ML20205F351
| ML20205F351 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/25/1987 |
| From: | Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20205F356 | List: |
| References | |
| CON-#187-2926 OL, NUDOCS 8703310144 | |
| Download: ML20205F351 (2) | |
Text
..
171 o
00CKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the P
(Ff3;, ~,[q ATOMIC SAFETY AND LICENSING BOARD nc
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW liAMPS!! IRE, et al.
)
50-444-OL
)
Off-site Emergency (Seabrook Station,
)
Planning Issues Units 1 and 2)
)
)
)
TOWN OF !!AMPTON MOTION FOR
SUMMARY
DISPOSITION NOW COMES the TOWN OF IIAMPTON, pursuant to 10 CFR Section 2.749, and requests this Board to enter Summary Disposition in the Town's favor on grounds there is no genuine issue as to any material fact and the Town is entitled to summary disposition as a matter of law, on the following issue:
The N!!RERP Revision 2 fails to demon-strate that adequate personnel have been assigned, identified, or are available, to implement protective responses for the llampton students and for those with special needs and thereby fails to provide reasonable assurance that adequate protective measures can and will be taken for these people in the event of a radiological emergency at Seabrook, in violation of 10 CFR Section 50.47 (a) (1)
(b) (1), NUREG. 0654 FEMAREPl Revision 1 at pages 31-33.
0703310144 070325 PDH ADOCK 05000443 0
PDR SH AINES re McEACHE,tN. Pseorrtuf4AL A%9tEIA flON
,9 MAMEwoop AvfPAM p O Isom no Rwet%Moutit N H outot
9^
In support of this motion, the TOWN OF HAMPTON relies upon all contentions filed by the Town and admitted for litigation before this Board including Town of Hampton Revised Contentions IV(D) (1) (2) and (E); and VI(A) and (B); paragraphs 13 and 14 of the Affidavit of Richard H. Strome, New Hampshire State Civil Defense Director, the Affidavit of Herbert Moyer, Winnacunnet High School teacher, the petition of EPZ teachers, the statement of issues as to which the TOWN believes there is no genuine issue of fact, and the Memorandum of Law filed herewith and incorporated by reference herein.
Respectfully submitted, Town of Hampton By its Attorneys SHAIN McEACHERN, P.
k aul McEachern DATED March 2.E, 1987
\\
O_
s Matthew T.
Brock 2
SHAINES dib McEACHERN PseortStKWAL AttoCAit)N
- 9 MAREWOOO AvtNUE p O IBOA pay M)ntgMrytM NM opin)$
u
..