ML20238F157

Testimony of Town of Amesbury in Evidentiary Hearings on State of Nh Radiological Emergency Response plan,870928.* Requirements of 10CFR50.47(a)(1) Cannot Be Fulfilled W/O Listed Vital Info.W/Supporting Documentation & Svc List

ML20238F157
Person / Time
Site:	Seabrook
Issue date:	09/28/1987
From:	Lord W AMESBURY, MA
To:
References
CON-#387-4383 OL, NUDOCS 8709160005
Download: ML20238F157 (16)

Text

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s , se - mesaury Board of Selectmen -, Town Hall, Amesbury, MA 01913 f,E t >

Tel. 388-0290 BEFORE THE ATOMIC SAFETY & LICENSING BOAPD In the matter of ) Docket Nos . 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY )

OF NEW HAMPSHIRE, et al. ) Offsite Emergency Planning

)

(Seabrook Station, Units 1 & 2) ) September 11, 1987 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

J to these proceedings of the Town's intention to participate in three j contentions admitted before this Board: Town of Hampton Revised Contention ,

I III, SAPL Contention 31 and SAPL Contention 34. Based on conversation

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with representatives of SAPL, the TOA feels secure in the fact that SAPL will more than adequately air the issues of greatest importance to TOA.

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 Oc tober 31, 1986. The TOA offers testimony in support and substantiation of bases C-1 and C-2.

The TOA agrees with TOH III, C-1, which states that there is no assurance that roads throughout the EPZ will remain 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 p;ritB88R818%p T

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I i planning efforts and echoed TOA's position. During the period of time I

I from 11-18-85 to 9-20-86 the remaining 5 Mass, communities within the EPZ established local policies of non-participation. Until such time as proven otherwise, this Board must acknowledge that these policies are within the

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l authority of both the local and State governments, and as such are binding, j I

The TOA anticipates that the Applicants will object to this line j l

of testimony, claiming its inclusion in the NHRERP proceedings bears no .  !

relevence. Appendix J of NHRERP Vol. 6 describes in detail the evacuation j I

l routes for all communities within the EPZ. By their inclusion, all routes are subject to question in this, the only forum available on the subject.

Not only is there no assurance of passable roads for Massachusetts residents (1986 est. population of 50593 operating 19459 vehicles), App. J , j i

also directs residents of Seabrook, South]!ampton and Newton, NH to 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 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 ,

i evacuation.

Should the Applicants prevail on the "not dealing with Massachusetts" i

objection, this Board must still deal with the issue of the three NH towns. 1 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 non-participation of l

several NH communities.

The case is quite clear --- literally thousands of permanent residents

TOA ( 3)  ;-

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will have no assurance of clear roadways. Evacuatiou will either become l

virtually impossible during severe weather conditions (a common event in ./

i this region) or' evacuation time estimates will be greatly lengthened, [

~ l causing Vol. 6 to be a totally ineffective tool in fu1 filling the T I i

l requirements of 10CFR50.47(a) D) and (b) (10) . '

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Natural Occurences and Conditions:

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Vol. 6 attempts to estiuute 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 closed many roadways. A brief description of each problem clearly outlines

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the extent of thurraffic complications created. Restrictions and closings of roadways continued from two to forty-eight hours. '

y Buttonwood, iHunt and Pleasant Valley Roads flooded; areas of Hunt Rd.

washed out completely prohibiting traffic. This condition lasted for 24 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />. Lions Mouth Road experienced flooding to a point where only one lane could pass th70 ugh. 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., 91ong the Merrimack River sustained considerable damage 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 a"r.d in one case i

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 aaad was under two feet of water; even the alternate access road washed out ar.d was not' passable by four wheel drive vehicles. Greenleaf St., the most direct route l from the densely populated Whitehall Rd. area, was not only under water,

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! 'N. but also experienced a large section of roadway breaking loose to a depth l r b of a couple of feet, Newton Road was closed as a result of the collapse of the earthen ders at Tuxbury Pond. Both High St. and Thompson St. had th be,ciorad for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> ( because rising waters were overflowing the

'gv bridges. Toute 110 cast (Macy St.), jv.st a-rew hundred yards west of I-95, f ,

jtg sdjitained a collapse of part of the roadway, limiting traffic to one lane only.

!i n? As1 this Board is well aware, Route 110 is an important link in Applicants' evacuation plans.

Vol. 6 offers no program for coping with closed roadways...there is no

1 public notification system for availabic alternate routes. . .no traffic centrol re-assignment plans. The assumption that roadways will remain i' passable is without merit. The failure to address what impact natural conditions have with respect to c. losing roadways causes Vol. 6 estimates to be useless as planning tools. Vol. 6 violates the requirements of 10 CFR 50.47(b) (10) which calls for aorarge of protective measures.

Exhibit "G" srcws'the location of'the serious flooding and road restrictions outllried above. * /

1. At this point 'it is ,important to state that the preceeding, and subsequent testimony, is intended to show a lack of contiguous jurisdictional t planning and its adverse effect on the NHRERP. This testimony in no way covers all probicas associated with the evacuation time estimates and traffic control'ccasuren. Maas problems will only adversely affect the Massachusetts portion of the 33Z and the TOA seeks to preserve its rights ,

e to raise these questions if and when hearings commence on any version of '

a Massachusetts Emergency Responso Plan.

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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 mgt 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-bound acceve 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. Proper coverage of the intersection will demand at least one additional police officer from the non-participating community.

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 access onto route 110 and Main St. Since no traffic controls exist at the lots, eastbound traf fic on route 110 will be able to cut Main St. south, crossing a traffic flow causing additional confusion and delay. No fewer than 4 more police officers would be required.

l Vol. 6, page I-18 (Exhibit "C") shows an intersection of Main and Market Sts. No such intersection exists in the TOAl Market St. is a north-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

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vest.4 /dath agaid) and eventually east to'ati w sewburypdrt. The TOA can; I 4 '

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only assume thaR an id;ttersict !on has- been md?hbeled, itaking it

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.y a traf'ic a otticer to deteriuine his/hc6arsignment. .

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j Conc equently, Xn un-manned intersection will disrupt any attenpt at'an y  ;

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orderly evacuat.lon.

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l Vol . 6,' pago I-20 (MC;titit "D") faite to show pa.tking , lots 'and drive.-

I ways which wf 11 contribute p avoidance of traffic control measocos. Once again traffic will,be 6ble to criss-cross derigr ed flow causing potential

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j delaysorcurhletestoppage. Unger ' normal cnnaitions dhe intersection is s <

t cor.wjered on6 of the' most accident prone in the coranunhy. No fewer than s

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b1 s 7 EddL2iona?. plice19 f ficers would be regoired.

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, ? Vol. 6, page I-lp (Exhibit "E") is the classic example of Applicants' ,

d itek of researda and inability to provide a planning com. ment that can be d

.4 utiirred in determining evacuation times or actual implementation during ( ]

an accident. The diagram e s submitted is t nntamount tc; fraud. Traffic

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westbound on route 110 from Salisbury (nearly .100* . of W Salisbury evacuees) is to gain access to b% soEth. 'Applicanta' diagram shaws half of that traffic turning lef t (south) throucJh on oper.ing in the divided roadvay and utilizing a normally southbound offramp as an emergency. on-ramp to;I-93 south. Applicants have atteng-ted to chcw this Board what aptee.rs to be a roadway when in fact no such connection exists. The two ramps, shown as or:aun Iaodvay, are actually divided by a rmditin strip ranging in width from about 6 fe n wide to as much as 50 feet wide. Furthermore, the median '

b constructed wi.;;h grenite cu> binge end W topography of the eva pre-ciudos it from being used, even in an emergency, as a pathsay.for vehicles.

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Two other factors either prohibit or s;eriously limit use of this ramp l

l 6s an access to I-95 south. The cut in the routa 110 divider war, designed l .i to make it extremely difficult to turn onto the " wrong" ramp. Evacuating i

tratfic rect drive slightly past the r.unp in order to cut back against he g W l k.

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TOA (E) median. Secondly, if the ramp were used 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 l with virtually non-existant breakdown lanes would cause both delay and i

f massive traffic congestion.

l In summary of this point, the Applicants have attempted to show this I

l Board 3 " entrances" to I-95 south where only 2 really exist. If one-third l

I of evacuating traffic was intended to be using each route, simple math shows us that the two actual evacuation ramps must now increase their capaci;y by 50%. Common sense tells us that the clear time for the area will al so increase by 50%. Traffic demands on this intersection with only 2, not 3, means of highway access will increase the evacuation time estimates to a degree that thoseestimate[havenovalueasaplanning 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., Spurhawk (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. 790 police officers would be required.

Route 110 at Highland St. is also omitted. Two police officers would be required. 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 (route 150)

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. At least 3 police officers would be needed.

TOA (7)

Exhibit "F" shows all intersections in question and those omitted.

It is the opinion of the TOA that 19 additional police officers would be required. Applicants' plan already calls for 16; a true total of 35 will be needed to provide minimal traffic flow support. Since that number exceeds the number of police officers available at any time, even if the TOA were participating, there is still no assurance of plan adequacy with regard to personnel to effect an orderly evacuation.

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 l

intersections throughout ti.e EPZ. Based on the Amesbury experience, potentially 25% of the important intersections may have been omitted; first hand observations and analysis was not properly conducted. Staffing requirements were under-estimated by more than 50%. There has not been a good faith effort on the part of the Applicants to provide a planning tool of value in determining a range of protective measures in the event l- of an accident at Seabrook Station. Without this vital information, the requirements of 10 CFR 50.47 (a) (1) -- ... adequate protective measures can and will_be taken..." (emphasis added) --- can not be fulfilled.

For the ow f Amesbury, ,

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l Amesbury Board of Selectmen -

Amesbury, MA 01913 I, William S. Iord, certify that the TESTIMONY OF TH TOWN OF AMESBURY IN )

EVIDENTIARY HEARINGS ON THE NHRERP, SEPTEMBER 28, 87 s been served on the attached list of parties, by express mail (*) rb 1rst clar mai the loth day of September, 1987. '

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A ill am S. d l

W@MR WoyE M Atomic Safety Lic. Board

• M]gi {rens,Esq. Brentwood Bd. of Selectmen Dept. of the Attorney General RFD Dalton Rd.

Augusta, ME 04333 Brentwood, Nil 03833 s, n ton, DC 20555

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'Gustave Linenberger d Mrs. Sandra Gavutis Gary W. Holmes, Esq.

Aton.ic Safety Lic. Board Board of Selectmen llolmes & Ells US NRC RFD 1 - Box 1154 47 Winnacunnet Rd.

Washington, DC 20555 Kensington, NH 03827 Ilampton, Nil 03842 Dr. Jerry Harbour y Matthew Brock, Esq. Mr. Edward Thomas Atomic Safety Lic. Board Shaines & McEachern FEMA - Region 1 US NRC P.O. Box 360 442 McCormack POCH washington., DC 20555 Portsmouth, NII 03801 Post Office Square Boston, MA 02109

! Atomic Safety & Licensing Senator Gordon Humphrey Michael Santasuosso Board Panel M U.S. Senate Board of Selectmen

! US NRC Washington, DC 20510 So, llampton, Nil 03027 Washington, DC 20555 attn: Tom Burcak Atomic Safety & Licensing Senator Gordon llumphrey Charles P. Graham,. Esq.

Appeal Board .)- 1 Eagle Sq. - Suite 507 100 Main Street US NRC Concord, Nil 03301 Amesbury, MA 01913 Washington, DC 20555 attn. Herb Boynton Docketing & Service Section II. Joseph Flynn Ms Jane Doughty Off. of the Secretary y Off, of General Counsel SAPL US NRC FEMA 5 Market St.

Washington, DC 20555 500 C St. , SW Portsmouth, Eli 03801 Washington, DC 20472 Robert Carrigg Mr. J.P. Nadeau Roberta C. Pevear Board of Selectmen Selectmen's Office 27 Drinkwater Ed.

Town IIall 10 Central Rd. Ilampton Falls, Nil 03844 No. Ilampton, Nil 03862 Rye, NH 03870 Diane Curran, Esq. Carol S. Sneider, Esq. Richard A. Ilampe liarmon & Weiss Off. of the Attorney Gen. Ilampe & McNicholas 2001 S St., NW - Suite 430 1 Ashburton Pl.- 19th F1. 35 Pleasant St.

Washington, DC 20009 Boston, MA 02108 Concord, N11 03301 George Dana Bisbee, Esq. Calvin A. Canney Judith 11. Mizner, Esq.

Of f. of the Attorney General City Manager Silverglate, Gertner et al 25 Capi tol St. 126 Daniel St. 88 Broad St.

Concord, Nil 03301 Portsmouth, Nil 03801 Boston, MA 02110 Sherwin E. Turk, Esq. # Mr. Angie Machiros Beverly llollingworth Off. of the Exec. Legal Dir. Board of Selectmen 209 Winnacunnet Rd.

US NRC Newbury, MA 01951 llampton, Nil 03842 Washington, DC 20555 Robert A. Backus, Esq. Mayor Peter S. Matthews Thomas Dignan.R P.O. Box 516 City Hall Ropes & Gray 116 Inwell St. Newburyport, MA 01950 225 Franklin St.

Manchenter, Nil 03105 -

Boston, MA 02110

' Traffic Control Post No. B-AM-02 ERPA: B TOWN: Amesbury LOCATION: Macy St. & Hillside Ave. (Route 110 & Route 150)

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2. Facilitate southbound movement on Hillside Ave, toward entry ramp onto I-495 westbound.

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Traffic Control Post No. B-AM-04 ERPA: B TOWN: Amesbury 1.UCATION: Macy St. & Main St.

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2. Permit eastbound movement along Route 110 if Macy Street MANPOWCH/l:OllIPMENT approach to I-495 is not congested.

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