ML20238F150

Seacoast Anti-Pollution League (Sapl) Motion to Accept Prefiled Testimony Pro Tanto as Sapl Supplemental Answer to Applicant Offsite Emergency Planning Interrogatories & Request....* Certificate of Svc Encl

ML20238F150
Person / Time
Site:	Seabrook
Issue date:	09/11/1987
From:	Doughty J SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
References
CON-#387-4377 OL, NUDOCS 8709160002
Download: ML20238F150 (5)

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. UNITED STATES,OF' AMERICA- UN[U

~ 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 OF )

Docket No. 50-443-OLht/f-d(_.

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 L, APPLICANTSOFFSITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS OF MARCH'5, 1987 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

" Applicants' Off-Site EP Interrogatories:and Request for-the Production of Documents to Seacoast Anti-Pollution ' League (SAPL)"

of March 5, 1987. As stated earlier, SAPL intends to litigate all-of its admitted contentions.

l 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 these identified in SAPL's 8709160002 870911 l PDR G.

ADOCK 05000443l PDR l .d i l

l; g.u-March 17 response to Applicants' interrogatories were not.

1 finalized.until.very'close to this. time. The availability of 1 witnesses to SAPL retained by the Commonwealth of-Massachusetts and,the Town.of Hampton were not under SAPL's control-and the

. final' shape and substance of their testimony was only recently.

completed. SAPL is indeed suspending its ultimate decis. ions as to l

which witnesses it will sponsor until the final form of testimony is seen. SAPL has not yet seen the final form of the prefiled 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 1for David P. MacDonald, whose testimony was finalized on Monday, September 7, 1987. Two witnesses previously identified, Roberta i 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 Sandra 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 by.the Town of Hampton SAPL joins in sponsoring

are:

Ann Hutchinson Daniel Trahan Herbert Moyer John Pennington Andrea Shepard

. Beverly Peeke Janice Galloway i Mary Alice Sargent Ellen Berry l

Dianne Dunfey l Marie Matthews Joanne B. Millette Barbara Knapp The educational backgrounds of each of the expert witnesses either we e 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 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 b;hb Jane Doughty d d STATE OF NEW HAMPSHIRE COUNTY OF HILLSBOROUGH Then personally appeared the above-named Jane Doughty and acknowledged that the foregoing statements by her subscribed are true and correct to the best of her knowled e and belief.

Yhuttbu k

-Nottrry--PuM4c/Justics of the Peace

. b CERTIFICATE OF SERVICE I hereby certify that copies of the within " Seacoast Anti-Pollution Leagues' Motion to Accept Prefiled Testimony Pro Tanto as SAPL's Supplemental Answer to Applicant's Offsite EP Interrogatories and Request for The Production of Documents of March 5, 1987" 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.

,' ? k' f ( 's/s/-j,g4y' )

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Robert A. Backus

CERTIFICATE OF SERVICE AND SERVICE LIST

'87 SEP 14 p4 :15 Jose Asst.Gn.Cnsl. Helen Hoyt. Chm.

• Thomas Dignan, Esq.*

Fed. ph Flynndgmt.

Emerg. Agcy. Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety E Lic fffd.S? 14 2p :fganklin St.

Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 00v s Office of Selectmen Dr. Jerry Harbour *

• Docketing & Serv. Sec .

• Town of Hampton Falls Admin. Judge Hampton Falls, NH 03844 Office of the Secretary Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555 Shenvin E. Turk, Esq. # Jane Doughty Office of Exec. Legl. Dr. Dr. Gustave A. Linenberger

• USNRC Admin Judge SAPL Atomic Safety & Lic. Brd. 5 Market Street Washington, D.C. 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.

Asst. Atty. General Matthew Bruck, Esq. Attorney General's OFF.

State House , Sta. #6 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, NH 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq. William S. Iord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Boston, MA 02108 Town Hall-Friend St.

Washingcon, DC 20009 Amesbury, MA 01913 Richard A. Hanpe, Esq. Maynard Young, Chairman Sandra Gavutis New Hampshire Civil Delense Board of Selectmen Town of Kensington Agency 10 Central Road Box 1134 Hampe & McNicholas Rye, NH 03870 East Kingston, N.H. 03827 35 Pleasant St.

Concord, NH 03301 Judith H. Mizner, Esq. Edward 'Ihomas Mr. Robert Harrison Silverglate, Gertner, FBIA Pres, & Chief Exec. Officer Baker, Fine, Good & Blizner 442 J.W. McCormack (POCH) PSCO 88 Broad Street Boston, MA 02109 P.O. Box 330 Boston, MA 02110 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03S44 Atomic Safety and Licensing Board Panel U.S. NRC Washington, D.C. 20555

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