ML20005B885

Errata Sheet to Commonwealth of Ma 810824 Request for Clarification/Motions for Extension of Time for Filing Direct Testimony on Emergency Planning & Ruling Re Rebuttal Testimony.Certificate of Svc Encl.Related Correspondence

ML20005B885
Person / Time
Site:	05000471
Issue date:	09/09/1981
From:	Shotwell J MASSACHUSETTS, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8109160072
Download: ML20005B885 (5)

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s 4, UNITED STATES OF AMERICA D G NUCLEAR REGULATORY COMMISSION @

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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BOSTON EDISON COMPANY et al. ) Docket No. 50-471

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(Pilgrim Nuclear Generating )

Station, Unit 2) ) A

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$ 0 (?b k9 ERRATA SHEET:

COMMONWEALTH'S REQUEST FOR 9.a. g, ,,,,g CLARIFICATION / MOTIONS FOR EXTENSION OF TIME kV ,N q

FOR FILING DIRECT TESTIMONY ON s '

EMERGENCY PLANNING AND FOR RULING RE REBUTTAL TESTIMON7 On August 24, 1981, the Commonwealth filed a pleading entitled " Request of the Commonwealth of Massachusetts for Clarification / Motions for Extension of Time for Filing Direct Testimony on Emergency Planning and for Ruling re Rebuttal Testimony." The Commonwealth notes the following corrections to that pleading:

1. The reference to the " week of August 17" on page 5 should read "the week of August 10."

2. The date of the conference call discussed at page 5 was August 20, 1981, not July 20, 1981.

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3. The refernece at pages 5-6 to the point at which the Commonwealth received informal answers to its emergency planning interrogatories should, again, be August 20, 1981 (the date of the conference call),

six days following the close of the period designated by the Board for completion of discovery.

Counsel for the Commonwealth notes these corrections for the record, but states that they in no way alter the substance of the Commonwealth's arguments in its August 24th pleading.

In addition, counsel for the Commonwealth is informed by Mr. Goldberg, counsel for the NRC Staff, that it was not he who advised the Commonwealth of the need of his co-counsel, Mr. Blume, to review relevant pleadings before negotiating an informal settlement to the dispute over the Commonwealth's interrogatories. (See page 5 of the Commonwealth's August 24 pleading.) Counnel for the Commonwealth assumes, cherefore, that it was Mr. Blume himself who was the source of that i

j communication. Although again not a substantive change , this i

l correction is noted for the aake of accuracy.

1 Finallyc the Commonwealth notes that, because of a change in the vacation plans of its expert, Mr. Herr , it may now have expert assistance in its review of the Applicanta' revised evacuation study at a slightly earlier time than was previously l

l expected. (Mr. Herr was also able to review the revised study very briefly on his own before leaving town.) Again, this

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slight change has no substantive effect on the Commonwealth's request for an extension of the deadline for filing direct testimony or the reasons provided in support of that request.

Respectfully submitted,

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JOjANN SHOTWELL Kssistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265 Dated: September 9, 1981 i

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d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

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BOSTON EDISON COMPANY ot al. ) Docket No. 50-471

)

(Pilgrim Nuclear Generating )

Station, Unit 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that the within Errata Sheet has been served on the following by deposit of copies thereof in the United States Mail, first clas , mail, postage prepaid this 1st day of September ,1981:

• Andr ew C. Goodbope , Esq. Henry Herrman, Esq.

Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massachusetts 02109 3320 Estelle Terrace Wheaton, Maryland 20906 Mr. & Mrs. Alan R. Cleeton 22 Mackintosh Street Dr. A. Dixon Callihan Franklin, Massachusetts 02038 Union Carbide Corporation P.O. Box Y William S. Abbot, Esq.

Oak Ridge, Tennessee 37830 Suite 925 50 Congress Street Dr . Richard F. Cole Boston, Massachusetts 02109 Atomic Safety and Licensing Board Thomas G. Dignan, Jr., Esq.

U.S. Nuclear Regulatory Ropes & Gray Commission 225 Franklin Street Washington, D.C. 20555 Boscon, Massachusetts 02110 Patrick J. Kenny, Esq. Atomic Safety and Licensing Edward L. Selgrade, Esq. Appeal Board Deputy Director U.S. Nuclear Regulatory Mass. Office of Energy Commission Resources Washington, D.C. 20555 73 Tremont Street Boston, Massachusetts 02108

T Atomic Safety and Licensing Office of the Secretary Board Panel Docketing and Service Section U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission

. Commission Washington, D.C. 20555 Washington, D.C. 20555 Chief Librarian Jack R. Goldberg Plymouth Public Library Office of the Executive North Street Legal Director Plymouth, Massachusetts 02360 U.S. Ni: clear Regulatory Commission William S. Stowe, Esquire Washington, D.C. 20555 Boston Edison Company 800 Boylston Street Thomas S. Moore, Chairman Boston, Massachusetts 02199 Atomic Safety and Licensing Appeal Board Francis S. Wright, Esquire U.S. Nuclear Regulatory Berman & Lewenberg Commission 211 Congress St.

Washington, D.C. 20555 Boston, Massachusetts 02110 Christi ne N. Kohl, Esquire Dr. John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Wr,shington, D.C. 20555 Steohen H. Lewis R. K. Gad III U.S. Nuclear Regulatory Ropes & Gray Commission 225 Franklin Street Office of the Executive Boston, Massachusetts 02110 Legal Director Washington, D.C. 20555 Michael Blume U.S. Nuclear Regulatory Commission Office of the Executive Lecal Director Washington, D.C. 20555 ft -

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@ fann Shotwell Msistant Attorney General l Enviromnental Protection Jivision Public Protection Bureau Department of the Attorney General '

l One Ashburton Place, 19th Floor Boston, Massachusetts 02108 l

l (617) 727-2265

• By Express Mail

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