ML20238F148

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Seacoast Anti-Pollution League (Sapl) Motion to Accept Prefiled Testimony Pro Tanto as Sapl Supplemental Answer to State of Nh First Set of Interrogatories & Request for Production of Documents....* Certificate of Svc Encl
ML20238F148
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 09/11/1987
From: Doughty J
SEACOAST ANTI-POLLUTION LEAGUE
To:
Atomic Safety and Licensing Board Panel
References
CON-#387-4376 OL, NUDOCS 8709160001
Download: ML20238F148 (5)
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Text

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UNITED STATES-OF AMERICA in MF' ii.: NUCLEAR REGULATORY COMMISSION Before the g7 ggp j 4 p4 ;)7 ATOMIC SAFETY AND LICENSING BOARD E. '. In the Matter of: -) 

                                       )     Docket No. 50-443-OL[ey'</p_g PUBLIC SERVICE COMPANY OF      )

NEW HAMPSHIRE, et a1 ) Off-site Emergency 

                                       )      Planning Issues (Seabrook Station, Unit 1)     )

SEACOAST ANTI-POLLUTION LEAGUE'S MOTION TO ACCEPT PREFILED TESTIMONY PRO TANTO AS SAPL'S SUPPLEMENTAL ANSWER TO i THE STATE OF NEW HAMPSHIRE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SEACOAST ANTI-POLLUTION LEAGUE ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN The Seacoast Anti-Pollution League hereby moves that the prefiled testimony of SAPL and that that testimony prefiled by the Town of Hampton and the Commonwealth of Massachusetts in which SAPL joins below serve as its supplemental response to "The State of New Hampshire's First Set of Interrogatories and Request for' Production of Documents to the Seacoast Anti-Pollution League on the New Hampshire Radiological Emergency Response Plan" Off-Site EP Interrogatories and Request for the Production of Documents to Seacoast Anti-Pollution League (SAPL)" , I of April 30, 1986. As stated earlier, SAPL intends to litigate all of its admitted contentions. Preparation of prefiled testimony has extended right up until the filing deadline and final decisions as to which witnesses would be called in addition to those identified in SAPL's l \ e o J5 d B i 1 t

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March 17 response to Applicants' interrogatories were not finalized until very close to this time. The availability of I witnesses to SAPL retained by the Commonwealth of Massachusetts j j and the Town of Hampton'were not under SAPL's control and the 

       . final shape and substance of their testimony was only recent yl                                            (

completed. SAPL is indeed suspending its ultimate decisions as to which witnesses it will sponsor until the final form of testimony is seen. SAPL has not yet seen the final form of the prefiled f testimony of the Commonwealth of Massachusetts' witnesses and may update'this response to sponsor additional witnesses when that testimony has been received. Insofar as SAPL's witnesses are concerned, preparation of testimony has extended to the final date before filing for all witnesses not previously identified except for David P. MacDonald, whose testimony was t'.nalized on Monday, September 7, 1987. Two witnesses previously identified, Roberta C. Pevear and Sandra Gavutis will not be called. Suzanne Breiseth and Sandra Fowler Mitchell will replace them. SAPL's witnesses are as follows: Donald L. Herzberg, M.D. Clifford Earl Andrew Christie, Jr. Richard W. Ingram Sanira Fowler Mitchell Maureen Barrows David P. MacDonald Walter F. Shivik Suzanne Breiseth SAPL intends to refile a motion for subpoena of David Laughton, Secretary-Treasurer of Teamsters Local No. 633. The witness brought by the Commonwealth of Massachusetts that SAPL joins in sponsoring is Thomas J. Adler. Witnesses sponsored q by the Town of Hampton SAPL joins in sponsoring , d i 

                                                                                                                    )
are:

Ann Hutchinson Daniel Trahan' Herbert Moyer John Pennington {' Andrea Shepard Beverly Peeke Janice Galloway Mary Alice Sargent Ellen Berry Dianne Dunfey j Marie Matthews Joanne.B. Millette Barbara Knapp The educational backgrounds of each of the expert witnesses either were provided earlier in this proceeding or are provided with'the prefiled testimony. Educational background other than as previously provided or stated in prefiled testimony for other witnesses is not presently known and SAPL further claims is not ' p relevant for the non-expert witnesses. Relevant background and experience is stated in prefiled testimony. , Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE Dated: September 11, 1987 By ba-, M ,3Y~~ Jane Do6ghty 4 d STATE OF NEW HAMPSHIRE COUNTY'OF HILLSBOROUGH Then personally appeared the above-named Jane Doughty and l acknowledged that the foregoing statements by her subscribed are true and correct to the best of her knowledae andibelief. 41 /~j f W,l/Ga. uaJLt . . &/ d i-- htr eG Publie/Justici' of the Peace i 

                                                                                           -____.___.________.__a

4 CERTIFICATE OF' SERVICE' I hereby certify thatl copies of the within'" Seacoast Anti-t Pollution Leagues' Motion to Accept Prefiled Testimony Pro Tanto 

             'as SAPL's! Supplemental-Answer to the State of New Hampshire's First Set' Interrogatories and Request for'The Production of Documents of=Apr1 30, 1986" were sent this date, September 11, 1987, by express mail to those asterisked on the enclosed service -

list and first class' mail, postage prepaid.to all other parties on the service. list.- Robert A. Backus 

         .' ::q .

CERTIFICATE-OF' SERVICE AND SERV' ICE. LIST i i 

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87 . SEP 14 P4115 - j 1 J'ose Asst.Gn.Cnsl.. Helen!Hoyt. Chm.

  • Thomas ~ Dignan , Esq.
  • Fed. ph Flynnhfgmt Emerg, . ' Agcy. . .Admn. Judge Hopes & Gray
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                                                      ' Atomic Safety &~ Lic ff17d.5714 2q ;pganklin St. .                             (
           , Washington, DC 20472'                     USNRC                                 Boston, MA                    02110       l Washington, DC       20555-00b  .              ;

Office ofESelectmen . Dr. Jerry Harbour

  • U Docketing & Serv. Sec.W
                                                                                                                                     -i Town of.Hampton~ Falls-                      Admin. J"dge Hampton Falls,-NH 03844                                                           Office of the Secretary Atomic Sofety & Lic Brd-             USNRC                                    R
 '"                                                    USNRC Washington,.DC       20555 Washington, DC                     20555  j j
         ~Sherwin E. Turk,'Esq. SF                                                                                                      .
Office of Exec. Legl. Dr* Dr. Gustave A. Linenberger
  • Jane Doughty
         -USNRC Admin. Judge                         SAPL Atomic Safety & Lic. Brd.            5 Market Street
          . Washington, D.C.                20555      USNRC                                Portsmouth, NH 03801
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Washington, DC 20555 Phillip Ahrens,.Esq. . -Paul McEachern,'Esq. George Dana Bisbee, Esq. 

       .. Asst. Atty.' General                         Matthew Brock, Esq.                . Attorney General!s OFF.

State House,- Sta. #6 25'Maplewood Ave. State-of New Hampshire i Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portstrouth, NH 03801 - l Carol Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. Iord i One.Ashburton Place,. Harmon, Weiss Board of'Selectrmn 19th Floor 20001 S Street NW Suite 430 Boston', MA Town Hall-Friend St. 02108 Washington, DC 20009 Amesbury, MA 01913 Richard A. Hampe, Esq. Maynard Young, Chairnnn Sandra Gavutis 

       .New Hampshire Civil Dolense                    Board of Selectmen                 Town of Kensington Agency                                       10 Central Road                    Box 1154                                     '

G Hampe & McNicholas. Rye, NH 03870 East Kingston, N.H. 03827 

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      - Judith H. Mizner, Esq.                         Edward Thonns                      Mr. Robert Harrison                             i Silverglate, Gertner,                           FEMA                               Pres, & Chief Exec. Officer Baker, Fine, Good & Mizner                      442 J.W. McConnack (POCH)          PSCO 88 Broad Street                                 Boston, MA 02109                   P.O. Box 330                                    i Ecston, MA 02110                                                                   Manchester, NH 03105                       j Roberta pevear-State Rep.-Town of Hampt Falls Drinkwater Road Hanpton Falls, NH 03844 l

Atomic Safety and Licensing Board Panel U.S. NRC Washington, D.C. 20555 L 4}}

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