ML20154P282
| ML20154P282 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/25/1988 |
| From: | Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6383 OL, NUDOCS 8806030283 | |
| Download: ML20154P282 (6) | |
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DOCKETED USHRC 18 Jd74D 2gg:ppes OFFICE OF SLGE!As i 00CKEll% & Vi<VO.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW FAMPSHIRE, et al.
)
50-444-OL
)
(Seabrook Station, Units 1 and 2)
)
(Off-site Emergency
)
Planning Issues)
APPLICANTS' RESPONSE TO "SEACOAST ANTI-POLLUTION LEAGUE'S LATE-FILED CONTENTION ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES" Under date of May 13, 1988, Seacoast Anti-Pollution League ("SAPL") submitted one late-filed contention on the Seabrook Plan for Massachusetts Communities ("SPMC"):
l l
SAPL Contention No. 10 l'
l The SPMC Amendment 4 fails to provide reasonable assurance that there will be adequate means of relocation for special facility populations in the 6 Massachusetts communities because numbers of buses for j
those special facilities have been drastically reduced.
l There are no compensating measures to make up for the l
reduction in bus numbers to assure reasonably the safety i
of the residents of the facilities.
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l D
ADO O
D DSo3 o
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Therefore, the requirements of 10 CFR 5 50.47 (a) (1),
5 50. 47 (b) (10), and NUREG-0654, FEMA-REP-1, Rev.
1,'
Supp.
1, J.10d and J.10g have not been met.
Bases The numbers of buses set out in amendment 3 of the SPMC for special facilities for the 6 Massachusetts communities have been drastically reduced with no apparent reason, rationale or compensating measures provided to explain these plan changes.
(See Appendix M, p. M-16)
For Amesbury special facilities, for example, buses were reduced from 13 down to 1 and wheel I
chair vans were reduced from 9 down to 1.
As another example, Newburyport's special facility buses were reduced from 18 down to 1.
Absent a reasonable number of emergency vehicles for the special facilities for these and the other Massachusetts EPZ communities, there is no reasonable assurance that residents of special facilities can be protected.
The vehicle numbers set forth in SPMC Amendment 4 are not at all reasonable given the numbers of special facility residents in those communities.
ADolicants' Position Applicants do not object to admission of this contention.
However, Applicants point out that in addressing the five factors governing admission of late-filed contentions under 10 CFR S 2.714 (a) (i), SAPL stated:
SAPL is filing within the 30-day time frame that has customarily been the set time for filing contentions on newly received plan amendments i. this case.
l 1..
This statement is in error; no such custom exists to be invoked by intervenors after any plan amendment, large or small.
Respectfully submitted, A / ul Tliom6s 'G.
Dignan, Jr.
George H.
Lewald Kathryn'A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 -..
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CERTIFICATE OF SERVICE I,
Kathryn A. Selleck, one of the attorneys for the Applicants herein, hereby certify that on May 25, 1988, I made service of the within document by mailing copies thereof,_ postage prepaid, to:
Administrative Judge Ivan W.
- Smith, Stephen E.
Merrill, Esquire Chairperson Attorney General Atomic Safety and Licensing George Dana Bisbee, Esquire Board Panel Assistant Attorney General U.S.
Nuclear Regulatory Office of the Attorney General Commission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Judge Gustave A.
Linenberger, Jr.
Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Robert Carrigg, Chairman Diane Curran, Esquire Board of Selectmen Andrea C.
Ferster, Esquire Town Office Harmon & Weiss Atlantic Avenue Suite 430 North Hampton, NH 03862 2001 S Street, N.W.
Washington, DC 20009 Adjudicatory File Sherwin E.
Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal Board Panel Docket (2 copies)
Director U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr.
J.
P.
Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333
Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Flr.
Portsmouth,in{ '03801 Boston, MA 02100 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, lui 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J.
Humphrey R.
Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn:
Tom Burack) 79 State Street l
Newburyport, MA 01950 l
Senator Gordon J. Humphrey Mr. Peter S.
Matthews One Eagle Sylare, Suite 507 Mayor Concord, NH 33301 City Hall (Attn:
Herb Beynton)
Newburyport, MA 01950 Mr. Thomas F.
Pow 0rs, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472 l
Gary W. Holmes, Esquire Richard A.
Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 7
{
Mr. Ed Thomas Judith H.
Mizner, Esquire FEMA, Region I 79 State Street, 2nd Floor 442 John W. McCormack Post Newburyport, MA 01950 Office and Court House Post Office Square Boston, MA 02109 - - _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
Charles P. Graham, Esquire Ashod N. Amirian, Esquire Murphy and Graham 376 Main Street-33 Low Street Haverhill, MA 01830 Newburyport, MA 01950 Leonard Kopelman, Esquire Kopelman.& Paige, P.C.
77 Franklin Street Boston, MA 02110 IDJ Kathyn'A. salleck l
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