ML20027D378

Answer to Concerned Citizens of Louisa County 821022 Petition to Intervene.Adequate Interest Established. Applicants Will Respond to Contentions When Filed. Certificate of Svc Encl

ML20027D378
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 8211040218
Download: ML20027D378 (4)

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9 November 2, g mvggD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION +82 NOV -3 PI :28 GFM:J CF SECRtTARY In the Matter of ) MEI$G a SEkvlCE

) Docket Nos. 50-338/339 Ed$h-1 VIRGINIA ELECTRIC )

AND POWER COMPANY )

(North Anna Power Station, Units 1 and 2)

APPLICANT'S ANSWER TO PETITION FOR LEAVE TO INTERVENE OF CONCERNED CITIZENS OF LOUISA COUNTY Applicant, Virginia Electric and Power Company ("Vepco"),

files the following Answer to the Petition for Leave to Intervene filed by Concerned Citizens of Louisa County which was served on Vepco by mail on October 22, 1982.

I.

Petitioner's Interest Petitioner 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 Petitioner has stated what it terms " specific contentions."

These contentions, however, are not specific, and Applicant construes them as aspects of the subject matter of this proceeding as to which Petitioner wishes to intervene.

Petitioner has adequately stated at least one 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) , Petitioner may 8211040218 821102 PDR ADOCK 05000338 9 PDR

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a amend its petition up to 15 days prior to the holding of the first prehearing conference. Pursuant to 10 C.F.R.

S 2.714 (b) (1982) , Petitioner 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.

Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY hAA A. k.

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 i

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CERTIFICATE OF SERVICE I hereby certify that I have this day served Vepco's Answer to Petition for Leave to Intervene of Concerned Citizens of Louica 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 addrsss 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

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By: /s/ Marcia R. Gelman Marcia R. Gelman, Counsel for

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Dated: November 2, 1982

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