ML20235R916
| ML20235R916 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/01/1987 |
| From: | Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20235R605 | List: |
| References | |
| OL, NUDOCS 8710080230 | |
| Download: ML20235R916 (3) | |
Text
- - - - - _ _ _ _ _ _ _ _
A i
Dated:
October 1, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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
)
)
1 APPLICANTS' OBJECTION IN THE NATURE OF A MOTION IN LIMINE TO THE ADMISSION IN EVIDENCE OF THE PREFILED TESTIMONY OF JOHN PENNINGTON, CONSTANCE LEAVITT, SHEILA NUDD, ANDREA SHEPARD, BEVERLY PEEKE, JANICE GALLOWAY, MARY ALICE SARGENT, ELLEN BERRY, HERB MOYER, DIANNE DUNFEY, MARIE MATHEWS, JOANNE B.
MILLETTE, AND BARBARA KNAPP REGARDING TOH REVISED CONTENTIONS IV AND VI ON SAPL CONTENTIONS 8, 8A, AND 15 AND " TOWN OF HAMPTON EXHIBIT FOR ASLB HEARINGS" RELATING THERETO Applicants object to and move in the nature of a Motion in Limine that the Board exclude as evidence in this proceeding the Prefiled Testimony of the captioned named witnesses and the accompanying " Town of Hampton Exhibit for ASLB Hearings" for reason that the testimony and exhibits are neither material or relevant to any issue in the proceedings.
8710000230 871001 PDR ADOCK 05000443 PDR qp i
M The testimony. responds negatively.in the form of witnesses' opinions to Town of Hampton Revised Contentions
~
IV and VI and Seacoast Anti-Pollution League Contentions 8, 8A and~15 as to whether early dismissal,-sheltering, or evacuation of schools in the Seabrook EPZ could be implemented adequately in the event of a radiological emergency at.Seabrook Station.
The opinions ventured rest on the uncertainty.of-teacher response to their professional responsibility to provide for the safety of students at and being transported to or from school as expressed in the testimony and on the strength of the execution of a petition, by several hundred Seabrook EPZ school teachers declaring their non-acceptance of conflicting employment and family roles.which they attribute to the NHRERP.
No Commission emergency planning regulation or emergency planning guidance require that teachers be polled or served as to whether they will fulfill their professional obligations.
Any survey or other opinion taken at one point in time as to the unwillingness or unavailability of a i
particular individual to participate when an emergency plan l
[may] be implemented has obvious drawbacks because of the 1
realities of disaster response.
See Philadelphia Electric
)
.Co.
(Limerick Generating Station, Units 1 and 2) LBP-85-14, 21 NRC 1292-1295 (1985).
Indeed they offer nothing by way of specialized knowledge on which their admissibility rests.
--2 C______._.
_.c._._._
_ _ =
8 -
.4.
.The testimony. serves no purpose except.as an airing of
. concerns which are not themselves at issue.
By their attorneys, 21111 Th'om[s G.
Dignan, Jr.
I George H. Lewald' Kathryn A.
Selleck l
Ropes &' Gray 225 Franklin Street l
Boston, MA 02110 (617) 423-6100
)
,.. L
.;