ML20205N270
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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 TOWN OF SOUTH HAMPTON'S (TOSH) CONTENTION 2 Pursuant to 10 CFR $ 2.749, on the basis of the " Affidavit of Richard H.
Strome (TOSH 2)", and the " Affidavit of Anthony M.
Callendrello (TOSH 2)", and for the reasons set forth below Applicants move the Board to enter and order summary disposition of TOSH Contention 2 by dismissal of the contention.
REASONS FOR GRANTING THE MOTION TOSH Contention 2 asserts:
The RERP for (TOSH] fails to provide reasonable assurance because, contrary to NUREG-0654 A.4. [ TOSH] lacks the capacity for twenty-four hour continuous operation for a necessary protracted period after declaration of an emergency.
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a The Board admitted the contention as modified in its Memorandum and Order of April 1, 1986 to provide "for twenty-four hour continuous operation for a necessary protracted period after declaration of an emergency."
The Callendrello affidavit identifies TOSH personnel needs and the availability of personnel resources necessary to fully implement the TOSH RERP and makes clear that there are sufficient numbers of persons to ensure a complete staffing of TOSH RERP organization.
This having been established the " realism" doctrine articulated by the Commission in the Shoreham Proceeding dictates allowance of the motion.
See Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1),
NRC
, CCH Nuclear Reg. Rep.
1 30,975 (July 24, 1986).
The Strome Affidavit makes clear that an emergency plan can be implemented for TOSH.
In the event TOSH persists in its unwillingness to implement TOSH RERP Rev. 2 the State of New Hampshire can and will implement the measures outlined in NHRERP Vol. 2 Appendix G so as to provide for the necessary emergency response capabilities for TOSH.
By their attorneys, Th1Sih
. Dignan, Jr.
R
. Gad III Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100.
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k STATEMENT OF MATERIAL FACTS NOT IN DISPUTE The Town of South Hampton has sufficient personnel resources available to it to staff the ROSH RERP.
In the event of an inability of TOSH to implement the TOSH plan, the State of New Hampshire will implement measures as outlined in HMRERP Rev. 2 Volume 2, Appendix G entitled Concept of Operations for Providing State Assistance to Municipalities Unable to Respond to an Emergency, so as to provide for the necessary emergency response capabilities for TOSH.
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