ML20215E181

Applicant Motion for Summary Disposition of Town of Kensington Revised Contention 10.*

ML20215E181
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: 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 8706190281
Download: ML20215E181 (4)

Text

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V 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 ) 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 TOWN OF KENSINGTON REVISED CONTENTION NO. 10 Pursuant to 10 CFR $ 2.749, on the basis of the facts set forth in the " Affidavit of Richard H. Strome" and-the

" Affidavit of Gary J. Catapano", and for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in favor of Applicants with respect to Town of Kensington (TOK) Contention No. 10 in favor of the Applicants.

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REASONS FOR GRANTING THE MOTION As submitted on 11/26/87, TOK Revised Contention No. 10 asserts:

The NHRERP, Revision 2 for "TOK" does not provide

'for communications with contiguous State / local governments within the plume exposure pathway EPZ, as required by 10 CER 50.47 App. E. E. (9) (a),

because provisions for communications with the State. government are inadequate.

This contention was admitted by the Board insofar as acceptance of equipment (2/18/87 Memorandum and Order at 2).

Specifically, the equipment in question is that which will adequately provide communications with the state government.

This would include additional telephone lines in the Kensington EOC and possibly a reconfiguration of existing lines from the ground floor to the second floor command post.

The NHCDA has made several attempts to enlist Kensington's help in identifying communications equipment needed to implement the local RERP. This has been done through a series of communications with the town. Strome Aff. 13.

The equipment necessary to communicate with contiguous-State / local governments is, in fact, in place at the Kensington EOC and is currently operational. Catapano Aff.

2. This equipment includes the Command-and Control base station and the ARES (Amateur Radio Emergency Services) radio system. The existing Police Department communication m i Yi 7 ,i

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. system'also provides,this capability'.' .I n~ a d d i t i o n ,.

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additionalDrequestediequipment has been purchased'and"is'

.available'for2 installation.. 'Id at?4 By.their attorneys,-

iThomas G. Dignan,..Jr.

George'H.' Lewald . _

Kathryn A. .SelleckL

.Deborah S. Steenland Ropes &' Gray:

225 Franklin'. Street:

Boston, MA- 02110' (617).423-6100J r ,-

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-i STATEMENT OF MATERIAL FACTS NOT IN DISPUTEL

1. There are'several ' systems' currently in place- ,

allowing.the: Town'of Kensington'to communicate with j

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contiguous State / local-governmentsiwithin.the. plume exposure' 1 pathway. ,

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2. There are two telephone lines in the Kensington'EOC,. )

I one fire emergency line (red phone) Land.one business line. .D

3. The'New Hampshire Civil Defense Agency has. sought j input from the Town of Kensington.regarding communications equipment on.several occasions.

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4. Additional requested communications equipment'for ,)

j Kensington's Police and Fire Departments has been purchased I and.is presently being stored in New Hampshire Yankee's.

Production Warehouse. It is available for installation at TOK's convenience.

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