ML11172A385
| ML11172A385 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/20/2011 |
| From: | Roisman A National Legal Scholars Law Firm, PC, State of VT, Dept of Public Service |
| To: | NRC/OGC, US Federal Judiciary, Court of Appeals |
| Sean Croston, 301-415-2585 | |
| References | |
| 11-1168, 11-1177, 1314013 | |
| Download: ML11172A385 (2) | |
Text
USCA Case #11-1168 Document #1314013 Filed: 06/20/2011 Page 1 of 2 UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT THE STATE OF VERMONT DEPARTMENT OF PUBLIC SERVICE, Petitioner, No. 11-1168 (consolidated with
-against-11-1177)
UNITED STATES NUCLEAR REGULATORY COMMISSION AND UNITED STATES OF AMERICA, Respondents.
x NON-BINDING STATEMENT OF ISSUES TO BE RAISED Pursuant to the Court's Order of May 20. 2011, Petitioner Vermont Department of Public Service ("Petitioner") hereby submits its statement of issues to be raised regarding its challenge to the United States Nuclear Regulatory Commission's ("NRC") Issuance of Renewed Facility Operating License No. DPR-28 for the Vermont Yankee Nuclear Power Station issued March 21, 2011. See 76 Fed. Reg. 17162 (March 28, 2011). Without waiving any rights to submit additional issues, as set forth below, Petitioner intends to raise the following objection in support of its challenge to the issuance:
USCA Case #11-1168 Document #1314013 Filed: 06/20/2011 Page 2 of 2 (1)
Whether the NRC violated federal law by issuing Renewed Facility Operating License No. DPR-28 because it granted a federal license without obtaining either a water quality certification or a waiver thereof from the State of Vermont as required by 33 U.S.C. § 1341(a).
Dated:
June 20, 2011
/s!
ANTHONY Z. ROISMAN National Legal Scholars Law Firm, P.C.
241 Poverty Lane, Unit 1 Lebanon, NH 03766 603-443-4162 aroisman@nationallegalscholars.
corn Counsel for State of Vermont Department of Public Service 2