ML20206M278
| ML20206M278 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/15/1987 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20206M223 | List: |
| References | |
| OL, NUDOCS 8704200076 | |
| Download: ML20206M278 (4) | |
Text
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f-
.e Dated:
April 15, 1987 UNITED STATES OF AMERICA 00LKETED
' NUCLEAR REGULATORY GMtMISSION USNRC before the
,87 Mg 16 gj gg ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SEurft.IAR f 00CMEitN3 5 SEFVICL BRANCH V
In the Matter of PUBLIC SERVICE COMPANY OF Docket No. 50-443-OL NEW HAMPSHIRE, ET AL Off-site Emergency Planning Issues (Seabrook Station, Unit 1)
SEACOAST ANTI-POLLUTION LEAGUE'S RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF SAPL REASSERTED CONTENTION No. 8
' Pursuant to 10 CFR 62.749, on the basis of facts set forth in the affidavits' cited in " Seacoast Anti-Pollution League's Response to Applicants' Motion for Summary Disposition of SAPL Reasserted Contention 8A" cnd incorporated by reference herein and for the l
reasons stated below, SAPL hereby moves this Board to enter an order denying summary disposition of SAPL Contention No.
8.
Reasons for Denying Applicants' Motion SAPL Contention No. 8 reads:
n704200076 870415 DR ADOCK 05000 3
l
The New Hampshire State and local plans fail to meet the requirements that there be adequate manpower and 24-hour per day emergency
- response, including 24-hour per day manning of communications
- links, as required by 10 CFR 650.47(a)(1),
~
050.47(b)(1), 650.47(b)(2), and NUREG-0654 II.A.1.e, II.A.4.
and II.F.1.a.
SAPL incorporates by reference
" Seacoast Anti-Pollution i'
League's Response to Applicants' Motion for Summary Disposition of SAPL Reasserted Contention 8A" and the 8 affidavits cited therein, i
SAPL further states:
i The Applicants' make no demonstration that sufficient numbers l
of personnel are available to the State and to the towns to support 1
implementation of the NHRERP.
Applicants assert that the towns have sufficient numbers of personnel readily available from within town and support organizations to implement emergency response tasks or that personnel needs "may be" supplemented by municipal volunteers, members of other town or support organizations and/or by State personnel.
This assertion is based on the Callendrello affidavit, which supplies n o' numbers whatsoever.
The Affidavits of Dona R.
Janetos and Roberta C.
Pevear, Rep. establish that there are not sufficient personnel in the Towns of Hampton and Hampton Falls to carry out the plans.
In the case of the State's personnel resources, Applicants continue to rely on the Callendrello Af fidavit. The Af fidavi t s tates a conclusory assertion that adequate personnel are available to supplement the local emergency response organization, but provides no numbers as basis for the assertion. Mr. Callendrello's asser t ions are purportedly based upon an " ongoing State and local personnel resource assessment program." On March 18, 1987, Applicants responded to SAPL's interrogatories on the Revision 2 plans.
In answer to y
SAPL's question, "What documents will be used i n support of
. Applienats' position on this contention?", the Applicants made no mention of a
personnel resource assessment.
- Further, SAPL Interrogatory #42, reads:
From what specific State agencies will the State draw personnel to fill in for lack of adequate personnel in local communi t i es ?
For each agency named, state the total number of personnel available to perform such functions.
How does the State plan to familiarize these personnel with the specific emergency arrangements, f acilities and needs of these local communities?
In answer, the Applicants made absolutely no mention of a personnel resource assessment' program.
SAPL would hold that the f actual basis i
behind Mr. Callendrello's assertions ought be provided and that, further, there must ce some showing that replacement personnel are sufficiently trained for the functions they might be called upon to perform and suf ficiently f amiliar with the local communities to carry them out adequately.
There has been no such showing.
NUREG-0654, element II.A.4. has not been found adequate by the RAC and there is no basis for assuming that it will be f ound adequate.
l Responses to Applicants' Motion with regard to bases b,c, and d,
i ncorporated by reference as grounds for SAPL Contention 8 from SAPL Contention 8A, are within " Seacoast Anti-Pollution League's Response to Applicants' Motion for Summary Disposition of SAPL Reasserted Contention 8A" incorporated by reference herein.
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Genuine Issues of Material Fact In Dispute (SAPL 8) 1.
SAPL incorporates by ref erence i tems #1-10 f rom " Genuine Issues of Material Fact In Dispute (SAPL 8A)."
2.
The Callendrello Affidavit fails to establish that there are sufficient numbers of personnel available to the towns, as members of personnel available to the towns, as members of support organizations, municipal volunteers, and/or State personnel to perform the tasks contemplated in town RERPs..No numbers have been provided to back the asserted sufficiency of local personnel.
Respectfully submitted, SEAOOAST ANTI-POLLUTION LEAGUE By its attorney, BACKUS, MEYER & SOLOMON
'Robeft A.
Backus P. O.
Box 516 116 Lowell Street Manchester, N.H.
03105 Tel: (603) 668-7272 DATE:
April 15, 1987 I hereby cer t i f y that a copy of the wi thin Seacoas t Ant i-Pollut ion League's Respcnse to Applicants' Motion for Summary Disposition of SAPL Reasserted Contention No. 8 has been sent this date, first class, postage prepaid, to those listed on the attached service list and Federal Expressed to those indicated by an asterisk on the service list.
/
Eote#t'A.' Backus -.
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