ML20029A034
| ML20029A034 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/18/1991 |
| From: | Dignan T, Greer L, Reis E MASSACHUSETTS, COMMONWEALTH OF, NRC OFFICE OF THE GENERAL COUNSEL (OGC), PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#191-11317 ALAB-937, ALAB-942, OL, NUDOCS 9102010086 | |
| Download: ML20029A034 (7) | |
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I at t LILD U*d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 91 Jtw 22 Ni:30 before the 1
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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)
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Flanning Issues
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JOINT STIPULATION REGARDING CONTENTIONS REMANDED IN ALAD-937 AND ALAD-942 The NRC Staff, the Attorney General for The Commonwealth of
'lassachusetts
(" Mass AG") and the Licensees hereby submit the following Joint Stipulation, which is intended to resolve the issues raised in certain of Mass AG's contentions which were remanded for admission in ALAB-937 and ALAB-942.
I.
AIAB-9 3 7 :
MASS AG CONTENTION 47 BASIS R Licensees have agreed to make the following changes with respect to procedures for ensuring adequate supervision of children evacuated to the School Host Facility at the College of the Holy Cross, Worcester, Massachusetts (" Holy Croas"):
l 1.
The implementing procedures for the Seabrook.Ilan for 1
Massachusetts Communities ("SPMC") will be modified to expressly allow for the retention of those Route Guides who accompany vehicles arriving at Holy Cross and to allow for nusuxwn st02010006 910112.
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the reassignment to Holy Cross of Route Guides who accompanied other vehicles.
The modified procedures will expressly address the use of Route Guides for studem.
supervision.
2.
The Support Plan for Holy Cross Host Facility Activation and Operation
(" Support Plan") will be modified to allow the Host Facility Supervisor to hold the 60 Route Guides arriving with school vehicles and to assign them to child supe rvision.
3.
The Support Plan will be modified to allow the Host Facility Supervisor to request up to 145 additional Route Guides who had accompanied other vehicles to report to Holy Cross to support child supervision.
4.
The Support Plan will be modified to add a Volunteer Coordinator to the ORO Host Facility Staff, whose task will be to accommodate and coordinate the use of arriving parents,. Holy Cross students, and other volunteers.
5.
The Support Plan will be modified to provide for the transfer, to the American Red Cross at congregate care centers, of all children not picked up from Holy Cross by their parents by 8:00 p.m.
6.
The Support Plan will be modified to provide that records will be kept of which children are transferred to which congregate care conter, so as to. facilitate the children's retrieval by their parents.
Prior to the assignment of a m sarx. n --
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i children to_ congregate care, the-School Host Facility 1 vill coordinate =with the Reception Centers-and, in the event lthat transit-dependent parents hevi already been assigned to a:
congregate care facility, th/irLchildren will be assigned-to the-same facility.
7.
The Support plan will be modified to add that the ORO Host-Facility Statf (including Route Guides)--will be_assignedEto -
support the transfer of remaining children to the-congregate care centers.
B.
Training material for Route Guides will be-~added that
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explains their student supervision duties.
The above changes will be subject to the oversight 1of the NRC and FEMA Staff.
The changes to the SPMC implementing procedures will be included in the revisions to the SPMC'which will be issued in February-1991. ~ Licensees Will submit the Support Plan and training changes to the Staff by March 15, 1991, and will simultaneously provide a copy of all changes to-Mass AG.
In light of those additional measures bf Licensees, Mass-AG agrees that the issues raised in1 Mass AG Contention 47-BasisLR, as remanded in ALAB-937, have been resolved.
Mass-AG accordingly withdraws his Contention 47 Basis R.I Also,'in111ght of this-stipulation, Licensees agree that.their motion-to compel filed on I
In withdrawing-Basis R of Contention 47, Mass AG does-not-intend to waive or prejudice-his-positioniwith respect'to any issue raised by any other basis or contention..
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. ? ? '.' OIIN. iGU IO JAN 15 '91 10:40 RoPts P. Gooy P.2 January 7, 1991, has baan mooted and Licensees Mordingly withdraw that motion.
II.
AflB-9421 MASS Ad CONTENTION !!s BARTE A In the light of the changes made to the SPMc subsequent to Mass AO's filings of his contentions in April, 1988, as reflected in the provisions of the BPMC as it was admitted into evidence and litigatsd, Mass AG agrees that the issues reised in Mass AG Contention 56 Basis A, as romanded in ALha-942, have been resolved.
Hans AG accordingly withdraws his contention 56 Basis A.2 Respectfully submitted, STAFF OF THE NUCLEAR ATTORHEY GENUAL FOR THE REGULATORY COMMI ION COMMONWEALTH OF MASS.
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By:
Edwin J.
als Leslie B. Greer office f the General Counsel Department of the U.S. N clear Regulatory Commission Attorney General one White Flint North, 15th Floor One Ashburton Place 11555 Rockv111a Pike Boston, MA 0210s Rockville, MD 20852 (617) 727-2200 (301) 492-1586 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, E,T AL.
By:
Wk6A Thomas G.
Dignan, Jr.
Ropes & Gray one International Placa Boston, MA 02110 (617) 951-7000 Filed:
January 18, 1991 8
In withdrawing Basis A of contention 56, Mass AG does not intend to waive or prejudice his position with respect to any issue raised by any othat basis or contention.
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, LC(JL iLD U5NHC CERTIFICATE OF-SERVICE
'91 2 22 All :31 1, Jeffrey P. Trout, one of the attorneys for the Licensees herein, hereby certify that on January 18,.1991NtJnadelservice of the within document by depositing copies therTdfki)i byW Tederal Express, prepaid, for delivery to (or, where indicated depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith
' Adjudicatory File Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Board Panel Docket (21 copies)
U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West' Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Administrative Judge Richard F.
Cole Robert R.
Pierce, Esquire Atomic Safety and Licensing Board Atomic Safety and Licensing U.S.
Nuclear Regulatory Commission Board
- East West Towers Building U.S.
Nuclear Regulatory 4350 East West Highway Commission Bethesda, MD 20814-East-West Towers Building 4350 East-West Highway Bethesda, MD 20814 Administrative Judge Kenneth A.
Mitzi A. Young, Esquire McCollom Edwin J. Reis, Esquire 1107 West Knapp Street Office-of the General Counsel i
Stillwater, OK 74075 U.S.
Nuclear Regulatory Commission One: White Flint North, 15th Fl.
11555 Rockville Pike Rockville,.MD 20852 John P. Arnold,-Attorney General-Diane Curran, Esquire George Dana Bisbee, Associate Andrea C.
Forster, Esquire Attorney General Harmon, Curran & Tousley_
Office of the Attorney General Suite'430 25 Capitol Street
.2001 S Street, N.W.
Concord, NH -03301-6397 Washington, DC 20009
- Atomic Safety and Licensing
-Robert A'.
Backus, Esquire Appeal Panel 116 Lowell Street
-U.S.
Nuclear Regulatory P. O.-Box 516 Commission Manchester, NH 03105 Mail Stop EWW-529 Washington, DC 20555 r
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Philip Ahrens, Esquire Suzanne P.
Egan, City Solicitor Assistant Attorney General Lagoulis, Hill-Whilton &
Department of the Attorney Rotondi General 79 State Street i
Augusta, ME 04333 Newburyport, MA 01950 Paul McEachern, Esquira Leslie Greer, Esquire Shaines & McEachern Matthew Brock, Esquire 25 Map'ewood Avenue Massachusetts Attorney General P.O.
Box 360 One Ashburton Place Portsmouth, NH 03801 Boston, MA 02108
- Senator Gordon J.
Humphrey R.
Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Hill-Whilton-&
Washington, DC 205:.0 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J.
Humphrey Barbara J.
Saint Andre, Esquire One Eagle Square, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301 101 Arch Street (Attn:
Herb Boynton)
Boston, MA 02110 H. Joseph Flynn, Esquire Judith H. Mizner, Esquire Office of General Counsel 79 State Street, 2nd Floor Federal Emergency Management Newburyport, MA 01950 Agency 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Ashod N.
Amirian, Esquire Holmes & Ells 145 South Main Street 47 Winnacunnet Road P.O.
Box 38 Hampton, NH 03842 Bradford, MA' 01835 Mr. Richard R.
Donovan Mr. Jack Dolan Federal Emergency Mar 3gement Federal Emergency Management Agency Agency - Region I Federal Regional Center J.W. McCormack Post Office &
130 228th Street, S.W.
Courthouse Building, Room 442 Bothell, Washington 98021-9796 Boston, MA 02109 metus,wu c_
George Iverson, Director N.H. Office of Emergency Management State House Office Park South 107 Pleasant Street Concord, NH 03301 O h!c.
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/Jef frey P.
Trout
(*= ordinary U.S.
First Clans Mail)
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