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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 KENSINGTON REVISED CONTENTION 2 Pursuant to 10 CFR 2.749, on the basis of the facts set forth in the " Affidavit of Gary J.
Catapano (TOK 2)" and for the reasons set forth below, the Applicants move the Board
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to enter an order granting summary disposition in i
Applicants' favor with respect to Town of-Kensington (TOK)
Contention No. 2.
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..T REASON FOR GRANTING THE MOTION REVISED CONTENTION 2 reads as'follows:
"The NHRERP, Revision 2.for 'TOK' does not provide for adequate notification, by licensee, of State and_ local response-organizations, and for notification of emergency response. personnel by organizations, as required by_10_CFR 50.47 (b)(5). Provision for notification of.the town emergency response organization is inadequate in that it
-depends upon notificationLthrough the-Rockingham County dispatch."
This contention was limited to the means whereby TOK will receive notification of an emergency (ASLB Memorandum and Order of February 18, 1987 at 2).
Specifically, the contention as revised in response to the issues of NHRERP Rev. 2 states that the provision for notification of the town emergency response organization is inadequate in that it depends upon notification through the Rockingham County Dfspatch Center.
TOK states that the town "will no longer.
be using the Rockingham County Dispatch as of the end of 1986."
A change in plan to no longer use Rockingham County Dispatch can in no way limit the ability of the County to notify Kensington.
The communication links between the Rockingham County Dispatch Center and the Town of Kensington consist of a variety of radio systems and frequencies.
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detailed description of these systems is included in the attached "Catapano Affidavit."
The' existing communication links between Rockingham County Dispatch Center and the Town J
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of Kensington allow notification of the local emergency s
response organization by Rockingham County Dispatch Center.
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By their attorneys,
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y Thomas G'.
an, Jr.
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R.K. Gad I 't Kathryn,A. S'elleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617)423-6100
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ti STATEMENT OF MATERIAL FACTS NOT IN DISPUTE (TOK REVISED CONTENTION 2) 1.
Rockingham County Dispatch is still capable of k;
, communicating with TOK and initiating notification, regardless of who provides dispatch services for TOK.
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Any equipment required to implement the communication link between Rockingham County Dispatch and TOK has been
-installed and is currently operational.
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