ML19322B893

Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re VEPCO Motion for Summary Disposition. Affidavit & Certificate of Svc Encl

ML19322B893
Person / Time
Site:	North Anna
Issue date:	06/05/1979
From:	Jay Dougherty Potomac Alliance
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19253C817	List: ML19253C816 ML19322B892 ML19322B893 ML19322B894 ML19322B895 ML19322B896 ML19322B897
References
NUDOCS 7912120178
Download: ML19322B893 (4)

Text

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O UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

) l In the Matter of ) Docket Nos. 50-338 SP

) 50-339 SP VIRGINIA ELECTRIC AND POWER COMPANY )

) (Proposed Amendment to (North Anna Power ) Operating License NPF-4)

Station, Units 1 and 2) )

)

l POTOMAC ALLIANCE STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD In response to VEPCO's Motion for Summary Disposition and pursuant to 10 CFR 2.749(a), Potomac Alliance (the Alliance), sub-mits this statment of material facts as to which the Alliance con-tends there exists a genuine issue to be heard.

The Alliance contends that there is a genuine issue to be heard with respect to the following facts, as numbered by paragraph in VEPCO's Statement Of Material Facts As To Which There Is No Genu- i l

ine Issue To Be Heard (May 11, 1979):

THERMAL EFFECTS l

4, 5, 9, 12, 14, 15, 16, 19, 20-25, 27-41, 46-53 i RADIOACTIVE EMISSION j l

58-70, 72, 74-79, 81-91, 94, 98, 100, 101, 103, 112, 113, 114 j l

1 7 Welt s / 7 f(

MISSILE ACCIDENTS 115, 118-122, 124-131, 133, 134 OCCUPATIONAL EXPOSURE 135, 136, 138-143, 145-156  ;

ALTERNATIVE _S_

157, 160, 161, 162, 163, 165, 167, 169, 170, 174, 175, 176, 177.

Respect fully submitted, Of counsel: / ,?

Gloria M. Gilman, Esq. -

Jdrmbs B . Dougherty Dated this 5th day of June, 1979 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

)

In the Matter of ) Docket Nos. 50-338 SP

) 50-339 SP VIRGINIA ELECTRIC AND POWER COMPANY )

) (Proposed Amendment to (North Anna Power ) Operating License NPF-4)

Station, Units 1 and 2) )

)

l AFFIDAVIT OF JAMES 3. DOUGIIERTY I hereby affirm that the facts set forth in the l

foregoing POTOMAC ALLIANCE ANSWER TO VEPCO'S MOTION FOR

SUMMARY

DISPOSITION are true to the best of my information and belief.

CD

@ es B. Dotfgher y Datec at Washington, D.C.

this th day of June, 1979 Counsel for the Potomac Alliance SUBSCRIBED AND SWORN TC before me this 5th day of June, 1979.

ML r _ -

Totary Public in and for District of Columbia WY Com- -:m grpe,s Aug. 14, 1582

CERTIFICATE OF SERVICE I hereby certify that copies of the POTOMAC ALLIANCE ANSWER TO VEPCO'S MOTION FOR

SUMMARY

DISPOSITION, POTOMAC ALLIANCE STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD, and AFFIDAVIT OF JAMES B. DOUGHERTY were served this 5th day of May, 1979, by United States Mail, First Class, to the following:

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Valentine B. Deale, Esq., Michael W. Maupin, Esq. 4 Chairman, Atomic Safety Hunton & Williams and Licensing Board P.O. Box 1538 i 1001 Connecticut Ave., NW Richmond, VA 23212 Washington, DC 20036 Steven C. Goldberg, Esq.

Mr. Ernest Hill Office of the Executive Lawrence Livermore Laboratory Legal Director University of California U.S. Nuclear Regulatory Commission P.O. Box 800, L-123 Washington, DC 20555 l Livermcre, CA 94550 Mr. Irwin B. Kroot Dr . Quer. tin J. Stober Citizens Energy Forum, Inc.

Fisheries Research Institute P.O. Box 138 University of Washington McLean, VA 22101 Seattle, WA 98195 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTN: Chief, Docketing and Serice Section

_ i C9 '

James B. Doughergy' [/

Counsel for the Potomac Alliance

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