ML20062D218

Believes That Alternative Sites Issue Is at Heart of Nuc Lic Process & That NEPA Mandates the Recirculation of Fes Suppl in This Case

ML20062D218
Person / Time
Site:	05000471
Issue date:	11/03/1978
From:	Abbott W SIMMONDS, WINSLOW, WILLIS & ABBOTT
To:	Cunningham G, Harold Denton Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 7811210140
Download: ML20062D218 (2)

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S I M O N DS. WI N S LOW, WI LLIS & AB B OTT A . se o r t s a s o N a b ASSOceATsON ATT O R N CY S AT LAW So CONG ACSS STRCCT BOSTON, M A S S A C H U S CTTS O2:09 weLLIAM S ABBOTT AaEA Coot es7 523-5520 November 3, 1978 Guy Cunningham III, Esquire Assistant Chief Hearing Counsel and Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 Washington, D.C. 20555 Re: Boston Edison Co., Pilgrim Unit, Docket No 50-471 Gentlemen: .

We understand by virtue of a telephone call from Barry. Smith, Esquire on October 12, 1978, that a meeting w'as held in your offices with Boston Edison Company officials on October 12,'1978 to discuss the subject of recirculation of the FES supplement 3 J

pertaining to the alternative sites analysis. It is also.our understanding that Mr. Denton had concluded that recirculation -

was appropriate in this case, and that Edison challenged such action at this meeting and was invited to file further written comments within ten days of the meeting.

1 I am in receipt of a memorandum prepared by_ Boston Edison dated October 20, 1978 in support of its position that recircula-tion is not required.

,W e believe that the altern 1tive sites issue is at the heart of the nuclear licensing process and that NEPA mandates the re-circulation of such FES supplement in this case. We are of the further opinion that the Licensing Board hearing on the alterna-tive sites issue should not proceed until recirculation has been completed.

Very truly yours, 7811s1oNO. A M 7t#@g William S. Abbott Attorney for Alan and Marion Cleeton cc: Service List Attached p hO

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Guy Cunningham III, Esquire Harold R. Denton, Director November 3, 1978 Page Two SERVICE LIST:

George H. Lewald, Esquire Dr. A. Dixon Callihan Ropes & Gray Union Carbide Corporation 225 Franklin Street P.O. Box Y Boston, Massachusetts Oak Ridge, Tennessee 37830 Dale G. Stoodley, Esquire Barry H. Smith, Esquire Boston Edison Company U.S. Nuclear Regulatory Commissio5 800 Boylston Street Washington, D.C. 20555 Boston, Massachusetts 02199 Henry Herrmann, Esquire 151 Tremont Street, 27K Boston, Massachusetts 02111 Mr. Daniel F. Ford c/o Union of Concerned Scientists 1208 Massachusetts Avenue Cambridge, Massachusetts 02138 Mr. and Mrs. Alan R. Cleeton 22 Mackintosh Street Franklin, Massachusetts 02038 The Honorable Charles Corkin, II Assitant Attorney General Environmental Protection Division One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Edward Luton, Esquire, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555