ML20205M769
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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 i
(Seabrook Station, Units 1 and 2) )
Planning Issues
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MOTION FOR
SUMMARY
DISPOSITION OF TOWN OF HAMPTON FALLS (TOHF) CONTENTION 4)
Pursuant to 10 CFR $ 50.47, on the basis of the
" Affidavit of Richard Strome (TOHF-4)" ("Strome Affidavit"),
the " Affidavit of Gary J. Catapano (TOHF-4)", and for the reasons set forth below, the Applicants move the Board to enter an order granting summary disposition in favor of the Applicants with respect to Town of Hampton Falls (TOHF)
Contention No. 4.
8704020489 870325 ADOCKOS000g3 PDR G
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i REASONS FOR GRANTING THE MOTION TOHF Contention No. 4 reads as follows:
The Hampton Falls RERP does not adequately meet the requirements of 10 CFR 50.47(a)(1), 50.47 (b)(5), 50.47(b)(6) and NUREG-0654 planning standard E because there are no mutually agreeable bases for notification of response organizations and much of the communications equipment referred to in the Hampton Falls RERP is nonexistent.
The contention was admitted limited to compensatory measures and equipment necessary for notification of emergency response personnel Memorandum and Order (April 19, 1986) at 13.
The attached affidavit of Richard H. Strome attests to the commitment of the State of New Hampshire (SONH) to implement a compensatory plan, if necessary, following the provisions of Volume 2, Appendix G,-pg.
5 of NHRERP - Revision 2.
The letters attached to the Strome Affidavit demonstrate some of the efforts made to assure that the communications equipment to carry out the provisions of the TOHF RERP are adequate and to assure that additional equipment is i
available to the town.
The affidavit of Gary J. Catapano makes clear that while the present TOHF communications equipment is adequate for J
emergency notification, additional communications equipment and an emergency power generator have been purchased for TOHF, and while'available for installation, TOHF has elected not to accept it.
By their attorneys, P'r x//P '
ThonfEs~ GT Dign Jr.
R. K. Gad III J
Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 1
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4 STATEMENT OF MATERIAL FACT NOT IN DISPUTE (TOHF-4)8 1.
In the event that the Town of Hampton Falls is unable or unwilling to provide for its necessary emergency response capabilities, then the State of New Hampshire can and will implement the NHRERP Revision 2 Vol. 2 Appendix G so entitled Concept of Operations for Providing State Assistance to Municipalities Unable to Respond to an Emergency, in order to provide such capabilities.
2.
The communications equipment necessary to implement the Hampton Falls Radiological Emergency Response Plan has i
been made available to the appropriate local i
authorities, but TOHF has elected not to accept it.
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