ML20205N927
| ML20205N927 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| 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:
|
| References | |
| OL, NUDOCS 8704030136 | |
| Download: ML20205N927 (7) | |
Text
s,,
4 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 ON SEACOAST ANTI-POLLUTION LEAGUE CONTENTION PO. 37 Pursuant to 10 CFR 5 2.749, on the basis of the facts set forth in the Affidavit of Richard H. Strome (SAPL 37) and the Affidavit of Edward B.
Lieberman, and for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in' Applicants'. favor with respect to Seacoast Anti-Pollution League Contention No. 37.
i l
i i
8704030136 B70325 PDR ADOCK 05000443 l
G PDR
REASONS FOR GRANTING THE MOTION SAPL Contention No. 37 reads as follows:
The NHRERP Rev. 2 fails to provide reasonable assurance of adequate public protection because an adequate number of emergency vehicles are not provided for in the plans and further there is no assurance that effective use of these vehicles will be possible in view of a potential outgoing flow of evacuating traffic and a significant lack of drivers.
Therefore, these plans do not meet the requirements of 10 CFR S 50.47(a)(1), 5 50.47(b)(3),
5 50.47(b)(lO) and NUREG-0654 II.J.lO.g.
and II.J.lO.K.
The Board limited this contention in the following respects:
Admitted:
SAPL Contention 37 (Limited to issues concerning availability of evacuation vehicles and drivers for persons requiring transport assistance and ability of transport vehicles to traverse EPZ to reach designated areas in an emergency).
Memorandum and Order of February 18, 1987 at 5.
As more fully set forth in the Affidavit of Richard H.
Strome (SAPL-37), all requirements for transportation resources can be met.
Affidavit at 11 2-9.
The numbers of buses and drivers available and committed to in letters of agreement exceed any foreseeable needs.
Id.
As more fully set forth in the Affidavit of Richard H. Strome (SAPL-37) 11 10-11 and the Affidavit of Edward B. Lieberman (SAPL-37).
0 11 2-3, there should be little impedance to emergency vehicles entering the EPZ following an order to evacuate.
By their attorneys,
--er,s/
y TH6 mas'CDi p, Jr.
R.
K. Gad IM Kathryn A.
Selleck Ropes & Gray 225. Franklin Street Boston, MA 02110 (617) 423-6100 -
8 STATEMENT OF MATERIAL FACTS NOT IN DISPUTE (SAPL-37) 1.
The Regional Assistance Committee (RAC) Evaluation of State Response in NHRERP, Revisjon 2 (8/86, p. 74-b of 134), states that there are adequate means of relocation.
2.
In Volume 4, Appendix I, the totals of 574 buses and 510 drivers are accurate and consistent with the numbers committed to in the letters of agreement.
An additional 1,500 Teamsters, however, make an overall total pool of over 2,000 drivers upon which to draw.
The RAC Evaluation of State Response (p. 74-b of 134) further states the following:
The plan properly allows for the fact that not all bus companies have as many drivers willing to serve as they have buses that would be made available.
A letter of agreement with Teamsters Local No. 633 of New Hampshire provides for the local to provide as many as 1500 personnel, a value well in excess of any foreseeable needs.
3.
Appendix I to Volume 2, of the New Hampshire RERP contains a summary listing of specific transpcrtation resource requirements for the State of New Hampshire EPZ.
Currently, a total of 515 buses is required; including all school buses, special needs buses, and coach buses.
4.
In each case, the capacity of buses allotted surpasses the number of residents who have indicated that they may require transportation assistance.
(A minimum of three buses have been allotted to each town regardless of l,
l l
n the fact that this capacity far exceeds the requirements 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.
Volume 5 of New Hampshire RERP contains letters of agreement with the bus and ambulance companies, Teamsters Local No. 633 of New Hampshire, and the New-Hampshire School Transportation Association.
Together, these organizations provide transportation resources in excess of the numbers required in Appendix I to Volume 2.
6.
Volume 4, Appendix I (p. I-8), entitled Transportation Resource Requirements, and Volume 2, Appendix I (p. I-3), are both being revised to indicate an updated requirement for 515 total buses.
This is less than the 574 buses currently available through letters of agreement.
7.
The Teamsters Local No. 633 of New Hampshire has agreed to provide drivers for evacuation transportation activities from within its membership ranks.
A letter of agreement to that effect is contained in Volume 5, Revision 2, of the NHRERP.
i 1
8.
The NHRERP is being revised to assure a reserve.of backup buses.
This will consist of having buses, which
)
originate from outside the EPZ, returning to their Staging Area after transporting persons to the Reception Center.
]
They originally received dosimetry at the Staging Area when i
they were initially mobilized.
Buses originating from.-
=
I within the EPZ, which will not have dosimetry, will' remain at the Reception Cen'ter to provide transportation to Congregate Care Centers (i.e., host facilities), if-necessary.
Buses will not of course, be utilized for either of the above if they are contaminated.
9.
Volume 6, Seabrook Station Evacuation Time Study.
(Evacuation Time Estimate or ETE), Section 11 pp. 11-19, 20, states that there should be little impedance to incoming emergency vehicles.
The basis justifying this is also provided.
10.
Volume 1, Section 2.6 (p. 6-16, Access Control),
discusses how access control helps clear traffic from the roads within the EPZ, so that they may be better used for.
evacuation and/or emergency vehicles.
11.
Volume 6 pg. 11-19 and 11-20 provides a detailed description of inbound travel time.
This section indicates that little impedence to vehicles entering the EPZ following an order to evacuate would be anticipated due to the following reasons:
a.
The first buses will not depart their points of origin until approximately 30 minutes following the order to evacuate.
b.
Some 70% of returning commuters will have reached their homes within the EPZ one hour following the evacuation order, and therefore will be off the highways.
(See also Vol. 6, Figure 11-1). J
'h i
t c.
Other inbound traffic would be limited due to discouraged entry via EBS and other media messages, and by peoples concern over the potential risk to their health and safety.
d.
Access control points established at the perimeter of the evacuated area would also discourage non-essential inbound traffic.
12.
It is reasonable to anticipate that incoming buses along at-grade primary highways (e.g.,
Route 1) may average 40 mph and those that travel along access-controlled highways, may average 50 mph. ]