ML20205N027

From kanterella
Jump to navigation Jump to search
Applicant Motion for Summary Disposition of Seacoast Anti- Pollution League Contention Number 18.* Motion Based on Listed Reasons & Rh Strome Affidavit.Statement of Matl Facts as to Which There Is No Dispute Encl
ML20205N027
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 8704020562
Download: ML20205N027 (6)
v • d • e


Text

.

Dated: March 25, 1987 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 HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

)

)

APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF SEACOAST ANTI-POLLUTION LEAGUE CONTENTION NO. 18 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 (SAPL Contention 18)" 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 Seacoast Anti-Pollution League (SAPL) Contention 18.

REASONS FOR GRANTING THE MOTION SAPL Contention 18 reads as follows:

"NHERP Rev. 2 significantly miscalculates the number of non auto owning population for the 17 New 8704020562 870325 PDR O

ADOCK 05000443 PDR

+ ,

, 's . p Q, w . , >

Hampshire local communiti'es. No buses 'n

~ ",are provided;in the plany fe'r the individuals nct acccunted for due to the i.

J' miscalculationm Therefore, these plans ,

fail to me'et t1m requiremests 10 a CFR $ 50.47(a)(1), 5 50.47(b)(.8), .,

NUREG-0654 II.J.10.g. and '

NUREG 0654-App. 4, p. 4-3". ,

As the S trome affidavit > ("Strome Aff ") poir,ta out, 'each ~

local plan in NHRERP Rev. 2 now lists the m,>:Aber of people who are " residents requiring trpnsportatich", hAomeAff.

12, as determined by the NHCDA Special 1 eedrL' Survey bs' ,

s

  • procedures already found ' adequate by thi:t Board. ASLs ' '

N.

(

Memorandum and Opjer of Nbir. 4, 198G . at . More than enough buses have been allocated in each Icase. Id. 9 3.

e. ,

The availah'ility of sufficient buses to satis. at? of the ,

NHRERP resource requests is made clear by a o parison of the resource needs', with'the number of tuse.e mudo.,availablo in the, LOA's. It is acknowledged .that a correction must be' made, but thi,s will not impact, tlie regource ~, sufficiency.

Strome Aff., 1 6. '

Finally, it is to be notednthat the fore ving nalysis, takes no credit for the phenomenen of " ride shs.ving",.Stromo -

Aff. 1 4, whichtwill be encoursged by EBS messaQos, 19 1 9. ,

nor the fact,that each town-l's allotted 3 buse.s even,'where ,

the capacity this repreEents O [Ar in excess o,f'actua*i

'. i~ ..

need. Both of these facts add additional cone,erv&tism to e < ,. /

' I ,

f s_

p 4 s\

4 a

, i b

e ,

.' t J

% 8 l I

J

\I i l

r

^ - ' --

(

n, .

i , -

e (i] ths conclusion that non-auto owning persons will be

(' adequately taken care of.

i By-their attorneys, Nu

< - -+

as C. K nan, Jr.

R. K. Gad III

, Kathryn A. Selleck

$ Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 1

4 i

,/*

l n z l I

l 3e

,) -

c. _

l' ,

{

l l

4 J

a

's. -

3-( ,i ' .

)$ \

s '

l'.

,i'

{

n . (3 . .. . .., .. . _ _

STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO DISPUTE

1. The Special Needs Survey conducted by the NHCDA in March,-1986 served to identify persons within the 17 communities of the Seabrook Station EPZ who do not have access to a private vehicle and who, therefore, may require.

transportation assistance at the time of an. emergency.

2.. The ASLB, in its order or November 4, 19b6, found this survey to be an adequate procedure for identifying persons who may require special assistance.

3. Volumes 16 through 32 of the NHRERP comprise all of n, 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. i each list is a category entitled " Residents Requiring  !

Transportation", which identifies the number of people s

within this category and the number of buses that have been allotted to meet their needs. These requirements are not based on an assumption of a specific percentage of the population without cars, but are obtained directly from the NHCDA Special Needs Survey.which the ASLB has previously ruled adequate-(11/4/86 ASLB Memorandum and Order) in identifying persons with special needs, including residents who may require transportation.

4. In each case, the capacity of buses allotted-surpasses the number of residents who have indicated that

.i

.i

k they may require transportation assistance. (A minimum of three buses have been allotted to each town regardless of the fact that this capacity far exceeds the rquirements in several cases.) The totality of bus resources, on which the plans rely, is confirmed by letters of agreement contained in Volume 5 of the NHRERP.

5. The allotment of transportation resources does not consider the phenomenon known as " ride sharing" which assumes that people will, in an emergency, obtain rides in the personal vehicles of other evacuees.
6. NHCDA has committed to the FEMA RAC to include language in public information materials and in EBS messages requesting people to provide assistance to others who may be in need.
7. NHRERP, Volume 2 (Appendices), contains in Appendix I (pg. I-3) a summary listing of transportation resource requirements. The total number of buses shown in this summary listing (as well as in a similar summary listing contained in Appendix I of Volume 4) does not reflect an adjustment that was made in the total number of buses allotted in the Town of Exeter RERP. This will be corrected. This discrepancy does not, however, impact on the sufficiency of the total bus capacity that is provided for persons who may require transportation assistance.

Furthermore, these figures will continually be updated to c.

e remain current with changes in transportation. requirements

-as they become know by further identification of needs.

l l

l l

l 4

1 i

2 i

r

.- -. . _ , . . . .- ._ _ .. , , - . ,. ., _ .-. __. , - _ . . , _ . _,_ . _ . ..

Retrieved from "https://kanterella.com/w/index.php?title=ML20205N027&oldid=3019994"