ML20246H173
| ML20246H173 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/02/1989 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#289-8574 OL-1, NUDOCS 8905160021 | |
| Download: ML20246H173 (6) | |
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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 OF
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Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al.
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50-444-OL-1
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(On-Site Emergency (Seabrook Station, Units 1 and 2)
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Planning and Safety
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Issues)
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APPLICANTS' OBJECTIONS TO MASS AG DIRECT TESTIMONY REGARDING PROMPT ALERT AND NOTIFICATION SYSTEM ISSUES For the reasons set forth below, the Applicants object to the admission into evidence of the following portions of the " Mass AG Direct Testimony Regarding Prompt Alert and Notification System Issues":
1.
Objection is made to page 10, the middle paragraph beginning "Moreover".
The reason for the objection is that there is no open issue on the question of " ground reflection" j
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As this Board has stated, the only issue t
concerning " reflection" that is available for litigation is the question of the effect of reflection of sound from I
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PDR ADOCK 05000443 T
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i buildings.
Therefore, this paragraph should be stricken as
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being irrelevant to the issues to be litigated in this proceeding.
2.
Objection is made to pages 21-24.
This testimony puts forth the thesis that certain persons will not appropriately react to the siren when they hear it.
Examples are given of elderly persons who.needed to sleep in shifts at TMI in order to be sure that they heard a warning; references are made to panic and other human reactions which might prevent people from taking the' appropriate step of turning on their radio.
None of this is relevant to the proceeding.
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Tne requirement is that the Applicants demonstrate the capability to notify.
Human response to sirens and radios, both of which are accepted methods of performing notification, are not open for litigation in this proceeding.
The Applicant simply needs to demonstrate that the capability exists to reach people.
The Applicant by law is not responsible for people's reactions to i
the notification device utilized.
Therefore, all of this testimony is irrelevant to any issue before the Board.
In the event the Board overrules the foregoing objections, the Applicants request leave to present rebuttal
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V testimony with respect to these two matters in the event the course of the hearing so dictates.1 By their attorneys, l
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ma's g'Dignan, Jr.
Kathryn A.
Selleck Jay Bradford Smith Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-7000 l
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1 In the event the Board overrules the objections, the filing of rebuttal may not be necessary in light of cross-examination with respect to this testimony or in light of other events occurring during the proceeding.
However, Applicants do wish to reserve the right to present rebuttal testimony should the same be necessary.
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~b CERTIFICATE OF SERVICE I, Thomas G.
Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on Marn3,,1989,-I made service of the within document by mailing copies ther' eof, postage prepaid, to:
Administrative Judge Ivan W.
- Smith, Administrative Judge Peter B.
Chairman Bloch, Chairman
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Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 l
Administrative Judge Richard F.
Dr. Jerry Harbour Cole Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 1
Administrative Judge Kenneth A.
Administrative Judge Emmeth A.
McCollom Luebke 1107 West Knapp Street Atomic Safety and Licensing Stillwater, OK 74075 Board Apartment 1923N 5500 Friendship Boulevard Chevy Chase, MD 20815 Diane Curran, Esquire Robert R.
Pierce, Esquire Andrea C.
Ferster, Esquire Atomic Safety and Licensing Harmon, Curran & Tousley Board Suite 430 U.S.
Nuclear Regulatory 2001 S Street, N.W.
Commission i
Washington, DC 20009 Washington, DC 20555 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal Board Panel Docket (2 copies)
Director U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Backus, Meyer & Solomon j
U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 i
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I Philip Ahrens, Esquire Mr.
J.
P. Nadeau Astistant Attorney General Selectmen's Office 1
Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General l
25 Maplewood Avenue Department of the Attorney P.O.
Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Flr.
Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A.
Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950 Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:
Herb Boynton)
Boston, MA 02110 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P.
Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas i
47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301
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Mr. Richar'd R.: Donovan Judith H. Mizner, Esquire Federal Emergency Management-
'79 State Street, 2nd Floor Agency Newburyport, MA 01950 Federal Regional Center-130 228th Street,.S.W.
Bothell, Washington 98021-9796 Ashod N. Amirian,' Esquire 145 South' Main Street
. P.O.
Box 38 Bradford, MA 01835 John.P.. Arnold, Esquire Attorney' General.
George Dana Bisbee, Esquire Assistant Attorney General Office,of'the Attorney General
' 25 Capitol Street.
Concord, NH 03301-6397 l
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N_omas G.
Di@nsn, Jr.
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