ML20248F728
| ML20248F728 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/31/1989 |
| From: | Jonas S, Selleck K MASSACHUSETTS, COMMONWEALTH OF, PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | |
| Shared Package | |
| ML20248F730 | List: |
| References | |
| CON-#289-8396 LBP-89-09, LBP-89-9, OL-1, NUDOCS 8904130171 | |
| Download: ML20248F728 (3) | |
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"E9 APR -5 P3 :02 March 31, 1989
- Ffy-UNITED STATES OF AMERICA'S r.
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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JOINT STIPULATION REGARDING CERTAIN ACOUSTIC IDCATIONS The Attorney General for the Commonwealth of Massachusetts
(" Mass AG") and the Applicants submit this Joint Stipulation to resolve two issues of fact which this Licensing Board found were raised under Mass AG's Amended Contention on Notification System, Basis A.3, to wit:
"A.3-1.
Whether the appointed destination locations, including VL-06, VL-07, and VL-12, are sufficiently level for the safe deployment of the VANS vehicles.
. hether or not VANS vehicles may gain physical "A.3-2.
W access to VL-03, VL-06, VL-07, and VL-12."
Memorandum and Order (Summary Disposition) of March 3,
- 1989, LBP-89-09, NRC slip op. at 37.
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The parties arranged and videotaped visits to the four acoustic locations onto which a VANS vehicle was driven and, at the three locations where the level was questioned, the outriggers were deployed and the vehicle leveled.
Persons present included the VANS vehicle operator, representatives-of the crane manufacturer and the company which outfitted the VANS vehicles, Applicants' counsel, an Assistant Attorney General from the office of the Mass AG, and an investigator for the Mass AG.
As a result of the sit-visits, Mass AG and the Applicants agree that the following facts are true:
1.
The appointed destination locations, including VL-06, VL-07, and VL-12, are sufficiently level for the safe deployment of the VANS vehicles; and 2.
VANS vehicles may gain physical access to VL-03, VL-06, VL-07, and VL-12.
Mass AG therefore withdraws those portions of Basis A.3 to his Amended Contention.
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This agreement does not waive any right of Mass AG to appeal th'e Board's denial of his motion to amend the basis of his Amended Contention.
FOR THE ATTORNEY GENERAL FOR THE APPLICANTS FOR THE COMMONWEALTH OF MASSACHUSETTS 1
/AM:V UM Stepheri' A. Jonas
%dgfas 'G.
Dignan, Jr.
j Chief, Public Protection Bureau Kathryn A. Selleck Department of the
' Jay Bradford Smith-Attorney General Ropes & Gray One Ashburton Place One International Place 19th Floor Boston, MA 02110-2624 Boston, MA 02108-1698 (617) 951-7000 (617) 727-2200 i
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