ML20215E030

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Applicant Motion for Summary Disposition of New England Coalition on Nuclear Pollution Contention NHLP-6.*
ML20215E030
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 8706190229
Download: ML20215E030 (6)
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4 Dated
June 11, 1987 UNITED' STATES OF AMER'ICA , .

n NUCLEAR REGULATORY' COMMISSION before the a ATOMIC. SAFETY AND LICENSING BOARD 

                                                         )

In the Matter of ) 

                                                         )

Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY OF ) NEW HAMPSHIRE, et al. ) 50-444-OL 

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

APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION l OF NEW ENGLAND COALITION ON NUCLEAR POLLUTION CONTENTION NHLP-6 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 (NECNP contention NHLP-6)", hereafter l 

             "Strome Affidavit",and for the reasons set forth below, move                          l the Board to enter an order granting summary disposition in                           ;

favor of the Applicants with respect to;New England Coalition on Nuclear Pollution (NECNP) Contention NHLP-6. REASONS FOR GRANTING THE MOTION 

                                                                                                   )

NECNP Contention NHLP-6 reads as follows: 

                           "The local emergency plans do not provide for an adequate range of 8706190229 870611 PDR   ADOCK 05000443PDR,4 g

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                                     -{,   l' protective actions,n 10 CFR 50.47(b)(10):                        'bl because'they.containiinadequate meansfof; relocation or other protection'for those-with special needs. Those without.                        ,

private. transportation, school children, or! persons confined"to\ institutions-or s t: elsewhere for health or.other reasons. Moreover,.the resources 7available toLthe 

                          ' towns for .these" purposes' are inadequate.

to provide a reasonable. assurance that: 

                         'the publicLwill be protected in the <

event'of an accident." The bases articulated for this contention that here are ,' -' inadequate provisions forfspecial needs populations.were (a). inadequacy of the. telephone system;as a-notification medium, (b).the fact that persons might not.know when'or where to wait for a bus, (c) provisions for school children including " latch key" children.were inadequate, and 4 (d) inidequacy of buses and procedures. Taking each of these matters' in turn, 'it isL - clear from - the Strome Affidavit that each of the alleged inadequacies NECNP complains of does not exist. Theonctifications will be given not by, telephone but by the emetgency broadcast system. Strome Affidavit, H 3. A procedure has been designed so that broadcasts can be made as to when buses begin traveling the routes, so that persons will know when to go to the place to be picked up, and"will not be cutside i unnecessarily. " Latch key" children are-accounted for, Strome Affidavit. 1 4. There' exist adequate plans and procedures for. handling school children. Strome Affidavit, SV 5-6. As to overall adequacy of bus resources: A total of 574 buses are available, vs. 515 needed for.all purposes. Compare Letter of Agreement, NHRERP Vol. V with NHREP Vol. 

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2,: App. I, p. I-3. These documents show less than j 574 drivers available, but'the teamsters can provide a back-up pool of up to approximately 1500 qualified drivers. j See LOA with Teamsters Local 633 in NHRERP Vol. 5. In addition, a review of the pertinent sections of the local plans reveals that in the case of each New. Hampshire Town. , the capacity of buses allotted exceeds the number of students who may require transportation assistance. By their attorneys, } k Thomas G. Dignan, Jr. George H. Lewald Kathryn A. Selleck Deborah S. Steenland Ropes & Gray 225 Franklin Street Boston, MA 02110 l (617) 423-6100 { 1 1 1 I i l I i 1 1

i STATEMENT OF MATERIAL FACTS NOT IN DISPUTE i l

1. The August 1986 RAC Evaluation of. State Response- q l

(pg. 73 of 134, Item 3) states that the concept of pre-designated bus routes is " adequate." i

2. Volume 4, Appendix G (Emergency Broadcast System Activation), contains in Attachment 2, EBS Sample Messages.  :

Messages "F" (General Emergency - Sheltering and Evacuation) and "G" (General Emergency - Evacuation) both contain a provision for notifying the transit dependent what time buses will begin traveling the pre-established bus routes (pg. G-32 and G-37/38, respectively). . I

3. While " latch key children" are not specifically j addressed, or singled out as a particular transportation )

dependent group, they are accounted for in establishment of access control to the Plume Exposure EPZ. Volume 1, Section l 2.6 (Protective Response) states the following on page 2.6-16. Before and during and evacuation, nonessential l population is denied entry to the controlled area. At ( this time only the following personnel will be allowed i entry: Residents with appropriate identification (e.g. drivers licenses) returning to their homes to prepare to evacuate. This provision will allow for parents to return home in- 1 1 order to pick up their children who may have arrived home as l a result of normal (or early) school dismissal.

4. Special arrangements have been planned for the w a

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   ' transport of students-when school'is in session.

Arrangements are described in VolumeL1'-(NHRERP Parts 1.0 ' through 7.0),.Section 2.6 (pgs. 2.6-11.through?2.6-11b). Transportation is a-coordinated effortibetween the State.of New HampshireLand each town. For. example' Volume 31 (Town: Lof South Hampton RERP) provides for school children in the; following sections. VOLUME'31, TOWN OF SOUTH HAMPTON RERP-

a. 'Section II.G -

Evacuation of-Schools-

b. Section III.C.3 - . Transportation.(Reference Section II.G) c.- Appendix F -

Special Facilities Plans - Barnard School-

5. Arrangements for transportation are also described.

in the following references; with emphasis onLthe role of~ the State of New Hampshire.

a. Volume 1, Section 1.2 - Pupil' Transportation Safety Supervisor
b. Volume 1, Section 2.6 - Protective-ResponseL (Evacuation, etc)  :
c. Volume 4, Section 7 -

EOC Resource! Coordinator- I Procedure '

d. Volume 4B, -

Director of Pupil Transportation, Safety- . e.* Volume 5 - Letter ofEAgreement { (Index and selected LOAs) J

6. Revision 2 of the NHRERP, Volume 2 (Appendices),

contains in Appendix I (pg. I-3) a summary of transportation resource requirements for all 17 New Hampshire towns and any j special facilities or institutions. These numbers are being

q updated to reflect current requirements. j u
7. Volume 5 of the NHRERP contains letters of agreement with bus and ambulance companies, Teamsters Local No. 633 of i
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4 , 3j New Hampshire', Land individual transportation providers. i a .. 

                                                                                                    .I Together, these organizations should be;able tol provide                              'l q

transportation resources in excess.of the'numbersLrequired. 1 8.: . Volumes 16 through'32 of'the'NHRERPLcomprise allDof-d 

              'thell7-New Hampshire Town'RERPs.           In Secti~on.IV.of each J
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plan,'an Attachment to the Transportation' Coordinator's (or i equivalent responsible individual)' procedure provides'the-individual. town. transportation requirements. Included in: each' list is a category' entitled "Public Schools: and/or- 

               " Private, Day Care Schools", which~ identifies the numbercof.

students within this category and the' number of buses / vans that have been allocated to meet their needs. 'These requirements are based on an annual determination of' maximum. student enrollment at the start of each:. school year and the. maximum. licensed capacity of each day care center. ,

9. In each case, the capacity of buses' allotted surpasses the number of students that may require.

transportation assistance. Thn totality of-bus / van resources, on which the plans rely, is confirmed by letters of agreement contained in Volume 5 of the NHRERP. 1 i a q o l t

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