ML19208D612

Motion for Extension Until 790907 to File J Beyea Written Testimony & to Schedule Witness Appearance on or After 790921.J Beyea,Nuclear Physicist at Princeton Univ,Is Presently Committed to Finish Study on TMI-2 Accident

ML19208D612
Person / Time
Site:	05000471
Issue date:	07/27/1979
From:	Wright F MASSACHUSETTS, COMMONWEALTH OF
To:
Shared Package
ML19208D613	List: ML19208D612 ML19208D614
References
NUDOCS 7909290028
Download: ML19208D612 (3)

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m m m at a suzaca UNITED STATES OF AMERICA opg l Imf ' N, NUCLEAR REGULATORY COMZ4ISSICM #

BEFORE THE ATOMIC LICENSING 9-5 0g$7.$r -

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AND SAFETY BOARD (I "Y [h, In the Matter of ) O&#

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BOSTON EDISON COMPANY, et al., )

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(Pilgrim Nuclear Generating ) 50-471 Station, Unit 2) )

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MOTION OF THE COMMONWEALTH OF MASSAC3USETTS FOR ENLARGEMEUT OF TIME WITHIN WHICH TO FILE THE TESTIMONY OF WITNESS JAN BEYEA The Intervenor Commonwealth of Massachusetts has today filed a motion to defer the evidentiary hearings on emergency planning and Class 9 accidents, hearings that are now scheduled to begin in Plymouth on August 27, 1979. It is the Commonwealth's position, as set forth in said motion, that recent events within the NRC and the rapidly changing groundrules on these two issues require postponement of the forthcoming hearings. If the Board does not act favorably the Commonwealth's motion to defer the hearings, however, then it is requested that the Commonwealth be allcwed further time for the filing of testimony of its witness Jan Seyea, for the reasons set forth below.

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In support of its recently accepted contention ~iith respect to emergency planning, the Commonwealth intends to introduce the testimony of Dr. Jan Beyea, a nuclear physicist at Princeton University. At the time Dr. Beyea was retained by the Commonwealth, he stated that he was also under contract with the President's Council on Environmental Quality (CZQ) to prepare a study of tha accident at Three Mile Island, but at that time it appeared that he would have no trouble in both finishing the CEQ report and preparing his written testimony for the instant case, testimony that by recent order of the Board is now due on August 10, 1979.

On July 18, 1979 Dr. Beyea telephoned Assistant Attorney General Laurie Burt and informed her that the scheduled completion date cf the CEO report had been pushed back,

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primarily because of new and unexpected data being discovered in the course of the Three Mile Island investigation. Dr.

Beyea's report to the CEO is now due on August 15, 1979, and he informed Assistant Attorney General 3urt that he will need at least until the beginning of September to adequately prepare testimony for the Commonwealth. Dr. Beyea must give priority to the CEQ report, which is in turn to be submitted to the President's Commission on the Three Mile Island accident.

Wherefore, Intervenor Commonwealth of Massachusetts requests that the time for filing Dr. Beyea's written testimony be extended to September 7, 1979, that his appearance as a witnes- scheduled on or after September 21, 1979.

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Respectfully submitted,

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FRANCIS S. WRIGHT Assistant Attorney General Environmental Protection Division Public Protection Bureau One Ashburton Place, 19th Floor Boston, Massachusetts 02103 (617) 727-2265 e

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