Orange County NC Website
02i16i99 09:45 HARMON.CURRAN.SPI j 919 644 0246 N0.093 D04 <br />.3_ <br />that they would not exceed 1.0 million BTU/houc.~ CP&L also seeks permission to use coolant <br />piping installed some years ago for Unit 2, for which quality assurance documentation has been <br />either lost or purged. <br />The January 13, 1999, Federal Register notice sets forth the reasons why the NRC Staff <br />believes the proposed amendment poses no significant hazards. It also offers interested members <br />of the public an opportutity to request a hearing on the proposed license amendment. The <br />Federal Resister notice provides no indication that the Staff has performed any environmental <br />review under NEPA: the notice contains no reference to an EIS, EA, or Finding of No Significant <br />Impact ("FONSI"). <br />Simultaneously with the filing of these comments, Orange County has filed a Request for <br />Hearing and Petition to Intervene regarding the proposed ticense amendment. Orange County's <br />Request for Hearing and Petition to Intervene (February 12, 1999). The County seeks a prior <br />hearing on the safety and environmental issues raised by the proposed license amendment, <br />including aU of the concerns raised in these No 5ienificant Hazards comments. <br />ARGUMENT <br />I. THE PROPOSED LICENSE AMENDMENT DOES NOT SATISFY THE NRC'S <br />STANDARD FOR A DETERMYNATION OF NO SIGNIFICANT HAZARDS <br />CONSIDERATIONS. <br />Under Section 189a of the Atomic Encrgy Act, the issuance of a license or License <br />amendment must await the conclusion of any public hearing that is granted. 42 U.S.C. § <br />4432(a)(I j. Pursuant to the "Sholly" amendment to Section 1 B9a, 42 U.S.C. § 4432(x)(2), the <br />NRC may issue a license amendment prior to the hearing. if it finds the amendment would pose <br />=At some later point, CP&L plans to upgrade the CCW to accommodate a larger heat <br />load. <br />