ML20205M198

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Motion for Summary Disposition of New England Coalition on Nuclear Pollution Contention NHLP-6.* Motion Based in Part on Facts Set Forth in Rh Strome Affidavit.Statement of Matl Fact as to Which There Is No Dispute Encl
ML20205M198
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 03/25/1987
From: Dignan T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20205L804 List: ... further results
References
OL, NUDOCS 8704020298
Download: ML20205M198 (6)
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Dated: March 25, 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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MOTION FOR

SUMMARY

DISPOSITION OF NECNP CONTENTION NHLP-6 Now come the Applicants, pursuant to 10 CFR 2.749, and on the basis of the facts set forth in the " Affidavit of Richard H. Strome (NECNP contention NHLP-6)", hereafter "Strome Affidavit",and for the reasons set forth below, move the Board to enter an order granting summary disposition in favor of the Applicants with respect to NECNP Contention NHLP-6.

REASONS FOR GRANTING THE MOTION NECNP Contention NHLP-6 reads as follows:

"The local emergency plans do not provide for an adequate range of protective actions, 10 CFR 50.47(b)(10) l 0704020290 07032D PDR ADOCK 05000443 o PDR t______

3 g b:ccuco thsy contoin ined;quoto macnc of relocation or other protection for those with special needs. Those without ,

private transportation, school children, or persons confined to institutions or elsewhere for health or other reasons.

Moreover, the resources available to the towns for these purposes are inadequate to provide a reasonable assurance that the public will be protected in the event of an accident."

The bases articulated for this contention that there are inadequate provisions for special needs populations were (a) inadequacy of the telephone system as a notification medium, (b) the fact that persons might not know when or where to wait for a bus, (c) provisions for school children including " latch key" children were inadequate, and (d) inadequacy of buses and procedures.

Taking each of these matters in turn, it is clear from the Strome Affidavit that each of the alleged inadequacies NECNP complains of does not exist. The notifications will be given not by telephone but by the emergency broadcast l system. Strome Affidavit, 1 3. A procedure has been designed so that broadcasts can be made as to when buses begin traveling the routes, so that persons will know when to go to the place to be picked up, and will not be outside unnecessarily. " Latch key" children are accounted for, Strome Affidavit'. 1 4. There exist adequate plans and procedures for handling school children. Strome Affidavit, 11 5-6. As to overall adequacy of bus resources: A total of 574 buses are available, vs. 515 needed for all purposes.

Compare Letter of Agreement, NHRERP Vol. V with NHREP Vol.

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, 2, App. I, p. I-3. Thaca dccum:nto ch w loca th n 574 drivers available, but the teamsters can provide up to approximately 1500 qualified drivers. See LOA with Teamsters Local 633 in NHRERP Vol. 5. In addition, a review of the pertinent sections of the local plans reveals that in the case of each New Hampshire Town the capacity of buses allotted exceeds the number of students who may require transportation assistance.

By their attorneys, 9

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Thoriias G.' DgiJr.

R. K. Gad III Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 l (617) 423-6100

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j STATEMENT OF-MATERIAL FACT AS l TO WHICH THERE IS NO DISPUTE NECNP CONTENTION NHLP-6)

1. The August 1986 RAC Evaluation of State Response 1

(pg. 73 of 134, Item 3) states that the concept of j pre-designated bus routes is " adequate."

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2. Volume 4, Appendix G (Emergency Broadcast System Activation), contains in Attachment 2, EBS Sample Messages.

j Messages "F" (General Emergency - Sheltering and Evacuation) and "G" (General Emergency - Evacuation) both contain a provision for notifying the transit dependent what time buses will begin traveling the pre-established bus routes (pg. G-32 and G-37/38, respectively).

3. While " latch key children" are not specifically addressed, or singled out as a particular transportation dependent group, they are accounted for in establishment of access control to the Plume Exposure EPZ. Volume 1, Section 2.6 (Protective Response) states the following on page 2.6-16.

Before and during and evacuation, nonessential population is denied entry to the controlled area. At this time only the following personnel will be allowed entry:

Residents with appropriate identification (e.g.

drivers licenses) returning to their homes to

prepare to evacuate.

This provision will allow for parents to return home in order to pick up their children who may have arrived home as a result of normal (or early) school dismissal.

4. Special arrangements have been planned for the l ,

1 transport of students when school is in session.

Arrangements are described in Volume 1 (NHRERP Parts 1.0 ,

through 7.0), Section 2.6 (pgs. 2.6-11 through 2.6-11b).

Transportation is a coordinated effort between the State of New Hampshire and each town. For example, Volume 31 (Town of South Hampton RERP) provides for school children in the following sections.

VOLUME 31, TOWN OF SOUTH HAMPTON RERP

a. Section II.G -

Evacuation of Schools

b. Section III.C.3 - Transportation (Reference Section II.G)
c. Appendix F -

Special Facilities Plans -

Barnard School

! 5. Arrangements for transportation are also described in the following references; with emphasis on the role of the State of New Hampshire.

a. Volume 1, Section 1.2 - Pupil Transportation Safety Supervisor
b. Volume 1, Section 2.6 - Protective Response (Evacuation, etc)
c. Volume 4, Section 7 -

EOC Resource Coordinator

Procedure
d. Volume 4B, -

Director of Pupil l Transportation Safety e.* Volume 5 -

Letter of Agreement (Index and selected LOAs)

6. Revision 2 of the NHRERP, Volume 2 (Appendices),

contains in Appendix I (pg. I-3) a summary of transportation

, resource requirements for all 17 New Hampshire towns and any special facilities or institutions. These numbers are being updated to reflect current requirements.

7. Volume 5 of the NHRERP contains letters of agreement with bus and ambulance companies, Teamsters Local No. 633 of d

3 N:w Hamprhire, end ths Ngw Htmpshira Schcol Trancportction Association. Together, these organizations should be able to provide transportation resources in excess of the numbers required.

8. Volumes 16 through 32 of the NHRERP comprise all of the 17 New Hampshire Town RERPs. In Section IV of each plan, an Attachment to the Transportation Coordinator's (or equivalent responsible individual) procedure provides the individual town transportation requirements. Included in each list is a category entitled "Public Schools: and/or

" Private, Day Care Schools", which identifies the number of students within this category and the number of buses / vans that have been allocated to meet their needs. These l requirements are based on an annual determination of student enrollment.

9. In each case, the capacity of buses allotted surpasses the number of students that may require transportation assistance. The totality of bus / van resources, on which the plans rely, is confirmed by letters of agreement contained in Volume 5 of the NHRERP.

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