ML20215E128
| ML20215E128 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| 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 8706190263 | |
| Download: ML20215E128 (4) | |
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Dated:
June 11,._1987-UNITED STATES OF AMERICA' s,
NUCLEAR REGULATORY COMMISSION.:
before be a
. ATOMIC SAFETY AND LICENSING BOARD l
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1 In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL
- i NEW HAMPSHIRE,-et al.
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50-444-OL j
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Off-site Emergency.
_(Seabrook Station, Units 1 and'2).).
Planning Issues i
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3 APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF TOWN OF KENSINGTON REVISED CONTENTION No. 6 Pursuant to 10 CFR $ 2.749, on.the basis of the facts j
set forth in the Affidavit of Richard H.
Strome (TOK 6), and-for the reasons set forth below, Applicants move the Board to enter an order granting summary disposition in favor of the Applicants with respect to Town of Kensington-(TOK)
Revised. Contention No.
6.
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REASONS FOR GRANTING THE MOTION l
TOK Revised Contention No. 6 reads as follows:
8706190263 B70611 ADOCK 050 g 3 PDR 0
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i The NHRERP, Revision 2 for "TOK" does not provide adequate arrangements for effectively using assistance and resources as required by 10 CFR 50.47(b)(3) because there are not appropriate j
letters of agreement to identify support
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organizations or other facilities which are to j
provide assistance.
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l As set forth in the Affidavit of Richard H. Strome (TOK
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1 Revised Contention 6), the State of New Hampshire is confident that all requirements for transportion resources l
can be met.
Affidavit 1 3.
The numbers of buses, j
i ambulances, and drivers which will be available are well in excess of any foreseeable needs.
See Affidavit 1 4-8.
Further, the State Department of Transportation has adequate backup resources to plow the snow in the Town of South i
I Hampton, should Midway Excavators fail to perform this J
function during a radiological emergency at Seabrook.
See j
Affidavit 2.
By their attorneys, Y
Thomas G.
Dignan, Jr.
George H.
Lewald Kathryn A.
Selleck Deborah S.
Steenland Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 g,
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STATEMENT OF MATERIAL-FACTS NOT IN DISPUTE l'.
Should, Midway Excavators fail to perform.then functions of snow ~ removal,-.the' State DepartmentLof Transportation has~ adequate back-up resources to'plo'w the snow in the Town of Kensington.
2.
The. State of.New: Hampshire is confident that all-l requirements for transportation resources _can be: met. :See I
The RegionaleAssistance Committee (RAC) Evaluation of. State.
1 Response in:NHRERP,;. Revision 2 (8/86, p. 74-b of;134).
3.
In NHRERP Volume 4, Appendix I the-totals 1of 574
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buses and 510 drivers are accurate.andLconsistent with the.
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numbers committed to in'the letters of. agreement. LOnlyfa.
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total of 515 buses and drivers are actually needed.
-A letter of agreement has been executed with Local 633 of the Teamsters whereby they agree to provide a'back-up: pool of up to 1,500 drivers.
Letters of agreement with owners are
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being obtained permitting the mobilization of these: drivers i
by the union 4.
As of June 3, 1987 Letters of Agreement with several i
i private trucking companics making available. a L total sof 53 Teamster employees to the emergency. driver pool have been obtained.
An effort to execute similar agreements with i
additional companies is ongoing.
5.
Volume 5 of the New Hampshire RERP contains letters of agreement with bus and ambulance' companies, Teamsters l -
1 Local No. 633 of New Hampshire, and individual j
transportation providers.
j 6.
The availability of adequate EMS or ambulance i
service is sufficient to respond to all New Hampshire EPZ needs.
Volume 5 contains letters of agreement which make j
i 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.