ML19241B156

Util Answer to Potomac Alliance 790509 Motion to Amend Petition to Intervene.Agrees to Introduction of Contention Re Svc Water Cooling Sys.Submits Improved Statement of Contention.Renews 790511 Motion for Summary Disposition

ML19241B156
Person / Time
Site:	North Anna
Issue date:	05/17/1979
From:	Christman J HUNTON & WILLIAMS
To:
References
NUDOCS 7907110746
Download: ML19241B156 (4)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Doc. Nos.50-338SP VIRGINIA ELECTRIC AND POWER COMPANY 50-339SP

) (Proposed Amendment to (North Anna Power Station, Units ) Operating License NPF-4) 1 and 2) )

VEPCO'S ANSWER TO POTOMAC ALLIANCE'S MOTION TO AMEND PETITION FOR LEAVE TO INTERVENE On May 9, 1979, the Potomac Alliance, intervenor in this procaeding, filed a " Motion to Amend Petition for Leave to Intervene," asking tc add a new contention to the issues in this proceeding:

Service Water Cooling System The intervenor contends that the service water cooling system for the facility will be inadequate to support the component cooling system for the spent fuel pool if the proposed modification of the pool is permitted.

The asserted good cause" for raising tne new contention at this point was Licensing Event Report 79-044, in which Vepco reported the effects of increased service water reservoir and component cooling water temperature on the spent fuel pool cooling system.

Vepco will agree to the introduction of a new issue based on the Licensing Event Report just cited. Vepco believes, how-ever, that a better statement of the contention wot ld the foi-308 349 s\ s 5

79 0711077f

lowing:

The intervenor contends that, in light of the in-creased service water temperatures, the fuel pool cooling system will be inadequate to cool the spent

&c.el pool below the FSAR limits (that is, 140 F for the normal condition and 170 F for the abnormal con-dition) if the :roposed modification to the pool is permitted.

Vepco reserves the right to contend that the evidence on thin is-sue should be limited to the incremental effects of the proposea modification, that, is, that the only question for resolution in this proceeding is the question whether the spent fuel pool cool-ing systcm becomes inadequate, in light of the revised maximum service water temperature, because 966 instead of 416 fuel assem-blima may be stored in the modified fuel pool.

Also, Vepco renews its motion for summary disposition as to this issue, based on the Statement of Material Facts and the affidavits submitted with Vepco's Motion for Summary Disposition of May ll, 1979. The issue was expressly addressed in the May 11 Motion.

Respectively submitted, VIRGINIA ELECTRIC AND POWER COMPANY A - MM

/ James N. Christman fames N. Christman Of Counsel Michael W. Maupin James N. Christman James M. Rinaca Hunton & Williams P.O. Box 1535 Richmond, Virginia 23212 DATED: May 17, 1979 308 350

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CERTIFICATE OF SERVICE I certify that I have served a copy of Vepco's Answer to Potomac Alliance's Motion to Amend Petition for Leave to Inter-vene on each of the persons named below by first-class mail, postage prepaid:

Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing & Service Section Valentine B. Deale, Esquire 1001 Connecticut Avenue, N.W.

Washingten, D.C. 20036 Dr. Quentin J. Stober Fisheries Research Institute University of Washington 9eattle, Washington 98195 Mr. Ernest E. Hill Lawrence Livermore Laboratory University of California Livermore, California 94550 Mr. Irwin B. Krc-Citizens' Ener6- a r ur.i , Inc.

P.O. Box 138 McLean, Virginia 22101 James B. Dougherty, Esquire 307 Eleventh Street, N.E.

Washingtcn, D.C. 20007 Gloria M. Gilman, Esquire 1508 28th Street, N.W.

Washington, D.C. 20007 Steven C. Goldberg, Esquire U.S. Nuclear Regulatory Commission Washington, D.C. 20555 308 351

Anthony J. Gambardella, Esquire Office of the Attorney General Suite 308 11 South Twelfth Street Richmond, Virginia 23219 Atomic Safety and Licensing Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 By /s m.

James N.

h Christman James 3. Lh*is tman , Counsel for Virginia Electric and Power Company DATED. May 17, 1979 308 352