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02i16i99 09:45 HARMON+CURRAN+SPI ~ 919 644 0246 N0.093 <br />-2- <br />plant's design would have to be modified to provide cooling by the component cooling water <br />("CCW 7 system for Unit 1. Because the CCW system has a limited heat load capacity, CP&L <br />would alter its tech specs to impose administrative limits on the heat load in pools C and D, such <br />that they would not exceed 1.0 million BTU/hour.' CPBtL also seeks permission to use coolant <br />piping installed some years ago for Unit 2, far which quality assurance documentation has been <br />either lost or purged. <br />III. REQUEST FOR HEARING AND PETITION TO INTERVENE <br />A. Orange Connty Has Staadiug to lnterveae on Behalf of Its Citizens. <br />Under the Atomic Energy Act and the rules and regulations of the Commission, "any <br />person whose interest may be affected by a proceeding and who desires to participate" in a <br />licensing proceeding may file a request for bearing and petition to intervene. 10 C.F.R. § <br />2.714(a)(I). A party's right to intervene under the Act is based upon whether (1) the action being <br />challenged could cause injury-in-fact to the petitioner, and (2) such injury is arguably within the <br />zone of interests protected by the Atomic Energy At or the National Environmental Policy Act <br />("1VEPA"). Vermont Yankee Nuclear Power Srarion, (Vermont Yankee Nuclear Power. station), <br />L$P-90-6, 31 NRC 85, 89 (1990), citing Portland General Electric Co.(Pebble Springs Nuclear <br />Power Plant, Units 1 and 2), CLI-76-27, 4 NRC 610, 613-14 (1976). <br />1. Orange Connty Will Suffer Injury-In-Fact If the NRC Grants the <br />Proposed License Amendment. <br />Orange County will suffer injury-in-fact if the proposed license amendment is granted. <br />Orange County is a political subdivision of the State of North Carolina, charged with carrying <br />'At some later point, CP&L plans to upgrade the CCW to accommodate a larger heat <br />D15 <br />load. <br />