ML20214T185

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Petition of State of Nh & Atty General SE Merrill to Participate as Interested State.* Large Portion of Plume Exposure EPZ Lies within State.Authors Notices of Appearance & Certificate of Svc Encl
ML20214T185
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 06/05/1987
From: Bisbee G, Huntington G
NEW HAMPSHIRE, STATE OF
To:
Atomic Safety and Licensing Board Panel
References
CON-#287-3699 OLA, NUDOCS 8706100154
Download: ML20214T185 (6)


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UNITED STATES OF AMERICA DOCKETED-

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NUCLEAR REGULATORY COMMISSION 09iRC BEFORE THE-ATOMIC SAFETY AND' LICENSING BOARD

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In the Matter of

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Vermont. Yankee Nuclear

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Power Corporation

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Docket No. 50-271-OLA

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(Vermont Yankee Nuclear.

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June 5, 1987 Power Station)

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PETITION OF THE STATE OF NEW HAMPSHIRE AND ATTORNEY GENERAL STEPHEN E. MERRILL TO PARTICIPATE AS AN INTERESTED STATE The State of New Hampshire, by and through its Attorney General, Stephen E.'Merrill, (hereinafter referred to as the=" State"), hereby petitions the Atomic Safety and Licensing Board to grant it leave to participate in this proceeding as an interested state pursuant to 10 CFR Section 2.715(c).

The Board heard arguments at the April 21-22, 1987 prehearing-conference on the several' proposed contentions on the application of Vermont Yankee Nuclear Power Corporation for an amendment to its operating license, to allow an expansion of the storage capacity of' its spent fuel pool.

By its Order of May 26, 1987, the Board ruled on Lne-contentions, admitting three of them.

Prehearing Conference Order (Rulings on Standing, Contentions, Schedules), (BP-87-547, NRC (May 26, 1987), Appendix A.

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. In the admitted contentions, the intervenors allege that (1) the Applicant has not demonstrated that both the fuel pool cooling system and the reactor cooling system satisfy the single failure criteria (Contention 1), (2) the fuel pool capacity expansion poses a significant enough risk to the quality of the environment to require the preparation of an Environmental Impact Statement (Contention (2),

and (3) the Applicant has failed to analyze adequately the alternatives to its proposal of dry cask storage and independent pool storage (Contention 3).

The State of New Hampshire has an interest in this proceeding and these issues.

The Vermont Yankee facility is located across the Connecticut River from the State of New Hampshire, so that a large portion of the plume exposure emergency planning zone lies within this State.

Consequently, the operation of the facility directly impacts the State of New Hampshire and its citizens.

In view of the foregoing, the State of New Hampshire respectfully requests that this Board grant its petition to participate as an interested state in this proceeding pursuant to 10 C.F.R. Section 2.715(c).

Respectfully submitted, THE STATE OF NEW HAMPSHIRE STEPHEN E. MERRILL ATTORNEY GENERAL Date:

June 5, 1987 By:

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A George Dana Bidbee Senior Assistant Attorney General Environmental Protection Bureau 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679

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June 5, 1987 By:

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Attorney V

Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 t

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In the Matter of

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EP M;L H Vermont Yankee Nuclear

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Power Corporation

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Docket No. 50-271-OLA

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(Vermont Yankee Nuclear

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June 5, 1987 Power Station)

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NOTICE OF APPEARANCE In accordance with 10 CPR Section 2.713(d), the undersigned counsel files this Notice of Appearance.

Name:

George Dana Bisbee Address:

Office of the Attorney General Environmental Protection Bureau 25 Capitol Street concord, NH 03301-6397 Telephone No:

(603) 271-3679 Admissions:

Supreme Court of New Hampshire United States District Court New Hampshire Party Represented:

State of New Hampshire Stephen E.

Merrill, Respectfully submitted, f

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k( Lh u George Dana Bisbef' Senior Assistant Attorney General Office of the Attorney General Environmental Protection Bureau 25 Capitol Street concord, NH 03301-6397 Telephone (603) 271-3679

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In the Matter of

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Power Corporation

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Docket No. 50-271-OLA

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(Vermont Yankee Nuclear

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June 5, 1987 Power Station)

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NOTICE OF APPEARANCE In accordance with 10 CFR Section 2.713(d), the undersigned counsel files this Notice of Appearance.

Name:

Geoffrey M.

Huntington Address:

Office of the Attorney General Environmental Protection Bureau 25 Capitol Street Concord, NH 03301-6397 Telephone No:

(603) 271-3679 Admissions:

Supreme court of New Hampshire United States District Court New Hampshire Party Represented:

State of New Hampshire Stephen E.

Merrill, Respectfully submitted, (W

Af e-Geoffrey M.

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Attorney V

U Office of the Attorney General Environmental Protection Bureau 25 Capitol Street concord, NH 03301-6397 Telephone (603) 271-3679 l

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CERTIFICATE OF SERVICE n

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I, George Dana Bisbee, do hereby certify that a copy of the foregoing Petition to Participate as an Interested State a,n Nptig p 3 :31 of Appearance has been forwarded this 5th day of June, 198$ bpufirst class mail, postage prepaid, to the following parties:

h0C D a ', J Charles Bechhoefer, Chairman George Dean, Esquire P y~

Atomic Safety & Licensing Board Assistant Attorney General Panel U.S. Nuclear Regulatory Commonwealth of Massachusetts Commission Department of the Attorney General Washington, D.C.

20555 One Ashburton Place Boston, MA 02108 Glenn O. Bright Atomic Safety & Licensing Board Panel U.S. Nuclear Daniel J. Mullett, Esquire Regulatory Commission Vermont Department of Public Service Washington, D.C.

20555 120 State Street Montpelier, VT 05602 Dr. James H. Carpenter Atomic Safety & Licensing Ann Hodgdon, Esquire Board Panel U.S.

Nuclear Office of the General Counsel Regulatory Commission Bethesda U.S.

Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Ellyn R. Weiss, Esquire Harmon and Weiss Diana Sidebotham 20001 S Street, N.W.

RFD #2 Washington, D.C.

20009-1125 Putney, VT 05346 Thomas G.

Dignan, Esquire Kathryn Selleck, Esquire Ropes & Gray 225 Franklin Street Boston, MA 02110 ce.ra, Dana,+sc,.

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