ML20045D220

Response of Boston Edison Co to Commonwealth of Ma Atty General Request for Hearing & Petition to Intervene.* Util Will Defer Further Response Until Petitioner Files Suppl Re Specific Contentions.Certificate of Svc Encl

ML20045D220
Person / Time
Site:	Pilgrim
Issue date:	06/08/1993
From:	Stowe W BOSTON EDISON CO.
To:	Atomic Safety and Licensing Board Panel
References
CON-#293-14036 OLA, NUDOCS 9306280103
Download: ML20045D220 (5)

Text

-

? /hbb d

UNITED STATES OF AMERICA M NUCLEAR REGULATORY COMMISSION 93 JUN 10 P3 :30 before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of Boston Edison Company ) Docket No. 50-293 '

) (Spent Fuel Pool Expansion)

(Pilgrim Nuclear Power Station)

RESPONSE OF HOSTON EDISON COMPANY TO TIIE MASSACIIUSE'ITS NITORNEY GENERAL'S REQUEST FOR A IIEARING AND PETITION TO INTERVENE This is an operating license amendment proceeding concerning the addition of spent fuel storage racks to an existing spent fuel pool. It involves Pilgrim Nuclear Power Station ("PNPS"),

which is owned and operated by Boston EJison Company (" Boston Edison") pursuant to an operating license issued by the Commission on June 1,1972 and amended several times theraafter. l A single petition has been filed reque :ing a hearing and seeking leave to intervene in the proceed og and ! cave to participate as n interestec' tate. The petition is sub; ct to the NRC's Rules of Practice,10 C.F.R. 6 2.714.

l The propost 'I axpan:. I spent fuel pool storage capacity at PNPS involves no novel l technicalinues tha' have not been reviewed in the context of a number of other spent fuel pool I swage expansion proceedings. It does not involve any consolidation or densification either of assemblics within the pool or pins within the assemblics. Rather, it simply involves the placement in presently unused space in the pool of additional racks of similar design to those presently resident in the pool. The proposal will have a slight impact on the heat load of the pool and does 9306280103 930608 b PDR ADDCK 05000293 g PDR

-. . _ _. __ . . .. . _ . ._- . _ - ~.

1 e

require the modification of several technical specifications; hence the requirement for the instant b

license amendment appl!~ttion.

Boston Edison accepts that the petitioner is the Attorney General of the Commonwealth, that his papers have been timely filed and that, subject to his tendering a supplement to his petition in which he identifies one or more admissible contentions, the petitioner has sudicient standing to intervene in this matter. It shoulti be nated, however, that Boston Edison does not accept that the

" concerns" asserted by petitioner in his hearing request constitute valid, litigable contentions in i accordance with 10 C.F.R. 6 2.714. Based upon the understanding that petitioner may at a later date file a supplement wherein specific contentions are asserted, Boston Edison will defer further ,

response until that filing.

Respectfully submitted, Boston Edison Company By its attorneys william S. Stowe John M. Fulton -

Boston Edison Company 800 Boylston Street Boston, MA 02199 Date: June 8,1993 (617) 424-2544 I

l 1

1 l

)

~ . . . . . . . - - - . . _ . - . .- . . _ . - .._ --,-_...-..-. --_. - ._ __ .__. ,_._----- - __ _ .

4

^5eE' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the 93 JUN 10 P3 :30

' ATOMIC SAFETY AND LICENSING BOARD

.r

.  % . .n, e f. l, L,6!

In the Matter of Boston Edison Company Docket No. 50-293 (Spent Fuel Pool Expansion)

(Pilgrim Nuclear Power Station)

NOTICE OF APPEARANCE Notice is hereby given of the appearance of the undersigned for Boston Edison Company.

Respectfully submitted,

$/.

John M. Fulton Senior Counsel 4

Boston Edison Company 800 Boylston Street Boston, MA 02199 Date: June 8,1993 (617) 424-2553

s, t UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION before the '93 . sul 10 P3 :30 ATOMIC SAFETY AND LICENSING BOARD t

u ,, ,

In the Matter of '

Boston Edison Company Docket No. 50-293 (Spent Fuel Pool Expansion)

(Pilgrim Nuclear Power Station)

)

NOTICE OF APPEARANCE Notice is hereby given of the appearance of the undersigned for Boston Edison Company.

Respectfully submitted, 9

W William S. Stowe Assistant General Counsel '

Boston Edison Company 800 Boylston Street Boston, MA 02199 '

Date: June 8,1993 (617) 424-2544 i

l 1

j

UNITED STATES OF AMERICA ItY NUCLEAR REGULATORY COMMISSION

'93 JUN 10- P3 :30 before the ATOMIC SAFETY AND LICENSING BOARD f, 1, ,

,.y

. F r.x, -

In the Matter of Boston Edison Company Docket No. 50-293 (Spent Fuel Pool Expansion)

(Pilgrim Nuclear Power Station)

CERTIFICATE OF SERVICE I hereby certify that copies of the Response of Boston Edison Company to the Massachusetts.

Attorney General's Request for a Hearing and Petition to Intervene along with the Notices of-Appearance of John M. Fulton and William S. Stowe were served by first-class mail on the parties listed below on this date.

Office of the Secretary Attn: Docketing and Service Branch ,

U.S. Nuclear Regulatory Commission i Washington,'D.C. 2055'5 Ann P. Hodgdon, Esq. l Office of the General Counsel  ;

U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 i Joseph W Rogers, Esq.

Assistant Attorney General The Commonwealth of Massachusetts Office of the Attorney General 131 Tremont Street Boston, MA 02111 William S. Stowe Assistant General Counsel Boston Edison Company 800 Boylston Street Boston, MA 02199 1 Date: June 8,1993 (617) 424-2544

. - . . . - .__ _ __ __ _ ____ _ - _ -