Orange County NC Website
02i16i99 09:45 HARMON+CURRAN+SPI ~ 919 644 0246 N0.093 D17 <br />-4- <br />environmental risks posed by the proposed license amendment. These concerns fall well within <br />the zone of interests protected by the Atomic Energy Act and NEPA. <br />B. Statement of Aspects on W6icr Orange Couaty Seeks to Intervene <br />Pursuant to 10 C.F.R. § 2.714(b)(2), a hearing petitioner is required to state the "specific <br /> <br />aspect or aspects of the subject matter of the proceeding" as to which it wishes to intervene. The <br />purpose of this requirement is not to judge the admissibility of the issues, but to determine <br />whether the petitioner specifies "proper aspects" for the proceeding. Consu~rrers Power Co. <br />(Midland Plant, Units 1 and 2), LBP-78-27, 8 NRC 275, 278 (1978). The requirement is <br />satisfied by identifying general potential areas of concern that are within the scope of the <br />proceeding Vermond Yankee, supra, 31 NRC at 89. <br />The aspects of the proceeding on which Orange County seeks to intervene are set forth in <br /> <br />detail in the attached Declazation of Dr. Gordon Thompson, Sections F and G, and in the <br />attached No Significant Hazards Comments, Section II. To summarize, Orange County seeks to <br />address the safety and environmental risks posed by the proposed cooling and electrical backup <br />system for the spent fuel pools, the use of coolant piping for which quality assurance <br />documentation is no longer available, the use of administrative measures to compensate for the <br />additional heat load placed on the CCW cooling system, the partial leakage of the spent fuel <br />pool, and the importation, transfer and handling of a large additional quantity of spent nuclear <br />power plant fuel to the Shearon Harris site. <br />