ML20215E128

Applicant Motion for Summary Disposition of Town of Kensington Revised Contention 6.*

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: ML20215D918 ML20215D966 ML20215D992 ML20215E002 ML20215E030 ML20215E043 ML20215E068 ML20215E081 ML20215E103 ML20215E128 ML20215E181 ML20215E191 ML20215E197 ML20215E206 ML20215E217 ML20215E234 ML20215E246 ML20215E272 ML20215E323 ML20215E337 ML20215E362 ML20215E383
References
OL, NUDOCS 8706190263
Download: ML20215E128 (4)

Text

_

7 , .- . - - -

7- ,

k+ ,

.) 1

'y T IS -

. , i l

.?. . ,

~

l Dated: June 11,._1987- _

s, UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION.:

before be a

. ATOMIC SAFETY AND LICENSING BOARD 1 l

g. .j

~1

)

). 1 In the Matter of ) I b ) -1 PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL -i NEW HAMPSHIRE,-et al. ) 50-444-OL j

_ ) Off-site Emergency.

_(Seabrook Station, Units 1 and'2).). Planning Issues i I

)

) .

3 l

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. i i

~

REASONS FOR GRANTING THE MOTION l TOK Revised Contention No. 6 reads as follows:

8706190263 B70611 PDR ADOCK 050 g 3 0

1 i

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 ]

organizations or other facilities which are to j provide assistance. 1 i

l As set forth in the Affidavit of Richard H. Strome (TOK {

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 l l

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.  ;

l 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,

f, '

t -

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

~

buses and 510 drivers are accurate.andLconsistent with the.

)

numbers committed to in'the letters of. agreement. LOnlyfa. )

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

]

l being obtained permitting the mobilization of these: drivers i by the union l

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 l

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 l

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.