ML20247A890

Applicant Objection in Nature of Motion in Limine to Portion of Prefiled Testimony of Tj Adler.* Question 21 Re Contention JI-4 & Answer Should Be Excluded

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: ML20247A867 ML20247A890 ML20247A912 ML20247A936 ML20247A962 ML20247A979 ML20247B001 ML20247B013
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 NUCLEAR REGULATORY COMMISSION 00CkYiI;hj

.. 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 j