ML19095A193

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01/30/1978 Legal Correspondence Motion for Further Extension of Time
ML19095A193
Person / Time
Site: Surry  Dominion icon.png
Issue date: 01/30/1978
From: Gambardella A
State of VA, Office of the Attorney General
To:
NRC/OCM
References
Download: ML19095A193 (3)


Text

' e e UNITED STATES OF AMERICA NUCLEAR REGULTORY COMMISSION In the matter of:

VIRGINIA ELECTRIC AND Docket Nos.

POWER.COMPANY 50-280 (Surry Power Station, ~

Units 1 and 2)

MOTION FOR FURTHER EXTENSION OF TIME

1. By its Order of December 6, 1977 the Board granted the Commonwealth of Virginia an extension of time to file a Petition for Leave to Intervene. and .request for hearing in this Proceeding to and including Deceffi?er 28, 1977. By further order of January 4, 1978 the Board granted the Commonwealth an extension of time to and including January 30, 1978 to file such a petition.
2. The Commonwealth has informed the NRC Staff of its concerns with respect to the steam generator modifications proposed by the licensee. However, the staff's response is not yet available.
3. Accordingly, the Commonwealth renews its request for an extension of time to file her Petition.to Intervene and Request for Hearing until ten (10) days after the issuance of the NRC Staff Safety Evaluation in this matter. The purpose of such extension.is to allow the Commonwealth and the Staff to attempt to resolve com-plet~ly the issues and record such resolution in the Staff Safety Evaluation. Such a course of action may eliminate the need for a formal hearing.
4. If the Board determines to deny this Motion, the Common-wealth requests that it be denied without prejudice to the immediate

filing of her Pet,ion.

e The Commonwealth submits that this Motion and her Motions of November 28, 1977 and December 27, 1977 herein establish that she has an interest and at least one contention in this proceeding.

5. For the foregoing reasons, the Commonwealth of Virginia requests an extension of time to file a Petition to Intervene and Request for Hearing herein until ten (10) days after the Staff Safety Evaluation is issued.

Respectfully submitted, COMMONWEALTH OF VIRGINIA By: ~-~~ ambardella t Attorney General 11 S. 1th Street Suite 308 Richmond, Va. 23219 January 30, 1978 Marshall Coleman Attorney General Stuart H. Dunn Deputy Attorney General

e CERTIFICATE OF SERVICE

  • I certify that I have served a copy of "Motion for Further Extension of Time" 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. 0~ Box 1535 Richmond, Virginia 23212 Marshall E. Miller~ Esq.

Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Frederick J. Shon Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission

. Washington, D. C. 20555 By:

Anthony G Assistany Attorney General Dated: January 30, 1978