ML19269D414

Notifies That Deposition Intervenor of Util Personnel Who Prepared Draft Rept Siting Study,Boston Edison Co, Will Be on 790426.Deponents Will Bring Documents Reflecting Changes in Rept Since 790731.Certificate of Svc Encl

ML19269D414
Person / Time
Site:	05000471
Issue date:	04/20/1979
From:	Burt L MASSACHUSETTS, COMMONWEALTH OF
To:
References
NUDOCS 7906020251
Download: ML19269D414 (5)

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UNITED STATES OF AMERICA M.% g NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD m~

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BOSTON EDISON COMPANY et al. Docket No. 50-4 71 g/ s 9; (Pilgrim Nuclea.. Generating ) N3i Station, Unit 2) )

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NOTICE OF DEPOSITION PLEASE TAKE NOTICE, that the Intervanor Commonwealth of Massachusetts, pursuant to 10 CFR S 2.740a, will take the deposition upon oral examination of the Applicant, by its employees and consultants, specifically, but not limited to the person (s) described below, before a Notary Pub'.ic or other person duly authorized to administer oaths, on Thursday, April 26, 1979, at 10:00 A.M. at the offices of the Attorney General, counsel for the Intervenor, Room 1905, One Ashburton Place, Boston, Massachu-setts 02108.

The Commonwealth of Massachusetts requests the Applicant to make available at said deposition the person (s) responsible for or who have assisted in the preparation of the demographic analysis contained in the draft report entitled " Siting Study Boston Edison Company", prepared for the Applicant by Stone & Webster of Boston, Massa chusetts .

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i The scope of the oral examination will deal primarily with the methodology, assumptions, data sources and results of the demographic analysis set forth in the aforementioned siting study.

The deponent (s) is (are) hereby requested to bring with him(them) all documents referenced, examined, consulted or otherwise used in the preparation of the demographic analysis in the Stone &

Webster Siting Study.

As used herein, " documents" shall meah written, recorded or graphic matter of every type and description, including but not limited to internal memoranda, working papers, drafts, cor-respondence, studies, reports, manuals and analyses, however made and by whomever prepared, produced, reproduced, disseminated or made, which is in the possession, custody or control of the deponent (s),

the Applicant or the Applicant's consultants, agents, employees or representatives.

If the aforementioned demographic analysis has been re-vised, modified, or otherwise changed in any manner since July 1978, the deponent (s) is (are) hereby requested to bring with him(them) all documents reflecting such changes in the analysis.

The Stone & Webster Siting Study has been afforded propri-etary status and presently is being withheld from public inspection by the Nuclear Regulatory Commission, pursuant to the provisions of Section 2.790 of 10 CFR Part 2. (See, enclosed letter of August 25, 1978 from William H. Regan, Chief Environmental Projects Branch 2, Division of Site Safety and Environmental Analysis to Boston Edison Company, Attn. R. M.

Butler, Nuclear Projects Manager, Docket No. 50-471.) Withholding from public inspection, however, does not hY

i affect the right of persons properly and directly concerned with this proceeding to inspect the study.

Any party or other proper person who desires to attend and cross-examine at the deposition should contact counsel for the Applicant beforehand regarding an appropriate protective agree-ment for inspecting proprietary data.

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LAURIE BURT Assistant Attorney General Environmental Protection Division

~Public Protection Bureau One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265 Dated at Boston, Mass.

April 20, 1979 2259 003

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BOSTON EDISON COMPANY et al. ) -

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I, LAURIE BURT, Deposition" submitted by the Intervenor Commonwealth of Ma has been served on the following by depositing copies thereofusetts, in the United States Mail, first class postage prepaid, this 20th day of April 1979:

Edward Luton, Esq.

Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Washington, D.C. 20555 Dr. A. Dixon Callihan William S. Abbott, Esq.

Union Carbide Corporation 50 Congress St., Suite 925 P. O. Box Y Boston, MA 02109 Oak Ridge, Tennessee 37830 office of the Secretary Dr. Richard F. Cole Docketing and Service Section Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm'n U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Daniel F. Ford Atomic Safety and Licensing Appeal Board U.S. Nuclear 1208 Massachusetts Ave.

Regulatory Commission Cambridge, MA 02138 Washington, D.C. 20555 Henry Herrmann, Esq.

Marcia E. Mulkey, Esq. 151 Tremont Street Barry H. Smith, ESq. Boston, MA 02111 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Chief Librarian Washington, D.C. 20555 Plymouth Public Library North Street Plymouth, MA 02360 2259 004

Mr. and Mrs. A.lan R. Cleeton 22 Mackintosh dtreet Franklin, MA 02038 Dale G. Stoodley. Esq.

Boston Edison Company 800 Boylston Street Boston. MA 02199 George H. Lewald, Esq.

Ropes and Gray 225 Franklin Street Boston, MA 02110 (hand-delivered)

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LAURIE BURT Assistant Attorney General Environmental Protection Division One Ashburton Place, 19th Floor Boston, MA 02108 (617) 727-2265 2259 005