ML20235R615

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Forwards Two Diskettes Containing Applicants Prefiled Testimony as Corrected & Will Be Submitted at 871005 Hearing.Applicants Have Also Filed Several Objections in Nature of Limine.Related Correspondence
ML20235R615
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 10/01/1987
From: Dignan T
ROPES & GRAY
To: Harbour J, Linenberger G, Smith I
Atomic Safety and Licensing Board Panel
Shared Package
ML20235R605 List:
References
OL, NUDOCS 8710080126
Download: ML20235R615 (2)


Text

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ropes & GRAY 00CKETED 225 FRANKLIN STREET USNP,C BOSTON, MASSACHUSETTS O2110 IN PROVIDENCE ,

IN WASHINGTON 30 KENNEDY PLAZA TELEX NUMBER 940519 ROPGRALOR BSN 1001 TWE NTY-SECOND STRE ET, N.W.

PR OVIDE NC E, R. l. 02903 TELCX NUMBER 9 51973 ROPES GRAY BSN WASHI NGTON, D. C. 2 0037 (403) 624-6400 TELECOPIER$. (617) 823-2377 = (6171 423-784 0; (202) 429-1600 TE LECOPIER: (401) 521-0910 INTERNAf tchAld617) 423-6905 g IER:(202) 429-1629 October 1, 1987 Administrative Judge Ivan W. Smith, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission

. East West' Towers Building

  • 4350 East West Highway ,

. Bethesda, MD 20814 Judge Gustave A. Linenberger Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Your Honors:

We enclose two diskettes containing Applicants' pre-filed testimony as corrected and as it will be submitted during the hearing commencing October 5, 1987. The testimony is filed under the following names:

APPDIRI - Applicants' Direct' Testimony No. 1 (Letters of Agreement)

APPDIR2 - Applicants' Direct Testimony No. 2 (Special Needs/ Transportation) b B710000126 871001 ,

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PDR ADOCK 05000443 \

PDR 7

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B 3 ROPES & GRAY Administrative Judge Ivan W.

Smith, Chairman Judge Gustave A. Linenberger Dr. Jerry Harbour. October 1, 1987 APPDIR3 - Applicants' Direct Testimony No. 3 (Personnel Resources)

APPDIR4 - Applicants' Direct Testimony No. 4 (Decontamination and Reception Centers)

APPDIR5 - Applicants' Direct Testimony No. 5 (Notification / Communications)

APPDIR6 - Applicants' Direct Testimony No. 6 (Sheltering)

APPDIR7 - Applicants' Direct Testimony No. 7 (Evacuation Time Estimate and Human Behavior in Emergencies)

All corrections to the testimony are described in errata ,

sheets filed this date. We further note that Applicants' Direct Testimony No. 7 (Evacuation Time Estimate and Human Behavior in Emergencies) has undergone formatting changes '

caused by use of a different word processing system.

Applicants have also filed this date several objections in the nature of motions in limine to the admission into evidence of certain pieces of testimony in advance of their being offered into evidence so as to give the Board and parties notice of Applicants' position. It should be understood that Applicants reserve their right to object to the admission of other testimony at the time it may be offered.

Very truly yours, AD Thomas G. Dignan, Jr.

TGD/crh Enclosures cc: Service List (w/out enclosures)(by Federal Express) l l

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