ML19341D420
| ML19341D420 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/26/1981 |
| From: | Brown R, Tierney J MAINE, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19341D417 | List: |
| References | |
| NUDOCS 8103050579 | |
| Download: ML19341D420 (7) | |
Text
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UNITED STATES OF AMERICA c
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homsamb6 d &N before the ATGMIC SAFETY AND LICENSING BOARD q
In the Matter of
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MAINE YANKEE ATOMIC POWER COMPANY
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Docket No. 50-309
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(Spent Fuel Compaction)
(Maine Yankee Atomic Power Station)
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PETITION TO INTERVENE OF THE STATE OF MAINE The State of Maine, acting by and through its Attorney General, Petitions for Leave to Intervene in the proceedings before the Commission in opposition to the pending application of Maine Yankee Atomic Power Company (hereinafter " Maine Yankee") as set forth in the Commission notice published in 46 Federal Register 9315-9316 (January 28, 1981).
In support of this Petition the State would show as follows:
1.
The State of Maine is a sovere:.gn State of the United States and is represented in this proceeding by the Attorney General.
2.
The State of Maine and its elected officials have a constitutional, statutory and common law responsibility for safeguarding the health, safety and welfare of the citizens of the State and, in the particular context of this proceeding, those citizens of the State living in reasonably close proximity tc Maine Yankee and who might be affected by its operation.
The State of Mtine is acting in this matter as the representative of all those citizens of the State, a2 oso9.us tg
Page 2 3.
The State of Maine is responsible for preparation and execution of plans to respond to any threats to public health or safety resulting from the operations or malfunctioning of Maine Yankee.
4.
The State of Maine has a proprietary interest in publicly-owned real and personal property locdted in the vicinity of Maine Yankee the value and use of which may be affected by the operation
-of Maine Yankee and the pending application.
5.
The State of Maine owns in trust for the people of the State inland and tidal waters, submerged lands and fish and wildlife all of which may be affected by the pending application of Maine Yankee.
6.
The pending application of Maine Yankee will have a significant impact on the State and the foregoing interests repre-sented by it since if granted, it will involve a substantial increase in the amount of nuclear materials and vastes stored and the length of time of such storage at Maine Yankee.
Such storage will far exceed that originally contemplated at the time
' of construction and commencement of operations at that facility.
7.
The pending application involves potential adverse public health, safety and environmental considerations that are of serious concern to the State of Maine.
Among those concerns are:
(a) the consequences of ordinary operation of the spent fuel pool under the pending application, including but not limited to increased criticality, and altered thermal hydraulics within the pool and exposure of workers to increased radiation levels; J
page 3 (b)' the consequences of certain accidents or abnormal occurrences under the pending application, including but not limited to so-called " Design Basis Accidents," and so-called " Class 9 Accidents;" and (c) the applicant may not have fully explored safer alternatives to the proposed spent fuel compaction and may not have adequately validated the safety features of the proposed fuel compaction.
8.
The State of Maine understands that the amended applica-tion of Maine Yankee now pending before the Commission involves a proposal for spent fuel compaction never before implemented in an operating power reactor in the United States.
Under the circum-tances the State believes that the interests of its residents are entitled to be represented by the State before the Commission to insure that the safety, health and environmental welfare of the citizens of the State are fully protected.
9.
The continuing interest of the State in the safe operation of Maine Yankee is also evident from the fact that the State has participated on two prior occasions as an intervenor in proceed-ings before the Commission involving Maine Yankee, including the hearings on the Construction Permit and Operating License.
l 10.
In light of the foregoing, the State opposes the pend-ing application of Maine Yankee to increase the capacity of its spent fuel storage pool.
Page 4 11.
The State of Maine is prepared to participate fully in all stages of the proceeding 4.n order to fulfill its obligation' to its residents.
For the foregoing reasons the State urges that this Petition be granted by the Commission.
Dated:
February 26, 1981.
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MES E. TIERNEY ttorney ral of the State of Maine
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c, u-RUF US E. BROWN Depaty Attorney General
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Department of the Attorney General State House - Station #6 Augusta, Maine 04333 Tel:
(207)289-3661 l
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UNITED STATES OF AMERICA p
DOCKETED NUCLEAR REGULATORY COMMISSION usNac MAR N >
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before the Z-Of'e, of g, ATOMIC SAFETY AND LICENSING BOARD 3 3ertice O
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In the Matter of
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MAINE YANKEE ATOMIC POWER COMPANY
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Docket No. 50-309
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(Spent Fuel Compaction)
(Maine Yankee Atomic Po'%c Station)
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APPEARANCE OF JAMES E.
TIERNEY Name:
James E.
Tierney Address:
Department of the Attorney General State House - Station #6 Augusta, Maine 04333 Tel: (207)289-3661 Admissions:
Maine Supreme Judicial Court United States District Court, Maine Appearing for:
State of Maine Dated:
February 2 6, 1981
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AMES E.
TIERNEYl Attorney General
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UNITED STATES OF AMERICA 4
i NUCLEAR REGULATORY COMMISSION p
DOCKETED USNRC
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MAR 31981 > :2 ATOMIC SAFETY AND LICENSING BOARD S
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In the Matter of
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ck MAINE YANKEE ATOMIC POWER COMPANY
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gpent el omp ction)
(Maine Yankee Atomic Power Station)
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APPEARANCE OF RUFUS E.
BROWN NAME:
Rufus E. Brown Address:
Department of the Attorney General State House - Station #6 Augusta, Maine 04333 (207)289-3661 Admissions:
United States District Court, Maine United States District Court, District of Columbia United States Court of Appeals, D.C. Circuit United States Court of Appeals, Third Circuit United States Court of Claims District of Columbia Superior Court and Court of Appeals Supreme Judicial Court of the State of Maine Appearing for:
State of Maine Dated:
February 26, 1981.
2 ROFCS B. ' BROWN Dept ty Attorney General
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CERTIFICATE OF SERVICE The undersigned hereby certifies that on February 26, 1981, j
he made service of the attached document by mailing a copy, postage prepaid to:
Robert M. Lazo, Chairman Atomic Safety and Licensing Board 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 Gustave H.
Linenberger Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C.
20555 O
e Office of the Executive Legal Director a
g U.
S. Nuclear Regulatory Cammission 00CKEED Washington, D.C.
20555
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USNnc B
Henry J.McGurran MAR 31981 >
Staff Counsel g
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U.
S. Nuclear Regulatory Commission D M- &Sdm g
Washington, D.C.
20555 B
RF ti Thomas G.
Dignan, Jr.
R.
K. Gad, III Ropes and Gray 225 Franklin Street Boston, Massachusetts 02110 Stanley R.
Tupper Tupper, Bradley and McDowell 102 Townsend Avenue Boothbay Harbor, Maine 04538 David Santee Miller 213 Morgan Street, N.W.
Washington, D.C.
20001
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O RUFUS E.
BROWN Deputy Attorney General l
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