ML19289D518

A&M Cleeton'S Request for Info Re Financial Qualifications from Boston Edison in Ltrs to Nrc.Certificate of Svc Encl

ML19289D518
Person / Time
Site:	05000471
Issue date:	01/25/1979
From:	Abbott W AFFILIATION NOT ASSIGNED
To:
Shared Package
ML19289D516	List: ML19289D518
References
NUDOCS 7903070348
Download: ML19289D518 (2)

Text

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I J

UNITED STATES NUCLEAR REGULATORY COMMISSION Washington D.C.

January 25, 1979 To: Edward Luton, Esq.

Chaircan, Atomic Safety and In the Matter of Licensing Board Boston Edison Conpany, et al U.S. Nuclear Regulatory Commission (Pilgrim Nuclear Generating Sta-Washington, D.C. 20555 tion, Unit 2; Docket No. 50-471)

Motion #2: That Boston Edison Be Ordered To Make Available to the Cleetons Certain Information Re Financial Qualifications Alan and Marion Clecton, by their counsel, hereby cove that the Licensing Board order Boston Edison Company to nake available to the Cleetons, by providing copies thereof, certain information re the issue of financial qualifications furnished by Boston Edison Company to the NRC Staff, as follows:

a) Letter dated May 5, 1978. Boston Edison to NRC.

b) Letter dated May 25, 1978. R.M. Butler to Olin D. Parr.

c) Letter dated June 2, 1978. R.M. Butler to Olin 9. Parr.

d) Letter dated June 23, 1978. R.M. Butler to Olin D. Parr.

e) Letter dated June 23, 1978. R.M. Butler to Olin D. Parr.

f) Letter dated June 30, 1978. R.M. Butler to Olin D. Parr.

g) Letter dated June 30, 1978. R.M. Butler to Olin D. Parr.

h) Letter dated September 1, 1978. R.M. Butler to Olin D. Parr.

i) Letter dated September 15, 1978. R.M. Butler to Olin D. Parr.

j) Letter dated October 16, 1978. R.M. Butler to Olin D. Parr.

k) Letter dated November 3, 1978. R.M. Butler to Olin D. Parr.

1) Letter dated November 7, 1978. R.M. Butler to Olin D. Parr.

m) Letter dated November 15, 1978. R.M. Butler to Olin D. Parr.

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n) Any other correspondence between Boston Edison Company and the NRC Staff subsequent to November 15, 1978, bearing upon the issue of financial qualifications.

As grounds the re fo r, they state the following:

1. From the period May 5, 1978 through November 15, 1978, and perhaps through the present date, Boston Edison has sent a series of letters to the NRC Staff re the issue of its financial qualifications to build Pilgrim 2. Such letters are specifically referred to in a letter of July 14, 1978 from Mr. Vassallo of the NRC Staff to Boston Edison, and in a letter of November 20, 1978 from Dale Stoodley, counsel tc Boston Edison,to Michael Myers, Massachusetts Assistant Attorney General.

2. Counsel for the Cleetons has requested copies of such materials from Boston Edison counsel by letters to such counsel dated July 20, 1978, August 7,1978, December 7,1978 and December 19, 1978. To date Edison counsel has steadfastly re-fused to make available to counsel for the Cleetons copies of any of the requested materials, and has provided no justification or explanation whatsoever, other than a one-sentence response that counsel was too busy to comply. Edison counsel has, how-ever, furnished such materials to the Massachusetts Attorney General's Office by transmittal letter dated November 20, 1978.

3. The Cleetons as full parties in this proceeding are en-titled as a matter of right to be provided copies of such corres-pondence between Boston Edison and NRC Staf f which bear upon the contested issue of financial qualifications , well in advance of the Board hearing with respect to this issue.

WHEREFORE, Alan and Marion Cleeton request that their motion be granted for the reasons stated hereinabove.

Respectfully submitted, 7Y" William S. Abbott Attorney for Alan and Marion Cleeton 50 Congress Street, Room 925 Boston, Massachusetts 02109 617-523-5520 _

Certificate of Service I, William S. Abbott, do hereby certify that a copy of this motion has been duly served on all parties indicated on the Service List attached to my letter of even date herewith addressed to the members of the Licensing Board.

Date i/.;Lv/ ? 9 N b A G A-+.M W William S. Abbott