ML20205P768

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Applicant Motion for Summary Dispostion Seacoast Anti- Pollution League Reasserted Contention 8.* Motion Based in Part on Rh Strome & T Wallace Affidavits.Statement of Matl Facts as to Which There Is No Dispute Encl
ML20205P768
Person / Time
Site: Seabrook  NextEra Energy icon.png
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
ML20205L804 List: ... further results
References
RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8704030369
Download: ML20205P768 (5)
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L' 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 ) 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 SAPL REASSERTED CONTENTION 8 Pursuant to 10 CFR 2.749, on the basis of the " Affidavit of Richard H. Strome (SAPL 8 and 8A)" (Strome Affidavit),

" Affidavit of William T. Wallace,'Jr. (SAPL 8 and 8A)"

(Wallace Affidavit), " Affidavit of Edward B. Lieberman (SAPL 8 and 8A)" (Lieberman Affidavit), and the " Affidavit of Anthony M. Callendrello (SAPL 8)" (Callendrello Affidavit), and for the reasons set forth below, Applicants hereby move this Board to enter an order granting summary disposition with respect to SAPL Reasserted Contention No. 8 in favor of the Applicants.

REASONS FOR GRANTING THIS MOTION SM*

O 188M BES$h .

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i SAPL Reasserted Contention 8 raises the issue of whether there are adequate personnel resources available at the State and local level to provide for a "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day emergency response including 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communications links." The contention specifically refers to NUREG-0654 Sections II.A.l.e, II.A.4, and II.F.1.a. Each refers to the necessity of 24-hour coverage for an extended period.

The FEMA RAC evaluation of these elements ccvered in the New Hampshire RERP evaluated them as " adequate", with the exception of II.A.4 which was left open pending a resource allocation study by the State. Strome Aff.

The first sentence of the supporting basis, as filed by SAPL on February 21, 1986, asserts that there are insufficient personnel resources "at both the state level and local level to ensure an effective and continuous emergency response effort . . ." (emphasis added). The basis provided, however, provides only a reference to a letter by FEMA to the New Hampshire Civil Defence Agency in which the concern about the number "of staff resources" available to the State . . ." is raised. Additionally, the supporting basis provides a litany of examples of various town positions that had yet to be filled as of the filing date of the contention and provides examples of various town organizations inclusive of personnel complements.

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i As a result of undertaking an ongoing state and local personnel resource identification and assignment program discussed in the RAC review, it has been established that there are sufficient numbers of personnel available to the State and to the towns to support the implementation of the New Hampshire Radiological Emergency Response Plan. In the case of the local plans, either the town has sufficent numbers of personnel readily available to it from within town and support organizations to implement the emergency response tasks outlined in the plans, or the town may be supplemented by the use of municipal volunteers, members of other town or support organizations, and/or by State personnel.

In the case of the State, either the State agency or support organization relied upon has from within its ranks-sufficient numbers of personnel to perform the tasks assigned or, the State agency or support organization may be supplemented from other state agencies or support organizations having personnel surplused, or by the use of persons or organizations volunteering support to the effort.

Callendrello Aff.

As the successful implementation of this program is subject to the scrutiny of the NRC Staff, reasonable  ;

I assurance that there are sufficient personnel resources i available to implement the plan is provided.

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6 Bases b, c and d incorporated by reference as grounds for this contention from SAPL 8A and the addition to the basis by SAPL are included in the responses within Applicants' Motion for Summary Disposition on SAPL 8A, filed

-herewith.

. By their attorneys, Thomas Mignan, Jr.

Robert K. Gad,~III Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 I

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o a 4-t STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS-NO DISPUTE (SAPL 8)

1. The FEMA RAC-evaluation of the State of New Hampshire Radiological Emergency Response Plan (RERP)

(Rev. 2 - 8/86) found the NHRERP adequate for the NUREG-9654 elements II.A.1.e, II.A.4., and II.F.1.a with element II.A.4 left open pending the outcome of a resource allocation.

2. Based upon an ongoing personnel resources assessment program, there are sufficient numbers'of personnel available to .the towns, as members of town or support organizations, municipal volunteers, and/or State personnel, to perform the tasks contemplated in the town RERPs.
3. Based upon the same program, there are sufficient numbers of personnel available to the State, as State employees, members of support organizations, or emergency response volunteers, to perform the tasks contemplated in the State of New Hampshire RERP.
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