ML20027D377
| ML20027D377 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/02/1982 |
| From: | Gelman M HUNTON & WILLIAMS, VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OLA-1, NUDOCS 8211040215 | |
| Download: ML20027D377 (5) | |
Text
4 00LKETED November 2lM1982
'82 NOV -3 P1 :28 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION fjFiCE OF SELRtIARY ggggENG & SERvlCE In the Matter of
)
BRANCH
) Docket Nos. 50-338/339-OLA-1 VIRGINIA ELECTRIC
)
AND POWER COMPANY
)
(North Anna Power Station, Units 1 and 2)
APPLICANT'S ANSWER TO PETITION FOR LEAVE TO INTERVENE OF LOUISA COUNTY, VIRGINIA AND THE BOARD OF SUPERVISORS OF LOUISA COUNTY Applicant, Virginia Electric and Power Company ("Vepco"),
files the following Answer to the Petition for Leave to Intervene filed by Louisa County and the Board of Supervisors of the County (collectively, the " County"), which was served on Vepco by mail on October 22, 1982.
I.
Petitioners's Interest The County has adequately established an interest in the proceeding and how that interest may be affected by the results of the proceeding, in accordance with 10 C.F.R. S 2.714 (1982).
II.
Petitioner's Contentions The County has adequately stated at least one specific aspect of the subject matter of this proceeding as to which it wishes to intervene.
Under 10 C.F.R.
S 2.714 (a) (3) (1982), the County may amend its petition up to 15 days prior to the holding of the first prehearing conference.
Pursuant to 10 C.F.R. 8211040215 821102 PDR ADDCK 05000338 Q-PDR ISOS
i S 2.714 (b) (1982), the County has until 15 days prior to the first prehearing conference to file a list of the contentions that it will seek to have litigated in this proceeding and a reasonably specific statement of the basis for each such contention.
Applicant will respond to the Petitioners' contentions after the list has been filed.
Applicant wishes to reserve the right to raise at that time any arguments that address the admissibility of the contentions, including any arguments that it might have made at this time.
III.
Consolidation Applicant has no objection to consolidating this proceeding with the ongoing proceeding in which Applicant has applied for amendments to its North Anna operating licenses that would authorize installation and use of neutron-absorbing spent fuel racks in the North Anna Units 1 and 2 spent fuel pool.
Applicant does not agree, however, that either shipment of spent fuel from Surry to North Anna or expansion of a North Anna Unit 3 spent fuel pool is an appropriate subject for consideration in either proceeding.
Applicant will address those issues, if they are raised, when the County has filed the list required by 10 C.F.R.
S 2.714 (b) (1982). -
i Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY
]PfMdA. b. hY By:
/s/ Marcia R. Gelman Marcia R. Gelman, Counsel Of Counsel Michael W. Maupin James N. Christman Patricia M.
Schwarzschild Marcia R. Gelman HUNTON & WILLIAMS P. O. Box 1535 Richmond, Virginia 23212 Dated: November 2, 1982 f.
CERTIFICATE OF SERVICE I hereby certify that I have this day served Vepco's Answer to Petition for Leave to Intervene of Louisa County and the Board of Supervisors of Louisa County upon each of the persons named below by depositing a copy in the United States mail, properly stamped and addressed to him at the address set out with his name:
Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Chief, Docketing and Service Section Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. George A. Ferguson School of Engineering Howard University 2300 5th Street Washington, D.C.
20059 Daniel T.
Swanson, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 J. Marshall Coleman, Esq.
Beveridge & Diamond, P.C.
1333 New Hampshire Avenue, NW Washington, D.C.
20036 James B. Dougherty, Esq.
3045 Porter Street, NW Washington, D.C.
20008 -
9 I
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 h AA Y f.
i By:
/s/ Marcia R. Gelman Marcia R.
Gelman, Counsel for Virginia Electric and Power company Dated:
November 2, 1982
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