ML20151T492
| ML20151T492 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/15/1988 |
| From: | Lewald T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20151T498 | List: |
| References | |
| CON-#288-6172 OL, NUDOCS 8804290047 | |
| Download: ML20151T492 (2) | |
Text
'4/7L i
COC ME T Er, E<D,Dfil51 April 15 88
'88 AR? 19 P4 M6 UNITED STATES OF AMERICA f0C G 4 k[;,Y'h' NUCLEAR REGULATORY COMMISSION i
BRANCH before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
(Off-site Emergency (Seabrook Station, Units 1 and 2)
)
Planning Issues)
)
)
APPLICANTS' SUPPLEMENTAL RESPONSE TO ATTORNEY GENERAL JAMES M.
SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS (SET NO. 3)
Pursuant to 10 CFR $ 2.740(e), Applicants supplement their response to "Attorney General James M.
Shannon's Off-Site EP Interrogatories and Request for the Production of Documents to the Applicants (Set No. 3)" as follows:
INTERROGATORY NO. 3 Ouestion:
Do you intend to offer the testimony of any expert witness with respect to sheltering contentions?
If so, please:
(
a.
.!dentify each expert witness who you intend to l
present with respect to each subpart of each such l
contention; I
b.
State the substance of the facts to which each expert witness is expected to testify; c.
State the substance of the opinion or opinions to which each expert witness is expected to testify;
$$[$Doh O
9 d.
Provide a summary of the grounds for each opinion to which each expert witness is expected to testify; e.
State whether the facts and opinions listed in response to the foregoing are contained in any document; f.
State whether the opinion of any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle; g.
State whethor the opinion of any expert witness is based in whale or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific se ction or portion thereof relied upon; and h.
State whet'ter the opinion of any expert witness is based in waole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.
Sucolemental Responrie:
Applicants intand to offer the testimony and basis for it of the panel of witnesses identified in Applicants' Direct Testimony No. 6 (Sheltering), dated April 15, 1988, along with appendix, attachments, exhibit, and the qualifications of witnesses.
These documents which have not already been served are served herewith.
By their attorneys, JheQ 3 t>rs.
Thomas G.
Dignan, Jr.
George H.
Lewald Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100