ML20010E076

Petition to Intervene in Proceeding & Request for Hearing. Certificate of Svc Encl.Related Correspondence

ML20010E076
Person / Time
Site:	Summer
Issue date:	09/01/1981
From:	Morrison H CAHILL, GORDON & REINDEL, SOUTH CAROLINA PUBLIC SERVICE AUTHORITY (SANTEE COOPE
To:	U.S. COURT OF APPEALS, 4TH CIRCUIT
References
81-1785, NUDOCS 8109030038
Download: ML20010E076 (4)

Text

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. 11 ELATED CORIiESPONDENCF Di; 1 iT N' E.2 P.

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Central Electric Power Cooperative, Inc., '

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Petitioner,

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MOTION OF THE SOUTH CAROLINA PUBLIC SERVICE ,

AUTHORITY TO INTERVENE PURSUANT TO 28 U.S.C. S23 g ,

The South Carolina Public Service Authority ("the j'

Authority"), an agency of the State of South Carolina, respectfully moves pursuant to 28 U.S.C. 52348 to intervene in the above-captioned mattet as a matter of right and States that its interests in and the grounds for inter-vention are as follows:

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1. Pursuant to its Petition for Review filed August 21, 1981, Central Electric Power Cooperative (" Central")

seeks review of an order of the Nuclear Reguletory Commission

("NRC") denying Central's petition for a finding of "signif-icant changes" under 42 U.S.C. S2135 (c) (2) ; a finding of ,

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{ "significant changes" would have triggered an antitrust i o

] review with respect to the pending operating license for the Virgil C. Summer Nuclear Station, Unit 1, owned jointly by

) the Authority and South Carolina Electric and Gas Company.*

• By filing this motion, the Authority does not necessarily i recognize there has been final agency action for purposes l of an appeal. Central's motions for reconsideration dated July 6, 1981 and July 20, 1981 are still pending before the NRC.

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2. As a co-applicant for an operating license for the Summer Nuclear Station, the Authority participated as a party in the NRC proceedings that are the subject of this appeal and has interests which will be materially affected by the outcome of this appeal and which can not be 1

adequately represented by any other party.

The South Carolina Public Service Authority hereby requests that all papers filed in this proceeding be served on its counsel at the address indicated below.

Respectfully submitted, A

Hugh /. Morrison, Jr.

Michael R. h:Quinn CAHILL GORDON & REINDEL 1990 K Street, N.W.

Suite 650 i Washington, D.C. 20006 Attorneys for South Carolina Public Service Authority Of Counsel:

Charles McGlothlin ,

General Counsel South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Dated: September , 1981 Washington, D.C.

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CERTIFICATE OF SERVICE I hereby certify that copics of the foregoing MOTION TO INTERVENE were mailed this first day of September, 1981, by first-class mail, postage prepaid, to the following:

Samuel J. Chilk Secretary Nuclear Pegulatory Commission Washington, D.C. 20555 Joseph Rutberg, Esq.

Antitrust Counsel Nuclear Regulatory Comission Washington, D.C. 20555 Jerome D. Salzman Chief Tintitrust and Indemnity Group Nuclear Reactor Regulation Office Nuclear Regulatory Commission Washington, D.C. 20555 Robert Fabrikant, Esq.

Janet R. Urban, Esq.

Department of Justico P.O. Box 14141 Washington, D.C. 20444 P.T. Allen Executive Vice President and General Manager Central Electric Power Cooperative P.O. Box 14555 Columbia, South Carolina 29201 s

Wallace E. Brand,f Esq. ~

Brand & Hall Suite 200 1523 L Street, N.W.

Washington, D.C. 20005

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' 1 C. Pinckney Roberts, Esq.

Dial, Jennings, Windham, Thomas

& Roberts P.O. Box 1792 Columbia, South Carolina 29202 Joseph B. Knotts, Esq.

Debevoise & Liberman 1200 - 17th Street, N.W.

Washington, D.C. 20036 Edward C. Roberts, Esq.

South Carolina Electric & Gas Company P.O. Box 764 Columbia, South Carolina 29202 Frederick D. Chanania, Esq.

Office of the Executive Legal Director Nuclear Regulatory Commission Washington, D.C. 20555 Marjorie S. Nordlinger, Esq.

Stephen F. Eilperin, Esq.

Office of the General Counsel Nuclear Regulatory Commission Washington, D.C. 20555 Mi'chael R. McQuinn Dated: September 1, 1981 Washington, D.C.

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