ML19262C316
| ML19262C316 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/24/1980 |
| From: | Miller D SENSIBLE MAINE POWER |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19262C317 | List: |
| References | |
| NUDOCS 8002110236 | |
| Download: ML19262C316 (2) | |
Text
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U!iITED STATES NUCLEAR REGULATORY COMMISSICN O ' '.
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- In the Matter of
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Docket No. 50-3Cc
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MAI iE LL;EEE ATOMIC PCWER CCMPAI!Y,
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(To increase and =cdify
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(:'aine Yankee Atomic Power Station),)
Spent Fuel Fool Capacity
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Applicant.)
and Systems; Compaction)
IIITERVENOR'S MOTION FOR RELOCATION OF SPECIAL PREHEARING CC:FERENCE Intervenor Sensible Maine Power = oves this F7ard and the Com-mission to relocate the situs of the first Special Prehearing Conference from BethesJ a, Maryland, to Wiscasset, Maine.
As grounds therefor Intervenor states as follo'<s:
1.
That Intervenor's Maine Counsel and all scientific experts or probable witnesses cooperating in the formulation of Specific Contentions, and likely to be consulted in exnlan' tion or defense of the same, are located within or near to such requested situs; 2.
That the facility is there located, together with all or most of Applicant's personnel likely to possess information rela-tive to the issues anticipated to be raised in Intervenor's Speci-fic Contentions; 3.
That such situs, ensuring access to Intervencr's better-informed Counsel and experts, and to Applicant 's facility and per-sonnel, will be more conducive to and productive of the sost ef-fici?nt and effective Special Frehearing Conference herein; 4.
That no prejucice to Applicant results from the granting 8002110ELES(~
of thic Motion; upon notice of Intervenor's cursuit f 4 6 321 f
- hi s relo-5.
- That,
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cation, Counsel for Applicant stated that he had n: objection to tha granting of this Motion; 6.
That such inconvenience as may ba suffered by Board r.en-bers herein as a result of such relocation ic ccre than offset by the benefits to be gained and the interests to te protectea by the granting of this Motion; and 7.
That the interests of justice and of fair, orderly and ef ficient administrative practice favor, and are best served by, the granting of this P.otion.
For these reasons, for the reasons developed in the accompany-ing Memorandun, and for such reasons as may be daveloped should oral argument be had hereon, Intervenor respectfully request 3 nat the Special Prehearing Conference currently scheduled to be naa in Bethesda, Maryland, be moved to Wiscasset, Maine.
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Divid Santee Miller Counsel for Intervenor 213 ': organ Street, N. 'll.
Washington, D. C.
20001 Telephone:(2C2)638-ChE3
- 2. C. Bar No. 216499A CIRTIFICATE CF SERVICE I hereby certify that the following have been mailed cc.cias of this.'*otion and ':ancrandum this 24th day of January, 1980:
Executive Lecal Eirector Thomas G.
Signan, Isq.,
J, S.
N.
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and R. ::. Gac,
II., acq.
llasninnton, S. C.
20555 R0 Pea L
Gr37 225 Franklin Jtreet Robert :. Lazo, Zs.,Chr.rn.
Boston, ':A C2ili
.i.tcLic Safety L lensg. 3c.
1OAE 790 n
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?!ashington, 2. C.
20555 s.jg,,7f,-
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.v-John M. R. Paterson, Esq.
David Santee. iller Deputy Attorney General Counsel for Intervenor Dept. of the Atty. Gnl.
Augusta, Maine C4333