ML19093A715
| ML19093A715 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/06/1978 |
| From: | Rinaca J Hunton & Williams, Virginia Electric & Power Co (VEPCO) |
| To: | US Atomic Energy Commission (AEC) |
| References | |
| Download: ML19093A715 (3) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of VIRGINIA ELECTRIC AND POWER COMPA...'1'-:JY
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)
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Docket Nos. G~
50-281
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(Surry Power Station, Units 1 and 2) )
VEPCO'S ANSWER TO VIRGINIA'S MOTION FOR FURTHER EXTENSION OF TIME
- 1. The Commonwealth of Virginia previously requested and was granted an extension of time in which to file a Petition for Leave to Intervene and a Request for Hearing
-in this proceeding. By the Board's Order of December 6, 1977, the Commonwealth was given 30 additional days after the original deadline of November 28, 1977 in which to file sucp. Petition. The Commonwealth now requests a further extension of time to file her Petition, an extension not to exceed 10 days after the issuance of the NRC Staff Safety Evaluation Report in this matter.
- 2. Following the Board's Order of December 6, 1977, Vepco has cooperated with the Commonwealth and her consultant in an effort to answer any questions she may have regarding the activities for which Vepco seeks an amendment to its facility operating license for the Surry Power Station, Units 1 and 2. The Commonwealth has been provided with proprietary portions of the Application, and a meeting has been held to answer questions posed by the Commonwealth and her consultant.
- 3. The issue the Commonwealth has tentatively raised is under consideration by the NRC Staff. Vepco believes this matter will receive adequate attention in the course of the Staff's review and that any questions the Commonwealth may have will be answered during that review and in the Staff I
Safety Evaluatiort Report. Moreover, Vepco agrees with the Commonwealth's desire to avoid duplication of effort between itself and the NRC Staff and to avoid an unnecessary formal hearing. Vepco therefore does not oppose the Commonwealth's Motion.
- 4. Although Vepco does not oppose this particular request, Vepco wishes to reserve the right to oppose any future requests for extensions of time, including such requests by parties other than the Commonwealth, depending on the situation at the time. Vepco also, of course, wishes to reserve the right to o~pose future petitions for leave to intervene and requests for a hearing.
Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY
/s/ James M. Rinaca By~~~~--~--==--~..,..,...,,.--=-,.....----------~
JamesM. R1.naca Of Counsel:
Michael W. Maupin James N. Christman James M. Rinaca Hunton & Williams P. 0. Box 1535 Richmond, Virginia 23212 Dated: January 6, 1978
CERTIFICATE OF SERVICE I certify that*. I have served a copy of Vepco' s Answer to Virginia's M:>tion for Further Extension of Time on each of the persons named below:
Secretary U.S. Nuclear Regulatory Commission Washington, D. c. 20555 ATTENTION: Chief, Docketing
& Service Section Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Marshall E. Miller, Esq.
Atomic Safety and Licensing Board Panel
- u. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Oscar H.* Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Frederick J. Shon Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Anthony Gambardella Assistant Attorney General 11 South 12th Street, Suite 308 Richmond, Virginia 23219 By /s/ James M. Rinaca James M. Rinaca Counsel for Virginia Electric and Power Company DATED: January 6, 1978