ML20148H766
| ML20148H766 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/22/1988 |
| From: | Olivera E MASSACHUSETTS, COMMONWEALTH OF, SALISBURY, MA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20148H773 | List: |
| References | |
| CON-#188-5428 OL, NUDOCS 8801270300 | |
| Download: ML20148H766 (9) | |
Text
-r Yj V
l
..N KElf.TED CORRESty!!DMiSh -
'~
~
DOCKETED
.USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'E JAN 26 N1:23 ATOMIC SAFETY AND LICENSING BOARD
- OFFICE OF iiCRETARY 00CKEitNfi ?. SEitvlCf.~
Before Administrative Judges:
BRAT 4CH Ivan W.
Smith, Chairperson Gustave A.
Linenberger, Jr.
Dr. Jerry. Harbour
)
)
In the Matter of
)
Docket No.
)
50-443-444-OL PUBLIC SERVICE COMPANY OF NEW
)
(Off-site EP)
)
(Seabrook Station, Units l' and 2)
)
January 22, 1988
)
)
REBUTTAL TESTIMONY OF EDWIN J. OLIVERA ON 3EHALF OF THE ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS REGARDING TRAFFIC DISORDERS EXPECTED DURING AN EVACUATION OF THE BEACH AREA BECAUSE OF AN ACCIDENT AT THE SEABROOK NUCLEAR PLANT Q.
Would you please state your name and current occupation?
A.
My name is Edwin J. Olivera, and I am the Chief of Police for the town of Salisbury, Massachusetts.
Q.
How long have you been the Chief of Police in Salisbury, and what did you do prior to becoming the chief?
A.
I have been the chief since 1979.
Prior to that time I was a police officer in Salisbury.
Altogether, I have been a Salisbury police officer for 25 years.
Q.
Where is the police station located in Salisbury?
8Q$3
])b f$k DO K T
s.
O A.
It is in the beach area, near the amusement park.
Q.
Are you familiar with the traffic conditions in the beach area of Salisbury during the summertime?
A.
Yes, certainly.
My staff and I see and respond to the traffic in the beach area on a daily basis.
Q.
Chief, a number of witnesses in this. proceeding have testified that in their opinion there will be no traffic disorderliness of any significance during an evacuation of the beach areas near the Seabrook nuclear plant if there were ever to be an accident at the plant, and I want to ask you a few questions on this topic.
A.
Okay, go ahead.
Q.
Have you ever seen situations in which most of the people who come to the beaches for the day all try to leave at once?.
A.
Well, we have had sudden rainstorms on days when the
[
beaches have been crowded.
When that happens there are an awful lot of people who do try to leave the beach areas within a short period of time, and it creates quite a traffic jam.
i Traffic is a real mess when that happens.
Q.
What are the traffic conditions like in the beach area when a sudden rainstorm occurs on a busy beach day?
A.
First, Route 1A heading west out of the beach area L
becomes a very congested line of very slow moving traffic.
This happens late in the afternoon on busy beach days even without a rainstorm.
The rain just makes the situation i
i All the drivers who came to the beach that day want worse.
to move out at once, and they just can't do it.
Cars are backed up everywhere.
Many of the cars in the big parking lots can't l
even get out onto the road for hours.
The chief problem is that, apart from heading north on Rt. lA up the beach into
(
Seabrook, there are only two roads out of the Salisbury beach area:
Rt. lA (Beach Road) in the south and Rt. 286 in the north (See the map attached hereto as Attachment A).
Each of these roads is a two lane, east-west road with one lane in each direction.
Bottleneck traffic jams occur where each of these roads leaves the main north-south beach area road (Route 1A).
This happens because vehicles from many lanes of north-south traffic flow are trying to merge onto the one westbound lane of either Beach Road or Rt. 286.
For example, as shown in the Beach Road sketch below, 6
w W
T
,1 4.G g>
1Ie$
0 WT d
~u q;)
O L
L J
L JC)C J
-+
4 m
I e
Gd
.4 U
Mlce
{
.31 A**
- g co,
4
.j i O,c e
53 0
Of.
g - -.-- --
I five lanes of exiting north-south traffic must merge into a single lane, westbound on Rt. lA (Beach Road).
During a' sudden rainstorm, this area is terribly snarled.
-Q.
Do you or your officers ever see disorderly traffic behavior when this kind of congested condition occurs?
A.
Oh, sure.
We see all kinds of things.
People get frustrated by the long traffic back-ups, and they try all kinds of things to get out of or to avoid the traffic jams.
For example, we have seen drivers who try to pass the traffic by driving on the right shoulder, to the right of the fog line.
We have seen other drivers who cross the double yellow center line into the eastbound lane on Beach Road in order to pass as many cars in the westbound lane as they can, despite the fact that passing is prohibited.
We have also seen them try to avoid the lengthy lines of slow-moving traffic on Beach Road (Route 1A) and Route 286 by taking secondary roads.
On Beach Road they often take Old County Road just to bypass about a
half mile of backed-up traffic on Beach Road.
Some of those backed up on Route 286 divert onto South Main Street, which appears to them to be a way to "beat the traffic" on Rt. 286.
In fact, it just leads them into a worse snarl in Salisbury center, making traffic flow through the intersection there (Rt. lA, Rt. 1, Rt. 110) even more congested and difficult.
Of course, because we are the police, and people tend to drive more orderly around us, I know that what we see is. - - _
n
..t-only a small fraction of the disorderly traffic behavior that goes on under these circumstances.
.Q.
Chief Olivera, do you have an opinion lregarding what kind of drivers are the most disorderly under.these conditions.
A.
As you probably.know, a.large percentage, probably half or more, of our beach area population in the summer is
. comprised of young people in the 17-25 age range.-
I would say that these drivers, more so than others, are the ones who.are the disorderly drivers.
Q.
Chief, would you please assume for a minute that it is La Sunday in the summer of 1988 when the skies are sunny and the temperature is 85 - 90 degrees and further assume that it is between 1 and 2 p.m. and that the beaches are as crowded as they ever get.
Now assume that the Seabrook nuclear plant is licensed and is operating at full power and that this fact is well known to those in the area, including the beachgoers.
Now assume that a sudden, unexpected announcement is made that due to problems at the Seabrook nuclear plant tne beaches have been closed and that evacuation of the area is recommended.
And further assume that all the people in the beach area, including Salisbury, Seabrook, and Hampton Beach, are given the announcement at roughly the same time and that, with little nr no exception, the entire population of the beach area -- all the day-trippers as well as all permanent residents, seasonal residents, those renting cottages and rooms, and all the i
I 1
merchants and their employees -- all see to leave the beach area at roughly the same time.
Now further assume that there are two traffic guides assisting the evacuation at the eastern end of Beach Road (Rt. lA) and that there is an additional traffic guide at the intersection of the State Beach Road and Beach Road.
Assume that from that spot the State Beach Road
-- there are no traffic guides stationed anywhere along the two mile stretch of Beach Road (1A) before it intersects with Route 1 in Salisbury Center.
And further assume that the one, westbound lane of Beach Road (Rt. lA) quickly backs up and slows to a very slow speed.
In your professional opinion and experience, after the evacuating traffic passes the traffic guide stationed on Beach Road at its intersection with the State Beach Road, will the evacuating traffic remain in the one westbound lane?
A.
Nc.
I think that under those conditions, evacuating traffic would quickly begin using the eastbound lane as well.
Without having a series of troops or police officers stationed at regular intervals along the mid-line of the road, I cannot believe that during an evacuation because of an accident at the nuclear plant the evacuating drivers would not refrain from using the (incoming) opposite lane on Beach Road.
At that time of day and under those conditions, there would be few vehicles coming into the beach area on Route lA; so that inbound lane would just be too tempting for snarled traffic to resist using, especially without any police or traffic guides stationed along
+ '
!the' center.line.
The traffic jam:under those condicions will Lbelmore-than twice~as' bad -- and last more than twice as long
-- as anything we have ever.seen in a sudden rainstorm,-because everybody would be. leaving, not just the day-trippers._.I'can't imagine how.long it would take for.that kind of a traffic jam to clear, but' tit will.be far longer than people with normal, frustration levels could tolerate.
Plus there is the radiation
' threat!
Drivers will_be trying everything possible to get away from the nuclear plant quickly, and they are not going to worry about getting cited by the police for a traffic violation.
I am confident that, under the conditions you have had'me assume, both lanes of Beach Road (the eastbound lane as well as the westbound lane) would be used by evacuating vehicles.
Q.
Chief,-assume the same facts as in my last question except that I want this time to focus on Route 286.
- And, further assume that there are two traffic guidos at the eastern end of Route 286, where it intersects with Route lA.
And assume that there are no other traffic guides anywhere along Route 286 until you reach its intersection, about two miles to the west, with Washington Street.
Agait Chief, in your professional opinion and experience, would the evacuating traffic remain in the single, westbound lane on Route 286 in that two-mile stretch?
A.
No, it would not.
It's the same situation as in the
^
prior question about Beach Road except that here the evacuating i
drivers are even closer to the nuclear plant and, to make drivers even more anxious, they are actually within view of the i t
nuclear plant for a good portion of that two-mile stretch.
No reasonable person who is familiar with the beach traffic would believe that vehicles evacuating out Route 286 would stay in just the westbound lane during an emergency at the nuclear plant unless, again, a series of troops or police officers were stationed at regular intervals along the mid-line to prevent it.
In addition to filling both lanes, many of tha 'ehicles evacuating out Route 286 will undoubtedly take Sous. Main Street, which leads south and west and will appear to many drivers to take them away from the nuclear plant faster than Route 286 does.
Route 286 at this point appears to parallel or almost circle the nuclear plant somewhat.
Q.
If the westbound evacuating vehicles do fill up the eastbound lane as well, and this happens on both Beach Road (Route 1A) and on Route 286, will returning homeowners, emergency vehicles, buses, and others be able to travel westbound on these roads at all?
A.
It will be extremely difficult if not impossible --
and it will be dangerous, given the risk of collisions.
Emergency planners should not assume, under the conditions you posed to me earlier, that two-way traffic flow will be possible on these roads during an evacuation because of an accident at the nuclear plant.
l l
l l
l l
l
s ATTACHMENT A
't.
4, w
OO b-I
.1ern[
4 y/
.,,,.p n w 'n 5
,~
4,
- [4 N
s s,
L' M
N,\\
o i
5
- 1. 5 O
=
q
<, s s
1 o
3
\\
4
[
x' s
s e
4
\\
o km
)
s 4
j 8
u 2/
\\i
@ u.Aysvt f
I s
s
\\
/
I '48
.t'd k
X i
?
- s j
\\
f CD t
D i
I
,w m
-