ML20154S281

Comments on Stipulation as to Contentions

ML20154S281
Person / Time
Site:	Seabrook
Issue date:	09/27/1988
From:	Traficonte J MASSACHUSETTS, COMMONWEALTH OF
To:	Harbour J, Linenberger G, Smith I Atomic Safety and Licensing Board Panel
Shared Package
ML20154S248	List: ML20154S244 ML20154S281
References
OL, NUDOCS 8810050032
Download: ML20154S281 (3)

Text

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AN THE COMMONWEALTH OF MASSACHUSETTS j le CEPARTMENT OF THE ATTORNEY GENERAL k,

JOHN w McCoAMACK STATE CFFICE BUILDING

/' CNE ASH 8URToN PLACE. BOSTON 02108 1698

>MES M SMANNQh

. -ase,m..u September 27, 1988 l t'AX Ivan Smith, Chairman Gustave Linenberger Jerry Harbour U.S. Nuclear Regulatory Commission Washington, DC 20555 Dear Judges; After review of the document antitled "Stipulation as to Contentions" and consultation with counsel representing several other intervenors, I offer these hopefully clarifying Corament3

1. Intervenors remain convinced that after contentions are admitted, bases offered (or not offered) in support of their admission do not limit the admissible evidence as to those contentions.

De100D003;? 000'130 PDR ADOCK 05000443 g PDR

2. The Stipulation *s primary purpose was to gpnsolidate contentiqDE around issues. This was done in the following manner:

A. The following Joint Intervenor Contentions are essentially unchanged although some have been consolidated: JI 6, 9, 10, 17, 24, 26, 27, 31, 34, 35, 37, 52, 58, 59, 61; B. The following JI contentions were reduced to J

the contention statement only but the bases as admitted are essentially incorpnrated by reference: JI 1, 3, 11, 12, 15, 20, 22, 25, 28, 29, 32, 36, 38, 39, 40, 47, 48, 54, 56, 57; I

C. The following JI contentions were consolidated and the contention statement was rewritten but the bases were omitted and are incorporated by reference: JI S, 7, 8, 13, 16, 18, 19, 21, 23, 30, 45, 46, 49, 50, 51, 53, 55, 60, 62, 63; D. The following JI contentions were rewrittet:

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j (both the contention statement and the bases) and supercede j older versions: JI 2, 4, 14, 33; 1

E. Finally, the legal contentions JI 41, 42, '

i and 43 were reduced to the col C.: *1' s t a t e.nent and JI 44A and  :

44B are set forth in full.

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3. The following changes should be made:

A. CON 6 is now part of JI 4. It should be l placed in JI 60 and JI 60 should include the City of ,

Newburyport in its text; f

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• B. TOWN 3 should be added as part of the  !

derivation of JI 30 and JI 32 (as well as JI 24 as at present);

C. '

TOS 16 should be deleted as a derivation of JI 38 and should not appear as a separate contention. '

very truly yours,

, gl

$. ,( ' l , y f, Jo Traficont s #

Assistant Attorney General Nuclear Safety Unit Attorney General's Office i

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