ML19341C452
| ML19341C452 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/27/1981 |
| From: | Miller D SENSIBLE MAINE POWER |
| To: | |
| References | |
| NUDOCS 8103030514 | |
| Download: ML19341C452 (2) | |
Text
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Dattetu t & Serate arasch e
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Docket No. 50-309 h,/w\\*
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'v MAIN 6 KEE ATOMIC POWER COMPANY,
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(To increase and modify
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(Maine Yankee Atomic Power Station),)
Spent Fuel Pool Capacity
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Applicant.)
and Systems; Compaction)
Atomic Safety and Licensing Board Panel INTERVENOR'S STAT WENT OF INTENT TO FILE ADDITIONAL SPECIFIC CONTENTIONS Pursuant to the renoticing ordered in this case on January 6, 1981, and effected on January 28, 1981, Intervenor Sensible Maine Power, ("SMP"), hereby notices its intent to file and/or resubmit additional Specific Contentions herein.
As grounds therefor SMP states:
1.
Upon prior Pleadings before and in prior Orders from this Board, SMP has been accorded Intervenor's status in this proceeding.
2.
On April 28, 1980, SMP timely filed and served fourteen Specific Contentions, some eight or nine of which have been accepted by Staff Counsel and Applicant as presenting triable issues of fact and/or law properly before this Board for resolution.
3.
After various procedural delays not material hereto, Appli-cant filed an Amended Proposal seeking, amongst other things, to in-crease its spent fuel pool storage to approximately 2,430 units from the 953 currently permitted, and to maintain the same through the year 2008.
4.
Applicant's Amended Proposal validates several of SMP's prior unaccepted contentions and establishes a basis for raising 81os o s u sM
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a' others: by way of example only, SMP's " Minnesota Contention",, con-
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cerning long-term storage through the end of Applicant's licensing period, is now clearly proper; further, and again as exa:ple only, Applicant's request to use the spent fuel lay-down area for stor-age, if allowed, would reduce or extinguish Applicant's capability to prepare spent fuel for shipment off-site, thus increasing the likelihood of long-ter= or indefinite-ter= nuclear waste storage at the Wiscasset facility.
Thus SMP hereby notices its intent to resubmit several prior Specific Contentions and to file a nu=ber of adcitional Specific Contentions.
DavidSahteeMiller Counsel for Intervenor SMP Copies hereof served by first class regular mail postage pre-paid, this 27th day of February, iUS1, upon:
Robert M. Lazo, Esquire, Chrmn.
Atty. Gen. Ja=es E. Tierney Atomic Safety & Licensing Ed.
Department of Attorney General U. S. Nuclear Reg. Comm.
State House Washington, D. C.
20555 Augusta, ME 04333 Dr. Cadet H. Hand, Jr.
Thomas Dignan, Esquire Director, Bodega Marine Lab.
Ropes Gray University of California 225 Franklin Street Post Office Box 247 3cston, MA 02110 Sodega Bay, CA 94923 Mr. Gustave A. Linenberger Atomic Safety & Licensing Ed.
U. S. Nuclear Reg. Co=m.
Washington, D. C.
20555 Office of Exec. Legal Dir.
U. S. Nuclear Reg. Comm.
David Santee Miller Washington, D. C.
20555 Counself.for Intervenor SMP.