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{{#Wiki_filter:.. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of: ) ) VIRGINIA ELECTRIC AND ) POWER COMPANY ) ) (Surry Power Station, ) Units 1 and 2) ) Docket Nos. 50-2.8-Q--50-281 MOTION FOR EXTENSION OF TIME TO FILE PETITION TO INTERVENE AND REQUEST FOR HEARING On October 27, 1977, the Commission published a Notice of Proposed Issuance of Amendments to Facility Operating Licenses with respect to the Surry Power Station. (42 Fed. Reg. 56,652, October 27, 1977). The amendments under consideration would authorize the licensee to remove and place portions of the steam generators now in use at the facility.
{{#Wiki_filter:..
Pursuant to said notice, Petitions to Intervene and Requests for Hearing must be filed on or before November 28, 1977. The Commonwealth respectfully requests that it be granted extension of time to file a request for hearing herein and states:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:         )
* 1. The Surry Power Station is located within the Commonwealth of Virginia.
                              )
The Commonwealth is an interested state within the meaning of Section 274(1) of the Atomic Energy Act of 1954, as amended (42 u.s.c. § 2021(1)) and 10 C.F.R. § 2.715(c).
VIRGINIA ELECTRIC AND   )         Docket Nos.
POWER COMPANY       )         50-2.8-Q-
                              )         5 0-281 (Surry Power Station,   )
Units 1 and 2)       )
MOTION FOR EXTENSION OF TIME TO FILE PETITION TO INTERVENE AND REQUEST FOR HEARING On October 27, 1977, the Commission published a Notice of Proposed Issuance of Amendments to Facility Operating Licenses with respect to the Surry Power Station.   (42 Fed.
Reg. 56,652, October 27, 1977). The amendments under consideration would authorize the licensee to remove and re-place portions of the steam generators now in use at the facility. Pursuant to said notice, Petitions to Intervene and Requests for Hearing must be filed on or before November 28, 1977. The Commonwealth respectfully requests that it be granted extension of time to file a request for hearing herein and states:
* 1. The Surry Power Station is located within the Commonwealth of Virginia. The Commonwealth is an interested state within the meaning of Section 274(1) of the Atomic Energy Act of 1954, as amended (42   u.s.c. § 2021(1)) and 10 C.F.R. § 2.715(c).
: 2. The Commonwealth of Virginia has an interest in the health, safety and welfare of her citizens, including their environment.
: 2. The Commonwealth of Virginia has an interest in the health, safety and welfare of her citizens, including their environment.
: 3. Any Order which may*be entered in this proceeding authorizing replacement of portions of the steam generators at the Surry facility may have a detrimental effect upon the health, safety and welfare of the citizens of the Commonwealth and their environment.
: 3. Any Order which may*be entered in this proceeding authorizing replacement of portions of the steam generators at the Surry facility may have a detrimental effect upon the health, safety and welfare of the citizens of the Commonwealth and their environment.
: 4. The NRC Regulatory Staff has not yet completed its review of the Application.
: 4. The NRC Regulatory Staff has not yet completed its review of the Application. In addition, the Application does not purport to be complete. Thus, an extension of time will not prejudice the licensee.
In addition, the Application does not purport to be complete.
: 5. A consultant retained by the Commonwealth advises that, based on a preliminary review of the Application, it appears that components of the modified steam generators for the Surry Power station may be similar or identical in design to components of steam generators of another manufacturer of nuclear components which have been subject to damage due to vibration during operation. Additional review, involving the proprietary portions of the Application and perhaps material not in the Application, will be necessary to confirm such preliminary review.
Thus, an extension of time will not prejudice the licensee.
: 6. Preliminary review of the Application has disclosed several other technical issues with respect to the steam generator tube modifications which the Commonwealth may seek to assert in a petition to intervene.
: 5. A consultant retained by the Commonwealth advises that, based on a preliminary review of the Application, it appears that components of the modified steam generators for the Surry Power station may be similar or identical in design to components of steam generators of another manufacturer of nuclear components which have been subject to damage due to vibration during operation.
                            -  2 -
Additional review, involving the proprietary portions of the Application and perhaps material not in the Application, will be necessary to confirm such preliminary review. 6. Preliminary review of the Application has disclosed several other technical issues with respect to the steam generator tube modifications which the Commonwealth may seek to assert in a petition to intervene.
: 7. If the Commission determines to deny this Motion, the Commonwealth requests that it be denied without prejudice to the immediate filing of its petition. The Commonwealth submits that the foregoing motion demonstrates that the Commonwealth has an interest and at least one colorable contention in this proceeding.
l ' ,* 7. If the Commission determines to deny this Motion, the Commonwealth requests that it be denied without prejudice to the immediate filing of its petition.
: 8. For the foregoing reasons, the Commonwealth of Virginia requests an extension of time to file a Petition to Intervene and request for hearing herein, not to exceed thirty (30) days.
The Commonwealth submits that the foregoing motion demonstrates that the Commonwealth has an interest and at least one colorable contention in this proceeding.
Respectfully submitted, COMMONWEALTH OF VIRGINIA By:
: 8. For the foregoing reasons, the Commonwealth of Virginia requests an extension of time to file a Petition to Intervene and request for hearing herein, not to exceed thirty (30) days. November 28, 1977 Anthony F. Troy Attorney General Stuart H. Dunn Deputy Attorney General By: Respectfully submitted, COMMONWEALTH OF VIRGINIA Anthony Assistan General 11 S. 1 h Street Suite 308 Richmond, Va. 23219 e e CERTIFICATE OF SERVICE I certify that I have served a copy of "Motion for Extension of Time to File Petition to Intervene and Request for Hearing" on each of the persons below by mailing him a copy today, by first class mail, to the address set out below: Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION:
Anthony Assistan           General 11 S. 1 h Street Suite 308 Richmond, Va. 23219 November 28, 1977 Anthony F. Troy Attorney General Stuart H. Dunn Deputy Attorney General l
Chief, Docketing  
 
& Service Section Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Michael W. Maupin James N. Christman Hunton & Williams P. o. Box 1535 Richmond, Virginia 23212 By: Dated: November 28, 1977 bardella Attorney General}}
e                           e CERTIFICATE OF SERVICE I certify that I have served a copy of "Motion for Extension of Time to File Petition to Intervene and Request for Hearing" on each of the persons below by mailing him a copy today, by first class mail, to the address set out below:
Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Chief, Docketing & Service Section Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Michael W. Maupin James N. Christman Hunton & Williams P. o. Box 1535 Richmond, Virginia 23212 By:
bardella Attorney General Dated: November 28, 1977}}

Latest revision as of 11:05, 2 February 2020

Motion for Extension of Time to File Petition to Intervene and Request for Hearing
ML19093A797
Person / Time
Site: Surry  Dominion icon.png
Issue date: 11/28/1977
From: Gambardella A
State of VA, Office of the Attorney General
To:
NRC/SECY
References
Download: ML19093A797 (4)
v • d • e


Text

..

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of: )

)

VIRGINIA ELECTRIC AND ) Docket Nos.

POWER COMPANY ) 50-2.8-Q-

) 5 0-281 (Surry Power Station, )

Units 1 and 2) )

MOTION FOR EXTENSION OF TIME TO FILE PETITION TO INTERVENE AND REQUEST FOR HEARING On October 27, 1977, the Commission published a Notice of Proposed Issuance of Amendments to Facility Operating Licenses with respect to the Surry Power Station. (42 Fed.

Reg. 56,652, October 27, 1977). The amendments under consideration would authorize the licensee to remove and re-place portions of the steam generators now in use at the facility. Pursuant to said notice, Petitions to Intervene and Requests for Hearing must be filed on or before November 28, 1977. The Commonwealth respectfully requests that it be granted extension of time to file a request for hearing herein and states:

  • 1. The Surry Power Station is located within the Commonwealth of Virginia. The Commonwealth is an interested state within the meaning of Section 274(1) of the Atomic Energy Act of 1954, as amended (42 u.s.c. § 2021(1)) and 10 C.F.R. § 2.715(c).
2. The Commonwealth of Virginia has an interest in the health, safety and welfare of her citizens, including their environment.
3. Any Order which may*be entered in this proceeding authorizing replacement of portions of the steam generators at the Surry facility may have a detrimental effect upon the health, safety and welfare of the citizens of the Commonwealth and their environment.
4. The NRC Regulatory Staff has not yet completed its review of the Application. In addition, the Application does not purport to be complete. Thus, an extension of time will not prejudice the licensee.
5. A consultant retained by the Commonwealth advises that, based on a preliminary review of the Application, it appears that components of the modified steam generators for the Surry Power station may be similar or identical in design to components of steam generators of another manufacturer of nuclear components which have been subject to damage due to vibration during operation. Additional review, involving the proprietary portions of the Application and perhaps material not in the Application, will be necessary to confirm such preliminary review.
6. Preliminary review of the Application has disclosed several other technical issues with respect to the steam generator tube modifications which the Commonwealth may seek to assert in a petition to intervene.

- 2 -

7. If the Commission determines to deny this Motion, the Commonwealth requests that it be denied without prejudice to the immediate filing of its petition. The Commonwealth submits that the foregoing motion demonstrates that the Commonwealth has an interest and at least one colorable contention in this proceeding.
8. For the foregoing reasons, the Commonwealth of Virginia requests an extension of time to file a Petition to Intervene and request for hearing herein, not to exceed thirty (30) days.

Respectfully submitted, COMMONWEALTH OF VIRGINIA By:

Anthony Assistan General 11 S. 1 h Street Suite 308 Richmond, Va. 23219 November 28, 1977 Anthony F. Troy Attorney General Stuart H. Dunn Deputy Attorney General l

e e CERTIFICATE OF SERVICE I certify that I have served a copy of "Motion for Extension of Time to File Petition to Intervene and Request for Hearing" on each of the persons below by mailing him a copy today, by first class mail, to the address set out below:

Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Chief, Docketing & Service Section Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Michael W. Maupin James N. Christman Hunton & Williams P. o. Box 1535 Richmond, Virginia 23212 By:

bardella Attorney General Dated: November 28, 1977

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