Agenda - 02-02-1999 - 9e1 - Laserfiche WebLink

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02i01~99 14:31 HARMON~CURRAN.SPI ~ 19196443004-004 N0.113 D03 ~N, CLAN, SPl~LBERG & EISEI~R'ERG, L.L.P. orange County Commissioners PIiIV1LEGED AND CONI4TDENTIAI. February 1, 1999 ATTORNEY-CLLENT CONIM'UNICATId)N Page 2 AND ATTORNEY WORK PRODUCT Register notice offers the public an opportunity to comment on whether this determination is reasonable, or whether instead the proposed action poses a significant danger, such that the hearing should be held before the license amendment is granted. These no significant hazards comments are also due February l2. If no such comments are made, or if the comments are rejected, Carolina Power & Light can go ahead and put the new racks into the spent fud pool before'the hearing is completed ar even started. This is a disadvantage to any members of the public who are seeking to litigate whether the proposed license amendment is reasonably safe, because it gives the proposed action momentuar that it otherwise would not have. Later on in the proceeding, probably inmid-March, any party that has requested a hearing will also be asked to submit "contentions," which set forth the issues that they wish to raise in the hearing. Those contentions that are admitted ittto the hearing will determine the scope of the issues that can be raised in the hearing. Descript~ Af L,egat Services As requested by the Board, I will prepare a Request for Hearing and Fetition to Irnervene on behalf of the County, to be filed on February 12. Working with Gordon Thompson, I will also prepare contentions challenging the safety of the proposed license amendment. I will also prepare any reply filings that are necessary and attend any prehearing conference scheduled by the NRC Incensing Board. My fee for this work is $150/hour plus expenses, including copying (tt~ 5.151page, long distance charges, postage, and travel costs- Although I will do most of the work on the case, I may receive assistance from my partners or associate attorneys, who charge $l50/hour and $100/hour, respectively. My estimate for completing the work is $6,t~0. Bills are sent out monthly, and payment is expected withip 30 days. In addition to the work described above,l would urge the Board to consider filing No Significant Hazards Comments. Although it is difficult to gain reversal of No Significam Hazards findings, I believe it is worthy of seriws consideration. The proposed amendment would make Shearon Harris the largest spent fuel storage facility on the East Coast. with a very large inventory of spent nuclear power plant foal. Consequently, an accident involving loss of coolant from the pool could have very severe consequences. Moreover, as discussed above, it is worthwhile to try to stop the the proposed expansion from gaining the momentum generated by pre-hearing implementation. I estimate that preparation ofNo Significant Hazards comments would take an additional ten hours of my time, costing $1,500. It would also require ih. Thompson to prepare an affidavit