ML20211D673

Answer Opposing Util Motion for Summary Disposition of Contentions 2 & 10.Existence of Revised Radiological Emergency Response Plan Incorporating New Notification Sequence Not Shown

ML20211D673
Person / Time
Site:	Seabrook
Issue date:	06/12/1986
From:	KENSINGTON, NH
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20211D677	List: ML20211D673 ML20211D680 ML20211D938 ML20211D951 ML20211D966 ML20211D985 ML20211D989 ML20211E002
References
CON-#286-515 OL, NUDOCS 8606130110
Download: ML20211D673 (1)

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NUCLEAR REGULATORY COMMISSION before the \hfD ATOMIC SAFETY AND LICENSING BOARD In the Matter of  :

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PUBLIC SERVICE COMPANY OF  : Docket Nos. 50-433-OL NEW HAMPSHIRE, et al  : 50-444-OL (Seabrook Station, Units 1 & 2)  : (Offsite Emergency Planning)

TOWN OF KENSINGTON'S ANSWER OPPOSING THE APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF KENSINGTON CONTENTIONS #2 AND #10 Pursuant to 10 CFR 2.749, on the basis of the Affidavit of Sandra Gavutis and the statement of undisputed facts attached hereto, the Town of Kensington moves the Board to enter an order dismissing the motion for summary disposition by the Applicant for Kensington Contentions #2 and #10.

The Gavutis Affidavit establishes that there is no showing that the notification sequence in Kensington will be changed to assure that verification will occur and that there is no showing of the existence of equipment for The' Town of Kensington.

The Gavutis Affidavit also refutes the sworn affidavit of Mr. Gary J. Catapano and the Statement of Facts not in Dispute of The Applicant regarding the installation of alleged equipment and the halting of such installation (See the May 29, 1986 letter from Robert J. Pariseau of the New Hampshire Civil Defense Agency supporting such a claim, attached as exhibit A). In light of the false statements contained in the Catapano Affidavit and the Statement of Facts not in Dispute, the credibility of the balance of those documents is in question.

STATEMENT OF FACTS NOT IN DISPUTE

1. There has been no showing that the alleged equipment for The Town of Kensington exists.

2. Installation of the allegedly purchased equipment was never initiated in The Town of Kensington.

3. Alleged installation of the alleged equipment for the Town of Kensington was never halted by any town official (See Exhibit A, included herein by reference).

4. There has been no revised radiological emergency response plan served upon the town indicating that a different notification sequence exists, nor has there been a showing that such revised radiological emergency response plan exists.

8606130110 860612 PDR ADOCK 05000443 G PDR 0