ML20151Y643

Town of Newbury Summary of Contentions & Table of Contents Re Applicant Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl

ML20151Y643
Person / Time
Site:	Seabrook
Issue date:	04/26/1988
From:	Hillwhilton R LAGOULIS, HILL-WHILTON & ROTONDI (FORMERLY LAGOULIS, NEWBURY, MA
To:
References
CON-#288-6218 OL, NUDOCS 8805050059
Download: ML20151Y643 (8)

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7 O\\g{C UNITED STATES OF AMERICA U

NUCLEAR REGULATORY COMMISSION 38 MY -2 P5 '45 ATOMIC SAFETY LICENSING BOARD

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IN THE MATTER OF:

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Docket No. b fM4'dkO'f,.'

PUBLIC SERVICE CO.

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Docket No. 50-444-OL of NEW P'r~. SHIRE

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(Offsite Emergency Planning)

(Seabrook Station, Units 1 and 2) )

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TOWN OF NEWBURY'S

SUMMARY

OF CONTENTIONS AND TABLE OF CONTENTS WITH RESPECT TO APPLICANT'S PLAN FOR MASSACHUSETTS COMMUNITIES Page

1. The SPMC does not provide a reasonable means of 1

evacuation and relocation.

a. The SPMC lacks adequate intersection control.

1-2 b.

The SPMC inadequately addresses road 2

impassability.

c. The SPMC inadequately addresses traffic flows 2-3 for ingress to and egress from evacuated areas.

d. Newbury Bus Route #1 is inadequate in that it:

I.

Includes inadequate roads.

3 II.

Inadequately addresses traffic flows.

4 III. Includes additional inadequate roads.

4 IV.

Inadequately addresses population distribution. 5 V.

A. Contains inadequate intersection controls.

5-6 B. Contains inadequate route choices for 6

evacuees.

C. Contains additional inadequate intersection 6-7 Control.

D. Contains additional inadequate intersection 7

control.

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c.

Page VI.

A. Flows contlary to evacuation routes.

8 B.

Includes unmarked streets.

8 C._ Inadequately addresses contrary directional 8-9 flow.

D. Provides an inadequate transfer point.

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e. Newbury Bus Route #2 is inadequate in that it:

I.

Includes unmarked streets.

9 II.

A.

Includes additional unmarked streets.

10 B.

Includes unmarked or incorrectly marked 10 streets.

C.

Includes inadequate roadways.

11 III. A.

Includes routes which oppose evacuation 11 traffic flow.

B.

Includes inadequate intersection control.

11-12 C. Contains inadequate and inaccurate maps.

12 D. Contains routes which oppose evacuation 12-13 traffic flows.

E.

Includes unmarked routes.

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IV.

A.

Includes inadequate evacuation and 13 alternate evacuation routes.

B.

Inadequately addresses route impassability. 13-14 l

l V.

Includes an inadequate transfer point.

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f. Newbury Bus Route #3 is inadequate in that it:

I.

A.

Includes inadequate routes.

14 l

l B.

Includes inadequately marked route maps.

14 C.

Includes inadequately marked route maps.

15 D.

Includes travel contrary to traffic flows.

15 E. Inadoquately addresses route impassability. 15 II.

A.

Includes unmarked streets.

15 11

Page B.

Includes inadequate roads and routes which 15 oppose traffic flows.

C.

Inadequately addresses road impassability.

15 D.

Provides inadequate intersection control.

15-16 E.

Inadequately addresses route impassability 16 and includes additional inadequate roads.

III. A.

Provides inadequate intersection control.

16 B.

Includes routes which further oppose 16 traffic flows.

C.

Inadequately addresses bridge traffic 16-17 flows.

D.

Includes inadequately marked routes.

17 IV.

A.

Inadequately addresses route impassability. 17 B.

Inadequately addresses evacuation traffic 17-18 flows.

V.

A. Contains inadequate intersection control.

18 B.

Includes unmarked routes.

18

g. Newbury Bus Route f4 is inadequate in that it:

I.

A. Contains inadequate roads and opposes 18-19 evacuation traffic flows.

B.

Provides inadequate traffic controls and 19 inadequately addresses traffic flows.

C. Contains inadequately marked routes.

19 II.

A. Contains additional inadequately marked 20 routes.

B.

Inadequately addresses impediments to 20 travel.

C. Contains unmarked routes.

20 D.

Inadequately addresses evacuation traffic 20 flows.

l I

III. A. Contains additional inadequate routes and 21 inadequately addresses traffic flows.

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Page B.

Provides inadequate intersection control.

21 C.

Inadequately addresses traffic flows.

21 IV.

A. Inadequately addresses impediments to 21-22 travel.

B. Provides inadequate and conflicting 22 intersection controls.

C. Inadequately addresses traffic flows and 22 intersection control.

h. The SPMC contains evacuation routes which utilize 23 nonexistent streets.

i. The SPMC generally deals inadequately with route 23-24 impassability and provides inadequate contingent routes.

j. The SPMC fails to provide for timely evacuation in that it:

I.

Fails to provide adequate evacJation routes, 24 alternate routes or intersection control.

II.

Wholly fails to identify "inland" routes or 24-25 alternatives.

III. Generally fails to address evacuation traffic 25 flows and impediments created by opposing flows.

IV.

Generally provides inadequate and insufficient 25 intersection control.

V.

Fails to provide adequate removal of travel 25 impediments.

VI.

Fails to provide adequate evacuation buses 25-26 or route repetition.

2. The SPMC fails to provide for adequate equipment 26 and maintenance.

a. The SPMC provides for insufficient buses.

26

b. The SPMC fails to provide for adequate traffic 26 control devices.

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c. Newbury lacks adequate personnel and equipment 26-27 to implement the plan.

3. The SPMC fails to provide adequate evacuation of 27 mobility impaired persons.

4. The SPMC fails to adequately project evacuation 27 route traffic capabilities.

5. The SPMC generally fails to adequately address 27-28 removing travel impediments.

6. The SPhC fails to include maps depicting population 28-29 distribution and contains incorrect population data.

7. The SPMC fails to contain an adequate means of notifying the resident and transient population.

a. The VANS system is insufficiently described.

29-30

b. The Parker River National Wildlife Refuge 30 population has no adequate means of notification.

8. The evacuation bus transfer point is not permitted by 30-31 local law.

9. The SPMC fails to adequately address the availability 31-32 and suitability of sheltering.

10. The SPMC fails to adequately address the needs of 32 mobility impaired persons requiring special transportation.

11. The SPMC erroneously assumes that the Town of Newbury 33 will, and has the resources to, implement the plan.

a. The assumption is rebutted due to the insufficiency 33 of personnel, equipment, shelters or adequate means of relocation.

b. Newbury officials will not implement or generally 33-34 follow the SPMC as they are unfamiliar with it and have concluded that an ad hoc response will have to be undertaken.

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12. The SPMC fails to adequately provide for coordinating 34-35 and communicating with local governments.

Respectfully submitted, Town of Newbury, By its Attorney:

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Dated:

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Scott Hill-Whilton Lagoulis, Clark, Hill-Whilton &

McGuire 79 State Street Newburyport, MA 01950 (617) 462-9393 I

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ScottHill-Whilton,CounselfortheTownofNewbEEk5dE0 I,

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the above-entitled action, hereby certify that I have cabse'd copies of the enclosed documents to be served upon the persons at the addresses listed below, by first clagg, MY -2 P5'46 postage prepaid, mail.

ut r ic. s.:t a.r-00CMDi404 E v:r.E BRANM Admin. Judge Ivan W. Smith Judge Gustave A.

Linenberger, Jr.

Chairman, Atomic Safety and Atomic Safety and Licensing Board Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Dr. Jerry Harbour Docketing and Service Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1717 H Street Washington, D.C. 20555 Washington, D.C.

20555 Thomas G.

Dignan, Esq.

A.S.L.A.B. Panel Ropes and Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, D.C.

20555 Boston, MA 02110 Diane Curran, Esq.

Stephen B. Merrill, Esq.

Harmon & Weiss Attorney General Suite 430 Office of the Attorney General Washington, D.C.

20009 Concord, NH 03301 Sherwin E.

Turk, Esq.

Robert A. Backus, Esq.

Office of General Counsel NRC 116 Lowell Street 15th Floor, 1 White Flint North P.O. Box 516 Rockville, MD 20852 Manchester, NH 03105 Philip Ahrens, Esq.

Paul McEachern, Esq.

Asst. Attorney General Shaines & McEachern Office of the Attorney General 25 Maplewood Avenue Augusta, ME 04333 Portsmouth, NH 03801 Mrs. Sandra Guvutis The Honorable Gordon J.

Humphrey Chairman United States Senate l

Board of Selectmen Washington, D.C.

20510 Kensington, NH 03827 Mr. Thomas Powers H. Joseph Flynn, Esq.

Town Manager Office of General Counsel Town of Exeter Federal Emergency Management Agency Exeter, NH 03833 Washington, D.C.

20472 (1)

Gary Holmes, Esq.

Stephen Jonas, Esq.

Holmes & Ells Assistant Attorney General 47 Winnacunnet Road Office of the Attorney General Hampton, NH 03841 Boston, MA 02108 Mr. Calvin A. Canney Charles P. Graham, Esq.

City Manager Murphy and Graham City Hall 33 Low Street Portsmouth, NH 03801 Newburyport, MA 01950 Barbara Saint Andre, Esq.

Mr. William Lord Kopelman & Paige Selectman 77 Franklin Street Board of Selectmen Boston, MA 02110 Amesbury, MA 01913 Brentwood Board of Selectmen Richard A. Hampe, Esq.

RFD Dalton Road Hampe & McNicholas Brentwood, NH 03833 35 Pleasant Street Concord, NH 03301 Mr. Ed Thomas Judith Mizner, Esq.

FEMA Region I 79 State Street 442 McCormick P.O. Building Newburyport, MA 01950 Boston, MA 02109 Mr. Robert Carrig, Chairman Board of Selectmen Town Office North Hampton, NH 03862 Signed under seal this 27th day of April, 1988.

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