ML20235R885

Applicants Objection in Nature of Motion in Limine to Portion of Seacoast Anti-Pollution League Testimony of Dp Macdonald on Seacoast Anti-Pollution League Contentions 8 & 8a Re Town of Rye.* Related Correspondence

ML20235R885
Person / Time
Site:	Seabrook
Issue date:	10/01/1987
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20235R605	List: ML20235R602 ML20235R615 ML20235R633 ML20235R643 ML20235R650 ML20235R664 ML20235R669 ML20235R678 ML20235R684 ML20235R731 ML20235R745 ML20235R761 ML20235R788 ML20235R799 ML20235R823 ML20235R842 ML20235R875 ML20235R885 ML20235R892 ML20235R916 ML20235R928
References
OL, NUDOCS 8710080216
Download: ML20235R885 (2)

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4' October 1, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL OF NEW HAMPSHIRE, ET AL. ) 50-444-OL

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(Seabrook Station, Units 1 ) (Offsite Emergency and 2) ) Planning Issues)

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APPLICANTS' OBJECTION IN THE NATURE OF OF A MOTION IN LIMINE TO A PORTION OF SEACOAST ANTI-POLLUTION LEAGUE TESTIMONY OF DAVID P. MACDONALD ON SAPL CONTENTIONS 8 AND 8A RELATIVE TO THE TOWN OF RYE The Applicants object to the admission into evidence of so much of the prefiled testimony of the witness David P.

MacDonald as encompassed in the paragraph beginning at the bottom of page 6 and running over to page 7, being the last paragraph of answer 8.1 This testimony concerns the alleged need for planning for an area known as the Isle of Shoals which is located outside the Emergency Planning Zone for Seabrook Station.

1This objection is being presented in written form in the nature of a Motion in Limine prior to the actual offer of the i testimony in order to give the Board and parties notice of the position of the Applicants in this matter. In addition, the motion seeks a ruling of the Board on the objection prior to the time that the testimony would be offered in the normal course, so as to simplify the issues and enable all parties to plan better their future actions.

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l 8710080216 071001 i PDR ADOCK 05000443 T

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in-CONCLUSION The testimony objected to should be excluded.

Respectfully submitted, 8

Thomas'G.

.f/

George H.Lewald p an, Jr.

Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Aeolicants l

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