ML20205P026

Applicant Motion for Summary Disposition Town of Hampton Falls (Tohf) Contention 2.* Motion Based on Listed Reasons & Callendrello & Strome Affidavits

ML20205P026
Person / Time
Site:	Seabrook
Issue date:	03/25/1987
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
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References
OL, NUDOCS 8704030159
Download: ML20205P026 (3)

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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 TOWN OF HAMPTON FALLS (TOHF) CONTENTION 2 Pursuant to 10 CFR 5 2.749, on the basis of the facts set forth in" Affidavit of Richard H. Strome (TOHF-2)", and

" Affidavit of Anthony M. Callendrello (TOHF-2)", and for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in Applicants' favor with respect to Town of Hampton Falls (TOHF) Contention No.

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REASONS FOR GRANTING 1 THE MOTION TOHF Contention No. 2 asserts: ,

The plan designated as Hampton Falls fails to provide reasonable assurance 9704030159 B70325 PDR ADOCK 05000443 G PDR _

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t-since it cannot provide'for continuous 24-hour operation for a protracted j period of local responsibilities, as

j. rquired by NUREG-0654.

.The Callendrello affidavit identifies specific TOHF personnel needs of up to 24 persons and available personnel a

resources of up to 30 persons to implement TOHF RERP Rev. 2.

TOHF nevertheless has been unwilling to commit its personnel resources to the TOHF RERP. The' availability of resources having been established, the doctrine of " realism" dictates

the allowance of this motion. See Long Island Lighting Co.

(Shoreham Nuclear Power Station, Unit 1), CLI-86-13, NRC

, CCH Nuclear Reg. Rep. 1 30,975 (July 24, 1986).

l The Strome affidavit commits the State of New Hampshire in the event of a radiological emergency at Seabrook Station to implement an emergency plan for TOHF. In the event that J

TOHF will not implement NHRERP, Volume 2, Appendix G

" Concept of Operations for Providing State Assistance to Municipaiities Unable to Respond to an Emergency," to 7

provide for the necessary emergency protection. capabilities for TOH.

By their attorneys, F

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Thomas G. DiFFyrra~n, Jr.

R.K. Gad III

-Kathryn'A. Selleck '

Ropes.& Gray 225 Franklin Street Boston,.MA 02110 .

(617) 423-6100 '

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STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO DI3PUTE ~

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TOHF has failed to staff the TOHF RERP Rev. 2 from the personnal resources available to it.

2. The State of New Hampshire has committed to implement-an RERP for TOHF in the event of a radiological emergency ,

at Seabrook Station, if TOHF has continued its'fallure to implement TOHF RERP, following the provisons of NHRERP Volume 2, Appendix G.

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