ML20247M708
| ML20247M708 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/19/1989 |
| From: | Hillwhilton R LAGOULIS, HILL-WHILTON & ROTONDI (FORMERLY LAGOULIS, NEWBURY, MA |
| To: | |
| References | |
| CON-#289-8379 OL-1, NUDOCS 8904060106 | |
| Download: ML20247M708 (28) | |
Text
{{#Wiki_filter:7....D '/ f ' eel.A4Q @R.WMSM . UNITED STATES OF AMERICA DOCKETED 'USNRC ' NUCLEAR REGULATORY COMMISSION '89 MAR 30 ' A10:58 before the ATOMIC SAFETY AND. LICENSING BOARD SFD C.. ', e uGCNTim : 13, February'1 N 1989 j ) ~I In the' Matter of:- ) ) PUBLIC SERVICE COfiPANY OF- ) Docket Nos. 5 0-4 4 3-O L' NEU. HAMPSHIRE, et al. ) 50-444-OL ) Offsite Emergency. (Seabrook Station, Units 1.and 2 ) Planning Issues ) TOWN OF'NEWBURY'S AMENDED DIRECT TESTIMONY Panel Members: Angelo 11achiros, Chairman Board of Selectmen Roger Merry, Chief of Police Introduction This testimony addresses the following contentions: JI 4 (Traffic Management Plan) JI 7 (Transit Dependent - Dus Routes) JI 63 (Local Government Equipment) Summary of Testimony JI 4 The traffic management plan fails to provide a reasonable assurance that ovacuating traffic will be able to leave the Town j l of Newbury (TON) in a timely and effective manner. The traffic t l control posts (TCP) identified in the SPMC are inadequately staffed'and -are. equipped. insufficiently. Other critical areas 1 L requiring traffic direction and control are uncontrolled. Maiot' l routes are too narrow to provide for simultaneous ingress and 1 1 t90 406
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f.. 4 a inbound' traffic will be blocked by:outboun'd vehicles. E . egress; .The TCP's will.not be able'to be manned after evacuation 1 commences -- control'of the evacuation, once' lost, cannot be obtained. Vehicle occupants will abandon'their vehicles.and attempt;to evacuate on foot. Seasonal impediments periodically impede evacuation. ~JI'7 The TON-bus routes' fail to provide a reasonable assurance that transit' dependent. persons will be evacuated in a timely ~ . fashion." The routes proposed utilize' roads which are. inadequate and which will be unavailable due to evacuating traffic...The routes will be driven an insufficient number of tines.. The routes' terminus, i.e. the transfer station is inadequate-for ito intended purpose. The. routes are periodically l unavailable due to-seasonal' impediments. JI'63 TON lacks sufficient personnel and resources to implement the planlinLthe event that ORO is unable to do so. EXPERIENCE OF PANEL MEMBERS .l.- Angelo Machiros has been a Newbury selectman for nine He has lived at the intersection of Plum Island Turnpike ' years.' and Old Point Road on Plum Island for appror.imately fifteen yearn. As a selectnen, he knows the number of emergency personnel and the types of emergency equipment TON has. As a long-term rceident of Plum Island at its most congested ' intersection, he'has for years observed traffic patterna of vehicles leaving'the' island under all types of weather 2
b 1-h cond 1 t ions.-.lle knows from his perconal expsrience and-observations how various types of. weather conditions-affect one's-E ability to travel on all roads i'n-TON, and particularly the one ~ . road leading to Plum Island. 2. Roger Merry has'been the chief of'the Newbury Police Department since November, 1986. Ile became a. f ull-time police officer in 1976..Before that, he was an auxiliary officer for one. year'and a reserve officer for three years. :He graduated from the Massachusetts Police Academy in 1976. Ile received a degree in criminal justiceiin 1986. :He is familiar with the road conditions-in. TON'under all types of weather, the types of weather patterns.which arise on Plum. Island and throughout TON, the effect adverse weather has on traffic and road passability, and the conduct of' drivers under normal and adverse' weather conditions. JI 4 - TRAFFIC MANAGEMENT PLAN 1. Plum Island - Plum Island Turnpike is the sole road leading to the island. It is a typical two lane road running east and west, one lane leading to the island and the other'from the island. It is located in a floodplain, crosses approxitaately' two miles of tidal marsh and crosses a bridge about one-quarter mile in length which spans the Plum T.sland River. Plum Island Turnpike and portions of other roads on the island are shown in as can be seen, portions of the roads the attached photographs become impassable at timos of'high water levels and ice cakes and other. debris float orito then during high tides and reitain af ter 1 the tide recedes. A nap of TON is also attoched. 3
The panel members have seen the traffic leaving the island under a variety of weather conditions during all times of the year. During the summer, when the beaches are crowded, traffic p jams frequently occur during afternoon weekends'when people visiting the beaches on the island leave. It-frequently takes hours before traffic is flowing normally.once these traffic jans begin to occur. Plum Island Turnpike typically contains a very j congested line of extremely slow moving cars during normal summer, late-afternoon conditions. The panel members have also i seen what happens when, for example, a sudden rain storm causes many beach visitors to leave at approximately the same time -- at these times, cars are backed up all over the. island. Bottleneck traffic jams occur at the following intersections: Plum Island Turnpike and Old Point Road, Plum Island Boulevard, Sunset Drive j and Northern Boulevard. At these intersections, vehicles attenpt to merge into the one westbound lane of Plum Island Turnpike. During normal conditions, this traffic becomes very snarled; during sudden rain storms, the traffic becomes extremely jammed and gridlock results at times. During weekends, two patrol officers are normally on duty in TON during the day. During summer weekends, one additional officer is on duty on the island. TON does not even attenpt to control traffic leaving the island since to do so would require six to ten officers under normal summer conditions and TON does l l not have that number on duty. In paragraph two of the testimony on this contention TOU has described what, in the panel's 1 opinion, would have to be provided. I 4 i
'The' panel:has. reviewed the SPMC traffic' management plan for. Plum Island. That~ plan' calls for one traffic guide to control' traffic attempting toLleave the. island.. If an emergency occ'urs at Seabrook Station, which requires evacuation of the island,.it-is the opinion;of the panel-that the traffic control provided in the SPMC would do-nothing more to facilitate evacuation of the island than would an uncontrolled evacuation. That'is, i I evacuation will occur-no more quickly or orderly under the SPMC than.would happen without that' control. In forming that opinion, i the panel ins' relied on its observations. and experience, and has I taken into account the fact that everyone on the island, .o including those who live.there, would be 1 caving at~once instead' of simply the,beachgoers. In addition, the panel has taken.into consideration ~the fact that tne evacuees would be under stress .due to their fear of radiation from the plant. In addition, the-panel has considered that the one traffic control post called for would probably not even be manned until after the evacuation started. Angelo Machiros lives at the intersection of Plum Island Boulevard, Northern Boulevard and Sunset Drive, where all traffic leaving the island merges into the one westbound lane. On summer weekend afternoons, he watches the traffic trying to leave the island. The traffic barely moves at all under normal conditions ~ when people are leaving at various times. Uc has often concluded while watching that traffic that, under an emergency evacuation, i the traffic would become hopelessly jammed. He worked with the Applicant in the past in attempting to arrive at a workable plan 5
ifor evacuation unti1 Lit became apparent that evacuating the island quickly enough to provide:some level of protection'for;the -people there'is impossible. For these reasons, the opinion of the panel is that evacuees would be unable to leave the island. Traffic attempting to merge fonto Plum Island Turnpike from Northern Boulevard, Old Point Road. and Sunset Drive woul'd become~ jammed and would move very-slowly, and probably not at all. Even assuming.that the' drivers.of those vehicles would not panic, frustration at not.being able'to-leave using the'one westbound l lane would naturally result in dr'ivers using-both lanes of_ Plum Island Turnpike in order to leave.- This would begin.quickly, before the TCP were manned. Control of the evacuation.would accordingly be lost'before the TCP could be placed into operation and it would be impossible to gain control once it-is lost. 2. Traffic Control Posts --The panel has formed the opinion,. based on its observations of traffic in TON and experience regarding traffic control, that the'following are errors and ambiguities which currently exist in the SPt1C traffic-control diagrams: A. Traffic Control Post No. E-NP-01: The diagram erroneously concludes that one traffic guide will be abl'e to control traffic attempting egress from Plum Island in.an orderly manner and simultaneously permit ingress to Plum Island. Even assuming diligent effort by that guide, one individual in not sufficient to maintain traffic flow at this major intersection of Plum 6 I
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~ i t f4} y Islarid. The diagram incorrectly assumes that traffic converging;at'the-intersection.will be utilizing normal travel' lanes only.- Theidiagram" fails to' acknowledge that'all traffic attempting;to leave Plum Island will . converge at'this intersection'or the controls which will accordingly be necessary. 'In order'to maintain control' at the, intersection and permit travel'to the island,.an: i emergency vehicle'with' flashing lights s'hould be placed. in the middle of the intersection and at least two traffic' guides'should be present at the intersection, one directing cars entering Plum Island Turnpike from Sunset' Drive,and the.other directing traffic ~on the two remaining streets shown. In ' addit' ion, each guide should be wearing highly reflective clothing and be equipped with high-power . flashlights. In addition, barricades should be erected-to reduce the possibility of outflowing traffic traveling on inbound lanes. O B. Traffic Control Post No. E-NP-07: This TCP is located within the City of Newburyport but will handle all traffic exiting Plum Island. One traffic guide will not, despite best efforts, be able to merge traffic from Plum Island and Hater Street into one southbound lane of Ocean Avenue /Rolfe's Lane. The TCP shows one traffic ~ guide'who appears to direct traffic on Plum Island Turnpike. At least one additional guide will be required.- The diagram shows that ingress to Plum Island 7
h N[,5 4.[ea. ,.i + ?[3em i.EE ~ 7TJ~ ~ ~ E' ~ m I 'willfbe blocked with~ cones. On January '2',: 1907, ? approximately. cine mil'e. of ' Plum Isiand. Turnpike between - this intersection'and Plum Island was under 1 approximately two feet.of flowing tide waters; during l q-that time'a minimum of two officers lwere employed [to-coritrol people attempting: to gain access to the island a'nd were barely able to do so.- Traffic cones Lwould be-ineffective to discourage travel. The same-resources identified with~ regard to the preceding y traffic control post should be employed'at this intersection. Barricades should be employed instead of- 'If cones'are to be' employed,'their number should cones. be doubled for this and every other' intersection where-they are used. C. Traffic Control' Post No. E-NB-02: Two traffic guides and an emergency vehicle with flashing lights should be located at the intersection of Rolfe's Lane and Route 1A. The guides should be equipped as noted above. Traffic cones are located on Route 1A in a canner which to will prohibit access of buses and returning commuters Plum Island. Traffic from Rolfe's Lane and northbound traffic on Route 1A crosses at the intersection, leading 4 1 to increased congestion. The diagram neither depicts nor takes into account other streets located within the in the diagram (e.g. Morgan Avenue which area shown intersects Route 1A between town hall as shown and Rolfe's Lane). No traffic control exists for the police 8
i :- h station / town hall, a site where significant activity would be expected. Barricades should be used where cones are shown or, at a minimum, cones should be doubled. A business parking lot permits travel from l Route lA to Parker Street but is not shown on the diagram nor are controls'present to prevent vehicles to enter Parker Street from Route 1A through that parking lot. One traffic guide, equipped as noted above, would be necessary to prevent travel from Route lA to Parker Street. A second traffic guide,, equipped as noted above, should be placed where the traffic guide is depicted near town hall. Similarly equipped guides should be placed at the intersection of Green and Hanover Streets and at the intersection of Morgan Avenue and Route 1. Location of cones discouraging westerly travel on Parker Street conflicts with Newbury Bus Route 4. D. Traffic Control Post No. E-NB-03: Blocking of travel across Route 1 from Hanover Street to Middle Road conflicts with Newbury Bus Routes 1 and 2. The number of cones should be doubled but even then would probably not stop travel; instead, barricades should be used. At least two emergency vehicles with flashing lights and four traffic guides, equipped as noted above, should be I located at this intersection. To maintain traffic flow 1 at this intersection, northbound travel on Route 1 should be eliminated and Hanover Street should be used only for outbound travel. 9
4 E. ' Traffic Control Post No. E-NP-01: A CON TCP, it conflicts with Newbury Bus Route 4 in that evacuation ~ buses on that route are supposed to proceed cn. Parker Street through its intersection with State Street and Route 1 but traffic in that manner is not permitted as depicted.- Moreover, crossing Route 1 on Parker Street is impossible due to the location of immovable barricades which prohibit entering Route 1 from Parker Street and. additional barricades which separate the northbound and southbound Route 1 lanes. 3. Additional areas requiring traffic control - The panel has formed the opinion, based on its experience and knowledge of TON and' traffic within TON, that maintaining traffic flow and two-way traffic will be impossible unless all controls are in place prior to the commencement of an evacuation. It is the opinion of the panel that the following areas require additional traffic control personnel: A. Old Point, Road, Northern Boulevard, Plun Island Turnpike, Rolfe's Lane, llanover Street, Route lA and Route 1: In order to maintain two-way traffic on these roads, traffic guides wearing highly visible clothing and equipped with flashlights should be located along the entire length of each road at a distance close enough to one another so that when a driver passes one guide another guide will be readily visible to the driver. B. Central Street and Route lA: One traffic guide 10 a-_-_-_-
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residential traffic and-traffic from the Governor Duuner ' Academy and Triton Regional High School will attempt'to n gain access to Route 1 at this location. C. . Triton' Regional-High School: A minimum of two traffic- - guides, equipped:as,noted above, should be-located at'this site, one at'the front entrance and one at the. rear entrance. D. . Route 1A Bridge Spanning the Parker Rivers iThree traffic guides,' equipped as noted above, and two-emergency.-vehicles with flashing lights should be located at the bridge, one vehicle and traffic guide at'the southbound entrance to the bridge, one traffic guide in the middle of the bridge and one traffic guide-and emergency vehicle at the southbound exit from the bridge. E. Highfield Road and Scotland Road: One traffic guide, equipped as noted above, is needed to permit evacuation buses to gain access to Scotland Road from the Highfield Road transfer point. F. Scotland Road: Traffic guides, equipped as noted above, should be located along Scotland Road close enough to one another so that when a driver passes one traffic guide another traffic guide will be immediately visible to the driver. Without such controls, two-way l traffic will not be possible. G. Hanover Street at Newbury Elementary School: At least t 1 11
.a,, ._z...._.... two traffic guides, equipped.as noted above, and one l emergency. vehicle with flashing lights, will be needed to permit ingress to the school and. evacuation therefrom. 11. Route 95 and Central Street: At least three traffic guides, equipped as noted above, should be present. One traffic guide and an emergency vehicle with flashing lights should be located at the entrance ramp from Route 95 to Central Street, directing all Route 95 northbound traffic to Central Street. A second traffic guide should be at the top of the ramp directing traffic from Interstate 95 to cross Route 95. A third traffic guide should direct such traffic to the southbound Route 95 ramp. This turnaround should not be attempted at Route 95 and Scotland Road as planned for the reason that significantly higher evacuation traffic will be present on Scotland Road than on Central Street. I. Woodbridge School and Route 1: One traffic guide, equipped as noted above, should be located at this location to control the arrival and departure of parents and evacuation buses. J. Northern Boulevard and Plum Island Turnpike: At least l one traffic guide, equipped as noted above, and an i emergency vehicle with flashing lights is needed to I merge traffic onto Plum Island Turnpike. K. Boston Road and Route 1: One traffic guide, equipped as noted above, should be located at this intersection in order to enable buses traveling Newbury 12
~ n't 4 Bus Routes 1 and 2'to~ cross Route 1.- L.. Route 1A and Low Streets At least one traffic guide, equipped as noted above,'should be located at this, site to enable' northbound: evacuation buses (Newbury Bus' Route 3)- to cross Route 1 and gairi access to Hay Street. 'M. Byfield Elementary School: One traffic guide, equipped as.noted above, should be located at this location to control the arrival and departure of parents and evacuation buses. JI'7 - TRANSIT DEPENDENT, BUS ROUTES There are four bus routes set up in the SPMC for TON. Two buses are assigned to each route. Each route is to be driven-twice. The panel =has formed the opinion that the' buses will be unable to travel the routes for.the. reasons set forth below: .A. Newbury Bus' Route 1: The bus cannot cross. Route 1 in either direction as called-for in the route because traffic cones put in place according to TCPE-ND-03 does not permit any vehicle to cross Route 1 as the plan calls for. Hanover Street, Rolfe's Lane and Plum Island' Turnpike, the three roads the bus is supposed to use to get to the island, will be blocked by evacuating traffic for the reasons discussed above..Once on the island, the bus will be unable to travel to the end of the island on either Old Point Road or Northern Boulevard as the route calls for because evacuating traffic will block travel in those directions on those roads. B. Newbury Bus Route 2: A portion of Orchard Street has 13
i 1 become impassable when the read washed out when a stream overflowed its. banks. The bus route does not provide an alternative route should a similar occurrence take place. The bus is to cross Route 1 at its intersection with Boston Road but the plan provides for no traffic control at that intersection and the bus will be seriously delayed because of the utilization of Route 1 as a major evacuation route. The bus will not be able to re-cross Route 1 at Hanover Street for the reason that TCPE-NB-03 provides for cones which block travel in that-direction. In addition, evacuation traffic on Route 1 will make it extremely difficult for the bus to cross Route 1 at this location. C. Newbury Bus Route _3: This bus route has been recently revised and no longer utilizes Hay Street or Newman Road, roads which had created problems due to, among other things, periodic flooding. But the bus is still supposed to cross Route 1 at its intersection with Boston Road and the same problem results with this route resulted with the previous route'at this location. as The bus is also supposed to travel north on Route 1A across the Parker River. A two-lane bridge spans the river at that point. Because no traffic controls exist at that bridge, the panel, based on its experience and Knowledge of driver behavior, has formed the opinion that both lanes of the bridge will be used by southbound traffic and that the bridge will not be accessible to 14
A. p,.wpp.y., 4 i, <.in,614 o,..~...:es.m.4 w-m . 6..c,.,y n .w r: l ll . northbourid ' traf fic as the route plans. In fact, the panel believes.that.the entire width of Route lh will be 3 I jammed with evacuees heading south.since Route 1A is'a major road leading away from Seabrook for Newburyport as i well as Newbury. Finally, the route as recently revised' q calls'for the bus-to make a U-turn on llay Street near the. intersection of Newman Road. While it would'not'be impossible-for.a bus to eventually reverse its direction i on-llay Street by going back'and forth a number of. times or using Newman Road to turn around on, this maneuver would.be extremely difficult if' Hay. Street is being used by evacuees. D. Newbury Bus-Route ~4: This route also has recently been . revised. The route now calls for the bus to travel on Scotland Road toward Newburyport. That road will be jammed with Newburyport evacuees and travel touard Newburyport will be impossible. In addition, the revised route calls for the bus to cross Route 1 at Parker Street. Immovable barricades'have been built at that location which make crossing Route 1 there impossible. Finally, the route plans for the bus to travel east on Parker Street to liigh Road -- Parker Street will be jammed by Newburyport and Pluci Island evacuees who are traveling in the opposite direction so eastbound bus traffic will be inpossible, i E. Transfer Point: The Newbury transfer point is located on Ilighfield Road. That road is extremely l 15
narrow and winding. Any degree of traffic on that road will make bus travel impossible, particularly from the transfer point to Scotland Road. The transfer point itself is really nothing more than a driveway leading to a Massachusetts Electric Company substation. No shelter exists there. Very little room exists to enable the bus to turn into or turn around within the transfer point. F. Evacuation Route 2, Beverly Reception Center: The SPt1C I diagram which shows the route from the Newbury transfer I point to the Beverly reception center includes written instructions. Those instructions, which presumably would be referred to by the bus driver or his or her assistant or guide, tells the driver to make a left turn on Downfall Road. Downfall Road does not exist at that location. JI 63 - LOCAL GOVERNMENT EQUIPt1ENT As noted with regard to JI 4, dealing with the traffic management plan, the panel believes that traffic controls must be in place before the evacuation begins. TON does not have enough personnel or equipment to provide those controls, even assuming that all of its off-duty personnel could be contacted and i responded promptly, an eventuality highly unlikely to occur. TON's police department consists of one chief, one deputy chief, i two lieutenants, one sergeant and three patrol officers and sixteen reserve patrol officers, one patrol officer / dispatcher and a dispatcher. Its fire-fighting personnel consists of two full-time individuals and approximately fifty volunteers. This 16 )
l i {- 1 L l total number of individuals is insufficient to provide the j traffic controls'previously identified which TON believes would be necessary. Also, it is doubtful that more than half of these workers will be able to be contacted and will respond. l In addition, TON's vehicles consist merely of three marked police cruisers and two all-terrain vehicles, twelve fire trucks of various sizes, four dump trucks, one pickup truck, one personnel carrier, two tractors, one back hoe and one sidewalk plow. TON also has one boat. These vehicles are not sufficient to establish the type of traffic control TON believes is necessary as is set forth above. Nor is this equipment sufficient to enable TON to remove impediments to travel on TON's roadways in a timely fashion, such as ice cakes which become deposited on Plum Island Turnpike. Dated: March,/7 1989 By: L ([ h R '. Scott Hill-Whilton Counsel for Town of Newbury Lagoulis, Hill-Uhilton & Rotondi 79 State Street Newburyport, MA 01950 (500) 462-9393 17
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w [h CERTIFICATE OF SERVICE I, R. Scott Hill-Whilton, Counsel for the Town of Newbury in the above-entitled action, hereby certify that I have ca'@)ef,AR 30 A10 58 copies of the enclosed documents to be s'rved upon the persons at the addresses listed below, by first class, OPI which have been marked with N q$,i{is '). postage prepaid, mail and by Federal Express, postage prepaid, mail to those names asterisk.
- Admin. Judge Ivan W.
Smith
- Dr. Kenneth A.
McCollom Chairman, Atomic Safety and Atomic Safety and Licensing Board Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 !* Docketing and Service
- Dr.
Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Conmission U.S. Nuclear Regulatory Commission 11555 Rockville Pike Washington, D.C. 20555 Rockville, MD 20852
- Thomas G.
Dignan, Esq. A. S. I.. A. B. Panel Ropes and Gray U.S. Nuclear Regulatory Commission One International Place Washington, D.C. 20555 Boston, MA 02110-2624 Diane Curran, Esq. Stephen B. Merrill, Esq. Harmon, Curran & Tousley Attorney General 2001 S. Street N.W. Office of the Attorney General Suite 430 Concord, NH 03301 Washington, D.C. 20009-1125 Sherwin E. Turk, Esq. Robert A. Backus, Esq. Office of the General Counsel 116 Lowell Street Nuclear Regulatory Commission P.O. Box 516 Washington, D.C. 20555 Manchester, NH 03105 Philip Ahrens, Esq. Paul McEachern, Esq. Asst. Attorney General Shaines & McEachern Office of the Attorney General 25 Maplewood Avenue Augusta, MS 04333 Portsmouth, NH 03801 Mrs. Sandra Gavutis The Honorable Gordon J. Humphrey Chairman United States Senate Board of Selectmen Washington, D.C. 20510 Kensington, NH 03827 Mr. Thomas Powers H. Joseph Flynn, Esq. Town Manager Office of General Counsel Town of Exeter Federal Emergency Management Agency Exeter, NH 03833 Washington, D.C. 20472 (1)
o< ~* a; l 1 Gary IIolmes, Esq. Stephen Jonas, Esq. Assistant Attorney General j Ifolmes & Ells 47 Winnacunnet Road Office of the Attorney General J Hampton, Nil 03841 One Ashburton Place j Boston, MA 02108 1 Mr. Calvin A. Canney Charles P. Graham, Esq. City Manager 11urphy and Graham 33 Low Street City Hall Portsmouth, nil 03801 Newburyport, MA 01950 Barbara Saint Andre, Esq. Mr. William Lord Kopelman & Paige Selectman 77 Franklin Street Board of Selectmen Boston, MA C2110 Amesbury, MA 01913 i Brentwood Board of Select. Richard A. Ilampe, Esq. j RFD Dalton Road Hampe & 14cNicholas Brentwood, NH 03833 35 Pleasant Street Concord, NII 03301 Mr. Robert Carrigg, Chairman Judith Mizner, Esq. Board of Selectmen 79 State Street Town Office Newburyport, MA 01950 North Ilampton, NH 03862 Robert R. Pierce, Esq. Mr. Richard R. Donovan Atomic Safety and Licensing Federal Emergency Management Agency Board Panel Federal Regional Center U.S. Nuclear Regulatory Comm. 130 228th Street, S.U. Washington, D.C. 20555 Bothell, Washington 90021-9796 Ashod N. Amirian, Esq. 145 South Main Street P.O. Box 38 Bradford, MA 01835 Signed under seal this di day of f*1d 1989. i W R. Scott flill-Whilton I l (2) __.}}