ML20148H797

Rebuttal Testimony of Tf Moughan on Behalf of Atty General for Commonwealth of Ma Re Presence of Hidden Parking Spaces in Salisbury Beach & on Plum Island.* Related Correspondence

ML20148H797
Person / Time
Site:	Seabrook
Issue date:	01/22/1988
From:	Moughan T MASSACHUSETTS, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20148H773	List: ML20148H766 ML20148H797 ML20148H813
References
OL, NUDOCS 8801270306
Download: ML20148H797 (3)

Text

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-UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 10 JW 26 N1:23 Before Administrative Judges: OFFICE 0F SECRt.1ARY Ivan W. Smith, Chairperson 00CKEllNG 4 SEilVICI.

Gustave A. Linenberger, Jr. BRANCH Dr. Jerry Harbour

)

)

In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY OF ) Off-site Emergency Planning NEW HAMPSHIRE, et al. )

(Seabrook Station, Units 1 and 2) ) January 22, 1988

)

)

REBUTTAL TESTIMONY OF THOMAS F. MOUGHAN ON BEHALF OF THE ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS REGARDING THE PRESENCE OF HIDDEN PARKING SPACES IN SALISBURY BEACH AND ON PLUM ISLAND Q. Would you please state your name and current address?

A. My name is Thomas F. Moughan, and I reside at 91 Lake .

Attitash in Amesbury, Massachusetts.

Q. Mr. Moughan, a prior witness in these proceedings, Mr.

Gordon Derman, has stated that there are not many garages, carports, or under-building parking spaces in the beach areas of the Seabrook EPZ. Would you agree that this is true for Salisbury Beach and Plum Island?

A. No, I would not. I have recently conducted a field i

survey to determine the number of garages, carports, and other under-building parking spaces in Salisbury Beach and on Plum hBk1270306880122 T ADOCK 05000443 PDR t

t-V Island,,and I-have also counted the parking spaces which exist in these structures. -A summary of my findings is as follows: '

Parking Spacet Observed In Garages Car. porta, and 'nder-Buildings Salisbury Beach. '95 Plum Island 253 TOTAL 5'8 Q. When did you conduct your field surysy, and how was it conducted?

A. The Salisbury' Beach survey was condacted on Sunday, January 10, 1988. I was assisted by Mr. Wi]liam Lord. We drove along each street in Salisbury Beach and recorded on paper the street address of each building which contained a garage, carport, or other under-building parking spaceJ. Next to the address we noted the total number of parking spaces by category of structure (garage, carport, or under-building). In cases where a street number was not visible, an estimate was made from the nearest property having a visible number.

Garages included both detached structures and those built in or beneath dwellings. Carports included both the typical carport structure as well as clearly-used parking spaces beneath decks and porches. The area surveyed included all streets from the New Hampshire line on the north to the Salisbury Beach State Park on the south. The western boundary was the marsh except '

that in counting west along Route lA (Beach Road) coming out of the Salisbury amusement park area, we stopped at the entrance l road to the State Beach.

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95 The'PlumLIsland survey'was conducted _the next day, Monday, i

JanuaryLil~, 1988.- _The same procedure was followed, however, I was unassisted. I recorded the count by street, ratherothan

' building by building using street addresses,_because very'few

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.of.the structures on Plum Island have street addresses'which .

are visible.

Q. Have you kept your records of these counts?

Yes. I_would_be~ happy to make them available to anyone who is_ interested.

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