ML20205P152

Applicant Motion for Summary Disposition of Revised Town of Kensington (Tok) Contention 10.* Motion Based on Listed Reasons & Rh Strome & Gj Catapano Affidavits.Statement of Matl Facts Not in Dispute (Tok 10) Encl

ML20205P152
Person / Time
Site:	Seabrook
Issue date:	03/25/1987
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
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References
OL, NUDOCS 8704030188
Download: ML20205P152 (4)

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I Dated: March 25, 1987 l UNITED STATES OF' AMERICA l NUCLEAR REGULATORY COMMISSION I

before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

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APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF REVISED TOWN OF KENSINGTON (TOK) CONTENTION 10 Pursuant to 10 CFR S 2.749, on the basis of th.s facts set forth in the " Affidavit of Richard M. Streme" and the

" Affidavit of Gary J. Catapano", and for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in favor of Applicants with respect to Town of Kensington Contention No. 10 in favor of the Applicants.

8704030188 DR 870325 ADOCK 05000443 PDR ,

s REASONS FOR GRANTING THE MOTION As submitted on 11/26/87, Revised TOK Contention 10 asserts:

The NHRERP, Revision 2 for "TOK" does

, not provide for communications with contiguous State / local governments within the plume exposure pathway EPZ, as required by 10 CFR 50.47 App. E. E.

(9) (a) because provisions for communications with the State government are inadequate.

This contention was admitted by the Board insofar as acceptance of equipment (2/18/87 Memorandum and Order at 2).

j Specifically, the equipment in question is that which will 1

adequately provide communications with the state government.'

This would include additional telephone lines in the Kensington EOC and possibly a reconfiguration of existing 9 lines from.the ground floor to the second floor command post.

The NHCDA has made several attempts to enlist Kensington's help in identifying communications equipment needed to implement the local RERP. This has been done through a series of communications with the town. Strome Aff. 1 3.

The equipment necessary to communicate with contiguous State / local governments is, in fact, in place at the

Kensington EOC and is currently operational. Catapano Aff.

T 2. This equipment includes the Command and Control base station and the ARES (Amateur Radio Emergency Services) 1 1

w/e 4

radio system. The existing Police Department communication system also provides this capability. In addition, additional requested equipment has been purchased and is available for installation. Id. at 4.

By their attorneys, Thonfa's'6. Dfgnan, 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 FACTS NOT IN DISPUTE (TOK 10)

1. There are several systems currently in place allowing the Town of Kensington to communicate with contiguous State / local governments within the plume exposure pathway.

2. There are two telephone lines in the Kensington EOC,-

one fire emergency line (red phone) and one business line.

3. The New Hampshire Civil Defense Agency has sought input from the Town of Kensington regarding communications equipment on several occasions.

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4. Additional requested communications equipment for Kensington's Police and Fire Departments has been purchased and is presently being stored in New Hampshire Yankee's Production Warehouse. It is available for installation at TOK's convenience.

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