ML20246H425
| ML20246H425 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/10/1989 |
| From: | Spielberg A HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20246H431 | List: |
| References | |
| CON-#289-8599 OLA, NUDOCS 8905160096 | |
| Download: ML20246H425 (2) | |
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COLKEiED LN;iiC j
UNITED STATES OF AMERICA L
NUCLEAR REGULATORY COMMISSION 89 MY 12 P3 :05 Before the Atomic Safety and Licensing Appeal Board 0 "i -. r
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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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(Spent Fuel Pool (Vermont Yankee Nuclear
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Amendment)
Power Station)
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NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S MOTION FOR LEAVE TO FILE MEMORANDUM ON NUREG-1353 New England Coalition on Nuclear Pollution ("NECNP") hereby requests leave to file the attached memorandum on NUREG-1353 in order to' respond to arguments made at the oral argument on May 3, 1989, on the admissibility of Joint Environmental Contention 1.
At the oral argument on the Licensing Board's admission of Joint Environmental Contention 1, both the applicant, Vermont Yankee,' and the NRC staff referred'to and relied on NUREG-1353,
" Regulatory Analysis For The Resolution of Generic Issue 82
'Beyond Design Basis Accidents in Spent Fuel Pools'" (May 1989),
I a newly released NRC staff document.
NECNP did not receive nor have an opportunity to review this document at the time of the oral argument.
Indeed, NECNP did not receive a copy of NUREG-1353 until May 5, 1989, two full days after the argument.
- Thus, NECNP had no opportunity to respond to the applicant's and staff's arguments.1 1
NUREG-1353 was subject to the Board notification procedures of 10 C.F.R. 5 2.781.
The purpose of those requirements, which require service on the parties of documents provided to the Board, is to allow interested parties the opportunity to respond to and comment on the issues contained therein.
8905160096 890510 PDR ADOCK 05000271 PDRt
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2-NECNP has the right to respond to arguments ra'ised at the oraltargument which it was unable to address because it had not yet received its copy of NUREG-1353.
Accordingly, NECNP requests leave to file the attached memorandum.
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1 Respectfully submitted,
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Anne Spielberg Andrea Ferster j
HARMON, CURRAN & TOUSLEY si on C.
b0 (202) 328-3500 l
l May 10, 1989 i
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