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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20216F4891999-09-17017 September 1999 Comment Supporting NEI Comments Re Proposed Rules 50 & 72 Re Certain Reporting Requirements for Nuclear Power Reactors. Expresses Concern Re Proposed Reporting Requirement 10CFR50.73(a)(2)(ii)(c) Re Significantly Degraded Component ML20206A0541999-04-26026 April 1999 Memorandum & Order.* All Petitioners to Intervene Have Withdrawn Their Petition,Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205S0031999-04-23023 April 1999 Affidavit of JW Yelverton Supporting Proposed License Transfer & Conforming Amends.Util Requests That Designated Documents Be Withheld from Public Disclosure,Per 10CFR2.790 (a)(4) & 10CFR9.17(a)(4) ML20203G7821999-02-16016 February 1999 Petition of Local 369 & 387,Utility Workers Union of America,AFL-CIO for Leave to Intervene & Request Hearing.* Requests That Hearing Be Scheduled on Commission Consideration to Approve Transfer.With Certificate of Svc ML20153C1411998-09-20020 September 1998 Comment on Proposed Rule 10CFR2 & 51 on Subpart M Re Transfer of Operating License ML20100M5251996-03-0101 March 1996 Comment on Proposed Rule 10CFR20 Re Rept Requirements for Unauthorized Use of Licensed Radioactive Matl.Proposed Rule Change Wording Concerning What Conditions Must Be Met to Require Reporting Inexact ML20101B9931996-03-0101 March 1996 Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matls BECO-95-125, Comment Supporting Pr 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel1995-12-14014 December 1995 Comment Supporting Pr 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel ML20093B5971995-10-0303 October 1995 Comment on Proposed Bulletin 95-XX & Reg Guide DG-1038, Debris Clogging of BWR ECCS Suction Strainers. Endorses BWROG Comments ML20086A8791995-06-14014 June 1995 Comment Supporting Proposed Rule 10CFR73 Re NRC Initiative to Eliminate Requirement to Post Security at Primary Containment Entrance During Refueling & Major Maint Periods ML20082Q5511995-04-21021 April 1995 Comment on Proposed Rules 10CFR170 & 171 Re Fee Schedules for FY95 Revisions.Endorses NEI Comments ML20082M3251995-04-14014 April 1995 Comment Supporting Proposed Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Concerns W/O Fear of Retaliation ML20078L2151995-02-0303 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20078S6631994-12-19019 December 1994 Comment Supporting Proposed GL Re Reconsideration of NPP Security Requirements for an Internal Threat ML20076L2561994-10-24024 October 1994 Comments on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Endorses Response Submitted by Nuclear Energy Institute ML20062M4241994-01-0303 January 1994 Comment Supporting NUMARC Position on Proposed Rule Re Protection Against Malevolent Use of Vehicles at NPPs ML20059C3721993-12-29029 December 1993 Exemption from DAC Values for Kr-89 & Xe-137 in Table 1 of App a to 10CFR20.Approves Use of Proposed Values in Request When Determining Whether Area Requires Posting as Airborne Radioactivity Area BECO-93-166, Comment Supporting NUMARC Petition for Rulemaking to Amend 10CFR21,PRM 21-21993-12-28028 December 1993 Comment Supporting NUMARC Petition for Rulemaking to Amend 10CFR21,PRM 21-2 ML20058P1811993-12-14014 December 1993 Director'S Decision 93-20 Denying Petition to Delaying Startup Until Hardware Modifications Designed to Eliminate Errors in Reactor water-level Measurement Made ML20058D6561993-11-19019 November 1993 Director'S Decision Under 10CFR2.206 Denying Petition Requesting That NRC Reconsider 910730 Decision Giving Unanimous Approval of Task Force Recommendation Re Reasonable Assurance Finding Re EP for Plant ML20057C0951993-09-13013 September 1993 Memorandum & Order (Termination of Proceeding).* Informs of Petitioner Withdrawal of Motion to Intervene & Request for Hearing,Therefore Board Terminates & Dismisses Proceeding Herein.W/Certificate of Svc.Served on 930914 ML20057C1281993-09-13013 September 1993 Memorandum & Order (Termination of Proceeding).* W/Certificate of Svc.Served on 930916 ML20057A1531993-09-0202 September 1993 NRC Staff Response to Ma Atty General Withdrawal of Motion to Intervene & Request for Hearing.* NRC Does Not Object to Atty General Withdrawal.Licensing Board Should Issue Order Dismissing Proceeding.W/Certificate of Svc ML20056G5081993-08-26026 August 1993 Commonwealth of Ma Atty General Withdrawal of Motion to Intervene & Request for Hearing.* W/Certificate of Svc ML20056E6871993-08-13013 August 1993 Memorandum & Order (Extension of Time).* Petitioner Suppl W/ Contentions Should Be Filed by 930827 & Licensee Response to Suppl Should Be Filed within 10 Days Thereafter.W/ Certificate of Svc.Served on 930813 ML20046D0251993-08-11011 August 1993 Joint Motion to Extend Date for Filing Petitioners Contentions.* Parties Jointly Request That Board Extend Date for Filing Petitioner Contentions from 930813 to 930827. W/Certificate of Svc ML20056C8601993-07-16016 July 1993 Memorandum & Order (Extension of Time).* Petitioner Suppl W/ Contentions Should Be Filed by 930813,util Response to Suppl within 10 Days After Svc & NRC Response to Suppl within 15 Days After Svc.W/Certificate of Svc.Served on 930719 ML20056C8971993-07-15015 July 1993 Joint Motion to Extend Date for Filing Petitioners Contentions.* W/Certificate of Svc ML20045D2201993-06-0808 June 1993 Response of Boston Edison Co to Commonwealth of Ma Atty General Request for Hearing & Petition to Intervene.* Util Will Defer Further Response Until Petitioner Files Suppl Re Specific Contentions.Certificate of Svc Encl ML20045D2271993-06-0808 June 1993 Response of Boston Edison Co to Ma Atty General Request for Hearing & Petition to Intervene.* W/Certificate of Svc & Notices of Appearance ML20045A6721993-05-27027 May 1993 State of Ma Atty General Request for Hearing & Petition to Intervene Re Plant Proposed Amend to License DPR-35 Increasing Allowed Fuel Assembly Storage Cells.* W/Certificate of Svc ML20045A6741993-05-27027 May 1993 Notice of Appearance.* Notice of Appearance of Undersigned for State of Ma Atty General BECO-92-135, Comments on Proposed NRC Generic Communication,Augmented Inservice Insp Requirements for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys1992-12-21021 December 1992 Comments on Proposed NRC Generic Communication,Augmented Inservice Insp Requirements for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20115A6581992-10-0505 October 1992 Comments on Proposed Changes to SALP Program BECO-92-073, Comment Opposing Draft Rev 3 to Reg Guide 01.0091992-07-10010 July 1992 Comment Opposing Draft Rev 3 to Reg Guide 01.009 BECO-92-072, Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & SNM1992-07-10010 July 1992 Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & SNM ML20086K8791991-10-31031 October 1991 Petitions Commission to Reconsider 910730 Approval of Task Force Recommendation Stating That NRC Did Not Need to Reconsider NRC Reasonable Assurance Finding Re Emergency Preparedness for Pilgrim Station ML20135A4581991-06-12012 June 1991 Transcript of 910612 Meeting in Plymouth,Ma Re Pilgrim Task Force Public Hearing.Pp 1-148.W/certificate & Title Page BECO-91-067, Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery1991-05-13013 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery ML19332G5121989-12-0101 December 1989 Comment on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Endorses Nuclear Power Industry Comments & NUMARC Position ML20235A9561988-12-0909 December 1988 Transcript of 881209 Meeting in Rockville,Md W/Public Officials Having Responsibility for Emergency Planning for Pilgrim Nuclear Power Plant.Related Info Encl.Pp 1-185 ML20205E1531988-10-14014 October 1988 Transcript of 881014 Meeting in Rockville,Md Re Discussion/ Possible Vote on Facility Restart.Pp 1-104.Supporting Documentation Encl ML20155D9391988-10-0505 October 1988 Second Interim Director'S Decision DD-88-17 Under 10CFR2.206 Re Request for Proceeding to Modify,Suspend or Revoke Ol.Portion of Petition Re Mgt Issues Denied.Portion Re Emergency Preparedness Issues to Be Addressed Later ML20205J3531988-10-0505 October 1988 Transcript of 881005 Meeting in Rockville,Md Re Status of Readiness for Restart of Facility.Pp 1-94 ML20206G9181988-09-29029 September 1988 Transcript of NRC 880929 Technical Meeting in Plymouth,Ma Re Review of Proposed Restart of Facility & NRC 881005 Meeting W/Util in Rockville,Md Re Readiness of Restart ML20153H0381988-08-26026 August 1988 Transcript of ACRS Ad Hoc Subcommittee on Pilgrim Restart 880826 Meeting in Plymouth,Ma.Pp 1-232.Related Documentation Encl ML20235T8761988-08-25025 August 1988 Rev 0 to Pilgrim Station Evacuation Time Estimates & Traffic Mgt Plan Update.* Apps A,B & M Encl ML20235T7301988-08-15015 August 1988 Rev 4 to Massachussetts Civil Defense Agency Area II Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* ML20235T6901988-07-28028 July 1988 Rev 5 to City of Taunton Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* Related Info Encl ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons 1999-09-17
[Table view] Category:NOTICES
MONTHYEARML20236T1911987-11-13013 November 1987 Receipt of Petition for Director'S Decision Under 10CFR2.206.* Requested Order Barring Plant Restart Not Immediately Necessary Since Plant Shut Down & Will Not Be Restarted W/O NRC Determination of Safety Issues ML20134C8601985-08-13013 August 1985 Notice of Appeal of ASLB 850719 Order Dismissing 850629 Petition for Leave to Intervene.Svc of Process Encl ML20127A0591985-08-0101 August 1985 Notice of Aslab Constitution.As Rosenthal,Chairman & WR Johnson & Gj Edles,Members.Served on 850802 ML20128M4181985-07-18018 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20129D3681985-07-12012 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20129D3461985-07-12012 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20129D3201985-07-12012 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20128K1591985-07-0808 July 1985 Notice of ASLB Constitution.Ps Bloch,Chairman & Ga Linenberger & J Harbour,Members.Served on 850709 ML20042A3901982-03-19019 March 1982 Notice of Intent to File Brief by 820331 in Response to NRC & Licensee Responses to 820217 Petition to Intervene. Certificate of Svc Encl ML20136B2961979-03-0808 March 1979 Notice of Proposed Imposition of Civil Penalties as Consequence of Insp Rept 50-293/77-31 on 771128-30. Enforcement History Relating to Radiation Protection Encl 1987-11-13
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20086K8791991-10-31031 October 1991 Petitions Commission to Reconsider 910730 Approval of Task Force Recommendation Stating That NRC Did Not Need to Reconsider NRC Reasonable Assurance Finding Re Emergency Preparedness for Pilgrim Station ML20235T8761988-08-25025 August 1988 Rev 0 to Pilgrim Station Evacuation Time Estimates & Traffic Mgt Plan Update.* Apps A,B & M Encl ML20235T7301988-08-15015 August 1988 Rev 4 to Massachussetts Civil Defense Agency Area II Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* ML20235T6901988-07-28028 July 1988 Rev 5 to City of Taunton Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* Related Info Encl ML20235T9091988-07-11011 July 1988 Draft Rev 5 to Town of Marshfield Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* Related Documentation Encl ML20235U0861988-07-0303 July 1988 Rev 2 to Offsite Emergency Preparedness Training for Pilgrim Nuclear Power Station Module 12:transportation Lesson Plan 12-1,introduction to Transportation Providers.* ML20235T7481988-03-0909 March 1988 Rev 4 to Town of Bridgewater Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* Related Info Encl ML20236T1911987-11-13013 November 1987 Receipt of Petition for Director'S Decision Under 10CFR2.206.* Requested Order Barring Plant Restart Not Immediately Necessary Since Plant Shut Down & Will Not Be Restarted W/O NRC Determination of Safety Issues ML20235T8651987-10-30030 October 1987 Draft Rev 6 to Town of Plymouth Radiological Emergency Response Plan for Pilgrim Nuclear Power Station.* ML20134C8601985-08-13013 August 1985 Notice of Appeal of ASLB 850719 Order Dismissing 850629 Petition for Leave to Intervene.Svc of Process Encl ML20127A0591985-08-0101 August 1985 Notice of Aslab Constitution.As Rosenthal,Chairman & WR Johnson & Gj Edles,Members.Served on 850802 ML20128M4181985-07-18018 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20129D3681985-07-12012 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20129D3461985-07-12012 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20129D3201985-07-12012 July 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20128K1591985-07-0808 July 1985 Notice of ASLB Constitution.Ps Bloch,Chairman & Ga Linenberger & J Harbour,Members.Served on 850709 ML20042A3901982-03-19019 March 1982 Notice of Intent to File Brief by 820331 in Response to NRC & Licensee Responses to 820217 Petition to Intervene. Certificate of Svc Encl ML20136B2961979-03-0808 March 1979 Notice of Proposed Imposition of Civil Penalties as Consequence of Insp Rept 50-293/77-31 on 771128-30. Enforcement History Relating to Radiation Protection Encl ML20126B1631973-07-20020 July 1973 Notifies That on 730712,Friends of Earth Filed Petition Seeking Emergency Derating,To Unspecified Extent,Of Nine Licensed NPPs as Listed 1991-10-31
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UNITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
BOSTON EDISOM COMPANY )
(Pilgrim Nuclear Power ) Docket No. 50-293 Station) ) (EA 81-63)
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ATTORDEY GENERAL'S NOTICE OF INTENT TO FILE BRIEF On February 17, 1982, the Attorney General for the Common-wealth of Massachusetts, Francis X. Bellotti, filed a Petition with the Commission seeking to intervene in its proceeding for nodification of the operating license for the Filgrim Nuclear Power Station in Plyrouth, Massachusetts. Boston Edison Company, the operator of the Pilgrim facility, and the Commission's Staff
! have both filed responses opposing the Attorney General's Peti-tion.
Attorney General Bellotti wishes to submit for the Commission's consideration a brief addressing the issues raised in the licen-see's and Staff's responses to his Petition. The Commission's procedural regulations provide no guidance as to the time within which the Attorney General should submit such a brief. Therefore, the Attorney General submits this Notice to advise the Commission that he wishes to file a brief in this matter and plans to do so on or before March 31, 1982.
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~2-Respectfully submitted, FRANCIS X. BELLOTTI ATTORNEY GENERAL of the Commonwealth of Massachusetts
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By: -
JO ANN SHOTWELL Assistant 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: March 19, 1982 l.
,0 CERTIFICATE OF SERVICE I, Jo Ann Shotwell, l.areby certify that on March 19, 1982, I made service of the within document by mailing a copy thereof, postage prepaid, to:
Thomas G. Dignan, Jr., Eso. Thomas M. Roberts, Commissioner Ropes & Gray U.S. Nuclear Regulatory Commission 225 Franklin St. Washington, D.C. 20555 Boston, Mass. 02110 Stephen G. Burns, Esq.
Office of the Executive Legal Director MNBB - 9604 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Peter Bradford, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John F. Ahearne, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard DeYoung, Director Office of Inspection and Enforcement .
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -
Signed under the pains and penalties of perjury this 19th day of March, 1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
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BOSTON EDISON COMPANY )
Docket No. 50-293 PILGRIM NUCLEAR POWER STATION: ) License No. DPR-35 Order Modifying License ) EA 81-63 Eff ective -Immediately )
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PETITION OF THE MASSACHUSETTS ATTORNEY GENERAL TO INTERVENE IN PROCEEDING FOR MODIFICATION OF PILGRIM STATION OPERATING LICENSE on January 18, 1982, the Commission's Office of Inspection and Enforcement issued an: Order modifying the operating license for the Pilgrim Nuclear Power Station in Plymouth, Massachusetts. That Order provides that "[c]ontinued operation of the Pilgrim facility requires significant changes in Boston Edison Company's control of licensed activities" and requires that the Company submit to the NRC, within thirty days
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of the Order, "a comprehensive plan of action that will yield an independent. appraisal of site and corporate management organizations and functions, recommendations for improvements l in management controls and oversight, and a review of previous l
safety-related activities to evaluate compliance with NRC l
1 requirements." See Order Modifying License Effective i
Immediately, Docket No. 50-263 (January 18, 1982) at 6.
(Hereinafter, " Order")
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For the reasons set forth below, Attorney General Francis X. Bellotti hereby exercises his right, pursuant to Section 189 (a) of the Atomic Energy Act of 1954, 42 U.S.C. S2239 (a) , to intervene in the NRC's proceeding in this matter on behalf of the citizens of the Commonwealth of Massachusetts. Attorney General Bellotui is the chief law officer of the Commonwealth, responsible for establishing the legal policy of the Commonwealth. Secretary of Administration and Finance v.
Attorney General, 326 N.E.2d 334 (Mass . , 197 5) . He is a separately elected officer, representative of the citizens of this state and seeks, through this intervention, to protect the interests of the Commonwealth and his constituents in the safe opeation of the Pilgrim plant. Attorney General Bellotti further requests, pursuant to Section 189(a), that a public hearing be held in this matter in the Town of Plymouth to allow for public review of the serious deficiencies identified in the Commission's Order and the Company's proposed remedial actions. Any action as significant as the amendment of an operating license for a nuclear power plant should'be subjected to maximum public exposure.
I. THE INTERESTS OF THE CITIZENS OF MASSACHUSETTS ARE AFFECTED BY THIS PROCEEDING According to its Order, the Office of Inspection and Enforcement has taken this action because of Boston Edison's numerous regulatory violations over the past several years, its below average rating in the NRC's recent Systematic Assessment
of Licensee Performance ("SALP"), and deficiencies discovered during NRC inspections between June 15 and September 30, 1981.
Those inspections revealed inadequacies in Boston Edison's controls in several functional areas of activity, including engineering and design review, revision of operating proce-dures, facility maintenance, notification of safety problems, and onsite safety committee activities. See Order, at 2.
Together with the weaknesses identified by the SALP and NRC enforcement actions over the past 2 1/2 years, the deficiencies discovered during these inspections have led the Office of Inspection and Enforcement to conclude that there exist
" substantial serious breakdowns in Boston Edison Company's management controls related to the Pilgrim facility" and that the "public health, safety and interest" require that significant changes be made in the Company's control of licensed activities. See Order at 6.
In light of these findings by the Commission staff, there can be no doubt that the citizens of Massachusetts have a direct and substantial interest in the subject matter of this Order. .71thout participating in the review of the Company's proposed corrective actions, the public can have no assurance that continued operation of the facility will not jeopardize their health and safety.
II. THE ATTORNEY GENERAL OF THE COMMONWEALTH OF MASSACHUSETTS HAS A NON-DISCRETIONARY RIGHT TO INTERVENE IN THIS PROCEEDING PRIOR TO ANY FURTHER NRC ACTION
The Atomic Energy Act of 1954 provides that "[i]n any proceeding, under this chapter, for the granting, suspending, revoking, or amending of any license . . . the Commission shall grant a hearing upon the request of any person whose interest may be affected by the proceeding, and shall admit any such person as a party to such proceeding." (Emphasis supplied.)
By its own terms, the Commission's action constitutes a modification of Boston Edison's license, and there is thus no discretion to deny this petition and hearing request filed on behalf of persons clearly affected by the subject matter of this license amend'.nent. Given this non-discretionary statutory obligation, the Commission's review of this Petition is limited to the question of whether the Petition properly sets forth the aspects of this proceeding as to which the Attorney General is intervening. See BPI v. Atomic Enerov Commission, 502 F.2d 424 (D.C . C ir . 1974 ).
The Commission has arguably failed already to comply with the procedural requirements of Section 189 (a) in that it has l
not provided thirty days' notice in the Federal Register of its l
intent to amend the Pilgrim license to allow for notices of intervention and hearing requests. This apparent failure will not prejudice Attorney General Bellotti in his effort to protect the interests of Massachusetts citizens, provided the Commission takes no'further action in this matter pending his admission as a party. Approval by,the Commission or its staff l
of Boston Edison's action plan, or other formal action thereon, pending admissi'on of the Attorney General as a party and an opportunity for exercise of the rights which attend that status would violate Section 189 (a) .
Therefore,f the Attorney General asks that he receive written assurance, within seven days of the receipt hereof, i
that the Commission will honor his trights under Section 189 (a) and suspend furthers formal action on Boston Edison's action plan pending his admission and participation in this matter.
III. ATTORNEY GENERAL BELLOTTI INTENDS TO PARTICIPATE FULLY '
IN EVERY ASPECT OF THIS PROCEEDING TO ASStTRE THE .
SAFETY OF MASSACEUSETTS CITIZENS '
s AttorneyGeneralBellottimoves\tointerveneinthis proceeding so as to participate in ali the issues considered, including but not limited to the followingth!
- 1. Any consideration of Boston Edison's continued operation of Pilgrim I pending'the identification and implementation of the necessary changes in Bos' ton Edison's management controls.
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As a separate matter, this office has notified the Commission that it unticipates exercising its rights pursuant to section 189 (a) with respect to appro :1 of the revised emergency plans for the Pilgrim Sta' tion. We suggest that the staff be required to complete its review of those plans in time that a hearing thereon, if it is necessary, can be conducted together with the hearing sought in this petition.
- 2. The adequacy of the plan of action submitted by Boston Edison, including the following issues:
- a. The appropriateness of the parties chosen to conduct the review of site and corporate management organizations and functions and the various reviews of safety-related activities set forth in paragraphs (1) and. (3) through (6) of the Order.
- b. The schedule for completion of these reviews.
- c. The specific matters to be addressed in these reviews.
- 3. The nature of the improvements which must be made in the Company's site and corporate management organization's and functions and safety-related activities to ensure the safe operation of the plant.
- 4. The determination as to whether Boston Edison has properly implemented all necessary improvements such that operation of the plant may continue.
IV. CONCLUSION For the reasons outlined herein, Attorney General Bellotti asks, on behalf of the Commonwealth of Massachusetts and its citizens , that he be admitted as a party to this proceeding and that no further action be taken by the NRC in this matter pending,his admission. Attorney General Bellotti further requests that a public hearing be held in the Town of Plymouth on the mattirs which are the subject of this proceeding.
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Respectfully submitted, FRANCIS X. BELLOTTI ATTORNEY GENEPAL i3 By: '
'!/ /.h s PAULA W. GOLD y Assistant Attorney General Chief, Public Protection Bureau nd A STESHEN M. LEONA41D 7#
Assistant Attorney General Chief, Environmental Protection Divis
- b. us l,- r NN SHOTWELL '
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stant Attorney General vironmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Bosten, Massachusetts 02108 l (617) 727-2265 Dated: February 17, 1982 l
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CERTIFICATE OF SERVICE I, Jo Ann Shotwell, hereby certify t' hat I have this day served a copy of the foregoing Petition on the NRC legal staff by mailing a copy thereof, postage prepaid, to the Executive Legal Director, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
Signed under the pains and penalties of perjury this 17th day of February, 1982.
By: /3 -_ '
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JO /NN SHOTWELL v AssL5 tant Attorney General Eny'ironmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265 CERTIFICATE OF SERVICE I, Jo Ann Shotwell, hereby certify that I have this day served a copy of the foregoing Petition on Boston Edison Company by mailing a copy thereof, postage prepaid, to its attorney, Thomas G. Dignan, Esq., Ropes and Gray, 225 Franklin Street, Boston, Massachusetts 02110.
Signed under the pains and penalties of perjury this 17th day of February,,1982.
By: / % _ M
, JCy SNN SHOTWELL "
A W1stant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor l
Boston, Massachusetts 02108 l