ML20009F836

Interrogatories Directed to Commonwealth of Ma Re Emergency Planning & TMI-related Issues.Certificate of Svc Encl. Related Correspondence

ML20009F836
Person / Time
Site:	05000471
Issue date:	07/27/1981
From:	Dignan T, Stowe W BOSTON EDISON CO., ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
NUDOCS 8108030082
Download: ML20009F836 (7)

Text

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UNITED STATES OF AMERICA

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In the Matter of

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BOSTON EDISON COMPANY, et al.

Docket No.

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Station Unit 2

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APPLICANTS' INTERROGATORIES TO THE COMMON 5 VALTH OF MASSACHUSETTS ON EMERGENCY PLANNING Ah h, f

TMI-2 RELATED ISSUES N

Pursuant to 10 CFR SS2.740 and 2.740b, the following interrogatories are propounded to the Commonwealth of Massa-chusetts to be answered fully in writing and under oath.

1.

Please state in detail each respect in which the Commonwealth of Massachusetts contends that the Appli-cants' preliminary plans for coping with emergencies fails to comply with the requirement of 10 CFR 50, z

Appendix E, Part II.

2.

Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to 9

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interrogatory number 1.

Please identify each document, and the particular parts thereof, of which the Common-wealth is aware which supports each fact so identified in this interrogatory.

Please further indicate each such document which the Commonwealth intends to offer in evidence in this proceeding.

For the purpose of this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison Company.

3.

Please state in detail each respect in which the Common-wealth of Massachusetts contends that the Applicants either fail to address or inadequately address the provisions of NUREG 0718, Revision 1, in their application for a construction permit, including the PSAR and amendments thereto.

l 4.

Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to interrogatory number 3.

Please identify each document, and the particular parts thereof, of which the Common-

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wealth is aware which supports each ' fact so identified in this interrogatory.'

Please further indicate each such document which the Commonwealth intends to offer i

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in evidence in this proceeding.

For the purpose of l

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this interrogatory, please utilize the same definition l

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of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison Company.

5.

For each item contained under the heading "TMI-2 Related Requirements" in the Staff's Supplement No. 6 to the Safety Evaluation Report for Pilgrim Unit 2 (which items are located on pages 4-51 of that document) please state whether the Commonwealth agrees with the Staff's conclusion.

If the Commonwealth disagrees with a particular item in any respect, please state, in detail, all reasons for such disagreement.

If the Commonwealth takes no position or neither agrees nor disagre,es with a particular item, please state what i

efforts the Commonwealth has undertaken or intends to undertake between now and the date of hearing to estab-lish a position as to such item.

l 6.

Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to interrogatory number 5.

Please identify each document, and the particular parts thereof, of which the Common-wealth is aware which suppor[s each~ fact so identified l

in this interrogatory.

Please further indicate each l

such document which the Commonwealth intends to offer l

in evidence in this proceeding.

For the purpose of i

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this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison.

7.

For each item labelled " Requirement" under the heading of " Emergency Planning" in the Staff's Supplement No. 5 to the Safety Evaluation Report for Pilgrim Unit 2 (which items are located on pages 13.3-1 through 13.3-10 of that document) please state whether the Common-wealth agrees with the Staff's conclusion.

If the Commonwealth disagrees with a particular item in any respect please state, in detail, all reasons for such disagreement. If the Commonwealth takes no position or neither agrees nor disagrees with a particular item, please state what efforts the Commonwealth has unGer-taken or intends to undertake between now and the date of the of hearing to establish a position as to such item.

8.

Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to in'te' r'ogatofy nu~m'bdr 7 ;

Please' identify each d6cument, r

I and the particular parts thereof, of which the Common-I wealth is aware which supports each fact so identified -

in this interrogate .

Please further indicate each i

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such document which the Commonwealth intends to offer in evidence in this proceeding.

For the purpose of this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison.

9.

Please identify each witness whom the Commonwealth of Massachusetts intends to have testify on its behalf on the subjects of emergency planning or TMI-2. related issues in this proceeding.

Please state the relevant qualifications and background of such witness along with the subject matter upon which such witness is expected to testify and the substance c_

such witness's testimony.

Respectfully submitted,

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Thomas G. Di'g nan, Jr.

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K. Gad, III Ropes & Gray 225 Franklin Street Bceton, MA 02110 (617)423-6100 jlj

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William S.

Stowe Boston Edison Company 800 Boylston Street Boston, MA 02199 (617)424-2544 O

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In the Matter of

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BOSTON EDISON COMPANY, et al.

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Docket No.

50-471

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(Pilgrim Nuclear Generating

)

Station, Unit 2)

)

)

CERTIFICATE OF SERVICE I hereby certify that the Applicants' Interrogatories to the Commonwealth of Massachusetts on Emergency Planning and TMI-Related Issues filed in the above-captioned matter has been served on the following by deposit of a copy thereof in the United States mail, first class, postage prepaid:

Andrew C. Goodhope, Esquire Stephen M.

Leonard, Esquire Chairman Jo Ann Shotwell, Esquire Atomic Safety and Licensing Board Environmental Protection Division 3320 Estel.le Terrace Department of the Attorney General Wheaton, Maryland 20906 One Ashburton Place, 19th Floor Boston, MA 02108 Dr.

A. Dixon Callihan Union Carbide Corporation Francis S. Wright, Esquire P.

O.

Box Y Berman & Berman Oak Ridge, Tennessee 211 Congress Street Boston, MA 02110 Dr. Richard F.

Cole t

l Atomic Safety and Licensing Board Henry Herrmann, Esquire l

U.S.

Nuclear Regulatory Commission Room 1045 I

Washington, D.C.

20555 50 Congress Street Boston, MA 02110 l

Atomic Safety and Licensing. Board._

L Panel Mr. and Mrs. Alan R.

Cleeton U.S.

Nuclear Regulatory Commission 22 Mackintosh Street Washington, D.C.

Franklin, MA 02038 Atomic Safety and Licensing William S.

Abbott, Esquire l

Appeal Panel Suite 925 l

U.S. Nuclear Regulatory Commission 50 Congress Street l

Washington, D.C.

20555 Boston, MA 02109 t

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t Jack R. Goldberg, Esquire Patrick J.

Kenny, Esquire Stephen H. Lewis, Esquire Edward L.

Selgrade, Esquire Office of the Executive Legal Mass. Office of Energy Resources Director 73 Tremont Street U.S. Nuclear Regulatory Commission Boston, MA 02110 Washington, D.C.

20555 office of the Secretary Chief Librarian Docketing and Service Section Plymouth Public Library U.S. Nuclear Regulatory Commission North Street Washington, D.C.

20555 Plymouth, MA 02360 Thomas S.

Moore, Chairman Dr. John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Christine N.

Kohl, Esquire Atomic Safety and Licensing

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Appeal Board U.S.

Nuclear Regulatory Commission Washington, D.C.

20535

(#/)~ S TL Dated:

July 27, 1981 m

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