ML20011E614
| ML20011E614 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/12/1990 |
| From: | Backus R, Curran D, Traficonte J BACKUS, MEYER & SOLOMON, HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#190-9885 ALAB-924, LBP-89-33, OL, NUDOCS 9002220018 | |
| Download: ML20011E614 (25) | |
Text
{{#Wiki_filter:w , .. . . l l g}h@ff6 D , yb' - m .
. 00CKETED'.,
I M USNRC 1, _% 0 4+ UNITED STATES OFIAMERICA '90 FEBl13 P4 :15, , s NUCLEAR REGULATORY. COMMISSION ~ ATOMIC SAFETY AND LICENSING BOARD hjhkn hy PRANCH 1i Before the' Administrative Judges: Ivan W. Smith, Chairman ' 4 Dr. Richard F. Cole p Kenneth A. McCollom l'.( ';
.q t
L .c '
)
L In the Matter of- ) Docket Nos. 50-443-OL L . .
) 50-444-OL-PUBLIC SERVICE COMPANY )
OF NEW HAMPSHIRE, ET AL. )
)
.Seabrook Station, Units 1 and 2)
H ( ) February 12, 1990 '
)
P INTERVENORS' REPLY TO.THE APPLICANTS' RESPONSE TO LICENSING BOARD ORDER OF JANUARY 11, 1990 The Massachusetts V ney General, the Seacoast Anti-Pollution League c whe New England Coalition on Nuclear y
' Pollution (the " Inter .s")-submit this reply to the Applicants' Februal .esponse (" Response") to this Board's u
January = 11,'1990 Order concerning the issues remanded in ALAB-924.M
- 1. LOAc for Teachers I g In its Response, the Applicants claim this Board
" resolve (d)" the teacher LOA issue, when the Board provided h I f
l: 1/ Intervenors again note that this Board has no jurisdiction to' proceed in this matter because of the pendency of the i Board's~" final agency action" on review before the Court of Appeals. Also, Intervenors simply adopt by reference their
' February 7 Opposition to Applicants' January 26 Motion to Dismiss Abandoned Remand-Issues as to Applicants arguments
- y. concerning a withdrawal by SAPL of certain issues.
p l' :9002220010 900212 i PDR ADOCK 05000443 G PDO l ) gg13 l
. E__________________ - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - -
W; ; Lv w reasons for'its licensing action, notwithstanding the pendency
;of the ALAB-924 romand.- Response at 3 citing LBP-89-33. Those reasons areLirrelevantfto the further LOA proceedings mandated
-by ALAB-924. The Appeal Board ruled as a matter of law that i
the present record'is not adequate to determine whether or not teacher 14As are required, since "the present record fails to disclose any definitive evidence addressing whether school personnel usually would (or would not) be expected to accompany their students in emergency evacuation situations." ALAB-924 at'10. Until the factual record is supplemented by further e.videntiary hearings on'the " usual role" of teachers in an emergency, Eag ALAB-924 at 9, there is no rational basis for this Board to make the leaal determination, required by ALAB-924, as to whether teachers are " service providers" for whom LOAs are required. San ALAB-924 at 7-11. SAR A112 id. at 10 (role abandonment issue is irrelevant to independent legal requirement for LOAs). At remand hearings, and by way of example, Intervenors intend to offer evidence from teachers who will testify in substance 1) that it is n21 the usual role of teachers "to accompany their students in emergency evacuation situations," ALAB-924-at 10; and 2) that tha NHRERP imposes certain additional emergency duties, which are n21 Part of the teachers' usual role, such as requiring teachers to remain with students potentially for hours awaiting evacuation buses. Egg ALAB-924 at 9. By this evidence Intervenors will establish conclusively that teachers are " service providers" within the 1 Q controllingLtest_ approved by ALAB-924, and that LOAs from these providers therefore are required.M Finally, Applicants make the irrelevant claim, citing this Board,Lthat teacher participation is not " essential" to evacuate' school children. Response at 4 n.11. citing LBP-89-33 at 8 citing Tr. 3388-89. The Board made no such express finding. Id. The portions of the record cited also establish' that New Hampshire refused to adopt the view that teachers were "not_necessary", and acknowledged that the NHRERP has no compensating measures in the event teachers do not respond. Tr. 3388-9. This is consistent with the uncontradicted testimony of Intervenors' teacher panel: Q. In your opinion, how many teachers would be required to reasonably and promptly evacuate students from your schools? A. In our opinion, a substantial majority of teachers within each school would be required to promptly and reasonably locate and supervise the students, and ensure their boarding and supervise their transportaticii to relocation centers. For example, if even a single teacher failed to remain with her/his class, those unsupervised students could attempt to leave their schools on their own, or otherwise become unaccounted for. Additionally, the students may likely become frightened, and disrupt other 2/ Applicants suggest the teacher LOA issue arose soleiv from a SAPL contention, and that SAPL allegedly, for all Intervenors, has waived this issue. Response at 4. Applicants are reminded that the Town of Hampton challenged the failure to obtain LOAs from school officials, agg Revised Contention IV to Revision 2, Basis D(1) (Oct. 31, 1986), sponsored a panel of thirteen teachers representing fifteen schools throughout the EPZ, and successfully pressed the LOA issue on appeal to the
' Appeal Board. ALAB-924 at 7.
-s ____ ____m.____-----u------------ _ - - - - - - - - - - - - - - - - " '" ' ~ - - ' - ' - ----^ -- '
y .. -- - k L eJ ~: l
' J4 5 , a >
l-students. We would anticipate these conditions to magnify during'the time necessar Under these conditions, at.a y forminimum, evacuation buses to arrive. a' substantial
>^
majority of EPZ teachers would be required to remain with their. students. For reasons previously stated, we do'not believe this will occur. ff T3945 at 10.
- 2. Special Needs Survev Although the Appeal Board expressly reversed this Board's t
grant of partial summary disposition on the contentions
" assert (ing) that adequate procedures for-identifying' persons with special needs do'not exist," ALAB-924 at 15, and remanded this issue for " additional proceedings," 14. at 19, Applicants invite this Board to repeat its error and again grant summary ;
disposition without conducting any further proceedings mandated . by the Appeal Board. Esa Response at 7 n.20. Intervenors reply to Applicants' request to disregard (again) the Appeal Board mandate as follows: } 'a) Applicants offer the claim, without record support or legal citation, that "it is also clear that at least some of ! [the issues concerning the special needs survey] did not , L- survive Applicants' summary disposition motion." Response at 6
- n.20. This is absurd in view of the Appeal Board's express reversal and remand, without aualification, of the survey issue, ALAB-924 at 19, 70, and the conspicuous absence from ALAB-924 of any order either granting Applicants partial summary disposition on any issue or "specifying the facts that 1.
L appear without substantial controversy." Egg Fed. R. Civ. P. 56(d) 21. ALAB-924 at 70. - b) Applicants also erroneously claim that SAPL's Statement of the Material Facts as to which SAPL Contends that i _-_ = ------ - - .. . - .
( ~ qs -
~ '
- i g
.SAPL Contentions 18 and 25 Raise Genuine Issues as to Identification of Those with Snecial Needs " defines the maximum i scope of the: issues to be: litigated." Response'at 6.n.20. Of -
course, it does not. It is black letter law that-Applicants, as novants for eartial summary disposition, had the burden to establish "that there is no genuine issue to be heard." 10 CFR . u 52.479(a).. As novants, Applicants may seek summary disposition on an entire contention or, as here, on only a portion of the contention. Obviously Aeolicants, not Intervenors, determine- ' how broadly or narrowly the motion is focused, and Intervenors , need only. respond-in opposition to the extent Aeolicants have put-issues in controversy. In this case, Applicants " motion is '- concerned only with the issue of identification" of special
, needs persons.2/ ALAB-924 holds that this issue should not have been disposed of by summary disposition. ALAB-924 at 16
-(disputed issues of material fact include those concerning
" methodology. utilized to identify-the special needs s
population"). By. reversing the grant of partial summary disposition, the Appeal Board returned the matter to the status auo ante, and all issues raised by the contentions are open in any1further proceeding.S/ 2/ - Applicants' Notion for Partial Summary Disposition of South Hampton Contentions No. 8, NECNP Contention NHLP-4, and SAPL Contentions 18 and 25 (May 20, 1986) at 2 (Exhibit 1 to this motion). A/ _If Applicants intend to refer to their own Statement of Material Facts allegedly not in dispute, Egg Ex. 1, Intervenors concur that a portion of these statements, beyond the disputed issues identified in ALAB-924, perhaps may be stipulated to preliminarily to conducting further proceedings.
=_= - _ _
4' c)- Finally, Applicants suggest that defects in the methodology for. identifying those with special needs have been n addressed "by-subsequent developments in the record" or by equallyL flawed survey updates. . Eat Response at 6-7 n.20. This is factually inaccurate /E and the Applicants are again simply-i requesting that this Board disregard the Appeal Board mandate for " additional proceedings" to fairly test the adequacy of the survey methodology. Until-these proceedings are conducted,. neither this Board nor the Appeal Board can even decide the issues _concerning the adequacy of transportation resources under the NHRERP. ALAB-924 at 19-20 and n.47. 3.- Leadina Time for ALS Patients-The Applicants at 8 of their Response propose to make-the. plan changes described by this Board in LBP-89-33 at-29. At- _ 48-56 of Intervenors' December 1 Supplemental Motion filed with
=
the commission and attached as Exhibit 1 to Intervenors' February 1 Response to this Board's January 11 Order, the
; Interveners analyze in detail why this proposed plan change not only does not resolve the' remanded issue but is'itself an egregious error and makes the plan worse! Intervenors note that in the December 8 Response to this December 1 Supplemental Motion (at 27-30), the Applicants provide no response whatever 5
5/ This Board excluded testimony of one of the foremost survey experts in-the country when Intervenors attempted to litigate this issue in the SPMC proceedings. Sag. Tr. 19987-88. Egg al1Q Intervenors' December 1 Supplemental Motion at 47-48. I I i !l
T
.p J' ,
to Intervenors' detailed _ analysis _of the issue and the NHRERP. Moreover, the Appeal Board also noted that special facility planning'in anneral under the NHRERP does n21 comply with the guidance of NUREG-0654. ALAB-924 at 27 n.71. The Applicants completely ignore the: mandate of ALAB-924 to this Board to ensure that in aeneral all special facility planning conforms with the command of the guidance that "relach special facility shall be treated on an individual basis." NUREG-0654, App. 4 at 4-9 to 4-10 (emphasis supplied).5/ Thus, this Board should indicate that-the NHRERP is presently inadequate as a matter of law under ALAB-924 in the absence of individualized special facility planning and these changes must be forthcoming before the NHRERP can be approved.
- 4. Imolementina Detail for Shelterina2 /
Intervenors have already moved for reopening of the NHRERP
; record based on the astounding disclosures concerning the I-5/ Intervenors at 50 n.35 of their December 1 Supplemental Motion indicate that the absence of individualized ETEs for special facilities is significant for the formulation of dose minimizing PARS for this portion of the population.
2/ Intervenors in response to the Applicants' February 1 Response have filed 2 pleadings which they reference here in incorporate if at any later time it is determined that this Board was the appropriate entity for the submission for these pleadings (and the arguments set forth therein): Intervenors' February 6, 1990 Emergency Motion: (1) To Clarify the Status of the-Appeal of-LBP-89-33 and (2) To Reopen the Record on the NHRERP as to the Need for Sheltering in Certain Circumstances filed with the Appeal Board and Intervenors' February 8, 1990 Request for an Opportunity to Brief ALAB-924 filed with the Commission.
=
l 4 l
k .
.. ' f; nature of the' changes made-'to-the NHRERP in October 1988.
t (Intervenors do note here that FEMA, the State of New g Hampshire, the NRC Staff and the Applicants never brought the I meaning.of_these October 1988 changes'to the-attention of this- ' Board which as recently as November 20 repeated its , understanding concerning the'use of sheltering for the general beach population in Condition (1). LSP-89-33 at 32 n.17. 133 also-id. at 33 n.18 noting the October 1988 plan changes and
-the apparent resolution of FEMA's concerns about implementing b
detail without understanding that October 1988 changes had eliminated sheltering for Condition (1). As to the need for sheltering detail for Condition.(2), the Applicants assert that what changes are needed are minor and can be left to Staff oversight. The changes are minor because, argue the Applicants, the beach population at Condition (2) is small by-definition:- if egress routes are-blocked then ingress routes lare likely blocked keeping the day tripper population down. Applicants' February 1 Response at 10-n.33. In response Intervenors assert:
- a. Condition (2) is not limited in the way Applicants now assert. Attached as Exhibit 2 hereto is Attachment C to Appendix U to Vol. 4A of the NHRERP which sets forth the local conditions which are. evaluated by decision makers pursuant to Appendix U step IV. B.4 (General Emergency) cited by the Applicants at 10 of their February 1 Response. (Although dated 2/88 Exhibit 1 was current and part of the October 1988
-8 -
i: >
, l 1 ~
U
-update.) Obviously,. local. condition b. (" population density and distribution") could'well signify that large beach populations without more, are a local condition which'is considered a constraint on evacuation thereby resulting in a sheltering PAR. (Attached as Exhibit-3 is the corresponding )
portion of Revision 3 of the NHRERP' dated February, 1990.)EI i
- b. The Applicants simply ignore the holding of ALAB-924 :
that sheltering detail is needed when they assert that somehow ~l the amount of detail is a function of the quality of the sheltering afforded. Egg Applicants Response at 11. r c. The Applicants also ignore the holding of.ALAB-924 as to.the right of the Intervenors to participate in any further. proceeding.that results in the determination that the sheltering detail put in place in response to the ALAB-924 i remand is adequate: When'the potential shelters have been identified pursuant to our remand, it then will be appropriate for the Licensing Board (and for us) to address any intervenor
-concerns relative to the adequacy of that shelter.
I-R/ Intervenors note that in the February 1990 revision of the NHRERP at Vol. 8 there is repeated ambiguity concerning the use of sheltering for the general beach population under condition (2); i.e., evacuation constraints. At 56.1, Section 8 -(at 6.1-8), it-is clear that (just as in the October 1988 iteration) sheltering is considered for the beach areas if the constraints (as identified at 56.4, Exhibit 2 here) on L evacuation exist. But at 56.10 (" Protective Action for ' L Seasonal Beach Populations") at Section 4 (at 6.10-3 to 6.10-4) l it is Dat clear that sheltering is considered even if the evacuation constraints as set out'at 56.4 are existant. e l ? . _ . . -
)
% ,. 4 -d ' s tI (' i ,
. ALAB-924 cat-68-69. -In light of this clear mandate, _the-r adequacy:of sheltering detail for condition'-(2),: no matter how Condition '(2)fis-now interpreted, can not be'left to Staff oversight as (what in~effect would be)-a post-post-licensing:
3 condition. W'~- . . Respectfully submitted,- COMMONWEALTH OF MASSACHUSETTS-a. NEW ENGLAND-COALITION ON ~ JAMES M. SHANNON NUCLEAR POWER ATTORNEY _ GENERAL
--l ^
' Diane Curran, Esq. hn Traficontef
[ Chief,NuclearSafetyUnit Harmon,-Curran, & Towsley Suite 430- Matthew Brock 2001 S- Street, N.W. Assistant Attorney General Boston,-MA 02108 One Ashburton Place Washington, DC 20008 Boston, MA' 02108 (617)E727-2200 SEACOASTEANTI-POLLUTION LEAGUE fdibert Backus, Esq. Backus, Meyer, & Solomon
-.116 Lowell Street P.O. Box 516
' Manchester, NH 03106 Dated: February 12, 1990
4 j. w'l ,, i . . , , ,-
;r . .
- .... , -.'.4 s.
mA
,5, t 'f ,. 9 ~.d'i
,-J j,t
,4, -
4, s I E 4 4/ }'.-
+ f 1
m ,iJ>' ; g ] . N Y, t , I_ < ,~ " t - !!N' p -
+
c. E
- g - i ..
' s I.r.
.-,=
1 i
\
4 -$. i
! t 1
F .d.'.
-( s y
J
. Y. . 9\.
t t
. ) ;.
1
; ib y.
- r. . -
->t.
< EXHIBIT 1-(r.).,
s k' J. S k h k'f 4 . b f. 4' t ?s t e i-h >' }e's K 4 i t ,rc C,
;4 .- . .,
6 4c. : ,, lf
.Y' h
Dated: May 20, 1986
/
UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMM*.SSION before the ATOMIC SAFETY AND LICENSING DOhRD'
)
In.the Matter.of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL. (Seabrook Station, Units 1 and 2
) Off-site Emergency
) Planning Issues
)
)
-APPLICANTS' MOTION FOR PARTIAL
SUMMARY
DISPOSITION OF SOUTH HAMPTON CONTENTION NO. 8, NECNP' CONTENTION NHLP-4 AND.SAPL CONTENTIONS'18 AND 25 - Pursuant to'10 CFR $ 2.749, on the basis of the Affidavit of. Richard H. Strome Re South Hampton Contention No. 8, NECNP Contention No. NHLP-4 and SAPL Contentions Nos. 18 and 25 ("Strome Affidavit") and the Statement of Facts Not in Dispute attached hereto and for the reasons set forth below, the. applicants move the Board to enter a decision summarily disposing of South Hampton Contention No. 8, NECNP Contention NHLP-4 and SAPL Contentions Nos. 18 and 25 insofar as these contentions assert that there do not exist J
c
. adequate procedures for: Adentifying persons with special:
needs'. REASONS FOR GRANTING THE' MOTION ' South Hampton Contention No. 8, in part. contends that l
" adequate arrangements have not been made to: identify . . .
persons who do not own an automobile." NECNP Contention ! NHLP-4 was for the most part rejected by this Board but was
, " admitted as limited to notification of persons with special notification needs as specified in part (e) of the basis statement." Memorandum and Order (April 29, 1986) at 67. .!
SAPL Contention 18 raised the issue of whether the methodology utilized to calculate the numbers of non-auto owning population had understated the number of persons who i would need transportation. SAPL Contention No. 25 raised the, issue of whether " mobility. impaired" individuals have been identified. Some of these contentions also raise'd issues as to whether, even using adequete identification procedures for "special needs" persons, proper assistance could be implemented. But this motion is concerned only-with the issue of identification. The Strome Affidavit demonstrates that an effective survey technique has been implemented to identify "special needs" persons and goes on to recite that this survey will be ongoing and the data annually updated and kept current.
- 2. - _ _ _ _ _ _
W 1 . - , !:s b
- p. ..t t.
[,. lit-~is respectfully submitted that the survey techniques being carried out and to be carried out constitute'a fully adequate method of identifying-special needs persons. Any additional requirements would-fall into the category of
" extraordinary measures" not required by the regulations.
Southern Califo'rnia Edison Co. (San Onofre Nuclear Generating Station, Units 2'and 3), CLI-83-10, 17-NRO 528, 533 (1983). By its attorneys,
^
[yof/sAy h GA.gn an, Jr , i Robert K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 _; (617) 423-6100 j Dated: May 20, 1986 'i i i
)
'b; MATERIAL FACTS AS TO WHICH
-THERE-IS NO DISPUTE
- 1. The State of New Hampshire has conducted a-survey within-the New Hampshire portion of the PEPZ to determine who needs: transportation, special notification, special help because of health conditions, or foreign language notification.
- 2. This survey will be updated annually.
- 3. Results of the surveys are compiled according to individual-jurisdictions within the PEPZ and supplied to local civil defense officials.
34 , % A--
,;- # F &
s s P
't I ..j
+ i i m s,i e 1 . ,
r';,( T ' I I- g.._ ('
->L- . "/ k 10, ,
r P
.- . ( I , a !
A 6 *. ; i6'...
h
-}
' ~
L P g .. r ,r-
* [ I, ;', , ' $ I .
1 1 -h' i 1 f
' i, j t.
tI, <
,' \
i i aa n
--- 1 j
4 r 7,' s 4
.,[
'h EXHIBIT 2 , e h
s 4 F
). t U
L p'f'.Lt( 4.g, . ( 6 0
.l. ..
0 6
$ 9 T
M. , ; .i. -
': .f n g3 ; :1; ,
L , 0 N L
): ,
ii ; ATTACHMENT C. EMERGENCY ORGANI,7.ATION STATUS AND LOCAL CONDITIONS t g g A. ResDonse Status of the State and Town'Eserrency Orrentratior-s 1. The protective ~ action decision must take into consideration the status-r of state and town emergency personnel and resources and the tim the protective uction announcements to the public n: 2, Of'particular importance to precautionary actions for the beach s. area la the status of the State Police and local police to implement traffic ano access controls. 3. Status considerations include: a, Availability of personnel
- b. ' Time required for mobilization i c.
Degree to which mobilization has progressed
.d.
~
. Time required for implementation of emergency actions B .'
Local conditions
- 1. '
Local conditions within an affected area may constrain protective .? action decisions and their implementation. 2. Local conditions should be reported to decision makers by local EOC
. personnel through the IFO at Newington, 3.
, . Pertinent' local conditions include: t ! ~. a. Conditions of road and evacuation routes considering: (1) Seasonal travel impediments (2) Status of road repairs (3) Surface conditions due.to weather l c l Vol 4A U-36 Rev. 2' 2/88
en + c 4 , P i. n r 't
- f. ;
E~ y ATTACRMENT C (cont'd)- r a t (; - (, :(4 ) Natural or man-made impediments
.(5)-'Effect of traffic signals.'on' traffic = flow in direction of evacuation.
IL- 2
'I b.-
Population. density and distribution , t- c. Evacuation. route capabilities i t- e' . d. Inclement weather conditions that would uffect travel (t.now.~ tog heavy rains etc.) ,
- e. ->
Lucal events whic'h may present requirements for special notifica-tion, traffic control-r transportation assistance
- f. '.
Status of schools and other special fac111 tics, i a 7 i l
+
l l 1 I ' L L-ll I l Vol. 4A U-37 Rev. 2 2/88 1
s 4, , ,1,.. 3
*i ) g--
r i 4 ( 1 ,
.... s. 1 , , 8"a.. ,
t.., ;i9' jj ~-, i ',-' (. .; {$I.a!-. -. , & 3
- , ,, . r
, 1
-..p . . . , -., '
.) , / y -'
3 L V t,g p-{ - . d k.' g ' .e ,: . ;Itr$ .4 , 4
,. .1 .
..) 'g ' + if.2 ' g
- i. +
saw ' ' f . 3 yi<, s
', t 4 ~,
j .s 5' i, Tt ) f_2V f f,, i ,
; -*a..
. 4 s.,4.; + ,
g <t .
,i. - .
FW, . % 8 m, . - 3, ['
...t'tf '
u ", I g p,' k (-
.qu - . ;h. ':
I 4 E u s.'s s *h.&.- c , q
- i: .
J
=
Y k' s 4
'.)7
-1s
- i
- 11 5
t T-g . EXHIBIT 3
'.J.
- g-4:
- h" 4-
..'. i-E
- h
^
8 i y
. 4 t
2 i 1 .; iy 1-(:J ts qi e, t-k m si'4
.- g ..-
t k s 3-t 3 4 1i _ / -
--t, , .+-
\l 4,
l
- 8
. .f.'
3.1.-
^
*hi
,f r) '
4
}
s
)
)
F k f L i V i,, f u i
- .j r y ,.
s
'Ys k l "i l
<-l^.-" l
D
- uu.
g ,,. 1
.) ,
e d 6.4 DewmCY CEGANIZATION S'DdUS AND ITE CONDI' RIM -
' l Section 1 Rennenne Stat us of the State and 'Ibwn h-cv l OcGanitations .
1 1.- The, protective actica decision nust take into censideration the s+.atus of r*. ate , and town energency personnel and resources and the timing of. the protective action announcements to the public. !
-s
-2.
Of particular importance to precautionary actions for the beach areas is the ( status of the State' Police and local police to inplement traffic and access controls.
- 3. Status ccmsiderations include:-
o Availability of patu mnel i o Tine required for nobilization o Degree to which mobilization has progressed o Time required for inplementation of anargency actions Section 2 local Conditions t
- 1. Iccal conditions within an affected area may constrain protective action decisions and their inplementation. '
2. Incal ccmditions should be reported to decision makers by local anargency Operations Cantar (BOC) personnel through the Incident Field Office (IFO) at Newington. 4
- 3. Pertinent local conditions include:
6.4-1 Vol. 8/Rev. 3
; y a-. ,- ;n u ,
i ! f,4 9 .
, ~,h i < .
. n. r 4
e
!!MERMNCY mGANIZATIN STA'IUS AND TmAL CCNDITICNS (cont.)
\
o- Ccmditions of road and evacuation routes ocnsidering: Seasonal travel 4 W imants-
' Status of road repairs ,
, , Surface cmditions due to weather -
..)
-1 Natural or rnan rede iWi==nts ,
Effect of traffic signals on- traffic .ficw in direction' of evacuation. .
.)
- o. Population density and distribution o Evacuation route capabilities o
Inclammt weather canditions that would affect travel--(snow, fog, heavy o rains, etc.) ! o Incal events which nay present requiremmits for special notification, traffic cmtrol, transportation assistance o Status of schools and other special facilities. i: l, I L L 1 I r l '. i. i-1- ,. l 6.4-2 vol. 8/Rev. 3
v 'N ,' v >w e l . r f '. 'hR;. ! v qq ~gy. t
,,,,. , ; s.~ ,1 , - \ _j , . f. : ,
+ , 9. .p'. ' 1 i
;., n -.%.,-,t s ,s y,,; ..,.,c 7.a.y x3 * .t.
- ' E
-'?,,..-. ,_
, s l 1/
J . . . ' i
)
I( 5 1 ' - o- .;:i , y 6- .*i 7
. e e- <
1
,/.,1 e
l j; i
,. + fi ;
i 3
. ,ya &S g 3
I 'f. f.
...f db p 4 M t
4' f . -
.,Sa >;.....,, e T [ 'N :. !1 4 -1 g'. I-3 i 1~ ? ,
ti h , i.
;e
. fr 3 h '
' fd
;tt' v
h 4 b f., s . T f s:f'a o
e%- , . y 4-1 ," , F i i:
.. j I;0ChETED U$NRC UNITED STATES OF AMERICA P
NUCLEAR REGULATORY COMMISSION- g g j3 -P4 :15 ATOMIC SAFETY'AND LICENSING BOARD QFHCE OF SECRE'IARY Before the Administrative Judges:90CK[ig}EitylCL .j s Ivan W.~ Smith, Chairman Dr. Richard F. Cole > 1 Kenneth A. McCollom
)
In the Matter of ) Docket Nos. 50-443-OL ,
) 50-444-OL '
Oj . ' .PUBLIC SERVICE COMPANY ) OF,'NEW HAMPSHIRE, EI AL. )
)
(Seabrook Station, Units 1 and 2) ) February 12, 1990
)
( CERTIFICATE OF SERVICE I, John Traficonte, hereby certify that on February 12, 1990, I . E made service of the within INTERVENORS' REPLY TO THE APPLICANTS' S
- RESPONSE TO LICENSING BOARD ORDER 0F JANUARY 11, 1990 by Federal o .,
. Express:as indicated by-(*) and by first class mail to:
*Ivan!W. Smith, Chairman *Kenneth A. McCollom I
-y Atomic Safety & Licensing Board 1107 W. Knapp St.
-U.S. Nuclear Regulatory Stillwater, OK 74075 ;
' Commission
,, -East West Towers Building
- Docketing and Service .
L 4350 East West Highway U.S. Nuclear Regulatory l Bethesda, MD 20814 Commission h Washington, DC 20555
*Dr. Richard F. Cole Paul McEachern, Esq.
. Atomic Safety & Licensing Board Shaines & McEachern U.S.-Nuclear Regulatory Commission 25 Maplewood Avenue East West Towers' Building P. O. Box 360 4350-East West Highway Portsmouth, NH 03801 Bethesda, MD 20814 l
p i e
- o-o4 1
.1 .- 1 I
- Robert R . Pierce Esq.
,
- Thomas G. Dignan, Jr., Esq.
Atomic Safety & Licensing Board Katherine Selleck, Esq. U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place j 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814 l H. Joseph Flynn, Esq. *Mitzi A. Young, Esq.
-Assistant General Counsel Edwin J. Reis, Esq.
Office of General Counsel U.S. Nuclear Regulatory Federal Emergency Management Commission Agency Office of the General Counsel 500 C Street, S.W. i 15th Floor Washington, DC: 20472 11555 Rockville Pike Rockville, MD 20852 Atomic Safety & Ljcensing Robert A. Backus, Esq. Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Board Jane Doughty
= U.S.-Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 Charles P. Graham, Esq. Barbara St. Andre, Esq.
Murphy-& Graham Kopelman & Paige, P.C. 33 Low Street 77 Franklin Street Newburyport, MA 01950 Boston, MA 02110 Judith H. Mizner, Esq. R. Scott Hill-Whilton, Esq. 79 State Street Lagoulis, Hill-Whilton 2nd Floor & Rotondi Newburyport, MA 01950 79 State Street Newburyport, MA 01950 Diane Curran, Esq. Ashod N. Amirian, Esq. Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W. Bradford, MA 01835 Washington, DC 20008 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton)
~P}C 1
,~ . .
-l
- l
- p. ,
~ John P. Arnold, Attorney General Phillip Ahrens, Esq. 1 office of the Attorney General' Assistant Attorney General 25 Capitol Street l Concord, NH 03301 Department of the Attorney i General !
Augusta, ME 04333 i
- 7. Jack Dolan George Iverson, Director j Federal Emergency Management N.H. Office of Emergency Agency Management Region 1 J.W. McCormack Post office & State House Office Park South Courthouse Building, Room 442 107 Pleasant Street Concord, NH 03301-Boston, MA 02109 COMHONWEALTH OF MASSACHUSETTS i
JAMES M. SKANNON ATTORNEY GENERAL l n Traficonte" ' asistant Attorney General Chief, Nuclear Safety Unit Department of the Attorney General One-Ashburton Place l i-Boston, MA 02108-1698 l (617) 727-2200 1: DATED: February 12, 1990 i. t l. L l
-3 -
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _}}