ML20027D381

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

ML20027D381
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-2, NUDOCS 8211040221
Download: ML20027D381 (4)

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November 2, IggTED

'82 E)V -3 P1 :32 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cm.E cv ut,MIARY DOCKLhhG a SERVICE BRAtlCH In the Matter of )

) Docket Nos. 50-338/339-OLA-2 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 Concern,ed 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."

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These " contentions", however, are not specific, and Applicant 8211040221 821102 l DR ADOCK 05000338 i PDR i

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O construes them as aspects of the subject matter of the 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 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 WAAOL k.

By: /s/ Marcia R. Gelman Marcia R. Gelman, Counsel Of Counsel Michael W. Maupin James N. Christman l Patricia M. Schwarzschild Marcia R. Gelman HUNTON & WILLIAMS P. O. Box 1535 Richmond, Virginia 23212 Dated: November 2, 1982

e 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 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.

i 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 i

e Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 WA4A .

By: /s/ Marcia R. Gelman Marcia R. Gelman, Counsel for Virginia Electric and Power Company Dated: November 2, 1982 1

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