ML20154D786

Discusses Commonwealth of Ma Proposal for Alternative to Imposition of Civil Penalty in Amount of $450,000

ML20154D786
Person / Time
Site:	Pilgrim
Issue date:	03/02/1982
From:	Parrish R NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20154D739	List: ML20154D737 ML20154D749 ML20154D775 ML20154D786 ML20154D799 ML20154D811 ML20154E181 ML20154E200 ML20154E235 ML20154E256 ML20195F929
References
FOIA-88-198 2.206, NUDOCS 8809160104
Download: ML20154D786 (1)

Text

.* 'o., UNITED STATES

! o NUCLEAR REGULATORY COMMISSION

{ j wAsHmo ton. D. C. 20S55

. . . . . p# March 2, 1982 Memorandum to File Frem: Rick Parrish, OGC '%'

Subject:

MASSACHUSETTS PROPOSAL FOR ALTERNATIVE TO '

IMPOSITION OF CIVIL PENALTY ON BOSTON EDISON (PILGRIM) 4

1. b/ [G Patrick J. Kenny, General Counsel e he Massachusetts N g~

Office of Energy Resources, requested OGC's informal opinion /

regarding the possibility of/ Boston Ed's satisfying its /

civil penalty obligations o $450,000 by contributing a like amount to a state energy co crvation fund (Februtry 8, 1982 letter attached). On February 22, I conveyed this office's response to Mr. Kenny, indicating that (1) the NRC was not authorized to order Boston Ed to adLpt such a program of funding energy conservation efforts, and (2) it is uncertain whether the NRC could accept a settlement of Boston Ed's civil penalty along these lines, whether proposed by the utility or a third party such as the state agency, and we are not inclined to analyze in depth this concept in the absence of a concrete proposal.

Mr. Kenny was informed that the NRC staff would review initially such a proposal. Petitions for rulemaking, statements, 2. 206 (a) motions for "such other action as policy

' may be proper," or Boston Ed's response to the Notice of Violation were mentioned as possible channels for their proposal. Mr. Kenny indicated that he was uncertain whether any more concrete proposal would be submitted, i cc: R. DeYoung, I&E l J. Lieberman, I&E ,

1 J. Murray, ELD

) R. Haynes, Region I l

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