ML20071A208

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Twentieth Motion for Summary Disposition of Contention Necnp III.2.No Genuine Issue of Matl Fact Exists & Util Entitled to Favorable Decision
ML20071A208
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 02/14/1983
From: Dignan T, Gad R
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20071A209 List:
References
ISSUANCES-OL, NUDOCS 8302180465
Download: ML20071A208 (3)


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Filed: February it, 1983

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'83 RB 15 P4:01 hiAf1 i.. SE 'V:f UNITED STATES OF AMERICA

. uK4 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 NEW

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Docket Nos. 50-443 OL HAMPSHIRE, et al.

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50-444 OL

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(Seabrook Station, Units 1 & 2)

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APPLICANTS' TWENTIETH MOTION FOR

SUMMARY

DISPOSITION (CONTENTION NECNP III.2)

Pursuant to 10 CFR S 2.749, the Applicants hereby move for summary disposition of contention NECNP III.2 This contention raises the issue of the ability of the Applicants to cope with one or more emergencies affecting both units at the same time.

The contention is founded upon alleged non-compliance with 10 CFR $

50.47(b)(1)-(13), 15.

The affidavit of James A.

8302180465 830214 PDR ADOCK 05000443 0

PDR D

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MacDonald, attached hereto and upon which this motion is submitted, provides a section-by-section analysis showing Seabrook's compliance with the cited regulations.

Resnactfu11v submitted,

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[ Ca E Thomas G.

Dignan, Jr.

R.

K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone:

423-6100 Dated:

February it, 1983 l

STATMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO DISPUTE 1.

The implementation of public p2.otective action is triggered by an extant radiological threat; it is of no moment if the source is one or two units.

2.

Only one communication link is needed to police and other officials in the event of an emergency regardless of whether or not two units are involved.

3.

There are separate Technical Support Centers thus assuring separately dedicated support staffs..