ML19312E999

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Motion to Postpone First Prehearing Conference Until 801001. Licensee Is Presently Involved in Considering Alternate Proposals & Implementing NRC Suggestion Re TMI Incident. Certificate of Svc Encl
ML19312E999
Person / Time
Site: Maine Yankee
Issue date: 06/11/1980
From: Dignan T, Gad R
Maine Yankee, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8006180326
Download: ML19312E999 (3)


Text

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UNITED STATES OF AMERICA

[4 usHM NUCLEAR REGULATORY COMMISSION dN1 cmca et ths SSC"f DWyfch before the ATOMIC SAFETY AND LICENSING BOARD g

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In the Matter of

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Docket No. 50-309

-MAINE-YANKEE ATOMIC POWER' COMPANY

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(Spent Fuel Pool

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Compaction)

(Maine Yankee Atomic Power Station) )

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LICENSEE'S MOTION TO POSTPONE PREHEARING CONFERENCE Now comes Maine Yankee Atomic Power Company, the Licensee herein and moves the Board to postpone the first prehearing conference in this matter to October 1, 1980, or thereafter and' as reasons therefore says as follows:

1.

Contentions and responses thereto have been filed in the above-entitled matter.

It would now normally be in order to schedule'a special prehearing conference.

10 CFR 6 2.751a.

The holding of such a conference, followed by the issuance of the order, would open discovery in this matter.

10 CFR

'$ 2 740(b)(1).

2.

However, the Licensee is,'at this timg5 giving serious

consideration =to' alternate proposals which might expand the 1800 618 032,(p

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onsite storage capacity possibly as long as plant life; in-addition, various supplements to the current proposal are being considered.

3.

In addition, the Maine Yankee technical staff is heavily engaged in the implementation of various NRC Staff suggestions and requests resulting from the analysis of the events which occurred one year ago at the Three Mile Island facility.

4.

Finally, it should be noted that the State of Maine, on September 23,'1980, is holding a referendum upon the con-tinued utilization of nuclear energy for power generation in Maine.

5.

Each and all of the matters described in Paragraphs 2-4'would appear to dictate that the better part of wisdom would be to postpone the delineation of issues and commencement of discovery at least until October 1, 1980.

By its attorneys,,

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/$ + h f Thomas G. Dignan, Jr.

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K. Gad III Ropes & Gray Dated:

June 11, 1980

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CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., hereby certify that on June ll, 1980, I made service of the within document, by mailing a copy thereof, postage prepaid, to:

Robert M. Lazo, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

-20555 Dr. Cadet H. Hand, Jr.

Director, Bodega Marine Laboratory

. University of California P.O. Box 247 Bodega Bay, California 94923 Mr. Gustave A.

Linenberger Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Henry J. McGurren, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555

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Stanley R. Tupper, Esquire Tupper and Bradley 102 Townsend Avenue Boothbay Harbor, ME 04538 David Santee Miller, Esquire 213 Morgan Street, N.W.

Washington, D.C.

20001 John M.

R. Paterson, Esquire Deputy Attorney General Department of the Attorney General o

State House Augusta, ME 04333 yQ-

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