ML20215E043

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Applicant Motion for Summary Disposition of New England Coalition on Nuclear Pollution Contention NHLP-4.*
ML20215E043
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 8706190235
Download: ML20215E043 (6)
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1 Dated: ' June 11, 1987.

"1 UNITED STATES OFLAMERICAL ,

NUCLEAR REGULATORY COMMISSION. j

'before the l

ATOMIC SAFETY AND LICENSING BOARD H

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.) Lj In the Matter of i)

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PUBLIC SERVICE COMPANY OF )  : Docket Nos. 50-443-OL:

NEW HAMPSHIRE,.et al. ~) . .

50-444-OL  ;

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

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APPLICANT'S MOTION FOR

SUMMARY

I DISPOSITION OF NEW ENGLAND COALITION'ON NUCLEAR POLLUTION CONTENTION NHLP 1 i

l Pursuant to 10 CFR S 2.749, on the basis of. facts set forth in the Affidavit of Gary J. Catapano (NHLP-4), the' Affidavit of Richard H. Strome (NHLP-4), and for the reasons set forth below, Applicants move that this. Board enter an order summarily disposing of New England Coalition on Nuclear Pollution (NECNP) Contention No. NHLP-4 in-favor of i Applicants.

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REASONS FOR GRANTING THE MOTION New England Coalition on Nuclear Pollution-Contention NHLP-4 reads as follows:

Procedures to provide early notification-and clear instruction ~to the populace within the plume-exposure pathway EPZ, 10 CFR 5 50.47(b)(5), are inadequate.

Applicants' Motion for Partial Summary Disposition,. filed on May 20,1986, sought a ruling on so much of the contention as alleged ~ insufficient procedures for identifying persons with special needs. In its Memorandum and Order of November 4~ ,

1986 at 14-17, the Board granted Applicants' motion. The only remaining basis for this contention reads:

The local plans do not make adequate provision for notification of people with special notification needs. _The plans H must demonstrate capability to notify-100% of the people within 5 miles of the  :]

site. NUREG-0654 at 3-2. The plans do 1 not identify individuals with.special 1 notification needs, nor do they make specific provision for their ]

notification. For example, the:Hampton plan states that the Fire-Chief maintains a " confidential list"'of people with , i special notification needs,-but does not j state how many people there are on the  ;

list. The plan lists a number of means by which they may be notified. However, j in the absence of a description of the' j extent and nature of the'need for special notification, there is no way to determine whether the. town has adequate  ;

personnel or equipment to carry out the j task. i 4

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Measures have been-and.are being-taken to ensure' adequate and expeditious notification of-persons with special notification needs-(i.e., hearing-impaired as have been identified by a Special Emergency Help Survey conducted by-NHCDA). As more fully set.forth in the1 Affidavit of Richard H.~Strome (NHLP-4), these measures include changes

'in the Emergency Broadcast System message and the. Emergency Public Information material urging neighbors.to' assist.

hearing-impaired individuals in understanding emergency instructions. -

As set forth in the Affidavit of Gary J. Catapano (NHLP-4), tone-alert radios have been received and'are- J l

available for distribution. The radios contain'a flashing . j i

light to indicate the radio has been alerted. Id. at 1 2. .]

Development of a design for an additional visual alerting device is currently underway. Id. at 3.

These tone-alert radio receivers will be distributed to- .

the hearing-impaired NHRERP, Vol. 1, Section 2.1.

Instructional labels will be affixed to'all the tone-alert radios, which will list all necessary instructions for the hearing-impaired to follow if the tone-alert radio is 7'g..-

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activated. . I,d . - at 1.--2 .

By their..attorneysi.

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Thomas.G. Dignan,..Jr.

George H. .Lewald-Kathryn A.?Selleck.

Deborah:S. Steenland-

-Ropes'& Gray.

225-Franklin: Street

-Boston,-l Massachusetts 02110 (617).423-6100:

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1 STATEMENT OF' MATERIAL FACTS ~NOT IN' DISPUTE: ,

1. -Tone ~ alert radios,with visual; alerting devices for~

1 notification'of the hearing impaired have'been received'and f i

are available for distribution. ~They will-have a-flashing -

light'to indicate the-radio;has been activated. Labels will-be affixed to'all of these tone alert radios with instructions for,thel hearing impaired to fo'llow if the tone-alert radio'is' activated.

2. Development cWE an additional alerting device, which .

will be compatible.to tone alert radios previously ordered,

is? currently underway.
3. The New Hampshire Civil Defense Agency has taken-reasonable measures to ensure adequate. notification ,

procedures for the hearing impaired.

4. The-Emergency Broadcast System: announcement will urge persons in the evacuation area to check on neighbors with hearing impairments and. assist them in understanding.

emergency instructions.

5. Text will be added to the Emergency Broadcast. System section of the Emergency Public Information Calendar mailed to every household in the EPZ. The addition instructs-neighbors of the hearing impaired to personall'y verify-that their neighbors understand any emergency instructions issued. Similar text will be added to Emergency Public Information material contained in telephone book advertisements and brochures.

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'6. .ThejNew; Hampshire: Civil; Defense Agency $as conducted.'.

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.a.Special-l Emergency Helpfsurvey~in part.to~ identify' people'.

~.who require specials notification (i.e.,; hearing-impaired).

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1 This.' survey.will be. updated annuallycemploying;ai i

distribution method designed.to reach as many EPZ. residents ',

i as.'possible.

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