ML20215E206

Applicant Motion for Summary Disposition of Town of Kensington Revised Contention 2.*

ML20215E206
Person / Time
Site:	Seabrook
Issue date:	06/11/1987
From:	Lewald G PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20215D921	List: ML20215D918 ML20215D966 ML20215D992 ML20215E002 ML20215E030 ML20215E043 ML20215E068 ML20215E081 ML20215E103 ML20215E128 ML20215E181 ML20215E191 ML20215E197 ML20215E206 ML20215E217 ML20215E234 ML20215E246 ML20215E272 ML20215E323 ML20215E337 ML20215E362 ML20215E383
References
OL, NUDOCS 8706190291
Download: ML20215E206 (4)

Text

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i Dated: June 11, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the i

ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

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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)

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f APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION l OF TOWN OF KENSINGTON REVISED CONTENTION NO. 2 Pursuant to 10 CFR 2.749, on the basis of the facts set forth in the " Affidavit of Gary J. Catapano (TOK 2)" and for the reasons set forth below, the Applicants move the Board to enter an order granting summary disposition in Applicants' favor with respect to Town of Kensington (TOK)

Contention No. 2.

8706190291 870611 PDR ADDCK 05000443 G PDR

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I REASONS FOR GRANTING THE MOTION i TOK Contention No. 2 reads as follows:

"The NHRERP, Revision 2 for 'TOK' does not provide for adequate notification, by licensee, of State and local response organizations, and'for notification of emergency response personnel by organizations, as required by 10.CFR 50.47 (b)(5). Provision for notification of the town emergency response organization is inadequate in that it depends upon notification through the Rockingham County dispatch."

1 This contention was limited to the means whereby TOK will receive notification of an emergency-(ASLB Memorandum and Order of February 18, 1987 at 2). Specifically, the l

contention as revised in response to the issues of NHRERP  !

Rev. 2 states that the provision for notification of the j

town emergency response organization is inadequate in that {

it depends upon notification through the Rockingham County Dispatch Center. TOK states that the town "will no longer be using the Rockingham County Dispatch as of the end of 1986."

A change in plan to no longer use Rockingham County Dispatch can in no way limit the ability of the County to notify Kensington. The communication links between the Rockingham County Dispatch Center and the Town of Kensington consist of a variety of radio systems and frequencies. A detailed description of these systems is included in the attached "Catapano Affidavit." The existing communication links between Rockingham County Dispatch Center and the Town m

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-ofcKensington allow notification of the' local emergency)

-response. organization by:Rockingham' County.-Dispatch Center.

1 Byftheir attorneys,.

= 4 c. M

. Thomas G. Dignan, . Jr. -

zGeorge H. Lewald Kathryn;A. .Selleck.1

-Deborah'S'. Steenland RopesL& Gray 225. Franklin Street Boston, MAL lO2110

.(617)423-6100, 1

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STATEMENT OF' MATERIAL' FACTS NOT IN DISPUTE

1. Rockingham County Dispatch-is1still capable of:

communicating with TOK and initiating;: notification, regardless of who: provides dispatch' services. forf TOK.

2. 'Any equipment required to implement the communication

. link:between RockinghamfCounty Dispatch and TOK has;been

installed and is currently operational ~.

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