ML20195D194

City of Haverhill Detailed Contentions.* Contentions Listed Re Plant.Certificate of Svc & Svc List Encl

ML20195D194
Person / Time
Site:	Seabrook
Issue date:	06/16/1988
From:	Amirian A HAVERHILL, MA
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-6549 OL, NUDOCS 8806230063
Download: ML20195D194 (6)

Text

an.p.+. = w..: :.. .. . .z. :.x =-~..

fy.aa;p O K C" M .2-.G.G2 .

~ 8,..

~ . ..

f 5 94 e r

00CMETED-USNRC 1B JN 21 P5:41 0FFICE Of $nre,1u y 00CMETmc ,* u.::v!Cr' -

UNITED STATES OF AMERICA BRANCH NUCLEAR REGULATORY COMMISSION \

\

before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

PUBLIC SERVICE COMPANY OF ) DOCKET NOS. 50-443-OL NEW liAMPSilIRE, et al. ) 50-444-OL

)

(Seabrook Station, Units 1 and 2 ) (Off-site Emergency

) Planning Issues)

)

l l

CITY OF liAVERilILL'S l

DETAILED CONTENTIONS 1 ,

.......__-..~.

$ g, i-l 1

G

t. --.

\ --

-~ -

... ~ _ w -, - . .a .w. .-..u. .

m .

.- ..,w.- . , - ,

CITY OF HAVERHILL CONTENTIONS TO THE S.P.t!.C.

Because of the close proximity of these schools and their large enrollment, the city of Haverhill feels that they should be included in the S.P.M.C.,

as the safety of the children and staff can not be ensured other wise.

1) The Whittier Regional Vocation Technical High School, 115 Amesbury Line Road, is within yards of the plume exposure zone. The enrollment includes vast residents from Haverhill and the E.P.Z. towns.

2) Northern Essex Community Collage, 110 Elliott Street, is approximately one mile from the plume exposure zone with students originating from throughout Rocks Village, other areas in Haverhill and many E.P.Z. towns.

Many students rely on public transportation and N.E.C',C. has a large handicapp enrollment which must be adressed.

3) Lakeview Nursing Home, 87 Shattick Street is approximately one mile from the plume exposure zone. Elderly and non-ambulatory clients will have to be addressed.

4) Merrimac Child Care Center, 366 Amesbury Line Road, is within the plume exposure zone but not included in any evacation plans. The enroll-ment includes pre-school children from throughout Haverhill and the E.P.Z. towns.

5) The Rocks Village Area of Haverhill is within the plume exposure zone but has not been included in any evacuation plan. None of the residents have been assured of a safe evacuation. All other towns within the plumo exposure zone are completely included even thoughtonly a small portion of its area is actually effected.

6) The population figures list approximately 44 homes in the plume exposure zone in Rocks Village for 1986. This figure has doubled.

7) Only nine (9) persons assigndd to five (5) access control points through out Haverhill. This is inadequate considering the amount of evacueea moving through Haverhill and the distances they will be traveling beyond the Rt.110 and Rt.108 intersection to Rt.125. There are no traffic control persons, road signs or evacuation route indicaters beyond the

. . - . . ~ . . - - - - . - . - . . . . . . ... . - ...

' ccn'tentieno p.2 .

Rt. 110 and 108 intersections. Persons unfamilinr with Javerhill may got lost or hold up traffic.

8) Amesbury persons will be evacuated on Rt.108 to Rt. 110 in Haverhill to get to I-495 along with the New Hampshire towns of South Hampton and Nswton adding to the congestion and confusion of MASS evacuees. Evacuees turning lef t on Rt.110 f rom Rt. 108 must cross the stream of evacuees on Rt. 110. This wil.'. result in a tie up and delayed evacuation.

9) Evacuees attempting to cross the Rocks Village Bridge into West Newbury will be turned away on the West Newbury side only to return to East Main and River Road with no indication of where to go.

10) West Newbury evacuees are directed down Rt.113 through Groveland into Haverhill. Traffic will have to move through Haverhill on Water Street blocking a major fire station to the intersection of Water and Merrimac

~

Streets, which is severly conjested under normal conditions. Upon turning into Rt.125 in Bradford, the traffic again is severly congested et best and at a stand still during peak hours. Again, there are no markers identifing evacuation routes.

i

11) The Kimball Farm, 789 East Broadway which produces beef for human consumption has not been addressed. The grazing fields are located in Rocks Village only yards from the plume exposure line.

12) Haverhills Hale Hospital has not been included in any plans to deal with accident victims of evacuation through the streets of Haverhill is ony thing less than perfect.

13) The problem of cars braking down or disabled in accidents has not l

been addressed. With all escape routes through Haverhill being only two city lanes wide, one disabled vehicle could stop the flow of evacuees for miles.

j

14) It is unlikely that Haverhills residents will remain in their homes l

while the evacuees from the E.P Z. towns are trying to flee through r

i Haverhill. If Haverhills residents were to jion the E.P.Z. evacuees with no supervision or evacuation plan to follow, Haverhill officals l such as police, fire and civil defense would be ill prepared to deal l

. s c:ntcntiens p.3 l 4

with the chaos that would be created. This S.P.M.C. will have a negitive impact on Haverhill and by only including Haverhill as a whole will a evacuation plan serve the best interests on this community.

. CIT OF HAVERHILL B3 it attorney:

DATED: June 16, 1988 Ashod N. Amirian, Esquire Assistant City Solicitor 376 Main Street Haverhill,MA 01830 617-372-8531 CERTIFICATE OF SERVICE I, Ashod N. Amirian, Esquire, Assistant City Solicitor to the City of Haverhill, hereby certify that on June 16, 1988, I have forwarded copie es the within detailed contentions to the following individuals an agencies as attached.

@\

x

- Ashod N. Amirian, ERquire 9

4 Jn

e . -

Ivra W. Smith, ch:frman 1.ob2rta Payact Edward V(gga Atomic Safety and Licensing State Rep Town of Hamp. ton pggA B:crd Fills 334((D U.S. 442 J. W. McCormack (POCH)

NRC Irinkwater Road Boggan A 02109 W chington, DC 20555 llampton Falls, Nil 03844 2f pg IffINu.jius).

sc Ar #

i Dr. Jerry Harbour Docketing & Serv. Sec. ThomakN8kgdEN'lfdsquire Attade Safety and Licensing Office of the Secretary Ropes & Gray Bosrd U. S. NRC U.S. NRC 225 Franklin Street Washington, DC 20555 Boston, MA 02110 W: hington, DC 20555 Gustave A. Linenberger Jane Doughty Cf fico of Selectmen Atomic Safety and Licensing SAPL Town of Hampton Falls Board H:mpton Falls, NH 03844 5 Market Street U. S. NRC Portsmouth, Nil 03801 Washington, DC 20555 Ashod N. Amirian, Esquire Joseph Flynn, Asst. Gen Cnsl. George Dana Bisbee, Esquire 376 H:in Street Fed. Emerg. Hgmt. Agey. Attorney General's Office Hcv2rhill, MA 01830 500 C Street SW State of New Hampshire Washington, DC 20472 Concord, NH 03301 l

Carol Sneider, Esquire Sherwin E. Turk, Esquire Sandra Cavutis Asciatant Attorney General Office of Exec. Legl. Dr. Town of Kensington On2 A hburton Place U. S. NRC Box 1154 19th Floor Washington, DC 20555 East Kensington, NH 03827 B:cton, MA 02108 Hr. Angie Machiros, Chairman Judith H. Mizner, Esquire Charles P. Graham, Esquire Town of Newbury Silvergate, Gerner, Baker, McKay, Hurphy and Graham Town Hall Fine, Good & Mizner 100 Main Street 25 High Road 88 Broad Street Amesbury, MA 01913 Newbury, MA 01951 Boston, MA 02110 Ellyn Weiss, Esquire Paul McEachern, Esquire William S. Lord, Selectman H:rmon & Weiss Matthew Brock, Esquire Town Hall 20001 S Street NW 25 Haplewood Avenue Friend Street Suits 430 P.O. Box 360 Amesbury, MA 01913 W:shington, DC 20009 Portsmouth, NH 03801

.r. n - - . . n 7 :.. .zaQ . -.. . ~ .. .. : . -. - .w. .a .

S natCr.C:rd:n J. Ilu;phrey U. S' Senate W:shington, DC 20510 Attnt Janet Coit Atonic Safety and Licensing Bo;rd' U. S. NRC F:urth Floor P.eception Area East West Towers, West Bldg.

4350 East West Highway B;thesda, MD 20814 J. P. Nadessu T;wn of Rye 155 Washington Road Rya, NH 03870

'A4j,udicatoa;y File

.Ar.ons Safpt;y gd Lirmasing Board Panel U. S. NRC Wzhington, DC 20555 Seacoast Anti-Pollution League c/o Robert A. Backus, Esquire 116 Lowe11 Street P.O. Box 516 Manchester, Nil 03105 e

l