ML19323G894
| ML19323G894 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 05/02/1980 |
| From: | Wright F MASSACHUSETTS, COMMONWEALTH OF |
| To: | Callihan A, Cole R, Goodhope A Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006090168 | |
| Download: ML19323G894 (2) | |
Text
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A gtxrED gyposDENC THE COMMONWEALTH OF MASSACHUSETTS
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DEPARTVENT OF THE ATTORNEY GENERAL gyy*
JOHN W. Mc CORMACK STATE OFFICE BUILDING DNE ASHBURTON PLACE. BOSTON 02105 g
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Andrew C. Goodhope, Esq.
Dr. A. Dixon Callihan 3320 Estelle Terrace Union Carbide Corporation Wheaton, Maryland 20906 P. O. Box Y Oak Ridge, Tennesseit 37830 Dr. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C.
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Re:
Boston Edison Company, et al.
(Pilgrim Nuclear Generating Station, Unit 2)
Docket No. 50-471 Gentlemen:
In its order of March 27, 1980, the Board requested all parties to advise it when testimony can be filed with respect to the issue of emergency planning.
In response, the Commonwealth states.that it will be able to file written testimony on the issue'within four to six weeks of receipt of the Staff's new evaluation of emergency plannning at the Pilgrim II site.
We emphasize that the appropriate course of action is to allow us to respond to the Staff's study rather than requiring all parties to submit pre-filed testimony simultaneously, and in support of this position quote from our Statement of February 7,1980 to this Board:
The Commonwealth notes that the Staff is still investigating the Pilgrim II emergency planning issue, most recently by seeking evacuation time estimates from the applicant, estimates which presumably will be 80060go l Y
used to prepare a feasibility analysis for the 10 mile EPZ.
For at least two reasons it would be far more appropriate to submit this analysis of the area surrounding Pilgrim II as a supplement to the SER rather than as pre-filed testimony:
1)
Since the Staff began reassessment of the Pilgrim II emergency planning issue in September, the Commonwealth has had little infor.mation as to the data being gathered and the conclusions being reached.
The Commonwealth, therefore, cannot begin to prepare its own testimony until it has had an opportunity to study the Staff's conclusions, which in such matters are usually contained in the first instance in the SER and not as written testimony filed just before an evidentiary hearing.
Written testimony typically is only in support of statemer.is and conclusions contained.in previously filed documents such as the EIS or SER.
2)
Once the Staff concludes its reassessment of the Pilgrim II emergency planning issue and presents its conclusions, the Commonwealth may be in a position to look again at its own concerns as to this matter, and to determine whether in light of the Staff's additional field studies its contention might be withdrawn or at least narrowed in scope.
I*or the above-mentioned reasons, the Commonwealth respectfully requests that it not be required to file its own testimony until it has had an opportunity to study the analysis currently being prepared by the Staff on emergency planning at the Pilgrim II site.'
Very tr"'-
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Francis S. Wright Assistant Attorney General Environmental Pro'tection Division i
Department of the Attorney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 FSW:ec j
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