ML19262C539
| ML19262C539 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/22/1980 |
| From: | Paterson J R MAINE, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8002140344 | |
| Download: ML19262C539 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION p.
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y
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e In The Matter Of
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Maine Yankee Atomic Power
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Docket No. 50-309 Company
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(Spent Fuel)
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(Maine Yankee Atomic Power )
Station)
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MOTION BY STATE OF MAINE FOR CHANGE OF LOCATION AND CONTINUANCE OF SPECIAL PRE-
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HEARING CONFERENCE In response to the Notice of Pre-Hearing Conference of the Atomic Safety and Licensing Board (ASLB), dated January 4,
1980, the State of Maine hereby moves that:
1.
The location of the conference be moved to Wiscasset, Maine or some point within the State of Maine located within reasonable proximity of the plant site, and 2.
The hearing be continued for a reasonable period of time, but no less than 180 days.
As grounds therefor 2 the State of Maine states as follows:
On January 2, 1980, the State requested certain data from the Commission staff.
As of the date of this Motion, no response has been received to this request.
(A copy of the request is attached hereto as Exhibit A.)
Once that information is received, a reasonable period of" time will be required for
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8 0 02140 T 4 '/-
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b Page 2 the State to analyze the documents and determine its contentions E
with respect to the application.
Because of the technical
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nature of these issues the State intends to consult with at least one independent expert in order to receive informed technical advice on the proposal.
Location of and consultation with informed and qualified consultants is a time consuming process.
Until technical evaluation is complete, however, the State E
will not be prepared to offer meaningful comments to the
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Board with respect to the pending application.
i In addition, it is clear that time is not now of the p
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Inasmuch as the capacity of the present fuel storage configuration is sufficient through approximately 1987, even f
assuming no off-site transfer of spent fuel before then, there
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is no compelling reason to immediately convene any hearings on--
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v this matter.
Since the applicant has undoubtedly devoted con-5 siderable time and resources to the preparation of its applica-
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E tion, in the interest of equity and in order to insure full f
r development of the facts we suggest that a delay of 180' days
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(6 months) in the Special Pre-Hearing Conference is reasonable.
The State also requests that this special Pre-Hearing Conference and all future conferences and hearings ba held in or near'to Wiscasset, Maine in the interest of providing maximum opportunity for public participation in or observation of the i[
-O licensing process.
Since citizens of the State of Maine are most directly affected by operation of the plant, we suggest E
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Page 3 that the public interest strongly favors holding all hearings in the vicinity of the plant site.
In addition, scheduling of hearings in Maine would result in a considerable reduction of time and expense to the State of Maine and petitioner, and presumably counsel for the applicant whose offices are located in Boston, Massachusetts.
For all the foregoing reasons the State respectfully
' requests that this motion be granted.
t Dated: January 22, 1980 d
JOHN M.
R.
PATERSON Deputy Attorney General State of Maine Counsel for State of Maine Office of Attorney General State House Augusta, Maine 04333 Tel:
(207) 289-3661 5
e UNITED STATEF OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of
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Maine Yankee Atomic Power
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Docket No. 50-309 Company
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(Spent Fuel)
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(Maine Yankee Atomic Power )
Station)
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Certificate of Service I hereby certify that copies of the " Motion By State of Maine for Change of Location and Continuance of Special Pre-Hearing Conference" have been served on the following by deposit in the U.S. Mai1~, first-class, postage prepaid, on Ianuary 22, 1980.
Robert M.
Lazo Atomic Safety & Licensing Board
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U..S. Nuclear RegulatoryCommission Washington, D.C.
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D5g Dr. Cadet H. Hand, Jr.
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Director, Bodega Marine Laboratory f
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.b g4 University of California 3
P.O. Box 247 gg Bodega Bay, California 94923 6
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I' Gustave A.
Linenberger 03 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas G.
Dignan, Jr.
R.
K. Gad, III
-g Ropes & Gray 225 Franklin Street Bost.on, Massachusetts 02110 6
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Stanley R.
Tupper M
Tupper & Bradley 1
102 Townsend Avenue s
Boothbay Harbor, Maine 04338 E
David Santee Miller
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213 Morgan Street, N.W.
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20001 i
a Henry J. McGuerren j
Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Bethesda, Maryland
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U.S. Nuclear Regulatory Commission
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Washington, D.C.
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)W-f JOHN M.
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PATERSON Deputy Attorney General 5
Attorney for State of Maine y
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