ML20215D992
| ML20215D992 | |
| Person / Time | |
|---|---|
| Site: | Seabrook |
| Issue date: | 06/11/1987 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20215D921 | List: |
| References | |
| OL, NUDOCS 8706190212 | |
| Download: ML20215D992 (4) | |
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Dated:
June 11, 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 HAMPTON FALLS CONTENTION NO. 4 Pursuant to 10 CFR $ 50.47, on the basis of the
" Affidavit of Richard Strome (TOHF-4)" ("Strome Affidavit"),
the " Affidavit of Oary J.
Catapano (TOHF-4)", and for the reasons set forth below, the Applicants move the Board to enter an order granting summary disposition in favor of the Applicants with respect to Town of Hampton Falls (TOHF)
Contention No.
4.
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REASONS FOR GRANTING THE MOTION-TOHF. Contention No. 4 reads ~as follows:
The Hampton Falls RERP does not adequately
-meet the requirements of-10 CFR 50.47(a)(1), 50.47 q
(b)(5),:50.47(b)(6) and NUREG-0654, planning standard E because there are.no, mutually agreeable bases for notification of response organizations and much of the' communications equipment-referred to in the Hampton Falls RERP is nonexistent.
The contention was-admitted limited to compensatory fl measures and equipment necessary for notification of emergency response personnel Memorandum and Order (April-19, J
1986) at 13.
The attached affidavit of Richard:H. Strome attests to the commitment of the State of New Hampshire (SONH) to implement a compensatory plan,.if necessary, following the provisions of Volume 2, Appendix G, pg. 5 of NHRERP - Revision 2.
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1 The letters attached to the Strome Affidavit demonstrate l
some of the efforts made to assure that the communications equipment to carry out the provisions of the TOHF RERP are adequate and to assure that additional equipment is available to the town.
The affidavit of Gary J.
Catapano makes clear that while the present TOHF communications equipment is' adequate for emergency notification, additional communications equipment' and an emergency power generator have been purchased for I
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TOHF, and while available for installation, TOHF.has elected E
notcto accept it.
By their attorneys, e
Thomas G.
Dignan,JJr.
George H.'Lewald Kathryn A.
Selleck Deborah S.
Steenland.
Ropes & Gray' 225. Franklin StreetL
-Boston,'.MA 02110 (617)-423-6100 j
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' STATEMENT OF MATERIAL FACTS NOT IN DISPUTE' A
1.
Currently, TOHF is dispatched.and. paged on= existing equipment b'y Rockingham County Dispatch Center on a 24-hour basis.
This same equipment would be utilized.by
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Rockingham County Dispatch Center!toLnotify TOHFlin the event of an. incident-at Seabrook Station.
2.
Additional communications equipment (base stations, mobiles, portables)'as well-as telephone. equipment and an emergency power generator have been purchased and arei available'for installation in TOHF,'but TOHF has elected' not to accept"it.
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