ML20195B886

Motion for Summary Disposition of New England Coalition on Nuclear Pollution Contention RERP-3 & Sapl Contention 14 (Strome Affidavit) Based on State of Nh Answers to Interrogatories & Encl Statement of Facts

ML20195B886
Person / Time
Site:	Seabrook
Issue date:	05/20/1986
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20195B803	List: ML20195B799 ML20195B811 ML20195B815 ML20195B826 ML20195B835 ML20195B848 ML20195B876 ML20195B886 ML20195B899 ML20195B924 ML20195B939 ML20195B945 ML20195B951 ML20195B956 ML20195B969 ML20195B985 ML20195B992 ML20195C010 ML20195C017 ML20195C022 ML20195C033 ML20195C041
References
OL, NUDOCS 8605290578
Download: ML20195B886 (3)

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Dated: May

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UNITED STATES OF AMERICA <N.>- '

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NUCLEAR REGULATORY COMMISSION .

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before the i

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 NECNP CONTENTION NO. RERP-3 AND SAPL CONTENTION NO. 14 Pursuant to 10 CFR $ 2.749, on the basis of the Affidavit of Richard H. Strome re NECNP Contention No. RERP-3 and SAPL Contention No. 14 (Strome Affidavit),

The State of New Hampshire Answers to Interrogatories the statement of undisputed facts attached hereto and for the reasons set forth below, the applicants move the Board to enter a decision summarily disposing of NECNP Contention No. RERP-3 and SAPL Contention No. 14.

' REASONS FOR GRANTING THE MOTION NECNP Contention No. RERP-3 and SAPL Contention No. 14 raise the issue of French language informational material 8605290578 860520 PDR ADOCK 05000443 l G PDR3 l

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and notifications. The informational materials have been designed and arrangements are being made to have French language emergency broadcasts. Strome Affidavit. In addition SAPL has now indicated that it no longer wishes to

-litigate SAPL-14. SAPL Answer to Applicants Interrogatory No.-XXXVIII-1. NECNP has, as of this writing, not answered the relevant interrogatory as to its_ contention RERP-3. It

.is clear that extensive distribution of the appropriate materials has been arranged for, NH Answer to NECNP Interrogatories at 14-16, including direct mailings to all PEPZ residents, delivery and mailing to commercial establishments, posting in recreational areas, delivery to Town _ offices and telephone directory advertising. Nothing remains to be litigated.

By their attorneys,

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Thodias G. Digdp6, Jr.

R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 U

e- STATEMENT OF FACTS AS TO WHICH THERE IS NO DISPUTE

1. Brochures and informational material have been designed and samples printed which contain.information in both French and English. These have been distributed to the parties to this proceeding.

2. Extensive arrangements have been made for distribution of informational materials.

3. Tape recorded messages are being prepared for broadcast over the public address - siren - system. In addition, arrangements are being made to have emergency information-broadcast (EBS) in French as well as English.

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