ML20215E002

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Applicant Motion for Summary Disposition of Town of South Hampton Contention 8.*
ML20215E002
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 06/11/1987
From: Dignan T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20215D921 List:
References
OL, NUDOCS 8706190219
Download: ML20215E002 (6)
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Dated: June 11, 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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1 APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF TOWN OF SOUTH HAMPTON CONTENTION NO. 8 i Now comes the Applicants, pursuant to 10 CFR 2.479, and on the basis of the facts set forth in the " Affidavit of Richard H. Strome (TOSH Contention 8)," 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 Town of South Hampton (TOSH) Contention No. 8.

REASONS FOR GRANTING THE MOTION TOSH Contention No. 8 reads as follows:

"The RERP for South Hampton fails to provide reasonable assurance because, contrary to NUREG-0654 J.10.d it fails to provide for protection of those ,

persons whose mobility may be impaired '

due to such factors as institutional or other confinement."

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4 This contention raises the issue of transportation of j l

"special needs" individuals in connection with the TOSH ];

Radiological Emergency Response Plan. This contention was J linked to mobility impaired individuals and transportation dependent persons. ASLB Order of April 1, 1986.

The Strome Affidavit establishes that there are j 1

currently three people with "special needs" transportation )

1 requests in TOSH and one bus conversion kit and one special- ]

l needs bus has been allotted for their transportation. l Strome Aff., t 2; NHRERP Vol. 31 at P. IV-25. One public school is located in that town with 76 students; 2 buses have been allotted for their transportation. Three buses have been allotted for other residents requiring transportation. Id.

As the Strome Affidavit and its attachments reveal, the buses, ambulances, drivers, etc., under letters of agreement will exceed the resource requests of the New Hampshire portion of the EPZ. Strome Aff. 3-4.

The procedures by which schools, special needs, and other transportation dependent persons will be evacuated are spelled out, Id. In particular the procedures for the Barnard School and the Tuxbury Pond Campground are spelled out. Id. NHRERP, Vol. 31 pp. F.-2-1--8; F.3-1--4.

It is clear from the foregoing that there is reasonable assurance that the needs of the mobility impaired in TOSH will be met in any emergency at Seabrook.

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.s CONCLUSION i

AnEorder should enter granting summary disposition in:

favor of the' Applicants with respect.to: TOSH Contention ,

-l No. 8. 4 I

By their attorneys, 1 y .-

Thomas G. Dignan, Jr '.  !

George H. Lewald.

Kathry.A. Selleck . . l Deborah S. Steenland- ,

Ropes &. Gray 1 225 Franklin Street i Boston, MA- 02110  :

(617) 423-6100 o

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'l STATEMENT OF MATERIAL FACT NOT IN DISPUTE

1. Revision 2 of the New Hampshire Radiological' Emergency Response Plan (NHRERP), Volume 31 (Town of. South ,

I Hampton RERP), contains in Attachment 1, (pg. IV-25) to the  !

Assistant Civil Defense Director's Emergency Procedure a detailed listing of South Hampton's specific transportation requirements. This includes residents requiring transportation (i.e., ambulatory non-auto owning) and those i with special needs (i.e., non-ambulatory or ambulatory with a special notification or transportation requirement). The allotted or required transportation resources needed to effectively evacuate the above groups are also specified.

2. The Town of South Hampton's requirements are included in Revision 2 of the NHRERP, Volume 2 (Appendices),

Appendix I (pg. I-3) this listing; which also defines the 1 specific transportation requirements. The column totals for each type of transportation resource include, and are consistent with, those listed in the Town of South Hampton RERP (Vol. 31), Attachment 1 (pg. IV-25) as described in item 1 above.

3. Revision 2 of the NHRERP, Volume 5 (Letters of Agreement in Support of the NHRERP), contains letters of agreement with bus and ambulance companies, Teamsters Local No. 633 of New Hampshire, and individual transportation providers; all of which should be able to combine to provide sufficient transportation resources.

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4. Arrangement for evacuation of mobility impaired and transport dependent persons is a coordinated effort between l the State of New Hampshire and each town. In the Town of i

South Hampton the assessment of emergency medical 1 transportation requirements and transportation requirements for people with special needs is the responsibility of the  !

Transportation Coordinator. This is detailed in Volume 31, III.F (pg. III-13), and the Transportation Coordinator procedure, Volume 31, IV-F (pgs. IV-26 through IV-28c). The l

Transportation Coordinator is supported and assisted by the ]

Assistant Civil Defense Director and the School ]

Superintendent; as described in NHRERP Volume 31, III.C.3, (pg. III-5), entitled " Transportation". j

5. Special arrangements have been planned for the transport of students (when school is in session),

institutionalized people, people without access to private automobiles and people with special needs in the Seabrook Station EPZ. The arrangements are detailed in Volume 31, II.G (pgs. II-28 through II-30). Appendix F to Volume 31 contains South Hampton's Special Facilities Emergency Response Plans.

6. Arrangements for transportation are also described in Volume 1 (NHRERP Parts 1.0 through 7.0), Section 2.6 (pgs. 2.6-11 through 2.6-llb). Evacuation of special facilities will be coordinated by the State EOC Resources Coordinator (Volume 4, Section 7), and the State Bureau of
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Emergency Medical Services (EMS) through the EMS Coordinator-(Volume 4B, EMS Coordinator Procedure). For residents-reg,uiring transportation, the State EOC Resources Coordinator will direct the dispatch of buses from the State Staging Area (letter of agreement with OMNE Mall, Portsmouth, in Volume 5 of NHRERP) to the Local Staging Area (this is the-local EOC.for the Town'of South Hampton).

There, the buses will be provided with route maps and directions for driving along the pre-designated routes.

Any j additional unanticipated bus needs will be' coordinated through the town Incident Field Office (IFO) Local Liaison, who is located at the State IFO and is in direct contact with the Town of South Hampton Transportation Coordinator at the local EOC.

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