ML20205P211
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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
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Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
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50-444-OL
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Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues,
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APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION ON TOWN OF KENSINGTON REVISED CONTENTION 6 l
Pursuant to 10 CFR $ 2.749, on the basis of the facts set forth in the Affidavit of Richard H. Strome (TOK 6), and for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in favor of the Applicants with respect to Town of Kensington (TOK)
Revised Contention No. 6.
REASONS FOR GRANTING THE MOTION Town of Kensington Revised Contention No. 6 reads as follows:
8704030205 870325 PDR ADOCK 05 g3 e
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j' The NHRERP, Revision 2 for "TOK" does not provide adequate arrangements for effectively using assistance and resources as required by 10 CFR 50.47(b)(3) because there are not appropriate letters of agreement to identify support organizations or other facilities which are to provide assistance.
As set forth in the Affidavit of Richard H. Strome (TOK Revised Contention 6), the State of New Hampshire is confident that all requirements for transportion resources can be met.
Affidavit 1 3.
The numbers of buses, ambulances, and drivers which will be available are well in excess of any foreseeable needs.
See Affidavit 11 4-8.
Further, the State Department of Transportation has adequate backup resources to plow the snow in the Town of South Hampton, should Midway Excavators fail to perform this function during a radiological emergency at Seabrook.
See Affidavit 1 2.
By their attorneys, W/
Thomas'G. D2f)rrin, Jr.
R. K. Gad III Kathryn A.
Selleck i
Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 i I
i lo STATEMENT OF MATERIAL FACTS NOT IN DISPUTE 1.
Should Midway Excavators fail to perform the functions of snow removal, the State Department of Transportation has adequate back-up resources to plow the snow in the Town of Kensington.
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The State of New Hampshire is confident that all requirements for transportation resources can be met.
See The Regional Assistance Committee (RAC) Evaluation of State Response in NHRERP, Revision 2 (8/86, p. 74-b of 134).
3.
In NHRERP 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.
Only a total of 515 buses and drivers are actually needed.
NHRERP Vol. 2, App.
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A letter of agreement has been executed with Local 633 of the Teamsters whereby they agree to supply up to 1,500 drivers.
Letters of agreement with owners are being obtained permitting the mobilization of these drivers by the union.
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Volume 5 of the New Hampshire RERP contains letters of agreement with bus and ambulance companies, Teamsters Local No. 633 of New Hampshire, and the New Hampshire School Transportation Association.
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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 -
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This is less than the 574 buses currently available through letters of agreement.
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The availability of adequate EMS or ambulance service is sufficient to respond to all New Hampshire EPZ needs.
Volume 5 contains letters of agreement which make available 39 ambulances.
This is in excess of the total vehicle needs for New Hampshire of 36 ambulances, as listed in the IFO Resource Coordinator's procedure - Volume 4, Section 18, Attachment 18B,
(" Local Transportation Worksheets".
A list of ambulance providers and number of ambulances is also provided in Volume 4, Appendix I (Section 2).
Section 3 to Appendix I summarizes transportation resource requirements with respect to the individual towns.
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