ML20247M481
| ML20247M481 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/27/1989 |
| From: | Adler T MASSACHUSETTS, COMMONWEALTH OF, RESOURCE SYSTEMS GROUP |
| To: | |
| References | |
| CON-#289-8377 OL, NUDOCS 8904060064 | |
| Download: ML20247M481 (21) | |
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%$f0 UNITED STATES OF AMERICA
~89_ MAR 30 A11_:02 NUCLEAR. REGULATORY COMMISSION On n : - -
ATOMIC SAFETY AND LICENSING BOARD gociy 7,;
U ta !.1 a Before'.the Administrative Judges:
Ivan'W. Smith,: Chairperson Dr. Richard F.< Cole
'Kenneth A. McCollom
)
l In the Matter of
)
)
PUBLIC SERVICE COMPANY OF'NEW
)
Docket.Nos.
)
50-443-444-OL (Seabrook Station, Units 1 and 2
)
(Off-site EP)
)
March 27, 1989
)
CORRECTED TESTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF JAMES M.
SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS CONCERNING CONTENTION JI-4 (TRAFFIC MANAGEMENT PLAN)
Department of the Attorney General Commonwealth of Massachusetts One Ashburton Place Boston, Massachusetts 02108-1698 (617) 727-2200 ffe 40to 60le4 U f
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L IDENTIFICATION OF WrINESS Q.
What is your name and current occupation?
A.
My name is Thomas J. Adler and I am President of Resource Systems Group of Norwich, Vermont.
Q.
Are your professional qualifications as set forth in the testimony and attachments filed on September 14,1987 in this case still accurate?
A.
Yes, they are.
Q.
Would you please summanze your qualifications as they relate to this testimony.
A.
My educational background includes a B.S. degree in Civil and Environmental Engineering from Cornell University and a M.S. and PhD in Transportation Systems from M.I.T.
For ten years I was a professor in the engineering school at Dartmouth College, teaching courses in transportation planning, transportation engineering, modeling and statistics and conducting research sponsored by the U.S. Department of Transportation and others. For the past two and one-half years, I have served as President and Principal-in-Charge for Transportation Projects at Resource Systems Group in Norwich, Vermont. Our current projects include approximately forty independent transportation modeling/ planning studies and traffic impact assessments. Over the past several years, I have authored reports and provided expert testimony on traffic flow and safety for over fifty regulatory proceedmgs at the federal and state levels.
IL TESTIMONY Q.
Have you reviewed Appendix J of the New Hampshire Yankee Seabrook Planfor Massachusetts Communities ("SPMC")?
A.
Yes, I have. It is the Trafic Management Manual.
Q.
Have you also reviewed SPMC contention JI-4, Traffic Management Plan?
A.
Yes, I have.
Q.
Would you please read that contention and its basis?
A.
"The evacuation plan contained in the SPMC is so poorly designed and so
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. Adler'R-4 Testany 3-y inadequately staffed that, even if State and local officials are assumed to make a best effons response, there is no reasonable assurance that either the permanent residents or the.
transients can or will be evacuated as efficiently as possible, therefore, the SPMC does not provide reasonable assurance that adequate protective measures can and will be taken, and :
it fails to comply with 10 CFR 50.47(a)(1),50.47(b)(10),50.47(c)(1), and NUREG' 0654, Rev.1, Supp.1,Section II.J.
Basis
' A'.
The number of traffic control personnel relied upon by the SPMC is inadequate.
B, Insufficient capacity-enhancing measures and other poorly conceived traffic control strategies are utilized by the SPMC's traffic management plan. The SPMC has not adequately addressed the problems that will occur during an evacuation in 2e event that the Gillis Bridge is closed to traffic in order to facilitate the passage of boats.
C.
He traffic control diagmms contained in the SPMC are not sufficiently clear to allow the SPMC's traffic muagement plan to be implemented."
Q.-
Have you evaluated this contention?
A.
Yes, I structured my evaluation around the five basic requirements for traffic control that are listed in the Manual on Unform Trq$ic ControlDevices (MUTCD). Dat manual is published and updated by the U.S. Department of Transportation, Federal Highway Administration and the standards that it details are required b; federal law to be adopted by each state, including Massachusetts, ne five requirements IL ad i the intmductory section of the MUTCD are that traffic control devices should:
- 1. Fulfill a need.
- 2. Command attention.
- 3. Convey a simple, clear meaning.
- 4. Command respect of road users.
- 5. Give adequate time for proper response. (p. l A-1)
I 1
Adler R-4 Tesumony 4
[
i Five basic considerations are listed as elements to insure that these requirements are met: design,
^ lacement, operetion, maintenance and uniformity. While the MUTCD is primarily used for the p
design and placement of devices to be used under normal highway operating conditions, the basic requirements and considerations are also applicable to the design of an evacuation traffic management plan. I have used these requirements both as yardsticks for evaluating the SPMC and as a way of organizing my comments within this testimony.
~!
Q.
Have other pmfessionals recommended that traffic control devices used in nuclear i
power plant area evacuations be consistent with MUTCD standards?
A.
Yes. The Applicants' consultants, KLD Associates,in Volume 6 of the NHRERP, state in the section on Access Control Posts, "It is essential that these control devices, installed singly or in combination, satisfy the specifications of the Manual on Uniform Traffic Control
- Devices (MUTCD)." (p. 9-16)
Q.
Will you please detail your evaluation of the SPMC against those requirements?
A.
Yes. I will start with the most fundamentalissue: does the traffic management plan, as currently designed, " fulfill a need"? My evaluation of the SPMC evacuation traffic management plan indicates that there is no reasonable assurance that either the permanent residents or the -
transients can or will be evacuated as efficiendy as possible. In fact, my analyses indicate that the Plan as currently designed will increase the amount of time required for evacuation of the Massachusetts population noticeably above the level that might be achieved without traffic guides k
i actively re-directing the traffic flow.
Q.
Would you explain why the SPMC Plan actually slows the Massachusetts evacuation?
A.
Yes. 'Ihe Plan calls for re-routing of traffic at two major intersections. Traffic Control Post (TCP) B-SA-06 in Salisbury is intended to re-direct traffic at the intersection of 3
Lafayette Rd. (Rt.1), Beach Rd. (Rt. l A), Elm St. (Rt.110), Mudnock Rd., Bridge Rd. (Rt.1, I A) and Pleasant St. All of the evacuation traffic from Salisbury Beach (Beach Rd.) and from 4
Lafayette Rd. (Rt.1) southbound is routed west onto Elm St. (Rt. I10). Only " light" traffic from
f.
Adler R-4 Testimony 5
l Mudnock Rd. is routed onto Bridge Rd. (Rt.1) southbound. In effect, the capacity of Bridge Rd.,
which passes south away from Seabrook Station, through Newburyport and Newbury and out of the EPZ is substantially undemtilized by this routing.
i At another key location, TCP B-AM-06 in Amesbury, the two lanes of westbound traffic from Salisbury traveling along Rt.110 are both routed onto I-95. The right lane of traffic uses the normal on-ramp, while traffic in the left lane (except large vehicles) is directed to man 4 U-turn to f
enter the Rt.110 eastbound I-95 on-ramp. In my opinion, -d rs.I.;; ;c :hdci. : S:ipdem T fd.
P.:ydN E" E==, this U-tum maneuver will reduce capacity to 50% of the normal on-ramp capacity. However, an I-495 on-ramp approximately one mile to the east along Rt.110 has surplus capacity which goes unused in the later stages of the evacuation.
Q.
In Appendix J, the TCP diagram for the I-95/Rt.110 intersection states (Description Note 3): " Facilitate U-turn by westbound traffic on Rt.110 at Elm St. for those who elect to travel on southbound I-95 or if westbound Rt.110, west of Elm St. is congested." Will this instmetion insure that the capacity of the I-495 on-ramp is used optimally?
A.
No. Given that I-95 will be, for beach evacuees, the first high-speed, free flowing traffic route that they encounter, most will, in fact, " elect to travel on southbound I-95."
Particularly in the later stages of the evacuation, most of the evacuees will have been trapped in stagnant traffic queues for long periods of time. Behaving rationally, they will certainly choose to enter I-95 over traveling one mile to the east to an I-495 ramp area with uncertain levels of congescon.
Q.
Have you conducted analyses to determine the effect of the TCP operations as I
described in SPMC Volume 67 A.
Yes, I have. 'Ihe attached Figures 1 and 2 display the results of ETE calculations conducted with the I-DYNEV simulation model developed and used by the Applicants' consultant.
Q.
Would you please describe the assumptions made in these I-DYNEV runs?
A.
The runs are based on the files used as inputs to the most recent " base" ETE runs submitted by the Applicants in the New Hampshire Plan hearings. These inputs were modified to
O Adler JI-4 Testimony 6
reflect the conditions written into the Joint Stipulation Regarding ETE Issues and were funher modified, for a subset of the runs, to reflect non-staffing of TCPs D-HA-02 (I-95/Rt. 51 in l
l Hampton -- analyzed only for comparative purposes), B-S A-06 (Rt.1/Rt. l A/Rt. I10 in Salisbury) and B AM-06 (I-95/Rt. I10 in Amesbury). The only major item in the ETE Stipulation not reflected in the runs is the inclusion of retuming commuters, which will increase the evacuation times above those shown here.
Q.
Would you describe the results as depicted in Figures 1 and 27 A.
Both figures show the number of vehicles and amount of time required for evacuation of a specific population to a cenain location under conditions with and without staffing of the three control posts listed earlier. The evacuation scenario is the same (summer weekend) as that used as the full evacuation planning basis in the Applicants' ETE analyses. Figure I shows i
the numbers of vehicles remaining within a three mile radius of Seabrook Station (in both New Hampshire andMassachusetts) at the different points in the evacuation timeline, for the two 1[d.
staffing conditions. Because the evacuation of the three-mile ring is constrained by conditions at the I-95/Rt. 51 interchange in Hampton, New Hampshire and because the New Hampshire Plan includes substantial capacity enhancement at that location, the evacuation time for this two-state population is decreased by over one hour by this staffing.
Figure 2 shows the evacuation progress ofjust the Salisbury Beach population, with and without staffing of the Massachusetts control posts. As this figure illustrates, the evacuation is increased two hours by the imposition of the SPMC's TCPs. Thus, as stated in Basis B of i
Contention JI-4, the SPMC does not provide assurance that "either the permanent residents or the transients can or will be evacuated as efficiently as possible."
Q.
Are there other elements of the SPMC that similarly fail to " fulfill a need" and/or l
work against an efficient evacuation?
A.
Yes. The Access Control Posts (ACPs), particularly those along I-95 (GT-2) and I-495 (HA-4) are poorly designed and are more likely to disrupt rather than expedite the evacuation.
t Adiern 4 Tesumony 7
Q.
Would you explain in what ways their design is inadequate?
A.
There are two problems that must be addressed by the design: the problem of estat:lishing the ACPs at the start of the evacuation and the problem of maintaining and operating them throughout the evacuation. Establishing the ACPs along I-95 and I-495 will require,in the former case, intercepting four lanes of traffic on an 8-lane highway and, in the latter case, three lanes of traffic. Both of these highways are very heavily trafficked facilities with speed limits of 55 mph. A typical police procedure for stopping traffic on facilities like this under heavy traffic conditions involves the use of two or more cruisers side-by-side with lights flashing acting as
" pacer" cars initially, then slowing and finally stopping in the highway travellanes. Warning flares are placed well upstmam of the diversion point, and additional flares att placed less than twenty feet apan at a shallow angle across the highway, leading to the diversion area. These procedures for attempting to divert high speed traffic still involve a potential risk to both the officers and to the motorists; however, the risk i; substantially less than that incurred using a less rigorous procedure.
While the diagrams in Appendix J indicate that both barricades and traffic cones will be used at the major ACPs, in fact, the Applicants now admit that only traffic cones will be supplied for ACPs. Sgg Applicants' response to Interrogatory No.11 of the Mass AG's First Set of Interrogatories to Applicants. The notion that two civilian traffic guides, equipped only with short (28 inch) orange traffic cones, will be able to re-direct the flow of four 55 mph traffic streams distributed across a fifty foot width of asphalt travellanes (at ACP GT-2) is one which assumes substantial safety risk at best and most likely is simply unworkable. The problems would be compounded if the ACP is to be established outside of daylight hours or during inclement weather conditions. Under any conditions, the results of this type ofinadequate staffing and planning mnge from serious accidents to a simple inability to carry out the ACP portion of the SPMC at these most criticallocations.
Assuming the ACPs could be established, the problems of operating and maintaining them will be equally daunting. No provision has been made for guides to take breaks within their 12-
Adler R-4 Testirnony 8
hour shifts to eat, rest or accommodate other bodily functions. Given that there is only one traffic guide stationed at each of the diversion points along the Interstates (I-95 and I-495), even a momentary absence of one of these critical guides could cause disruption of the contml function; a sustained absence would almost certainly lead to breakdown of the function.
The " Access Control Point Traffic Guide Procedure" included in the SPMC's Traffic Management Manual requires ACP guides to "Do the following":
- a. Discourage persons from passing the peripheral ACP g3 ssp.1 for:
- Federal, State and local emergency response personnel;
- emergency irsponse vehicles with specific missions and destinations (i.e., buses, ambulances, tow trucks);
- employees of the utilities responding to the plant, who have appropriate identification; and
- conunuters returning to EPZ to gather household members for evacuation.
- b. Advise persons that they may be subject to radiation exposure if they pmceed bey ond the ACP. Also advise persons to listen to the local Emergency Broadcast System station for specific information on the emergency.
- c. Time permitting, expedite the flow of traffic leaving the controlled area, but not at the expense of access control functions. Do not allow lines to form at the ACPs entering the EPZ. (emphasis added)(p. J-5)
This procedure, in practice, will involve contradictions. At the Interstate ACPs, the initial traffic volumes will be too high for a single individual determine whether a vehicle should be allowed or T
" discouraged" access without allowing " lines to form." For example, at the I-95 ACP in
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Georgetown, almost one vehicle per second will arrive at the northbound ACP during normal rush hour conditions. Over the course of the evacuation a total of over 5,000 vehicles will be genern ed at this point by returning commuters. Even assuming that these are evenly spread over the first four hours of the evacuation, the guide will have to process one such vehicle every three seconds.
Given that there will have to be some form of verbal communication with each such vehicle to determine " eligibility" according to Pmcedure a., the screening task will be impossible to perform without lines forming at the ACP. Yet, if no screening is performed, the basic purpose of the ACP is defeated and the design does not fulfill the stated purpose. If, on the other hand, screening is rigomusly applied, the efficiency of the evacuation will suffer significantly for those delayed in the
Adlern-4 Tesumony 9
queues.
I An additional problem at the ACPs is that there will be no signs indicating the nature of the emergency or of the diversion routing, so the guides will almost certainly be called upon to answer
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questions regarding these matters. This will add to the competing demands already faced by traffic guides.
Q.
' Moving on to the second MUTCD criterion, do the controls specified in the SPMC traffic management plan, " command attention"?
A.
In several critical areas, no. Of particular concem is the exclusive use of cones rather than barricades at key ACPs and TCPs. KLD Associates,in the NHRERP recommended '
the use of Type III barricades for road closures, consistent with the MUTCD. NHRERP, Volume 6, p. 9-16. They further recommended mounting AREA CLOSED signs to the barricades and lights on every barricade and every third cone at all ACPs and TCPs. Fmally, they recommended that "[altrow panels and advance waming lights should be used on approaches to all ACPs and TCPs located on Expressways so as to inform drivers that traffic will be channelized onto an exit ramp." NHRERP, Vol. 6, p. 9-16.
Q.
Do you believe that barricades for road closures, signs, lights and advance warning devices, as recommended by the Applicants' consultants in the NHRERP, are necessary to
" command attention" at the ACPs and TCPs in the SPMC7 A.
Yes. Type III barricades are 5 feet high,4 feet wide and have three reflectorized faces, so that they are clearly visible from a reasonable distance day and night. By contrast, the cones substituted in the SPMC are only 28" high, less than a foot wide and are not reflectorized.
The complete absence of supplementary lighting and of advance waming signs on expressway approaches to ACPs and TCPs are significant deficiencies. In total, the SPMC deviates substantially from the standards for commanding attention specified in the MUTCD.
Q.
Do the traffic controls specified in the SPMC " convey a simple, clear meaning"?
A.
No. There are numerous ambiguities both in instructions to the traffic guides and in cues that will be received by motorists that will ultimately result in confusion and inefficiency in the 4
t 73 Adler H.4 Tesumony 10 evacuation.
Q.
Would you give some examples of these problems?
A.
. Yes. One example given earlier is the basic contradiction between access control screening and avoiding queue formation at ACPs. Other specific' examples can be found in many of the ACPs and TCPs specified in the SPMC. At several locations, traffic guides will be directing traffic below operating traffic signals (red, yellow, green). Should the traffic guides ignore the signal indications and wave cars through on red signals? The SPMC commands traffic guides as follows: "Do not tamper with traffic signals" (Appendix J, p. J-2), but it does not indicate whether they may direct traffic independently of the signalindications. If the guides elect to direct traffic contrary to the signal indications, the motorists will, in effect, be asked to break the law in deference to an un-uniformed civihan.
Several further examples of ambiguous instructions to guides and cues to motorists can be found in the SPMC design for the major intersection of Rts.1/1 A/110 in Salisbury (TCP B-SA-06). In that diagram, as in most others, arrows are used to indicate traffic flow to be facilitated, and arrows with bars to indicate traffic to be discouraged. However, in this diagram cones are used to block certain movements, but no arrows at all are shown to indicate how this traffic is to be treated. For example, there is no arrow indicating the control intentions for westbound Rt. I A traffic tuming left opposite the post office onto Mudnock Rd. His traffic stream would be relatively benign, if allowed. There is, Lowever, also no arrow on the TCP diagram indicating how traffic exiting Mudnock Rd. across School St. towani the post office should be treated. This movement would disrupt a major evacuation flow, if allowed. Finally, there is a curved, dashed arrow on Rt.110 for eastbound traffic, accompanied by a set of barricades with the legend, " Block eut Traffic Flow." He intention of the TCP diagram appears to be to totally exclude wombound Rt. 1 110 from entering the intersection, and this makes sense in the context of the intended diversion of heavy westbound evacuating traffic across the double yellow lines into the eastbound lane at this location. But, does the instruction, " Block Traffic Flow," apply to all vehicles, and how is this instmetion to be interpreted in the context of the general traffic guide instruction, "DO NOT
Y J
AdlerJI-4 Tesumony
'11 POSITION CONES OR BARRICADES TO COMPLETELY BLOCK PASSAGE THROUGH ANY INTERSECITON"? Appendix J, p. J-2.
Evacuating motonsts will be faced with additional ambiguities at this major Salisbury intersection. Approximately one-half of the westbound trame will be directed by a traffic guide to -
cross the double yellow line through the intersection. Have they then been given license, west of the intersection, to cross the double yellow line again, given the " light" oncoming traffic streams?
If they do cross again, they will seriously disrupt retuming commuters and emergency vehicles :
attempting to use this route.
Similar ambiguities to those in the TCP design for the Salisbury Rts.1/l A/l10 intersection are found throughout the SPMC. In short, the Plan, as presently designed does not " convey a simple, clear meaning," but is fraught with contradictions and ambiguities.
Q.
Will the traffic control plan " command respect of road users"?
A.
In several key areas, no. The use of un-uniformed traffic guides and of insubstantial traffic cones as control devices in particular simply are elements not likely to -
" command respect." I agree with Salisbury Police Chief Frank Beavers (see his testimony) that the drivers will not petreive un-uniformed traffic guides as having any authority, and the drivers will' simply not be deterred by traffic cones alone.
Q.
Finally with respect to the MUTCD requirements, do the SPMC control devices "give adequate time for proper response"?
A.
Particularly on the high-speed roadways, no. The absence of advanced signage, the absence of lighting for nighttime or inclement weather conditions, the use of small cones without reflectors and the placement of cones along very short taper sections are contrary to MUTCD guidelines.
Q.
Do you have an overall opinion with respect to the adequacy of the SPMC's Traffic l
Management Plan and specifically with respect to the assertions in Contention JI-47 A.
My opinion is that there is no reasonable assurance that the residents or transients in the Massachusetts portion of the EPZ will be evauated as efficiently as possible, that the Plan is i
t..
^
Adler Ji-4 Tesumony -
12 poorly designed and inadequately staffed and it specifically does not employ traffic control strategies that are in confonnance with best professional practice, as embodied in the Manual on Uniform Trq0tc ControlDevices.
Q.
Were you asked to perform additional runs with I DYNEV to evaluate ETEs under other evacuation scenarios?
A.
Yes, and I have provided the results of those runs to Dr. Robert Goble to assist in I
the preparation of his tesnmony.
Q.
Would you please describe those runs?
A.
The additional runs are all similar to those described earlier as Figures 1 and 2 in that they use the JI-1/JI-2 stipulations as the base for analysis, and simply represent different evacuation scenarios. Figure 3 shows the vehicles mmaining within 3 miles for a beach evacuation with 50% resident evacuation, and Figure 4 shows the results from the same scenario, for the Salisbury Beach area. Both Figures 3 and 4 show results for staffed and unstaffed TCPs. Figures 5 and 6 show the results of a 50% beach evacuation with 50% resident evacuation.
Q.
Does this conclude your testimony?
A.
Yes, it does.
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s, UNITED STATES OF AMERICA
'89 ti/W 30 Al' :01 NUCLEAR REGULATORY COMMISSION
.;i t% 'w :,,
)
In the Matter'of
)
Docket Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
(Off-Site EP)
OF NEW HAMPSHIRE, ET AL.
)
)
(Seabrook Station, Units 1 and 2)
)
March 27, 1989
)
CERTIFICATE OF SERVICE I, Allan.R. Fierce, hereby certify that on March 27, 1989, I made service of the within MASSACHUSETTS ATTORNEY GENERAL'S RESPONSE ON THE ISSUE OF RETURNING COMMUTERS AND THEIR IMPACT ON EVACUATION TIME ESTIMATES and the CORRECTED TESTIMONY OF DR.
THOMAS J.
ADLER ON BEHALF OF JAMES M.
SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS CONCERNING CONTENTION JI-4 (TRAFFIC MANAGEMENT), by first class mail to:
Ivan W.
Smith, Chairman Kenneth A. McCollom Atomic Safety & Licensing Board 1107 W.
Knapp St.
U.S.
Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Richard F. Cole Docketing and Service Atomic Safety & Licensing Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Building Washington, DC 20555 4350 East West Highway l
l Bethesda, MD 20814 l
l l
l u_--.-_--------
Robert R.
Pierce, Esq.
Thomas G. Dignan, Jr.,
Esq.
Atomic Safety.& Licensing Board Katherine Selleck, Esq.
U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814 H. Joseph Flynn, Esq.
Sherwin E.
Turk, Esq.
-Assistant ~ General Counsel U.S. Nuclear Regulatory Office of General Counsel Commission Federal Emergency Management Office of the General Counsel Agency 15th Floor 500 C Street, S.W.
11555 Rockville Pike Washington, DC 20472 Rockville, MD 20852 Atomic Safety & Licensing Robert A.
Backus, Esq.
Appeal Board Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Board Jane Doughty U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 Charles P. Graham, Esq.
Barbara St. Andre, Esq.
Murphy & Graham Kopelman & Paige, P.C.
33 Low Street 77 Franklin Street Newburyport, MA 01950 Boston, MA 02110
. Judith H.
Mizner, Esq.
R. Scott Hill-Whilton, Esq.
79 State Street Lagoulis, Hill-Whilton 2nd Floor
& Rotondi Newburyport, MA 01950 79 State Street Newburyport, MA 01950 Dianne Curran, Esq.
Ashod N.
Amirian, Esq.
Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W.
Bradford, MA 01835 Washington, DC 20008 Senator Gordon J.
Humphrey Senator Gordon J.
Humphrey U.S.
Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack)
(Attn: Herb Boynton) _ _ - _ - _ _
p.
hr George. Dana Bisbee,.Esq..
.Phillip Ahrens, Esq.
Assistant-Attorney ~ General:
Assistant Attorney General:
Office of the. Attorney General' Department of the. Attorney
- 25 Capitol' Street General Concord,- NH '03301 Augusta, ME 04333 Sandra Gavutis, Chairperson
-Calvin A. Canney Board of Selectmen City. Manager RFD 1, Box 11154.
City Hall Rte.-107 126 Daniel Street Kensington, NH 03827-'
Portsmouth,'NH 03801 Gary W. Holmes,.Esq.
Richard A.
Hampe, Esq.
Holmes & Ellis Hampe & McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton,,NH 03842.
Concord, NH 03301 Robert Carrigg, Chairman J.P.
Nadeau Board of' Selectmen Selectmen's Office Town Office' 10 Central Road
' Atlantic Avenue Rye, NH 03870 North Hampton, NH 03862
. William S. Lord.
James H. Carpenter, Alternate Board of Selectmen Technical Member, Town Hall - Friend Street Atomic Safety & Licensing Amesbury,.MA 01913 Board Panel U.S.
Nuclear Regulatory Commission Washington, DC 20555 JAMES M.
SHANNON ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS Allan R.
Fierce Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED:
March 27, 1989 _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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