ML20215E103
| ML20215E103 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/11/1987 |
| From: | Lewald G PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20215D921 | List: |
| References | |
| OL, NUDOCS 8706190255 | |
| Download: ML20215E103 (4) | |
Text
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5 Dated:
.' Juno 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 COMPANYLOF
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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 OF TOWN OF SOUTH HAMPTON CONTENTION NO. 3 Pursuant to 10 CFR $ 2.749, on the basis of theLfacts 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 Hampten (TOSH) Contention No. 3.
REASONS FOR GRANTING THE MOTION Town of South Hampton Contention No. 3 reads as follows:
The RERP for South Hampton fails to provide reasonable assurance because, contrary.to NUREG-1
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8706190255 870611 PDR ADOCK 05000443 O
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0654.C.4, it.contains no letter of agreement from transportation. companies and' Midway Excavators.
Memorandum and Order of AprilI29, 1986Lat 33.
Applicants' motion for summary disposition was-denied only to the extent of deficiencies-noted.by FEMA'and RAC in1their review.
Memorandum and Order of November 4, 1986 at 6.
'Those deficiencies have now been cured.
j As set forth in the Affidavit.ofTRichard H. Strome' filed-
'I herewith, all' requirements for transportation resources can i
be met.
The numbers of buses, ambulances, and drivers j
i committed to in letters of agreement are well in excess of j
1 any foreseeable needs.
See Affidavit 11 3-7.
.Further, the ll State Department of Transportation has adequate' backup i
resources to plow the snow in the Town of South Hampton, i
should Midway Excavators fail to perform.this function
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during a radiological emergency at Seabrook.
By their attorneys, 9
Thomas G. Dignan,-Jr.
George H. Lewald Kathryn A.
Selleck Deborah S.
Steenland Ropes & Gray j
225 Franklin Street Boston, MA 02110 (617)423-6100 i
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STATEMENT OF MATERIAL FACTS-NOT IN' DISPUTE l
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1.
-All' requirements for, transportation resources;can be I
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The Regional-Assistance Committee (RAC) Evaluation of2
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. State Response in NHRERP,' Revision 2.(8/86', p. 74-b-lof 134),
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.found there are adequate means of relocation.
2.
In NHRERP Volume 4,. Appendix I the totals of:574'
.j buses'and'510' drivers are accurate and consistent with the-numbers committed to in the letters of agreement.
Only a g
total of 515 buses and drivers are actually needed. ~ A'
.lett'r of agreement has been. executed with Local 633 of the-1 e
Teamsters whereby they' agree to provide a back-up pool of up to l',500 drivers.-
Letters of agreement with owners-are
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being obtained permitting the mobilization of these drivers' by the. union.
-3.
As of June 3, 1987-Letters of Agreement with several 1
i private trucking companies; making available a total of 53 i
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- Teamster employees to the emergency driver pool have been obtained.
An effort to execute similar agreements with l
additional companies is ongoing.
4 4.
Volume 5 of the New Hampshire RERP contains letters of agreement with bus and ambulance companies, Teamsters i'i Local No. 633 of New Hampshire, and individual I
transportation providers.
Together, these organizations provide transportation resources in exccess of the numbers required in Appendix I to Volume 2.
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I 5.
The availability of adequate' EMS or' ambulance-service isisufficient'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 Hampshireiof 36 ambulances, asslisted' in the IFO Resource Coordinator's procedure - Volume 4,-
Section 18,sAttachment'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.
6.
The State Department of Transportation has' adequate backup resources to plow the snow'in the town of South Hampton.
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