ML20127A629

Limited Appearance Statement of Oglethorpe Power Corp.* Statement Submitted in Response to Notice,Dtd 921214,for Consideration of Board.W/Certificate of Svc

ML20127A629
Person / Time
Site:	Vogtle
Issue date:	01/06/1993
From:	Self D OGLETHORPE POWER CORP.
To:
References
CON-#193-13515 96-671-01-OLA-3, 96-671-1-OLA-3, OLA-3, NUDOCS 9301120026
Download: ML20127A629 (5)

Text

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. yS G ww UllITED STATES OF AMERICA .

IlUCLEAR REGULATORY COMMISSION '93 Ja -7 P4 35 ATOMIC SAFETY AtlO LICENSIllG BOARD -

Before Administrative Judges '

Peter B. Bloch, Chair Dr. James H. Carpenter Thomas D. Murphy

)

In the matter of ) Docket tios. 50-424-OLA-3

) 50-425-OLA-3 GEORGIA POWER COMPANY, )

et al. ) Re: License Amendment

) (Transfer to Southern (Vogtle Electric Generating ) truclear)

Plant, Units 1 and 2) )

) ASLDP 'lo. 96-671-01-OLA-3

)

LIMITED APPEARAtlCE STATEMENT OF OGLETHORPE POWER CORPORATICN In response to tho.flotico (Limited Appearanco; Prohoaring Conference), dated December 14, 1992, Oglethorpe Power Corporation (Oglethorpe) submits the following limited appearance statement for consideratton by the Board.

1. Oglothorpe la an Electric Mombornhip Corporation organized and existing under the laws of the State of Georgia, with its principal place of business in Tucker, Georgia. It is engaged in the generation and transmission of electric power and energy for its 39 member rural eloctric cooperatives, that provide electric servico to their respectivo retail customors throughout the Stato of Georgia.

2. Oglothorpo owns a 30% undivided ownership interest in the Vogtlo Electric Generating Plant (Plant Vogtle). The other joint owners of this plant are Georgta Power Company (Georgia Power), the Municipal Electric Authority of Georgia (MEAG) and the CLty of Dalton (Dalton).

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3. Oglethorpe's 30% ownership interest in Plant Vogtle  ;

represents a significant portion of the capacity required to l serve the needs of the customers of oglethorpe's member cooperatives. The continued reliable operation of Plant l Vogtle is .i mpo rt a n t to Oglethorpe and each of its member '

cooperatives. '

4. In ordar to protect its interest, Oglethorpe has exerciseci its rights to monitor the management of Plant Vogtle. This monitoring is conducted by executives and a small staff.

Some are located at Oglethorpe's corporate offico and some are permanently located at the plant site. Overall, the Oglethorpe personnel involved in the monitoring of Plant Vogtle have in the aggregate, more than 100 man years of nucioar training and experience in the United States flavy's nuclear program and at other utilities which own and operate commercial nuclear generating stations.

5. As a result of its monitoring activities and its revie.. of operations of other nuclear units, Oglethorpe considers that the objectives of assembling all of the nuclear expertise of Tha Southern Company under the management of a s ingle entity, Southern tiuclear, will be beneficial to Oglothorpe and all others affected by the operation of Plant Vogtle. First, the combination of resources required for the operation of these nuclear plants will mean that each plant will have greater resources available to it under both normal and abnormal circumstancos. Second, the singular focus of Southern fluclear on the oporation of nuclear facilities without competing distractions of conducting transmission, distribution and other utility business should lead to enhancements in the safe and reliable operation of Plant Vogtlo and oach of the other nuclear facilities as well. Third, the focused mLaston of Southern tiuclear should serve to attract and retain qualified and profossionally motivated people to manago, operate and maintain all of the nuclear facilities involved. Fourth, placing the licensed authority to operato all of the nuclear facilities involved with Southern fluclear should result in the simplification of the rathor convoluted dologations of responsibilities that currently exist.

6. In l ig h t. of all of the f oregoing considorations, Oglethorpe supporta the propocod amondmont of the licensoo for the Vogtle units to transfer the licensed authority to operate auch units f rom Goorgia Power to Southern fluclear.

Accordingly, Oglethorpe urgos that the roquested amendmonts of the licensos be tsauod as promptly as may bo roosonably foaelblo.

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Oglethorpe does not-wish to make an oral'_ presentation to the Board at the limited appearance session scheduled for_ January-11, 1993, nor otherwise become as party to the proceeding.

Respectfully submitted, OGLETIIORPE POWER CORPORATION By: cv David Self Senior Vice President, Operations a

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a i;Cri.LD dh iC UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION g3 JM -7 P4'*J6

) =;- , u-Docket Nos. 50-424-OLA13,#" 'iC In the matter of )

) 50-425-OLA-3 GEORGIA POWER COMPANY, )

et al. )

)

(Vogtle Electric Generating )

Plant, Units 1 and 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Limited Appearance Statement of Oglethorpe Power Corporation have been served upon the following persons by U.S. mail, .first class, or overnight mail as otherwise in accordance with the requirements of 10 CFR Sec. 2.712.

Office of Commission -Administrative Judge Appellate Adjudication Peter B. Bloch, Chairman U.S. Nuclear Regulatory Atomic Safety and '

Commission Licensing Board Washington, D.C. 20555- U.S. Nuclear Regulatory Commission Washington,.D C. . 20555 Administrative Judge Administrative Judge James H. Carpenter .

Thomas D. Murphy Atomic Safety and Licensing Atomic Safety;and Board Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission-Washington, D.C. 20555 Washington, D.C. 20555 Office df the General Counsel John Lamberski, Esq.

U.S. Nuclear Regulatory Counsel for Georgia Power Commission- Company.

Washington, C.C. 20555 Troutman Sanders Suite 5200, 600_Peachtree Street, N.E.

Atlanta,-Georgia 30308 j i

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.a-Michael D. Kohn, Esq. C.K. McCoy Stephen M. Kohn, Esq. V. President Nuclear Kohn, Kohn'& Colapinto, P.C. Vogtle Project ,

517 Florida Avenue, N.W. Georgia Power' Company Washington, D. C. 20001 Birmingham, AL 35201 Dated this h D day of January, 1993 m

/ . fi' CDO '

)/Jeffrey W ) C. Stair Attorney Oglethorpe Power Corporation 2100 East Exchange Place Tucker, Georgia _30085

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