ML20059C593

State of VT Motion for Leave to File Reply to Vermont Yankee Nuclear Corp & NRC Staff Answers to State of VT late-filed Contention.* Requests Permission to File Written Reply to Filings of Util & Nrc.W/Certificate of Svc

ML20059C593
Person / Time
Site:	Vermont Yankee
Issue date:	08/23/1990
From:	Janson K VERMONT, STATE OF
To:	Atomic Safety and Licensing Board Panel
References
CON-#390-10773 OLA-4, NUDOCS 9009050177
Download: ML20059C593 (3)

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UNITED STATES'OF AMERICA NUCLEAR REGUIATORY COMMISSION

-usNRC 4 before the  !

, . ATOMIC SAFETY AND LICENSING BOARD  % E 28' N0:45

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In the Matter of )

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VERMONT YANKEE NUCLEAR

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) Docket No. 50 271-OLA-4 j POWER CORPORATION ) (Operating License "

) Extension)  ;

(Vermont Yankee Nuclear ) i

, Power Station) )

STATE OF VERMONT MOTION FOR LEAVE 4 TO FILE REPLY TO. VERMONT YANKEE'S AND NRC STAFF'S  !

I. ANSWERS TO VERMONTS LATE FILED CONTENTION l o' Pursuant to 10 C.F.R. 5 2,730(c), the State of Vermont (" Vermont") moves the '

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s Atomic Safety and Licensing Board (" Board") for permission to file a written reply to l

" Answer of Vermont Yankee to State of Vermont Motion for Leave to Submit Late-Filed Contention" and "NRC Staff Response to Motion to Amend State of Vermont

}, Supplement to Petition to Intervene and to Accept and Admit an Additional Late- [

Filed Contention." In support of this motion Vermont states the following:

1. On July 16, 1990 Vermont filed " Motion to Amend State of Vermont Supplement to Petition to Intervene and to Accept and Admit an Additional L Late Filed Contention."

2. On_ August 8,1990 Vermont ' Yankee Nuclear Power Corporation

(" Vermont Yankee") fi!cd " Answer of Vermont Yankee to State of Vermont Motion for Leave to Submit Late Filed Contention." Vermont Yankee concurrently filed a volume of Attachments to its Answer.

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3. _ On' August 13,1990 the NRC Staff filed "NRC' Staff Response .to:

Motion to Amend State of Vermont Supplement to Petition to Intereene and to I Accept and Admit an Additional Late Filed Contention."

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4. Vermont's written reply to the Vermont Yankee and Staff filings will- 4 assist the Board in ruling on the admissibility of Vermont's late-filed Contention i 3

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5. If Vermont is permitted to file a written reply to the Vermont Yankee and Staff filings, the Board and all parties will have Vermont's responsive s

arguments in writing prior to a hearing on Vermont's late filed Contention X.

Such prior statement of Vermont's responsive arguments will expedite the hearing on the late-filed contention.

6. If Vermont is permitted to file a written reply to the Vermont Yankee -

i and Staff filings, Vermont will be prepared to file that reply by September 7, 1990.

WHEREFORE, Vermont respectfully requests permission to file a written reply to.the above referenced filings of Vermont Yankee and the Staff.

By its Attorney, t

^W l Kurt Janso Special Assistant Attorney General Department of Public Service 1' 120 State Street-Montpelier, Vermont 05602 (802) 828 2811 Dated: August 23, 1990 2

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C0CKLIED UNITED STATES OF AMERICA USHkC NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD- 70 RJ3 28 NOM 4 I

OfftCE Di SECREMRY '

In the Matter of ) DochtilNG A 5LWICL VERMONT YANKEE NUCLEAR ) Docket No:. ' 50-27140tA-4 POWER' CORPORATION ) (Operating License-

. )- Extension)_

(Vermont _ Yankee Nuclear )

1 Power Station). )

)

CERTIFICATE OF SERVICE I hereby certify that on August 23, 1990, I made serviceLof

" State of Vermont Motion for Leave to File Reply to. Vermont Yankee's and NRC Staff's Answers to Vermont's Late-Filed Contention", in accordance with rules of the Commission by mailing a copy _thereof postage prepaid to the following:

Administrative Judge Administrative Judge Robert M. Lazo, Chairman Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and-Licensing U.S. Nuclear Regulatory Commission Board Washington, DC 20555 U.S. Nuclear Regulatory '

Commission Washington, DC 20555 Administrative Judge Ann P. Hodgdon, Esq.

Frederick J. Shon Patricia A. Jehle,-Esq.

Atomic Safety and Licensing Board Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 R. K. Gad, III, Esq. Anthony Z. Roisman,.Esq.

Ropes & Gray Cohen, Milstein, Hausfeld &

One International Place Toll Boston, MA 02110 Suite 600 1401 New York Avenue, N.W.

Adjudicatory File Washington, D.C. 20005 Atomic Safety and Licensing Board Panel U.S.N.R.C.

Washington, DC 20555 A M i---

KurtJanspn/stant Special Assi Attorney General Dated: August 23, 1990