ML20246F045
| ML20246F045 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/22/1989 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#389-9092 OL, NUDOCS 8908300137 | |
| Download: ML20246F045 (6) | |
Text
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tm August 22, 1,9 9 gus 25 P2:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,g,.
.d t,OD before the
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ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY
)
Docket Nos. 50-443-OL OF NEW HAMPSHIRE, 31 al.
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50-444-OL
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(Seabrook Station, Units 1
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(Offsite Emergency and 2)
)
Planning Issues)
)
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APPLICANTS' MOTION TO CIARIFY AND CORRECT OFFICIAL RECORD Now come the Applicants and say that it has recently come to their attention that Applicants' Rebuttal Testimony No. 9 (Traffic Management Plans) as bound into the record, ff. Tr. 17333 (Transcript of March 29, 1989) did not include Page 55 of the testimony, as filed and offered.
A copy of the missing Page 55 is attached hereto and marked "A."
Wherefore, the Applicants move the Board to clarify and correct the record by entering an order stating that the attached Page 55 of Applicants' Rebuttal Testimony No. 9 is admitted into evidence as was intended and may be cited and DOfkfffy22 MP SSINSERT.$8 9
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referred to in the same manner as other evidence actually bound into the transcript.
Respectfully submitted, af7 /
/, n s-Thomas G.
Di'gnin, Jr.
George H. Lewald Jeffrey P. Trout Jay Bradford Smith Geoffrey C.
Cook William L.
Parker Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-7000 i
counsel for Applicants 1
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per hour for the first two hours would attempt to cross this bridge.
Even assuming that the bridge was open to permit passage of boat traffic 50 minutes of each hour, evacuation traffic could still use it for 10 minutes each hour.
The available vehicular capacity is then 240 vehicles per hour, (1/6 hour x 1,440 vph), far in excess of the demand of 156 vph.
Thus, even under this highly unlikely scenario, these evacuees would not experience delay that would extend the ETE:
any queue that developed as a result of the bridge opening would quickly discharge when it closed.
If the Gillis Bridge remained open due to mechanical trouble or due to some other unforeseen event during an evacuation, such that it substantially delayed evacuation traffic, the emergency response would be similar to that applied to other traffic impediments.
The situation (bridge open) and resulting traffic backup would be reported to the Staging Area by the Traffic Guide at TCP B-SA-08 which is located on Route 1 just north of the bridge.
(The TCP diagram for B-SA-08 is Attachment G hereto.)
As with any traffic impediment, this situation would be evaluated at the Staging Area and EOC.
A potential reroute of evacuation traffic for this situation would have the Traffic Guide at TCP B-SA-08 direct all traffic northbound on Route 1 away from the bridge.
This traffic would proceed north to School Street where the Traffic Guide at TCP B-SA-06 would direct it Fl"
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CERTIFICATE OF SERVICE 1
y ;- a 5 I, Thomas G. Dignan, one of the attorneys forithe }ppl' cants i
herein, hereby certify that on August 22, 1989, I made serv $ce of i
.the within document by depositing copies thereof with Federal l
Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Adjudicatory File Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Board Panel Docket (2 copies) l U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20614 Bethesda, MD 20814 Administrative Judge Richard F. Cole Robert R.
Pierce, Esquire Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East West Towers Building U.S. Nuclear Regulatory 4350 East West Highway Commission Bethesda, MD 20814 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A.
Sherwin E. Turk, Esquire McCollom Office of General Counsel 1107 West Knapp Street U.S. Nuclear Regulatory Stillwater, OK 74075 Commission One White Flint North, 15th Fl.
11555 Rockville Pike Rockville, MD 20852 John P. Arnold, Esquiro Diane Curran, Esquire Attorney General Andrea C.
Ferster, Esquire George Dana Bisbee, Esquire Harmon, Curran & Tousley Assistant Attorney General Suite 430 Office of the Attorney General 2001 S Street, N.W.
- 25 Capitol Street Washington, DC 20009 Concord, NH 03301-6397
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board 116 Lowell Street U.S. Nuclear Regulatory P. O.
Box 516 Commission Manchester, NH 03105
-Washington, DC 20555
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o Philip Ahrens, Esquire Assistant Attorney General.
Mr.
J..P.
Nadeau Selectmen's Office Department of the Attorney 10 Central Road General Augusta, ME 04333 _
Rye, NH 03870 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Department of the Attorney P.O.
Box 360 General Portsmouth, NH 03801
'One Ashburton Place, 19th Fl.
Boston, MA -02108 Mrs-. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH' 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott-Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &
. Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Barbara J.
Saint Andre, Esquire One Eagle Squara, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:- Herb Boynton)
Boston, MA 02110 Mr. Thomas F. Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Judith H. Mizner, Esquire l
Office of General Counsel 79 State Street, 2nd Floor Federal Emergency Management Newburyport, MA 01950 l
Agency 500-C Street, S.W.
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l Washington, DC -20472 i
l Gary W. Holmes, Esquire Richard A. Hampe, Esquire f
Holmes & Ells Hampe and McNicholas i
47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301 l L
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Mr.' Richard R. Donovan Federal, Emergency Management.
Agency
. Federal. Regional. Center 1301228th Street, S.W.
Bothell,._ Washington-98021-9796 AshodLN.'Amirian, Esquire
- 145' South Main Street P.O.= Box.38 Bradford, MA 01835-J
.pi Thoma1 K nan, Jr.
!(*= Ordinary U.S.IFirst Class' Mail) l :.
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