ML20236V718
| ML20236V718 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/30/1987 |
| From: | Lord W AMESBURY, MA |
| To: | |
| References | |
| CON-#487-4956 OL, NUDOCS 8712070025 | |
| Download: ML20236V718 (10) | |
Text
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NN DOOPET NUMEEf? p-g-- -g_.gj C PROD. fi UTIL FAC.
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- Eoard of Selectmen h0NbG IYN[C T wn Hall, Amesbury, MA 01913 BRANCH Iel 380'0290 November 30, 1987 s
Town of Amesbury testimony errata sheet.
Page 1 - no changes.
Page 2 - delete from lines 3,4 & 5, "Until..
binding".
Page 2 - delete paragraph 1 Page 2 - paragraph 3, delete "Should.
. objection," from first sentence.
Page 2 - paragraph 3, line 2, delete "still".
Page 3 - no changes Page 3a - footnote, line 5, change "...only adversely..." to "...substantially...".
Page 4 - paragraph 3, delete last sentence 4 Page 4 - paragraph 4, delete'3ast sentence.
Page 5 - paragraph 1, delete last sentence.
Page 6 - paragraph 2, delete last sentence.
Page 6 - paragraph 3, delete second sentence.
Page 6 - paragraph 4, delete last sentence.
Page 7 - delete paragraph 1.
Page 7 - paragraph 2, delete from lines 6 & 7 " staffing..
50%".
Page 7 - updated certificate of service.
All changes described above have been incorporated in the corrected testimony.
No changes have been made to exhibits as provided September 11, 1987.
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USNRC w u, o Ames,aury Board of Selectmen Town Hall, Amesbury, MA 01913 g.ggg g.
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Tel. 388 0290 E d t.tt C H BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the matter of
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Docket Nos. 50-443-OL
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50-444-OL PUBLIC SERVICE COMPANY
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OF NEW HAMPSHIRE, g al.
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Offsite Emergeracy Planning
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(Seabrook Station, Units 1 & 2)
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November 30, 1987 CORRECTED TESTIMONY OF THE TOWN OF AMESBURY IN EVIDENTIARY HEARINGS ON THE NHRERP, SEPTEMBER 28, 1987.
On March 6,1987, the Town of Amesbury (TOA) notified all parties a
to these proceedings of the Town's intention to participate in three contentions admitted before this Board: 'Ibwn of Hampton Revised Contention III, SAPL Contention 31 and SAPL Contention 34.
Based on conversation with representatives of SAPL, the TOA feels secure in the fact that SAPL will more than adequately air the issues of greatest importance to TCA.
The TOA will not offer testimony on the SAPL contentions, but maintains its interest in the issues raised through Hampton Revised Contention III.
TOH III was admitted before this Board, limited to the bases proffered October 31, 1986. The TOA offers testimony in support and substantiation of bases C-1 and C-2.
The TOA agrees with TOli III, C-1, which states that there is no assurance that roads throughout the EPZ will rcrain passable during an evacuation. On November 18, 1985, the Town Meeting and Board of Selectmen of the TOA voted a policy of non-participation in emergency planning for Seabrook Station. Furthermore, on September 20, 1986, the Governor of the Commonwealth of Massachusetts announced his decision rejecting all C____________-.--
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(.l TOA (2).
plarging efforts and echoed TOA's position. During the period of time from 11-18-85 to 9-20-86 the remaining 5 Mass. communities within the EPZ established local policies of non-participation.
Not only is there no assurance of passable roads for Massachusetts l
residents (1986 est. population of 50593 operating 19459 vehicles), App. J l
also directs residents of seabrook, South Hampton and Newton, NH to 1
evacuate through Massachusetts. The principle roadways to be utilized by NH residents include Interstate Highways I-93, I-95, I-213 and I-495 as I
well as Massachusetts routes 28, 97, 108 and 110. The three NH towns have an estimated 1986 permanent population of 12,601 residents operating an estimated 4,847 vehicles.
In total, 63,194 residents, or 44% of the EPZ population, have no assurance that roads will be passable during an evacuation.
This Board must deal with the issue of the three NH towns. Applicants have had a full year to remedy the situation as it affects these towns, and have failed to do so..No attempt has been made to redesign evacuation routes avoiding use of roadways within the Commonwealth.
In addition, the issue is further complicated by the nonparticipation of several NH communities.
The case is quite clear x-- literally thousands of permanent residents
'1VA ( 3)
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will h ve no assurance of clear roadways. Evacuation will either becone virtually impossible during severe weather conditions (a common event in this region) or evacuation time estimates will be greatly lengthened, causing Vol. 6 to be a totally ineffective tool in fulfilling the requirements of 10CFR50.47(a) (1) and (b) (10).
Natural Occurences and Conditions:
Vol. 6 attempts to estimate evacuation times under a number of differing conditions, including adverse weather. However, Vol. 6 fails to include as part of those estimates the reality that roads are of ten totally impassable due to natural conditions.
During the first week of April,1987, the TOA, as well as the entire region, experienced prolonged natural conditions which limited use of or e
closed many roadways. A brief description of each problem clearly outlines the extent of the _ traffic complications created.
Restrictions and closings of roadways continued from two to forty-eight hours.
Buttonwood, Hunt and Pleasant Valley Roads flooded; areas of Hunt Rd.
washed cut completely prohibiting traffic. This condition lasted for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Lions Mouth Road experienced flooding to a point where only one lane could pass through. Main St., near the Post Office (a main route to route 110, I-95 and I-495) was limited to one lane for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; Main St., along the Merrimack River sustained considerable damage i
and erosion making travel very slow and dangerous. The flooding on Cedar St. required sandbagging to protect property and hold the street from collapse.
The more significant cases caused major road damage and in one case stranded residents of 100 homes for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Lake A ttitash Road was under l
two feet of waters even the alternate access road washed out and was not passable by four wheel drive vehicles. Greenleaf St., the most direct route from the densely populated Whitehall Rd. area, was not only unde' water,
TOA (32) but also experienced a large section of roadway breaking loose to a depth of a couple of feet. Newton Road was closed as a result of the collapse of the earthen dam at Tuxbury Pond. Both High St. and Thompson St. had to be closed for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> because rising waters were overflowing the bridges.
Route 110 east (Macy St.), just a few hundred yards west of I-95, sustained a collapse of part of the roadway, limiting traffic to one lane only.
As this Board is well aware, Route 110 is an important link in Applicants' evacuation plans.
Vol. 6 of fers no program for coping with closed roadways...there is no public notification system for available alternate routes...no traffic control re-assignment plans. The assumption that roadways will remain passable is without merit. The failure to address what impact natural conditions have with respect to closing roadways causes Vol. 6 estimates to I
l be useless as planning tools. Vol. 6 violates the requirements of 10 CFR 50.47(b) (10) which calls for a range of protective measures.
Exhibit "G" shows the location of the serious flooding and road restrictions outlined above.
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At this point it is important to state that the preceeding, and subsequent testimony, is intended to show a lack of, contiguous jurisdictional planning and its adverse effect on the NilRERP. This testimony in no way covers all problems associated with the evacuation time estimates and traffic control measures. Many problems will substantially affect the Massachusetts portion of the EPZ and the TOA seeks to preserve its rights to raise those questions if and when hearings commence on any version of a Massachusetts Emergency Response Plan.
l m_____.
TOA (4)
TOH Revised Contention III, Basis C-2.
The TOA agrees with TOH revised contention III basis C-2.
Without becoming repetative, the policies of local governments in both MA and NH and that of the Commonwealth of Massachusetts establish that recommended traffic control tactics will not be in effect during an evacuation. The mere assumption that measures may be taken provides no assurance of plan adequacy, nor does that assumption provide that measures will be taken in accordance with 10 CFR 50.47(a) (1).
Additionally, through the following discussion and exhibits, TOA will show that Applicants have submitted substantially flawed methods of traffic control.
In Exhibit "A", page I-15 of Vol. 6, Applicants fail to show the entire intersection and its inherent problems. The bold lines show a north-a bound access to route 150. That road leads directly to the center of Town and more importantly to 2 schools, a number of nursing homes and the hospital. An opportunity is created for traffic to move against the out-bound flow and to attempt turns across traffic complicating and slowing evacuation.
Vol. 6, page I-17 (Exhibit "B") fails to show two large parking lots on both southern corners of the Intersection. Both lots have immediate ace.ess onto route 110 and Main St.
Since no traffic controls exist at the lots, eastbound traffic on route 110 will be able to cut Main St. south, crossing a traffic flow causing additional confusion and delay.
Vol. 6, page I-18 (Exhibit "C") shows an intersection of Main and l
Market Sts.
No such intersection exists in the TOA! Market St. is a north-t south road (not east-west as shown) beginning at the north side of Market Square. Main St. starts at the south side of Market Square, goes south and 1
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wast, south again, end eventually east toward Newburyport. The TOA can only assume that an intersection has been mis-labeled, making it 1
impossible for a traf fic officer to determine his/her assignment.
Consequently, an un-manned intersection will disrupt any attempt at an orderly evacuation.
Vol. 6, page I-20 (Exhibit "D") fails to show parking lots and drive-l ways which will contribute to avoidance of traffic control measures.
Once again traffic will be able to criss-cross designed flow causing potential delnys or complete stoppage. Under normal conditions the intersection is considered one of the most accident prone in the community.
Vol. 6, page I-19 (Exhibit "E") is the classic example of Applicants' lack of research and inability to provide a planning document that can be utilized in determining evacuation times or actual implementation during an accident. The diagram as submitted is tantamount to fraud. Traffic westbound on route 110 from Salisbury (nearly 100% of the Salisbury evacuees) is to gain access to I-95 south. Applicants' diagram shows half of that traffic turning left (south) through on opening in the divided roadway and utilizing a normally southbound offramp as an emergency on-ramp to I-95 south.
Applicants have attempted to show this Board what appears to be a roadway when in fact no such connection exists.
The two ramps, shown as common raodway, are actually divided by a median strip ranging in width from about 6 feet wide to as much as 50 feet wide.
Furthermore, the median is constructed with granite curbings and the topography of the area pre-cludes it from being used, even in an emergency, as a pathway for vehicle s.
Two other factors either prohibit or seriously limit use of this ramp as an access to I-95 south.
The cut in the route 110 divider was designed to make it extremely difficult to turn onto the " wrong" ramp.
Evacuating i
l traffic must drive slightly past the ramp in order to cut back against the d
.i
II wva tu) median. ' Sicondly, if ths ramp ware ussd and traffic did not attempt to cross the curbing and median, the only other access to the highway would require evacuees to drive into the face of southbound traffic and make an approximately 300 degree right-hand turn.
That type of turn into an area with virtually non-existant breakdown lanes would cause both delay and massive traffic congestion.
In summary of this point, the Applicants have attempted to show this Board 3 " entrances" to I-95 south where only 2 really exist.
If one-third of evacuating traffic was intended to be using each route, simple math shows us that the two actual evacuation ramps must now increase their capacity by 50%.
Common sense tells us that the clear time for the area will also increase by 50%. Traffic demands on this intersection with only 2,. not 3, means of highway access will increase the evacuation tine estimates to a degree that those estimates have no value as a planning tool.
"A range of protective actions..."(10 CFR 50.47(b) (10)) cannot be assured for the general public.
The TOA also notes that a number of other important intersections within the Town have been omitted from Vol. 6.
The intersection of Main St., Sparhawk (route 150) and School St. --- one of the busiest in Town ---
is not shown to have any traffic control. Traffic from major population centers must use these roads to travel toward route 110 and I-495.
Route 110 at Highland St. is also omitted.
Highland St. is the immediate access to the hospital and a common route to the High School.
Of utmost concern is the intersection of Highland, Hillside (routel50)
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Sparhawk and Greenleaf Sts.
Highland becomes the principle route to the High School and the Cashman Elementary School. Sparhawk/ Hillside is the outbound road to I-495.
Greenleaf is the feeder road from the densely populated Whitehall Road area.
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'TOA (7).
5 Exhibit "F" shows all intersections in question and those omitted.
Since we are dealing with a plan based almost totally on assumptions, it is safe to assume that the planning deficiencies outlined above are not
' peculiar to Amesbury alone.
Vol. 6 attempts to describe 107 traffic
. control intersections throughout the EPZ.
Based on-the Amesbury experience, potentially 25% of tihe important intersections may have been omitted; first hand observations and analysis was not properly conducted. There has not been a good faith sffort on the part of the Applicants to provide a planning tool of value in determining a range of protective measures in the event of an accident at Seabrook Station. Without this vital infonnation, the requirements of 10 CFR 50.47(a) (1)
"... adequate protective measures w-can and will be taken.. " (emphasis added) --- can not fulfilled.
For the own o Amesbury, m
William S. Lord Amesbury Board of Selectmen Amesbury, MA 01913 I, William S. Lord, certify that the CORRECTED TESTIMONY OF THE TOWN OF AMESBURY IN EVIDENTIARY HEARINGS ON THE NHRERP, SEPTE R 28, 1987 has been served of the attached list of parties, by first class mail or in-hand, this 30th day of November, 1987 d./pvf William S. Lord
Ivan W. Smith, Ch:irman
- Atom [c S foty Lic. Borrd Philip Ahrcn3, E!q.
Brantwood Bd. of Salactmen US NRC Dept. of th3 Attorn2y' Gen 2rni RFD Dalton Rd.
W::hington, DC 20555 Auguatn, ME 04333 Brantwood, Nil 03833 Gu:tave Linenberger Mrs. Sandra Gavutis Gary W. !!olmes, Esq.
Atomic Safety Lic. Board Board of Selectmen IIolmes & Ells US NRC RFD 1 - Box ll54 47 Winnacunnet Rd.
W :hington, DC 20555 Kensington, Nil 03827 Ilampton, NII 03842
.Dr. Jerry Farbour Matthew Brock, Esq.
Mr. Edward Thomas Atomic Safety Lic. Board Shaines & McEachern FEM - Region 1 US NRC P.O. Box 360 442 McCormack POCil Wu hington, DC 20555 Portsmouth, NH 03801 Post Office Square Boston, MA 02109 Atomic Safety & Licensing Senator Gordon Humphrey Michael Santasuosso Board Panel U.S. Senate Board of Selectmen US 10 0 tJashington, DC 20510 So. Ilampton,. Nil 03827 Wrahington, DC 20555 attn: Tom Burcak
" Atomic Safety & Licensing Senator Gordon Humphrey Charles P. Graham, Esq.
Appeal Board 1 Eagle Sq. - Suite 507 100 Main Street US NIC Concord, NH 03301 Amesbury, MA 01913 Wichington, DC 20555 attn: lierb Boynton Dockoting '& Service Section H. Joseph Flynn Ms Jane Doughty Of f. of the Secretary Off. of General Counsel SAPL US NRC FEMA 5 Market St.
W s hington, DC 20555 500 C St., SW Portsmouth, N11 03801
, Washington, DC 20472 Robsrt Carrigg Mr. J.P. Nadeau Roberta C. Pevear Bozrd of Selectmen Selectmen's Office 27 Drinkwater Rd.
Town Hall 10 Central Rd.
Ilampton Falls, Nil 03844 No. Ilampton, Nil 03862 Rye, Nil 03870 m
Dicna Curran, Esq.
Carol S. Sneider, Esq.
Richard A. Hampe Hcrmon & Weiss Off. of the Attorney Gen.
Hampe & McNicholas 2001 S St., NW - Suite 430 1 Ashburton Pl.- 19th Fl.
35 Pleasant St.
W:shington, DC 20009 Boste"1, MA 02108 Concord, Nil 03301 George Dana Bisbee, Esq.
Calvin A. Canney Judith II. Mizner, Esq.
Of f. of the Attorney General City Manager Silverglate, Gertner et al 25 Capitol St.
126 Daniel St.
88 Broad St.
Concord, N1103301 Portsmouth, N!! 03801 Boston, MA 02110 Sh2rwin E. Turk, Esq.
Mr. Angie Machiros Off. of the Exec. Legal Dir.
Board of Selectmen Beverly llollingworth 209 Winnacunnet Rd.
,US HIC Newbury, MA 01951 Hampton, Nil 03842 W hington, DC 20555 Robert A. Backus, Esq.
Mayor Peter S. Matthews Thomas Dignan P.O. Box 516 j
City Itall Ropes & Gray 116 Iowell St.
Newburyport, MA 01950 225 Franklin St.
Manchester, nil 03105 Boston, MA 02110
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