ML20205M707
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Dated:
March 25, 1987 UNITED STATES OF AMERICA 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 NEW HAMPSHIRE, et al.
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50-444-OL
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Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues
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APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF SOUTH HAMPTON (TOSH) CONTENTION NO. 6 Pursuant to 10 CFR S 2.749, on the basis of the
" Affidavit of Richard H. Strome'(TOSH 6)" and " Affidavit of j
Gary J. Catapano (TOSH 6)" and the reasons set forth below, Applic2nts move the Board to enter an order granting summary disposition in the Applicants' favor with respect to Town of South Hampton (TOSH) Contention No.
6.
REASONS FOR GRANTING THE MOTION As originally submitted South Hampton Contention No. 6 read as follows:
"The RERP for South Hampton fails to provide reasonable assurance because, contrary to NUREG-0654 H.3, the town of South Hampton does not have an EOC l
8704020472 870325 PDR ADOCK 05000443 G
PDR A
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,a capable for use in directing and controlling response functions."
The bases ascribed to the TOSH 6 is the lack of an adequate EOC location and equipment, including a generator and two-way radio equipment.
TOSH has refused to accept its Fire Station as its EOC.
The Strome and Catapano affidavits make clear that a i
generator has been purchased for TOSH and its NHCDA has offered to coordinate the identification and installation of equipment necessary to implement TOSH RERP.
TOSH by vote of its Town Meeting has refused to accept any RERP equipment.
The State of New Hampshire is committed, in the event that TOSH refuses or is unable to implement TOSH RERP, to implement the New Hampshire Radiological Emergency Response Plan Volume 2 Appendix G entitled Concept of Operations for Providing State Assistance to Municipalities Unable to Respond to an Emergency, to provide for the necessary emergency response capabilities for TOSH.
By their attorneys,
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Thr i e' M ig g Jr.
R. K. Gad III Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100
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STATEMENT OF MATERIAL EACTS 2
NOT IN DISPUTE A 15 KW generator described by TOSH as needed EOC equipment has been purchased for TOSH.
1 NHCDA has offered to coordinate the identification and installation of any additional equipment items needed to implement the RERP.
TOSH by town meeting vote has refused to accept any NHRERP equipment.
j The State of New Hampshire is committed to implement
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NHRERP Volume 2, Appendix G entitled Concept of Operations I
for Providing State Assistance to Municipalities Unable to Respond to an Emergency, should the TOSH refuse or be unable P
to implement the TOSH RERP.
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