquiries and/or replies or other connunications should be directed to that address.

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<CJ2Ci?GE JACKSON Secrstary, ELP CERTIFICA?C I hereby certify that copies of this motion have been served on the parties listed below, by deposit of same in a U.S.

mail recository box, first class postage pre-paid, addressed as indicated below, this / T/ LSday of F.ny, 1982.

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<CCEORGE g:ACESCI; Secreta.y, ELI Office of the Ex6cutive Lecal Director U.S. Nuclear Reg Wachington, DC $ulatory 0555 Concission U.S. Nuclear . Regulatory Commission ATT::: Docketing and Service Eranch, 50 400 & 401 Washington, DC 20555 T.r. George Troubridge Shaw, Fittman,IPotts, and Trowbridge 1800 I:. St., D Washincton, DC 20036 r

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• s AFFIDAVIT I have read and understand the notion, and am willing to have my interests represented as stated therein.

Date /V A1 % / U L Signed Ef-- e e

" GTCh'lE J.Wi.SGI; I have read and understand the motion, and am willing to have' my interests represented as stated therein.

Date "

7 b Signed '

W MM" /

?;. AL"J; CHA?. :S I have read and understand the notion, and am willint. co have my interests represented as stated thepein.

-Signed ,w 6 's.f..,.m_)  ;

Date M MAv ME2.

STfM3:: SIZT.7p ACK!;0WLEDGEI;;"".

and have no objection l I have read and understand the ..tior A to it.

Date IS M6Vh1 Sirned Y/

' DANTZL ?. &;AD '

Fresident, CHA1:GE F.O. Fox 524 Chapel Hill,I!C 27511+

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