ML20205P250
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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 SOUTH HAMPTON CONTENTION NO. 3 Pursuant to 10 CFR 5 2.749, on the basis of the facts set forth in the Affidavit of Richard H. Strome (TOSH 3),
and for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in Applicants favor with respect to Town of South Hampton (Tosh) Contention 3.
REASONS FOR GRANTING THE MOTION Town of South Hampton Contention 3 reads as follows:
The RERP for South Hampton fails to provide reasonable assurance because, contrary to'NUREG B704030217 B70325 PDR ADOCK 05000443 0
PDR L
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0654 C.4, it contains no letter of agreement from transportation companies and Midway Excavators.
Memorandum and Order of April 29, 1986 at 33.
Applicants' motion for summary disposition was denied only to the extent of deficiencies noted by FEMA and RAC in their review.
Memorandum and Order of November 4, 1986 at 6.
Those deficiencies have now been cured.
As set forth in the Affidavit of Richard H. Strome filed herewith, all requirements for transportation resources can be met.
The numbers of buses, ambulances, and drivers committed to in letters of agreement are well in excess of any foreseeable needs.
See Affidavit 11 3-7.
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.
By their attorneys, U
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T! row ~ii W. Digna Jr.
R. K. Gad II Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617)423-6100
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STATEMENT OF MATERIAL FACTS NOT IN DISPUTE 1.
All requirements for transportation resources can be met.
The Regional Assistance Committee (RAC) Evaluation of State Response in NHRERP, Revision 2 (8/86, p. 74-b of 134),
found there are adequate means of relocation.
2.
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.
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.
I, p.1-3.
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 f
t by the union.
3.
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.
Together, these organizations provide transportation resources in exccess of the numbers required in Appendix I to Volume 2.
4.
Volume 5, 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 3
s requirement for 515 total buses.
This is less than the 574 buses currently available through letters of agreement.
5.
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.
6.
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.
7.
The State Department of Transportation has adequate backup resources to plow the snow in the town of South Hampton.
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