ML20195C010

Motion for Summary Disposition of South Hampton Contention 8,New England Coalition on Nuclear Pollution Contention NHLP-4 & Sapl Contentions 18 & 25 Based on Rh Strome Affidavit Assuring Identification of Special Needs Persons

ML20195C010
Person / Time
Site:	Seabrook
Issue date:	05/20/1986
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20195B803	List: ML20195B799 ML20195B811 ML20195B815 ML20195B826 ML20195B835 ML20195B848 ML20195B876 ML20195B886 ML20195B899 ML20195B924 ML20195B939 ML20195B945 ML20195B951 ML20195B956 ML20195B969 ML20195B985 ML20195B992 ML20195C010 ML20195C017 ML20195C022 ML20195C033 ML20195C041
References
OL, NUDOCS 8605290624
Download: ML20195C010 (4)

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Dated: May 20, 1986

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UNITED STATES OF AMERICA ,?

NUCLEAR REGULATORY COMMISSION /

before the i g <3 7 Y 7 '~

v' 3 ATOMIC SAFETY AND LICENSING BOARD sci As

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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 PARTIAL

SUMMARY

DISPOSITION OF SOUTH HAMPTON CONTENTION NO. 8, NECNP CONTENTION NHLP-4 AND SAPL CONTENTIONS 18 AND 25 Pursuant to 10 CFR S 2.749, on the basis of the Affidavit of Richard H. Strome Re South Hampton Contention No. 8, NECNP Contention No. NHLP-4 and SAPL Contentions Nos.

18 and 25 ("Strome Affidavit") and the Statement of Facts Not in Dispute attached hereto and for the reasons set forth below, the applicants move the Board to enter a decision summarily disposing of South Hampton Contention No. 8, NECNP Contention NHLP-4 and SAPL Contentions Nos. 18 and 25 insofar as these contentions assert that there do not exist i

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's adequate procedures for identifying persons with special needs.

REASONS FOR GRANTING THE MOTION __

South Hampton Contention No. 8, in part contends that

" adequate arrangements have not been made to identify . . .

persons who do not own an automobile." NECNP Contention NHLP-4 was for the most part rejected by this Board but was

" admitted as limited to notification of persons with special notification needs as specified in part (e) of the basis statement." Memorandum and Order (April 29, 1986) at 67.

SAPL Contention 18 raised the issue of whether the methodology utilized to calculate the numbers of non-auto owning population had understated the number of persons who would need transportation. SAPL Contention No. 25 raised the issue of whether " mobility impaired" individuals have been identified. Some of these contentions also raise'd

. issues as to whether, even using adequete identification procedures for "special needs" persons, proper assistance could be implemented. But this motion is concerned only with the issue of identification.

The Strome Affidavit demonstrates that an effective survey technique has been implemented to identify "special needs". persons and goes on to recite that this survey will lme ongoing and the data annually updated and kept current.

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.It is respectfully submitted that the survey techniques i

being carried out and to be carried out constitute a fully adequate method of identifying special needs persons. Any additional requirements would fall into the category of

" extraordinary measures" not required by the regulations.

Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-83-10, 17 NRC 528, 3 533 (1983).

By its attorneys, f /

r /"$Y Chomas1 f.Egnan,Jr.

Robert K. Gad III

, Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110

, (617) 423-6100 4

g- Dated: May 20, 1986 4

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MATERIAL FACTS AS TO WHICH THERE IS NO DISPUTE

1. The State of New Hampshire has conducted a survey within the New Hampshire portion of the PEPZ to determine

-who needs transportation, special notification, special help t-because of' health conditions, or foreign language notification.

-2. -This survey will be updated annually.

~3. Results of the surveys are compiled according to individual jurisdictions within the PEPZ and supplied to

j. local. civil defense officials.

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