ML20211M815

Objection,In Part,To Applicant Motion to Correct 861201 Hearing Transcript.Proposed Changes Would Not Only Correct Typos But Substantively Alter Testimony.Certificate of Svc Encl

ML20211M815
Person / Time
Site:	Seabrook
Issue date:	12/12/1986
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
References
CON-#486-1906 OL-1, NUDOCS 8612180057
Download: ML20211M815 (4)

Text

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.. ~/ gg Filed:

Daccmber 12, 1986 UNITED STATES OF AMERICA

%gEi,EP p'

NUCLEAR REGULATORY COMMISSION

,t-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '86 DEC 16 Pl2:17 Offict ir..

tA In the matter of:

$jh *E PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, ET AL 50-444 OL- /

(Seabrook Station, Units 1 and 2)

Onsite Emergency Planning l

& Safety Issues SEACOAST ANTI-POLLUTION LEAGUE'S OBJECTION IN PART TO APPLICANTS' MOTION TO CORRECT THE HEARING TRANSCRIPT l

NOW COMES the Seacoast Anti-Pollution League and objects to certain corrections in Appendix A of " Applicants' Motion to Correct l

the Hearing Transcript" dated December 1,

1986.

Those portions of Appendix A to which SAPL objects are as follows:

A)

At page 778 at line 10, Applicants propose to add a ques t ion l

to the transcript as follows:

"Is hydrogen concentration used to ini t iate containment spray flow?" This is not the question that was asked and indeed the question the Applicants propose does not make any sense.

SAPL moved on November 7, 1986 to correct the transcript to read at that point as follows:

"Is it also important in the determination as to whether or not it is safe to initiate containment sprays?"

The Board granted SAPL's motion on December 3,19 86. Furthermore, SAPL has the detailed notes l

that counsel employed in cross-examining l

861218o057 861212 l

ADOCK0500g3 1

PDR hsos L

witnesses and the ques t ion.was indeed asked as SAPL's motion for correction has indicated.

B)

At page 787 at line 4, Applicants propose to change the contract ion "Isn' t" to the word "is."

SAPL's Field Director was listening very attentively to the answer given by Applicants' witness G.S. Thomas to this particular quest ion and recalls that he answered "isn't" to the question as to whether the main plant computer manufacturer is still in business.

SAPL would request that that answer not be changed absent a sworn affidavit being supplied by Mr.

Thomas which avers that the main plant

. computer manufacturer for Seabrook Station still is in business.

SAPL has heard contrary information from an independent source and therefore thinks that the Applicants ought provide a sworn answer to this question before any change is made to the script.

C)

SAPL believes t hat the correct ion that Applicants proposed for page 797 at line 8 is in error.

D)

At page 830 line 2, the correction should be "NUREG 0737" rather than "NUREG 737."

E)

At page 985 line 13, "Q"

should simply be striken as in the Staff's correction to the transcript.

3 !

This Board will be aware that the so-called " corrections" proposed by the Applicants, referred in paragraphs A & B above, are not merely typographical error corrections, but' rather - i f allowed

- would make a subs tant ive change in the tes t imony.

This should not l

be permitted, absent an evidentiary basis.

No such basis has been supplied.

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE l

By its attorney, l

BACKUS, MEYER & SOLOMON l

l g ehaft A.

Backus P. O.

Box 516 116 Lowell Street Manchester, N.H.

03105 Tel: (603) 668-7272 l

DATE:

December 12, 1986 l

i l

I hereby cer t i fy that a copy of the wi thin Seacoas t Ant I-Pollut ion League's Objection In Part to Applicants' Motion to Correct the Hearing Transcript has been sent this date, first class, postage prepaid, to those listed on the attached service listel.

o N

Y

/

Rob e r't A.

Backus i

I l

! i

CERTIFICATE OF SERVICE AND SERVICE LIST p

Jose Asst.Gn.Cnsl.

Sheldon J. Wolfe, Chrm."

Thomas Dignan, Esq.+

Fed. ph Flynnlgmt. Agcy.

.Emerg, b Admn. Judge Ropes & Gray 500 C.St.' So West Atomic Safety & Lic Brd.

225 Franklin St.

Washington, DC 20472 USNRC Boston, MA- 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour #

Docketing & Serv. Sec.c Town of Hampton Falls Admin. Judge Office of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd.

USNRC USNRC Washington, DC 20555 Washington, DC 20555 Shenvin E. Turk, Esq.

Dr. Emmeth A. Luebke *'

Jane Doughty Office of Exec. Legl. Dr.

Admin Judge SAPL USNRC Atomic Safety & Lic. Brd.

5 Market Street Wahsington, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.

Paul McEachern, Esq.

George Dana Bisbee, Esq.

Asst. Atty. General Matthew Brock, Esq.

Attorney General's OFF.3 State H0use, Sta. #6 25 Maplewood Ave.

State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, hH 03801 Carul Sneider, Esq., Asst. AG

• Diane Curran, Esq.

William S. lord One-Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430

'Ibwn Hall-Friend St.

Boston, MA 02108 Washington, DC 20009 Amesbury, MA 01913 Richard A.'Hampe, Esq.

Maynard Young, Chairman Sandra Gauvutis New Hanpshire Civil Defense Board of Selectmen Town of Kingston Agency 10 Central Road Box 1154 Hampe & McNicholas Rye, hH 03870 East Kensington, NH 03827 35 Pleasant St.

Concord, NH 03301 Edward Thomas Mr. Robert Harrison FDIA Pres. & Chief Exec. Officer 442 J.W. McCormack (POCH)

PSCO Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844

• Federal Expressed

1. - Irjud by<ess

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