Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend to Authorize Receipt & Storage of Surry Spent Reactor Fuel at North Anna.Certificate of Svc EnclML20065P813 |
Person / Time |
---|
Site: |
North Anna |
---|
Issue date: |
10/22/1982 |
---|
From: |
Jay Dougherty DOUGHERTY, J.B. |
---|
To: |
NRC COMMISSION (OCM) |
---|
References |
---|
NUDOCS 8210260348 |
Download: ML20065P813 (8) |
|
|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20095L2141984-08-27027 August 1984 Response to Concerned Citizens of Louisa County,Va (Cclc) Revised Contention 4 Re Physical Protection Sys for Spent Fuel Shipments.Protective Order Necessary for Cclc Access. Certificate of Svc Encl ML20094L7861984-08-14014 August 1984 Response to 840730 Third Draft of Contentions of Concerned Citizens of Louisa County.All But Contention 4 Should Be Denied.Certificate of Svc Encl ML20064N8311983-02-0909 February 1983 Reply to Util & NRC Responses to Louisa County,Va Contentions.Arguments That Consequences of Spent Fuel Transportation from Surry to North Anna Beyond Scope of Hearing Exalt Form Over Substance.Certificate of Svc Encl ML20028G2181983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa,Va Contentions.Contentions Untimely & No Good Cause Shown. Contentions 1 & 4 Should Be Deferred & Contentions 2,3 & 5 Denied.Certificate of Svc Encl ML20028G2041983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa County,Va Contentions.Contentions Untimely & No Good Cause Shown. Contention 1 Re NEPA Requirements & Contention 2 Re Dry Cask Alternative Should Be Deferred.Certificate of Svc Encl ML20028G2121983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I, IIIB2,VB,VD,VF,VG,VH(4),VI & VJ(3) Should Be Rejected & Contentions 2,IIIA,IIIB1,VA,VC,VE,VH(1 - 3) & VJ(1,2 & 4) Should Be Deferred.Certificate of Svc Encl ML20028G2291983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I,Iiic, IVB,IVD,IVF,IVG,IVI(4),IVJ,IVK(3),VA,VC & VI Should Be Denied & Contentions 2,IIIA,IIIB,IIID1,IIIE,IVA,IVC,IVE,IVH, IVI(1 - 3),IVK(1,2 & 4) & VB Deferred.W/Certificate of Svc ML20028E1411983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1321983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1601983-01-17017 January 1983 Contentions Re Proposed License Amend to Expand Spent Fuel Pool Capacity.Certificate of Svc Encl ML20028E1531983-01-17017 January 1983 Contentions Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry 1 & 2 in North Anna Spent Fuel Pool.Certificate of Svc Encl ML20027D3811982-11-0202 November 1982 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 ML20027D3781982-11-0202 November 1982 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 ML20027D3771982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20027D3751982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20065P8851982-10-22022 October 1982 Petition to Intervene of County of Louisa,Va & Board of Supervisors of County of Louisa,Va Re Proposed License Amend to Expand Fuel Storage Capacity.Certificate of Svc Encl ML20065P8621982-10-22022 October 1982 Petition of County of Louisa,Va & Board of Supervisors of County of Louisa,Va to Intervene Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Certificate of Svc Encl ML20065P8411982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend Authorizing Increase in Capacity of Spent Fuel Pool.Notice of Appearance & Certificate of Svc Encl ML20065P8131982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend to Authorize Receipt & Storage of Surry Spent Reactor Fuel at North Anna.Certificate of Svc Encl 1984-08-27
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20095L2141984-08-27027 August 1984 Response to Concerned Citizens of Louisa County,Va (Cclc) Revised Contention 4 Re Physical Protection Sys for Spent Fuel Shipments.Protective Order Necessary for Cclc Access. Certificate of Svc Encl ML20094L7861984-08-14014 August 1984 Response to 840730 Third Draft of Contentions of Concerned Citizens of Louisa County.All But Contention 4 Should Be Denied.Certificate of Svc Encl ML20064N8311983-02-0909 February 1983 Reply to Util & NRC Responses to Louisa County,Va Contentions.Arguments That Consequences of Spent Fuel Transportation from Surry to North Anna Beyond Scope of Hearing Exalt Form Over Substance.Certificate of Svc Encl ML20028G2181983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa,Va Contentions.Contentions Untimely & No Good Cause Shown. Contentions 1 & 4 Should Be Deferred & Contentions 2,3 & 5 Denied.Certificate of Svc Encl ML20028G2041983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa County,Va Contentions.Contentions Untimely & No Good Cause Shown. Contention 1 Re NEPA Requirements & Contention 2 Re Dry Cask Alternative Should Be Deferred.Certificate of Svc Encl ML20028G2121983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I, IIIB2,VB,VD,VF,VG,VH(4),VI & VJ(3) Should Be Rejected & Contentions 2,IIIA,IIIB1,VA,VC,VE,VH(1 - 3) & VJ(1,2 & 4) Should Be Deferred.Certificate of Svc Encl ML20028G2291983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I,Iiic, IVB,IVD,IVF,IVG,IVI(4),IVJ,IVK(3),VA,VC & VI Should Be Denied & Contentions 2,IIIA,IIIB,IIID1,IIIE,IVA,IVC,IVE,IVH, IVI(1 - 3),IVK(1,2 & 4) & VB Deferred.W/Certificate of Svc ML20028E1411983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1321983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1601983-01-17017 January 1983 Contentions Re Proposed License Amend to Expand Spent Fuel Pool Capacity.Certificate of Svc Encl ML20028E1531983-01-17017 January 1983 Contentions Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry 1 & 2 in North Anna Spent Fuel Pool.Certificate of Svc Encl ML20027D3811982-11-0202 November 1982 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 ML20027D3781982-11-0202 November 1982 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 ML20027D3771982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20027D3751982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20065P8851982-10-22022 October 1982 Petition to Intervene of County of Louisa,Va & Board of Supervisors of County of Louisa,Va Re Proposed License Amend to Expand Fuel Storage Capacity.Certificate of Svc Encl ML20065P8621982-10-22022 October 1982 Petition of County of Louisa,Va & Board of Supervisors of County of Louisa,Va to Intervene Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Certificate of Svc Encl ML20065P8411982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend Authorizing Increase in Capacity of Spent Fuel Pool.Notice of Appearance & Certificate of Svc Encl ML20065P8131982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend to Authorize Receipt & Storage of Surry Spent Reactor Fuel at North Anna.Certificate of Svc Encl 1984-08-27
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20148M6511997-06-18018 June 1997 Comment Opposing Proposed Suppl to Bulletin 96-001 That Would Request Licensees to Take Action to Ensure Continued Operability of Control Rods L-95-045, Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors1995-10-19019 October 1995 Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors ML20080M1121995-02-27027 February 1995 Comment Re Proposed Suppl 5 to GL 88-20 IPEEE for Severe Accident Vulnerabilities. Proposed GL Suppl Should Indicate That Licensees Can Use Llnl Hazard Results of NUREG-1488 Re Revised Hazard Estimates Instead of NUREG/CR-5250 ML20073M0751994-09-23023 September 1994 Comment on Proposed Rules 10CFR30,40,70 & 72 Re Clarification of Decommissioning Funding Requirements. Permitting Access to Funds Only on Semiannual Basis Seems Unnecessarily Restrictive ML20069L5291994-06-13013 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Petition for Rulemaking & Changes to 10CFR50.54 ML20029D8251994-04-29029 April 1994 Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity ML20044G1971993-05-24024 May 1993 Comment Supporting Draft Insp Procedure Re Commercial Grade Procurement & Dedication ML20044E5721993-05-19019 May 1993 Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits ML20044D3271993-05-0707 May 1993 Comment Opposing Proposed GL Availability & Adequacy of Design Bases Info ML20125B6141992-12-0303 December 1992 Exemption from Requirements of 10CFR50,app a Re GDC-2 & 10CFR50.49 Re Environ Qualification of Electric Equipment Important to Safety for Nuclear Power Plants ML20095J6881992-04-23023 April 1992 Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants ML20077R5161991-08-14014 August 1991 Comment Supporting Petition for Rulemaking PRM-20-20 Re Reduced Total Effective Dose Equivalent to Individual Members of Public from 0.5 Rem (5 Msv) to 0.1 Rem (1 Msv) ML20235N8531989-02-14014 February 1989 Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices ML20235P3311989-02-0808 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20236P5851987-11-0909 November 1987 Transcript of 871109 Briefing in Washington,Dc Re Facility Steam Generator Tube Rupture Event.Pp 1-56.Supporting Documentation Encl ML20138N5311985-11-0101 November 1985 Memorandum & Order Affirming ASLB 850903 Initial Decision Authorizing Director of NRR to Issue License Amend for North Anna to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry Power Station.Served on 851101 ML20133K7171985-10-18018 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133K6801985-10-18018 October 1985 Forwards Notice of Withdrawal of Appearance in Proceeding. Requests Svc List Be Revised to Include Client Under Listed Address.W/O Encl ML20133F4241985-10-0909 October 1985 Order Stating That ASLB 850903 Initial Decision Authorizing NRR to Amend OL to Permit Receipt & Storage of Spent Fuel Should Not Be Deemed Final,Pending Further Order. Served on 851009 ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N6981985-09-0303 September 1985 Initial Decision LBP-85-34 Authorizing NRR to Issue Amends to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Initial Decision Effective Immediately.Served on 850904 ML20134N4381985-09-0303 September 1985 Order Granting Licensee 850621 Request to Correct Transcript.Proposed Transcript Corrections & Certificate of Svc Encl.Served on 850904 ML20129K1251985-07-18018 July 1985 Brief in Support of NRC 850718 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing Issuance of Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129K1281985-07-18018 July 1985 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing NRR to Issue Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129F8231985-07-12012 July 1985 Reply Opposing Concerned Citizens of Louisa County post- Hearing Brief.Licensee Proposed Findings of Sabotage & Human Error Not Addressed.Challenge of NRC EIS Conclusion Unnecessary.Certificate of Svc Encl ML20209F0021985-07-0808 July 1985 Post-hearing Brief Re Issues Raised at ASLB 850521 & 22 Evidentiary Hearings.Nrc Required by NEPA to Evaluate Alternative of Constructing & Operating Dry Cask Storage Facility,But Failed to Perform Even Cursory Review ML20209F2041985-07-0808 July 1985 Proposed Findings of Fact & Conclusions of Law Re Application for Amend to Ol,Authorizing Licensee to Ship 500 Spent Nuclear Fuel Assemblies from Surry Power Station to North Anna Station.Certificate of Svc Encl ML20128H0791985-07-0808 July 1985 Order Granting Concerned Citizens of Louisa County 850627 Motion for 7-day Extension Until 850708 to File Proposed Findings of Fact & Conclusions of Law.Served on 850708 ML20128G9471985-06-27027 June 1985 Motion for Extension of 850701 Deadline to File Proposed Findings of Fact & Conclusions of Law.Addl Wk Required Due to Addl Legal Duties.Certificate of Svc Encl ML20127F0511985-06-21021 June 1985 Proposed Findings of Fact & Conclusions of Law Re Util 820713 Application to Amend Ol,Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.Unsigned,Undated Order & Certificate of Svc Encl ML20127F0451985-06-21021 June 1985 Post-hearing Brief Requesting Board Find in Util Favor Re Proposed OL Amend Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.No Basis from Sabotage or Human Error Considerations for Denying Proposed Amend ML20128A7731985-05-22022 May 1985 Transcript of 850522 Hearing in Charlottesville,Va.Pp 313-364.Supporting Documentation Encl ML20125C4081985-05-21021 May 1985 Applicant Exhibit A-H-11,consisting of Undated,Untitled Photograph H ML20125C3601985-05-21021 May 1985 Applicant Exhibit A-B-5,consisting of Undated,Untitled Photograph B ML20125C4221985-05-21021 May 1985 Applicant Exhibit A-J-13,consisting of Undated,Untitled Photograph J ML20125C3471985-05-21021 May 1985 Applicant Exhibit A-3,consisting of SAND82-2365, Assessment of Safety of Spent Fuel Transportation in Urban Environs, Dtd June 1983 ML20125C4301985-05-21021 May 1985 Applicant Exhibit A-K-14,consisting of Undated,Untitled Photograph K ML20125C3941985-05-21021 May 1985 Applicant Exhibit A-F-9,consisting of Undated,Untitled Photograph F ML20125C4361985-05-21021 May 1985 Applicant Exhibit A-L-15,consisting of Undated,Untitled Photograph L ML20125C3101985-05-21021 May 1985 Staff Exhibit S-1,consisting of Undated Environ Assessment & Finding of Proposed No Significant Impact Re 820713 & 0820 Applications for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,allowing Receipt & Increased Storage of Spent Fuel ML20125C3411985-05-21021 May 1985 Applicant Exhibit A-2,consisting of 830915 Procedure 1-OP-4.19, Receipt & Storage of Spent Fuel TN-8L Shipping Cask Unloading & Handling Procedures ML20125C3291985-05-21021 May 1985 Staff Exhibit S-3,consisting of Forwarding NMSS Apr 1985 Environ Assessment Re 821008 Application for Authority to Construct & Operate Dry Cask ISFSI at Surry Power Station ML20125C4001985-05-21021 May 1985 Applicant Exhibit A-G-10,consisting of Undated,Untitled Photograph G ML20125C3381985-05-21021 May 1985 Applicant Exhibit A-1,consisting of 831104 Procedure OP-4.3, Shipping of Spent Fuel TN-8L Shipping Cask Loading & Handling Procedures, for Surry Power Station ML20125C3711985-05-21021 May 1985 Applicant Exhibit A-C-6,consisting of Undated,Untitled Photograph C ML20125C3791985-05-21021 May 1985 Applicant Exhibit A-D-7,consisting of Undated,Untitled Photograph D ML20125C3821985-05-21021 May 1985 Applicant Exhibit A-E-8,consisting of Undated,Untitled Photograph E ML20125C3501985-05-21021 May 1985 Applicant Exhibit A-A-4,consisting of Undated,Untitled Photograph a ML20125C3191985-05-21021 May 1985 Staff Exhibit S-2,consisting of Undated Safety Evaluation Re Increasing Spent Fuel Storage Capacity.Proposed Mods to Spent Fuel Pool & Transshipment/Storage of Spent Fuel Acceptable ML20125C4131985-05-21021 May 1985 Applicant Exhibit A-I-12,consisting of Undated,Untitled Photograph I 1997-06-18
[Table view] |
Text
.o , 10/22/82
' 00tKETED
. unac UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION *82 OCT 251
- :, .i;ff,%
) .. . .; xav1C
' In the Matter of
) I I'M
)
VIRGINIA ELECTRIC AND POWER COMPANY )
)'
(North Anna Power Sta., Units 1 & 2)
Docket Nos. 50-338 (Proposed Amendment to Operating )
50-339 License to Permit Storage of )
~
Surry Spent Fuel) )
)
PETITION FOR LEAVE TO INTERVENE Concerned Citizens of Louisa County (hereinafter
" Citizens") hereby requests leave of the Nuclear Regulatory Commission (" Commission" or "NRC") to intervene with re-i spect to the Commission's consideration of the July 13, 1982 application by the Virginia Electric and Power Company
("VEPCO" or " Applicant") for an amendment to the operating l license for the North Anna Power Station authorizing the i
receipt and storage,of spent reactor fuel from the Surry l Power Station. Said application was noticed in the Sep-tember 22, 1982 edition of the Federal Register, 47 Fed.
i 41892. Citizens further requests that the Commission hold i
7 a hearing on VEPCO's application.
i h *& ffg
~
~
osos
DESCRIPTION OF THE PETITIONEP AND HOW ITS INTERESTS WILL BE AFFECTED Concerned Citizens of Louisa County is a not-for-
' profit organization cot. prised of approximately 70 persons who reside in the vicinity of the North Anna power plant.
Citizens was established because of concern on the part of its members over threats to the safety and health of the public, and to the quality of the environment, which may be posed by the operation of the North Anna plant. Fore-most among the goals of the group are to assure that the .
plant is operated safely, and to educate its members and the general public on matters related to the plant's safe operation.
Citizens submits that it has standing to participate in the above-captioned proceeding as a representative of
- its members, most if not all of which reside within 20 miles of the North Anna plant and thus satisfy the prevail-ing rules governing standing in NRC licensing proceedings.
In particular, the following members have authorized Citizens, through counsel, to represent their interests in this matter:
- Donna M. Dellett, Rick W. Dellett, and their children -
Christen, age 4, and Andy, age 1 - reside in Bumpass, Vir-ginia, within 10 miles of the North Anna plant. In addition, the Delletts are the proprietors of a retail store in Bumpass.
The Delletts' health and safety, as well as their financial
interest in the store, are threatened by VEPCO's propo' sal to add Surry spent fuel to the North Anna spent fuel pool.
If authorized, VEPCO's proposal would increase the amount
, of radioactive disharges which routinely emanate from the plan t, and create a risk of spent fuel pool accidents lead-ing to even greater harm to the Delletts.
- Collette Cole resides in Mineral, Virginia. The prop-erty on which her home is located lies adjacent to Lake Anna, into which the North Anna plant discharges thermal and radioactive effluents. Because of the risk of accidents and the chronic, long-term radioactive discharges to which VEPCO's proposal, if approved, will give rise, Ms. Cole's interest in her personal health, and in the quality of the Lake Anna area's environment, will be affected by the pro-posed license amendment.
- Pamela H. and Frederick S. Richardson reside, with their 6-year old son, Joel, alongside' Route 522 in Mineral, Virginia. Their home is situated less than a quarter-mile from the roadway, which has been designated a " primary" route for shipments of spent fuel from the Surry plant to the North Anna Plant (see letter from T.S. Scherr, U.S.
N.R.C., to R.H. Leasburg, VEPCO, July 28, 1982). Because of the risk of accidents involving spent fuel shipments, the Richardsons will suffer impairment of their safety, health, and environmental interests should the proposed license amendment be granted.
_~,---e * -
- Gary and Theresa Schwartz reside in Louisa, Virginia, with their children Lydia and Graham. Both children are en-rolled in the Mineral Elementary School in Mineral, which
.is located less than five feet from Route 522, which has been designated a " primary" route for shipments of Surry spent fuel to the North Anna plant. Because of the risk of accidents involving spent fuel shipments, as well as the children's regular exposure to low-level radiation emanat-ing from the proposed shipments, the personal safety and environmental interests of the Schwartz family will be jeop-ardized if the proposed license amendment is issued.
CONTENTIONS Citizens makes the following specific contentions con-cerning (1) alternatives to.VEPCO's proposed action, (2) the environmental hazards associated with the proposed spent fuel shipments under accident and non-accident conditions, and (3) the NRC's statutory obligations to evaluate the env-ironmental. implications of the proposed license amendment.
Citizens intends to amend and/or supplement this list in the near future.
(1) Applicant has not demonstrated that the proposed trans-fer of Surry spent fuel to North Anna is environmentally and economically preferable to the construction and use of a dry cask storage facility at the Surry Power Station.
F -.
(2) Applicant has not demonstrated that the proposed trans- ,
fer of Surry spent fuel to North Anna is environmentally and economically preferable to increasing the capacity of the
. spent fuel storage pool at the Surry Power Station.
(3) Applicant has not demonstrated that the proposed trans-fer of Surry spent fuel to North Anna is environmentally and economically preferable to operating the Surry Power Station at a reduced rate of output.
(4) Applicant has not demonstrated that the casks in which it proposes to ship Surry spent fuel to North Anna are suf-ficiently safe such that the proposed license amendment will not be inimical to the public safety and health.
(5) Applicant has not demonstrated that it will implement a transportation security plan consistent with the require-ments of part 73 of the LCommission's regulations.
(6) ' Applicant has not demonstrated that the risk of acci-dents involving shipments of Surry spent fuel to North Anna is sufficiently low such that issuance of the proposed li-cense amendment will not be inimical to the public safety and health.
(7) Applicant has not demonstrated that the radiologilal emergency response capabilities of state and local govern-ments is adequate to protect the public health and safety.
(8) The proposed license amendment constitutes a major federal action significantly af fecting the environment
and thus may not be granted prior to the preparation of an' environmental impact statement.
Respectfully submitted, Dated this 22nd day TAffles B. Doughefty of October, 1982 Counsel for Concemed Citizens of Louisa County
. 3045 Porter St., N.W.
Washington, D.C. 20008 (202)362-7158 1
e
UNITED STATES OF AMERICA US P-NUCLEAR REGULATORY COMMISSION ,
)
In the Matter of - t-ogtftpk[y, VIRGINIA ELECTRIC AND POWER COMPANY ) N'
)
(North Anna Power Sta., Units 1 & 2)
Docket Nos. 50-338 (Proposed Amendment to Operating )
50-339-License to Permit Storage of )
Surry Spent Fuel) )
)
NOTICE OF APPEARANCE Name: James B. Dougherty Address: 3045 Porter St., N.W.
Washington, D.C. 20008 Telephone: (202)362-7158 Client: Concerned Citizens of Louisa County Admitted to practice: United States Supreme Court United States Court of Appeals for for the District of Columbia Circuit United States District Court for for the District of Columbia District of Columbia Court of Appeals l
. % f'lA /
J6mds B. Dougherty /p/
4
- - s.-
t UNITED STATES OF AMERICA CC,%pf NUCLEAR REGULATORY COMMISSION
.g2 og 25 M 'N
)
In the Matter of
., i ttg
- VIRGINIA ELECTRIC AND POWER COMPANY ) ~ iBANO
)
(North Anna Power Sta., Units 1 & 2) )
Docket Nos. 50-338 (Proposed Amendment to Operating 0-339 License to Permit Storage of )
Surry Spent Fuel) )
)
CERTIFICATE OF SERVICE I certify that copies of the foregoing PETITION FOR LEAVE TO INTERVENE were served this 22nd of October, 1982, by deposit i'n the U.S. Mail, upon the following:
Michael W. Maupin, Esq.
Hunton & Williams P.O. Box 1535
- Richmond, VA 23212 Executive Legal Director Nuclear Regulatory Commission Washington, D.C. 20555 Cw Dw Jambs B. Dougherty e