ML20247A890
| ML20247A890 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/21/1989 |
| From: | Trout J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20247A872 | List: |
| References | |
| OL, NUDOCS 8903290222 | |
| Download: ML20247A890 (2) | |
Text
.
i0 J.
DCL Qirr March 21, 198UMRC'
'89 4W 27 P4 :07!
UNITED STATES OF AMERICA l
CFF <
l 00CkYiI;hj NUCLEAR REGULATORY COMMISSION
.. R s.yt.,
before the ATOMIC SAFETY AND' LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF-
)
Docket Nos. 50-443-OL j-NEW HAMPSHIRE, et al.
)
50-444-OL' H
)
Off-site Emergency (Seabrook Station, Units 1 and 2)
)
Planning Issues
)
)
APPLICANTS' OBJECTION IN THE NATURE OF A MOTION IH LIMINE TO A PORTION OF THE PREFILED TESTIMONY OF THOMAS J. ADLER a
Applicants object to and move this Board in the nature 1
of a Motion iD Limine to exclude as evidence in this
. proceeding a portion of the " Testimony of Dr. Thomas J.
Alder on Behalf of James M. Shannon, Attorney General for the l
Commonwealth of Massachusetts, Concerning Contention JI-4
-)
i (Traffic Management Plan)."
In support of their motion,
)
Applicants say that the section of testimony in question is l
l l
not material or relevant to any issue presently before this Board.
j i
8903290222 890321 PDR ADOCK 03000443 G
PDR L-
i-o' At'page 11 of his testimony, in response to Question 21, the witness opines as to the relative effectiveness of "un-uniformed traffic: guides."
However, as this Board has noted, the Interveners failed to raise any issue in their original contentions as to the need for uniformed-police rather than volunteer' traffic guides.
Memorandum and Order (Followina
'Prehearina Conference) at 6 (August 19, 1988).
Accordingly, Question 21 and the answer thereto should be excluded.
Respectfully submitted, W
Thomas G.
Dignan, Jr.
George H.
Lewald Kathryn A.
Selleck Jeffrey P. Trout Jay Bradford Smith Geoffrey C.
Cook Ropes & Gray 1
One International Place Boston, MA 02110.
(617) 951-7000 _ _ _ _ _ _ _ _ _ _ _ _ _. - _ _
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