ML20010B203

Second Set of Requests for Production of Documents Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence

ML20010B203
Person / Time
Site:	05000471
Issue date:	08/05/1981
From:	Shotwell J MASSACHUSETTS, COMMONWEALTH OF
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8108140212
Download: ML20010B203 (5)

Text

-.*_.- , _ . - _ .

W RELX1ED COluiESPONDE'.'C3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) '

) '\ 'h BOSTON EDISON COMPANY, et al. ) DockYtb s (Pilgrim Nuclear Generating )

&/

D/ I47}$h' Station, Unit 2) )

) J r \y C .cg I'

)

-j g S '@/

. h' b' COMMONWEALTH OF MASSACHUSETTS' SECOND SET"OF .,Y/

/ .

V/*

1. M REQUESTS FOR PRODUCTION OF DOCUMENTS FROM THE NUCLEAR REGULATORY COMMISSION STAFF b mo 10190)F 7 RELATIVE TO EMERGENCY PLANNING ( t'

'[#{

s

.w . W,

'O Pursuant to 10 C.F.R. 52.744, the Intervenor Commonwealth

! of Massachusetts hereby requests the NRC Staf f to produce and i

l permit the Commonwealth to inspect and copy the documents i

l designated below at the offices of the Attorney General, One Ashburton Place, 19th Floor, Boston, Massachusetts, 02108 on or

before September 8, 1981, at 10

00 a.m.

l D 6#T s ll D 8108140212 810805 gDRADOCK 05000471 POR

r I

DEFINITIONS The term " document (s)" refers to the original and copy (but not both if identical in every respect) of any printed, written, recorded, transcribed, punched, taped, filmed, photographed or graphic matter in the possession or subject to the control of the NRC or any Commissioner, employee, agent or attorney thereof, whether sent or received or neither, whether a draft or otherwise, however produced or reproduced, and both sides thereof, including but not limited to, any memorandum, correspondance , letter , af fidavit, court paper, transcript, ,

diary , report , study , telegram, table , telex message , record ,

chart, paper, work paper, gramb, index, book, notebook, pamphlet, periodical, tape data sheet, data processing card, note, notation, minute desk calendar, appointment book, sound recording, computer print-out or microfilm.

DOCUMENTS REQUESTED (1) All documents identified by the Staff in answer to the Commonwealth's Second Set of Interrogatories to the Nuclear Regulatory Commission Staff Relative to Emergency Planning, including any reports, studies, papers, articles, and books identified in response to Interrogatory No. 8. The Commonwealth states, as required by 10 C.F.R. 5 2. 74 4 (a) , that these documents are clearly relevant to this proceeding as they have been identified by the Staff as pertaining to the subject matter of and/or forming bases for Staff answers to

-::: . - - ::T:"::::.: L : . L . :: :. . ~_ ^ - ~ ~ ~

^

, c i

interrogatories which relate specifically to the issues of the 1

feasibility of emergency measures-at Pilgrim and the adequacy I

{

of current plans therefor. Any documents identified in f response to Interrogatory No. 8 are of particular relevance to this proceeding since they have been written, at least in part, by individuals who will offer testimony during the hearing or l .

i

organizations with which they are affiliated. l l

! (2) Transcripts e,and copies in the case of written testimony) of all tectimony listed in response to Interrogatory j i

No. 7 of the Commonwealth's Second Set of Interrogatories to l

i

\

the Nuclent Regulatory Commission Staff Relative to Emergency l l

Planning which relates in any way to the subject of emergency 1

planning Any documents responsive to this request are clearly I

relevant to this proceeding as they constitute prior pronouncements by individuals who will offer testimony during l this hearing,- or organizations with which they are affiliated, l I

on the very subject which will be at issue.

(3) A copy of "The Consequences From Liquid Pathways  :

After a Reactor Meltdown Accident" prepared for the NRC by f S. J. Niemczyk of Sandia Labora*ories and all documents l relating thereto, including correspondence between the Staff f and Sandia and internal Staff memoranda. These documents are I

relevant to the Commonwealth's contentions, since they relate l f l to an entire class of accident consequences which must enter into any assessment of the feasibility of emergency measures l and the adequacy of plans therefor.

I l i- . - - . - -_ -

p 4

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

)

In the Matter of )

)

BOSTON EDISON COMPANY et al. ) Docket No. 50-471 (Pilgrim Nuclear Generating )

Station, Unit 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that the within Request been served on the following by deposit of copies thereof in the United States Mail, first class mail, postage prepaid this 5th day of August, 1981:

Andrew C. Goodhope, 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 l

50 Congress Street Dr. Richard F. Cole Boston, Massachusetts 02109 Atomic Safety and l Licensing Board Thomas G. Dignan, Jr., Esq.

U.S. Nuclear Regulatory Ropes & Gray l

Commission 225 Franklin Street Washington, D.C. 20555 Boston, 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 l 20555

! Resources Washington, D.C.

73 Tremont Street Boston, Massachusetts 02108 l

l

(

Atomic Safety and Licensing Office of the Secretary Board Panel Docketing and Service Section U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission l Commission Washington, D.C. 20555  !

Washington, D.C. 20555 Chief Librarian Jack R. Goldberg Plymouth Public Library i I

Office of the Executive North Street 02360 Legal Director Plymouth, Massachusetts l l

U.S. Nuclear Regulatory Commission William S. Stowe, Esquire Washington, D.C. 20555 Boston Edison Company l 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 Christine 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 Washington, D.C. 20555 i Stephen H. Lewis R. K. Gad III U.S. Nuclear Regulatory Ropes & Gray Commission 225 Franklin Street Boston, Massachusetts 02110 Office of the Executive Legal Director Washington, D.C. 20555 4 S go nn Shotwel1' '

ssistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265 l

l

_ _ . . _ _ _ - . . . _ . . _ . _ _ _ _ _ _ . . . . - _ _ _ _ . _ . __ - . _ _ . _. _